2025 was an active year for TAPS, including the following:

Legislation

TAPS’s 2025 legislative work can be framed as a continuation of its long‑standing priorities, but in a more active House environment and under a new administration that shifted the political context for transmission, reliability, and Federal Power Act policy.

In 2025, TAPS continued to advocate for a robust, cost‑effective transmission grid and competitive wholesale power markets, emphasizing reliability and ratepayer protection as the electric sector faced rising demand, evolving resource mixes, and increasing stress on the bulk power system. The transition from the Biden to the Trump administration shifted federal energy priorities. Control of the House, Senate, and White House created an opportunity for legislative action, requiring TAPS to adjust its emphasis and messaging while maintaining its core focus on transmission‑dependent utilities and consumer impacts.

TAPS devoted most of its legislative advocacy in 2025 to the House Energy and Commerce Committee, which has primary jurisdiction over the Federal Power Act and key elements of electric reliability policy. The Committee was significantly more active on electric energy policy than in prior years.  TAPS provided comments and questions for the record to House staff ahead of hearings on electric reliability and the performance of the electric grid, helping shape oversight conversations and draw attention to the needs of transmission‑dependent load‑serving entities.

As the House considered a series of bills and oversight initiatives related to the Federal Power Act and grid reliability, TAPS stressed the importance of preserving effective federal tools while avoiding changes that could undermine open access, cost discipline, or local and regional planning. TAPS framed its input around ensuring that any statutory changes or oversight directions recognize the role of load‑serving entities and the importance of joint ownership and transparent planning in keeping the lights on at reasonable cost.

In the Senate, TAPS continued its engagement with the Energy and Natural Resources Committee as work proceeded on permitting reform, albeit slowly and behind closed doors. TAPS met with and messaged new Senate staff to reiterate concerns with the Manchin‑Barrasso transmission title in the 2024 permitting reform legislation, which was being treated as a baseline for a 2025–2026 Senate permitting reform draft.

TAPS also shared those transmission‑related concerns with House policy leaders to help ensure that any House–Senate negotiations on permitting or transmission titles would better account for transmission‑dependent utilities and their customers. Although the Senate did not advance new reliability‑ or “ratepayer protection”‑branded proposals that required TAPS input in 2025, TAPS’s ongoing engagement helped keep member concerns on the table as staff refined legislative text.

Throughout 2025, TAPS maintained consistent substance in its advocacy: emphasizing open and equal transmission access, joint ownership opportunities for load‑serving entities, robust but cost‑disciplined transmission planning, and protections against the exercise of market power. TAPS highlighted that giving transmission‑dependent utilities a meaningful role in planning and ownership decisions is essential to right‑sizing the grid, preventing overbuilding, and ensuring that transmission investments genuinely address regional and local reliability needs. In conversations about the Federal Power Act and potential legislative changes, TAPS stressed the need for guardrails that support reliability and competitive markets without shifting costs unfairly to transmission‑dependent systems and their customers.

TAPS continued its practice of sustained, direct engagement with Congress through its Legislative Committee and member fly‑ins, using those opportunities to educate key House and Senate offices on the practical implications of proposed statutory changes for transmission‑dependent utilities. During TAPS’s annual Washington, DC meeting, Rep. Julie Fedorchak, a member of Congress who has made electric utility policy a priority, addressed TAPS members and discussed congressional focus on grid reliability, transmission development, and consumer protection.

TAPS also continued to coordinate closely with other public power organizations on technical and policy issues, including with the American Public Power Association and the Large Public Power Council, consistent with its broader mission of protecting transmission‑dependent utilities and their customers.

NERC/NAESB

As the FERC-certified Electric Reliability Organization (“ERO”), NERC is authorized to establish and enforce mandatory reliability standards, subject to FERC review. FERC also reviews NAESB standards and incorporates them into its regulations by reference. TAPS works to ensure representation at both NERC and NAESB, mobilizing and coordinating TAPS’s efforts to monitor and participate in activities at both organizations to protect the interests of TDUs. Starting in 2025, Devon Tremont (Utility Services) has headed up TAPS’s NERC/NAESB efforts, taking on responsibilities on the NERC Member Representatives Committee (“MRC”), the ERO Business Plan and Budget Group, the NAESB Wholesale Electric Quadrant Executive Committee and the NAESB Board of Directors. TAPS Executive Director Tom Heller, Roy Jones (ElectriCities), Colin Hansen (KPP), and Scott Tomashefsky (NCPA), also served on the MRC in 2025. Additionally, Mr. Tomashefsky served as chair of the Compliance and Certification Committee, and as such was a member of the Standing Committee Coordination Group and the Enterprise-Wide Risk Committee; he also served on the Modernization of Standards Processes and Procedures Task Force. John Stephens (City Utilities of Springfield) was Vice Chair of the Reliability and Security Technical Committee, on which another TAPS member also serves. TAPS members also have a presence on the Reliability Issues Steering Committee and Standards Committee, and on significant drafting teams.

