LPPC Supports Grid Reliability and Disaster Response in Federal Grant Reforms
LPPC submitted comments to the Office of Management and Budget (OMB) on its proposed revisions to the Uniform Guidance governing federal financial assistance. LPPC supports responsible stewardship of federal funding that ensures cost-efficiency, accountability, and advances the national interest. Because LPPC member utilities are responsible solely to the 30+ million customers they serve, LPPC recommends targeted clarifications to ensure new grant requirements work as intended in the public power context.
LPPC's member utilities reviewed the proposed rule closely and identified several provisions where targeted changes would help the rule function effectively for public power, particularly for disaster response and long-term infrastructure investment.
Among LPPC's top recommendations:
- An emergency exemption from proposed E-Verify requirements for mutual aid crews responding to federally declared disasters. Public power utilities rely on thousands of lineworkers and contractors from across the country to restore power after hurricanes, wildfires, ice storms, and other emergencies. LPPC recommended the exemption so that E-Verify requirements do not slow restoration when rapid response is critical.
- Preserving cost-reimbursement structures for early-stage engineering, feasibility studies, and system design. These contracts play a critical role in evaluating transmission, generation, energy storage, and grid modernization projects before construction begins, work whose scope often cannot be fixed in advance. LPPC asked OMB to confirm that such structures remain available for this defined category of work.
- Additional safeguards surrounding OMB's proposed authority to suspend or terminate federal awards. Because public power utilities often commit significant capital and financing to multi-year resilience and transmission projects, LPPC recommended written notice, an opportunity to respond, protection for costs already incurred, and prospective application of any new termination authority.
- Confirmation that new priority reviews of discretionary grants supplement the technical evaluations that have long guided infrastructure funding decisions. LPPC also asked OMB to clarify that negotiated indirect cost rates will not be applied in ways that disadvantage public power applicants, and separately requested confirmation that the routine use of commercial off-the-shelf software is not treated as a prohibited foreign collaboration.
