Prior Approval – What is it and how do you do it?

Q: What is “Prior Approval” and why do I/my utility need to sign a form?

A: The FEC requires PowerPAC to obtain written approval from APPA members before it may solicit and accept contributions from employees of the member utility. Granting Prior Approval does not obligate the utility or its employees to support the PAC – it simply gives APPA permission to communicate in much greater detail about the PAC to certain employees (a member’s general manager, executive team, managers and other salaried, exempt employees under the Fair Labor Standards Act) and the role it plays in advancing and protecting the industry’s interests in Washington.

Q: Can anyone from the utility sign the Prior Approval form?

A: Prior Approval may be granted by anyone so authorized by the utility. This includes the utility’s General Manager/CEO, but may also include those designated to represent the utility at APPA conferences/meetings.

Q: Do I have to sign a Prior Approval form every year? Can I withdraw approval?

A: Prior Approval may be granted for up to five (5) consecutive years by the utility and may be withdrawn at any time. Only one approval form is required per utility.

Q: Will PowerPAC directly solicit employees at my utility?

A: That’s up to you. By signing a Prior Approval form, you could allow PowerPAC to solicit all principals and senior executives in your firm, or only certain individuals in the utility. You could also give PowerPAC approval for yourself, but request that no solicitations be made to firm employees, and PowerPAC will honor that request.

Q: Our utility has our own Federal PAC; can we still contribute to PowerPAC?

A: Yes. Even if your utility has a federally registered PAC, your employees can still contribute up to $5,000 each year to PowerPAC.

Q: If our firm signs a Prior Approval form, can APPA members contribute to other PACs?

A: A firm cannot give approval to more than one trade association PAC to solicit its employees. However, this does not preclude firm employees from contributing to a state PAC, candidate PAC, corporate PAC, or an ideological PAC (i.e. National Rifle PAC, AARP, etc).

Q: Why should a firm sign a Prior Approval form?

A: In addition to not being able to accept contributions, APPA cannot communicate important information on PowerPAC's activities without a prior approval form.

To submit prior approval on behalf of your organization

1. Email Amy Thomas at athomas@publicpower.org

a. Indicate in your email whether you are giving approval to solicit your entire eligible class, a targeted list of members of your eligible class (and attach that list), or if the solicitation should be targeted to you only.

b. Indicate in your email for which years you are giving prior approval (up to five years out).

2. OR You may Complete this form and mail to:

American Public Power Association

Attn: Amy Thomas

1875 Connecticut Avenue NW, Suite 1200

Washington, DC 20009-5715

Please note: Only the primary contact for an organization can give prior approval authorization. If you are unsure if you are the primary contact, email Amy Thomas at athomas@publicpower.org or at 202/467-2934.