TAPS has also made its voice heard on reliability issues through submissions to FERC in NERC and NAESB-related proceedings, as well as submission of comments to NERC. TAPS attempts to maximize its impact by filing separate TAPS comments that reflect the distinct viewpoint of TAPS members, both as users highly dependent on the bulk electric system (“BES”) facilities owned by others and as entities subject to NERC’s mandatory reliability standards for our own BES facilities, or where appropriate, submitting joint comments with all or portions of the rest of the industry to emphasize the widespread support for a position. Insiders have told us that seeing TAPS and EEI on the same submission to FERC sends a strong message. While a number of these efforts are still playing out, there is no doubt that in 2025 TAPS played an important role in the ever-evolving relationship among FERC, NERC, and stakeholders.

TAPS 2025 NERC and NAESB-related activities

  • Modernization of Standards Processes and Procedures (MSPP) Task Force
    • February 2025 After two standard development efforts led to use of a mechanism expected to be rarely applied (Section 321 of NERC’s Rules of Procedures) to approve a standard, the NERC Board of Trustees formed the Modernization of Standards Processes and Procedures Task Force (“MSPPTF”) to conduct a strategic review of and re-envision the standards process. The goal is to enable the timely resolution of reliability issues that merit a standard while maintaining the traditional hallmarks of stakeholder engagement for which NERC is known. In identifying potential areas for improvement in the standards process, the MSPPTF is conducting a deep dive into three areas: (1) standards initiation/standard authorization requests, (2) standards development/drafting, and (3) balloting. Scott Tomashefsky (NCPA) is appointed to the Task Force.
    • May 16, 2025 MSPPTF launches Stakeholder Survey, seeking (1) input from stakeholders on areas of improvement in the current standards development process and (2) transformative ideas for reforming current processes.
    • June 5, 2025 TAPS, APPA, and LPPC submit joint comments responding to MSPP Stakeholder Survey.
    • July 2025 MSPPTF White Paper describes potential options for transforming the standards development framework: (1) standards initiation; (2) standards drafting; and (3) balloting.
    • August 27, 2025 TAPS submits comments in response to the White Paper, offering feedback on the White Paper’s standards initiation and drafting reforms, while drawing a hard line on balloting reforms (which would eliminate or severely diminish the role of stakeholder balloting).
    • October 20, 2025 MSPPTF Draft Recommendations refine potential options for transforming the standards development framework and drop the suggestion for fundamental reforms to balloting, but raise for the first time the possibility of combining the TDU and LSE voting segments.
    • November 10, 2025 TAPS provides feedback on the October 2025 Draft Recommendations, commending the MSPPTF for its efforts but raising concerns with the elimination of the TDUs as a distinct voting segment and other aspects of the Draft Recommendations.
    • November 19, 2025 Devon Tremont participates at the Atlanta MSPP Stakeholder Feedback Forum, urging against combining the TDU and LSE voting segments.
    • December 18, 2025 The MSPPTF hosts a webinar describing key changes to be made between the draft recommendations and the final recommendations, which includes a number of positive changes, including retention of the TDU and LSE voting segments.
  • Security Management Controls for Low Impact Systems Notice of Proposed Rulemaking (RM25-8)
    • September 18, 2025 FERC issues a NOPR proposing to approve NERC’s proposed Reliability Standard CIP-003-11 to establish security management control requirements for low impact systems with external routable connectivity. FERC seeks comment on cyberattack risks faced by low impact systems, industry activities to mitigate those risks, and whether to direct NERC to perform a study on evolving threats to low impact systems.
    • November 24, 2025 TAPS, APPA, EEI, EPSA, LPPC, and NRECA file joint comments supporting the approval of proposed Reliability Standard CIP-003-11 without any further directives. NERC also files comments supporting approval and opposing a study directive.
  • Issues Pertaining to Definitions of Inverter-Based Resources Referenced in Order 901 (NERC Project 2024-01/RD25-10, NERC Projects 2022-02 and 2021-01/RD26-1)
