Environmental Protection Agency

On August 10, 2017, the Environmental Protection Agency (EPA) posted on its website a copy of the Association’s Draft Risk Based Approval to Dispose of PCB remediation for public comment. EPA will be accepting comment on the draft through September 8, 2017.

APPA, EEI, and NRECA joint webinar on PCBs: Powerpoint slides and audio (stream, download)

APPA filed comments with EPA on the proposed rule for Postponement of Certain Compliance Dates for ELG Guidelines and Standards for Stream Electric Generation Point Sources (7-6-17)

APPA  filed comments in accordance with Executive Order (EO)13777, “Enforcing the Regulatory Reform Agenda" (5-12-17)

APPA filed comments with EPA on the proposed rule, the Clean Energy Incentive Program Design Details (11-1-16)

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Federal Energy Regulatory Commission

APPA and NRECA filed a protest in the Petition for Declaratory Order of Advanced Energy Economy in Docket No. EL17-75-000 (7-19-17)

APPA filed post-technical conference comments and post-technical conference reply comments on State Policies and Wholesale Markets Operated by ISO New England Inc., New York Independent System Operator, Inc., and PJM Interconnection, L.L.C. in Docket No. AD17-11-000 (6-22-17; 7-14-17)

APPA, LPPC, and NRECA filed joint comments on the Review of Generator Interconnection Agreements and Procedures in Docket No. RM17-8-000. In addition, APPA and LPPC also filed joint comments in Docket No. RM17-8-000 objecting to one of the Commission's specific proposals which would expand interconnection customers' option to build their own interconneciton facilities and stand-alone network upgrades (4-13-17)

APPA and NRECA filed comments on the Uplift Cost Allocation and Transparency in Markets Operated by Regional Transmission Organizations and Independent System Operators in Docket No. RM17-2-000 (4-10-17)

APPA and NRECA filed comments on the Fast-Start Resource Pricing NOPR in Docket No. RM17-3-000 (2-28-17)

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North American Electric Reliability Corporation

APPA, ELCON, NRECA, and TAPS submitted comments in FERC Docket No. RR15-2-005 on proposed changes to NERC's CMEP (3-14-17)

APPA, LPPC, and TAPS submitted comments in FERC Docket No. RM16-18 on possible modifications to the Critical Infrastructure Protection (CIP) reliability standards regarding the cybersecurity of Control Centers (09-26-16)

APPA, EEI, EPSA, ELCON, and LPPC submitted a Request for Clarification in resonse to Order No. 824 issued by FERC; the order requires NERC to provide the Commission and staff with access on a non-public and ongoing basis to certain NERC databases (7-29-16)

Allen Mosher speaks at June 1 FERC Reliability Technical Conference Written Statement Conference Webpage

APPA, LPPC, and TAPS filed joint post-technical comments in FERC Docket RM15-14 in response to the supply chain NORP (4-19-16)

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Occupational Safety and Health Administration

APPA comments on OSHA - Occupational Exposure to Respirable Crystalline Silica, Docket No. OSHA-2010-0034 (8-18-14)

APPA comments on OSHA - Improve Tracking of Workplace Injuries and Illnesses, Docket No. OSHA-2013-0023 (3-10-14)

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Commodity Futures Trading Commission

APPA and NRECA filed comments to the CFTC on its Proposed Amendment to its 2013 RTO/ISO Exemption Order. TAPS joined the filing as a supporting party. (6-15-16)

APPA, NRECA, and EEI filed comments on the CFTC's Proposed Guidance on Certain Natural Gas and Electric Power Contracts (5-9-16)

APPA, in coalition with LPPC, NRECA, EEI, EPSA and AGA, filed comments on the CFTC’s proposed changes to its interpretation on forward contracts with embedded volumetric optionality (“FCEVO”) (12-22-14)

APPA, EEI, EPSA, NGSA, and NRECA submit comments on harmonization of data fields across all swap data repositories. (7-3-13)

APPA, EEI, EPSA, and NRECA submit comments in support the request for no-action relief for reporting trade options. (3-8-13)

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Other Filings

Department of Energy: APPA, LPPC, NRECA, and TAPS filed comments on DOE's Grid Security Emergency Orders: Procedures for Issuance NOPR in Docket No. RIN 1901-AB40 (2-6-17)

Courts: On Feb. 13, 2017, APPA joined a brief of intervenors in support of FERC in an appeal challenging FERC’s orders declining to order MISO to adopt a mandatory forward capacity market. The case is NRG Power Marketing LLC v. FERC, D.C. Cir. Case No. 16-1027.

Courts: APPA, Conway Corporation, Municipal Energy Agency of Nebraska, City of North Little Rock, Southern Minnesota Municipal Power Agency, and Great Lakes Utilites filed an intervenor brief in Madison Gas and Electric Company et al. v. FERC (11-16-16)

Courts: APPA and the American Public Gas Association filed a joint brief as amici curiae in Clarksville, TN v. FERC (11-1-16)

Courts: APPA joined with other parties in a petitioners’ brief challenging FERC’s orders approving the “Capacity Performance” rules for the PJM capacity market. (09-23-16)

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