July 13, 2020
VIA EMAIL: bulkpowersystemEO@hq.doe.gov
Dear Sir/Madam:
The American Public Power Association (APPA), National Rural Electric Cooperative Association
(NRECA), Edison Electric Institute (EEI), Large Public Power Council (LPPC), Utilities Technology
Council (UTC), American Petroleum Institute (API), Electricity Consumers Resource Council (ELCON),
and the Electric Power Supply Association (EPSA) respectfully request an extension of the deadline to
submit comments in response to the Request for Information (RFI) Related to Executive Order 13920,
“Securing the United States Bulk-Power System,” published in the Federal Register on July 8, 2020, by
the Department of Energy (DOE), Office of Electricity. Comments are currently due on August 7, 2020.
Our associations represent all facets of the electric utility industry, and significant elements of the oil and
natural gas industries. Our members take seriously the security of the electric grid and energy supply and
are keenly aware of its criticality to the health, safety, and security of the nation. We appreciate DOE’s
work in ensuring the security of the nation’s electric grid and energy supply and we value our partnership
with DOE in this endeavor. As such, we appreciate the thoughtful questions in DOE’s RFI and our
intention is to provide thoroughly researched, complete and thoughtful responses. However, considering
the complexity and breadth of the data requested by the RFI, a 30-day comment period is not sufficient to
provide the level of research that would support fully informed responses. Further, economic and other
analysis identified in several comment categories may need to be undertaken to ensure a comprehensive
response to the notice and it is unlikely that such analyses can be completed by the current August 7
deadline.
For these reasons, we respectfully request a 60-day comment period, with comments due on September 7,
2020. This brief delay will allow our members to provide more thorough and thoughtful comments in
response to the RFI.
If you have questions about this request for an extension of the comment deadline, please direct
them to Amy Thomas at APPA (athomas@publicpower.org; 202-467-2934).
Sincerely,
American Public Power Association
National Rural Electric Cooperative Association

 Edison Electric Institute
Large Public Power Council
Utilities Technology Council
American Petroleum Institute
Electricity Consumers Resource Council
Electric Power Supply Association