    • February – April 2024 Following NERC submission to FERC of proposed Inverter-Based Resource owner/operator registration changes that seem likely to cause confusion and delay in standards development and compliance, including hampering NERC’s compliance with Order 901, TAPS develops a draft Standard Authorization Request (“SAR”) proposing revision of the NERC Glossary definitions of “Generator Owner” and “Generator Operator” for consistency with NERC’s revised Rules of Procedure, and the development of a NERC Glossary term for Inverter-Based Resource facilities that meet the new Rules of Procedure registration thresholds.
    • May 17, 2024 TAPS, joined by APPA, EPSA, and LPPC, submits draft SAR to NERC.
    • July 6, 2024 At NERC Staff’s request, TAPS, APPA, EPSA, and LPPC submit a somewhat revised draft SAR, along with a technical support document.
    • July 17, 2024 Standards Committee accepts draft SAR for posting and assigns it to NERC Project 2024-01, which is the Standard Drafting Team handling an existing NERC Staff SAR to update the Glossary definitions of Generator Owner and Generator Operator consistent with the revised Rules of Procedure definitions.
    • August 2024 Colten Mitchell (IMPA) appointed to Project 2024-01 Standard Drafting Team.
    • September 16, 2024 TAPS submits comments supporting stakeholder IBR SAR. TAPS argues that, to avoid unnecessary delays, defined terms for non-material IBRs and IBR-DERs should be developed on an expedited timeframe so that drafting teams working on Milestone 3 and 4 standards can refer to those IBRs clearly and consistently.
    • April 16, 2025 The Standards Committee terminates the stakeholder SAR, suggesting that the concerns it raised regarding definitional consistency for non-material IBRs and IBR-DERs have been addressed. TAPS learns, to the contrary, that several of the Milestone 3 Standards due to FERC in November 2025 (MOD-32 and MOD-33) incorporate Bulk Power System (a term that only FERC can define) and are otherwise problematic in their use of “unregistered IBR” and “IBR-DER.”
    • May 16 and 21, 2025 TAPS comments on MOD-32-2 and MOD-33-3. These comments, which TAPS prepares for use by interested members as well, highlight the deficiencies of the proposed terms “unregistered IBR” and “IBR-DER.”
    • June 3-5, 2025, Utility Services attends NERC’s Milestone 3 technical workshop in person, providing input on behalf of TAPS.
    • July 14, 2025 Final ballots submitted supporting the Category 2 GO/GOP definitions.
    • August 27, 2025 NERC petitions for approval of Category 2 GO/GOP definitions (Docket No. RD25-10).
    • August 28, 2025 MOD-32/MOD-33 resubmitted for ballots and commenting. The MOD-32/MOD-33 drafting teams eliminate references to undefined terms, which, while not the solution TAPS advocated, largely mitigates the problems TAPS identified.
    • September 29 – October 3, 2025 Final ballots submitted, approving the MOD-32/MOD-33 standards.
    • October 1, 2025 FERC issues a letter order accepting the revised definitions for the terms Generator Owner and Generator Operator for inclusion in the Glossary of Terms used in NERC Reliability Standards (NERC Glossary) and the proposed implementation plan.
    • November 4, 2025 NERC submits to FERC a petition for approval of proposed Reliability Standards MOD-032-2, IRO-010-6, and TOP-003-8 (Docket No. RD26-1).
  • Extreme Cold Weather Grid Operations, Preparedness, and Coordination (RD23-1, RD24-5, NERC Project 2024-03, RD25-7)
    • June 27, 2024 FERC issues an order accepting the proposed extreme cold weather standard while directing additional changes. Consistent with TAPS’s comments, FERC reiterates that cost recovery is outside the scope of the proceeding and more appropriately addressed in proceedings pursuant to FPA Sections 205 and 206 and agrees that it is appropriate to exempt from certain requirements generators that do not self-commit and are not required to operate at or below 32 degrees, even if those generators may be called upon to assist in mitigation of emergencies. FERC characterizes its “five core directives” as “targeted modifications necessary to fully address issues identified in the Commission’s prior February 2023 Order,” and directs that the revised Reliability Standard be submitted within 9 months, i.e., by March 27, 2025.
    • July – August 2024 NERC forms new Project No. 2024-03 to address FERC’s directives. Jonathan Davidson (City Utilities of Springfield) and Jill Loewer (Utility Services) are appointed to the Standard Drafting Team.
    • January 10, 2025 Based on ballot results, the NERC Board invokes its authority under Rule 321 of NERC’s Rules of Procedure to invite comments (but not provide for balloting) to ensure timely submission of Standard EOP-012-3 to FERC.
    • April 10, 2025 NERC submits a petition for FERC’s approval of proposed Reliability Standard EOP-012-3 in Docket No. RD25-7.
    • September 18, 2025 FERC issues an order approving proposed Reliability Standard EOP-012-3, but modifies the proposed effective date to October 1, 2025 (instead of the later of October 1, 2025 or three months after FERC’s approval).
    • October 17, 2025 NERC requests clarification of the September 18, 2025 Order approving Reliability Standard EOP-012-3, related to the data collection and reporting required by the Order.
    • October 20, 2025 TAPS, APPA, EPSA, LPPC, and NRECA jointly request clarification of the September 18, 2025 Order approving Reliability Standard EOP-012-3, regarding the source of FERC’s authority to establish the effective date set in the Order.
    • December 5, 2025 FERC issues Order on Clarification, granting NERC’s clarification request and granting TAPS’s joint request in part and denying it in part. FERC clarifies that it relied on the “as otherwise provided for by the applicable governmental authority” provision in the implementation plan to establish the alternative effective date of October 1, 2025, but denies the clarification request to the extent it suggests that FERC lacked the authority to alter the Standard’s effective date without directing the Standard be remanded to NERC.
  • Supply Chain Risk Management Notice of Proposed Rulemaking (RM24-4)
    • September 19, 2024 FERC issues a NOPR proposing to direct NERC to develop new or modified Reliability Standards to address the “(A) sufficiency of responsible entities’ [Supply Chain Risk Management (“SCRM”)] plans related to the (1) identification of, (2) assessment of, and (3) response to supply chain risks, and (B) applicability of SCRM Reliability Standards to [protected cyber assets (“PCAs”)]”.
    • December 16, 2024 TAPS files a motion for leave to file limited comments and limited responsive comments, supporting the comments of APPA/LPPC in advocating that FERC consider centralized approaches (as opposed to decentralized, utility-specific compliance requirements) to address security risks associated with vendors’ software, hardware, or services.
    • February 24, 2025 FERC/NERC schedule joint workshop focusing on the “assessment” aspect of supply chain risk management (i.e., the validation requirement raised in TAPS’s limited responsive comments).
    • March 20, 2025 FERC/NERC host joint workshop focusing on the “assessment” aspect of supply chain risk management. TAPS monitors and reports.
    • April 11, 2025 APPA, LPPC, and TAPS submit joint comments following up on the supply chain risk management workshop, reiterating their concerns with the validation requirement.
    • September 18, 2025 FERC issues a Final Rule largely adopting the NOPR proposal. In response to the concerns of TAPS and others, FERC declines to direct NERC to require responsible entities to validate data received from vendors.
  • State/Municipal and TDU Sector Policy Input to NERC Board of Trustees
    • The NERC MRC members from the State/Municipal and TDU Sectors (“SM-TDUs”) submit joint policy input to the Board of Trustees in response to the Board’s quarterly request for input. The responses are generally coordinated by TAPS, APPA, and LPPC.
      • January 29, 2025 SM-TDUs provide input that: (1) with the increasing integration of large loads, NERC and the industry should continue collaborating to identify reliability gaps and address those gaps in cost effective, legally defensible ways; (2) SM-TDUs are committed to participating in NERC’s efforts to improve the standards drafting process; (3) and the public power community is looking forward to participating actively in the development of the 2025 ERO Risk Priorities report.
      • April 23, 2025 SM-TDUs provide input on the reliability implications of large load integration, specifically (1) supporting NERC’s focus on addressing the reliability risks associated with gas-electric interdependencies; (2) pointing out that NERC’s existing jurisdiction allows for NERC to continue improving transparency into gas-electric interdependency issues and to play a coordinating role among various stakeholders; and (3) urging NERC to keep in mind regional differences when addressing gas-electric coordination issues.
      • July 29, 2025 SM-TDUs provide input on the Modernization of Standards Processes and Procedures Task Force (MSPPTF). SM-TDUs support the MSPPTF’s outreach efforts and encourage continued engagement with industry as the Task Force develops its recommendations to the Board, and argue that any changes made to the standards process should include broad consensus across industry and that decisions to modernize the standards process should rely on data to ensure that changes translate to improved outcomes.

TAPS 2025 FERC (Non-Reliability) Efforts

  • Interconnection of Large Loads to the Interstate Transmission System (RM26-4)
    • October 23, 2025 The U.S. Department of Energy (“DOE”) exercises a rarely used authority to direct FERC to initiate a rulemaking on the interconnection of large loads (expected to primarily consist of data centers) directly to the interstate transmission system. DOE’s ANOPR asks FERC to assert jurisdiction over such interconnections, consider standardizing large load interconnection procedures, and take final action on the ANOPR by April 30, 2026.
    • October 27, 2025 FERC issues DOE’s ANOPR.
    • November 21, 2025 TAPS submits comments framed around two overarching points: (1) FERC should ensure that any reforms are protective of wholesale transmission customers, so that these other customers are not stuck bearing the cost, reliability, or resource adequacy burdens associated with meeting the needs of large loads, and affordability to consumers should be a key objective; and (2) any large load interconnection reforms should be carefully crafted to avoid opportunities for gaming or undue preference that is not tied to and justified by specific, relevant characteristics.
  • Notice of Information Collections and Request for Comments (IC25-7)
    • February 3, 2025 FERC issues a notice of information collections and request for comments regarding a three-year extension of the currently approved information collection forms: FERC Form Nos. 1 (Annual Report of Major Electric Utilities, Licensees, and Others), 1-F (Annual Report for Nonmajor Public Utilities and Licensees), and 3-Q (Quarterly Financial Report of Electric Utilities, Licensees, and Natural Gas Companies).
    • April 2025 Edison Electric Institute and a handful of transmission owners filed comments urging FERC to delete the Form No. 3-Q report, because they claimed it is not used by utilities or customers, is duplicative of other financial reports made by utilities to the Securities Exchange Commission and state regulators, and is unduly expensive for utilities to prepare.
    • June 16, 2025 FERC issues its second notice. FERC responds to EEI and transmission owners that FERC Form No. 3-Q report provides FERC with useful information that is not otherwise available to FERC in other public reports filed by utilities.
    • July 21, 2025 APPA and TAPS submit joint comments in support of FERC’s proposed three-year extension of FERC Form Nos. 1, 1-F, and 3-Q without changes to the current reporting requirements, stating that the elimination of the Form No. 3-Q report would harm customers, because the quarterly reports provide updated data that are particularly useful to review transmission rate updates.
  • Establishing Minimum Requirements for Interregional Transfer Capability (AD25-4)
    • November 19, 2024 NERC submits to FERC its Congressionally-directed Interregional Transfer Capability (“ITC”) Study.
    • February 25, 2025 TAPS submits comments highlighting the Study’s finding that “a one-size fits all requirement or approach to additional transfer capability is expected to be inefficient and ineffective”; the Study’s significant caveats; and tools currently at FERC’s disposal that can advance solutions to interregional transfer capability deficiencies.
    • August 6, 2025 Then-Chairman Christie sends letters to individual legislators regarding the ITC Study, describing his key takeaways. Christie’s takeaways are closely aligned with positions TAPS advocated in comments: that the study does not provide support for a mandated minimum transfer capacity, that reliability risks are highly dependent on regional conditions, and that one-size-fits-all requirements may be ineffective.
  • Meeting the Challenges of Resource Adequacy in Regional Transmission Organization and Independent System Operator Regions (AD25-7)
    • June 4-5, 2025 FERC hosts a Commissioner-led technical conference on Meeting the Challenge of Resource Adequacy in RTOs/ISOs.
    • July 7, 2025 TAPS submits post-technical conference comments urging FERC not to assume higher prices will solve resource adequacy challenges, to carefully consider the costs imposed by resource adequacy construct reforms, and to be skeptical of one-size-fits-all solutions.
  • Electric Transmission Incentives Policy Under Section 219 of the Federal Power Act (RM20-10)
    • March 20, 2020 FERC issues NOPR (RM20-10) proposing to move to a new regimen of plentiful benefits-based ROE incentives.
    • July 1, 2020 TAPS files comments opposing most aspects of the NOPR, and urging modifications, including incentivizing joint transmission ownership.
    • April 15, 2021 FERC issues Supplemental NOPR (RM20-10) proposing to decrease the RTO Incentive Adder rather than increase it. Supplemental NOPR’s proposal to limit the current 50-basis point adder to three years after a transmission owner joins an RTO is consistent with TAPS’s position in the Transmission Incentives NOI/NOPR.
    • June 25, 2021 TAPS comments in support of the April 15, 2021 Supplemental NOPR.
    • July 26, 2021 TAPS and APPA submit joint reply comments on Supplemental NOPR.
    • April 3, 2025 WIRES, EEI, and GridWise Alliance, Inc. file joint supplemental comments, urging FERC to terminate the incentive dockets that propose to diminish existing transmission incentives (focusing on the 2021 Supplemental NOPR), or alternatively, provide a renewed opportunity for comments or initiate a new, generic rulemaking proceeding.
    • May 5, 2025 TAPS files an answer to the WIRES et al. joint supplemental comments, urging FERC to deny their request and arguing for prompt FERC action on the 2021 Supplemental NOPR.