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Testimony, Filings, and Briefs

EEI public policy advocacy documents are organized by date and by entity in the table below. Those specifically relating to the implementation of the Energy Policy Act of 2005 (EPAct) are also available, listed under the "EPAct 2005" below.

List by: Date | Entity | EPAct 2005

  
  
  
Abstract
130211RosenstockDoeWaterHeaterEfficiency.pdf2/11/2013Comments on DOE’s Uniform Efficiency Descriptor for Residential and Commercial Water Heaters RFI
EEI comments on the U.S. Department of Energy (DOE) request for information (RFI) on developing a uniform efficiency descriptor for residential and commercial water heaters (Docket # EERE-2011-BT-TP-0042; 78 Fed. Reg. 2340, January 11, 2013).
120224ComerDoeTransmissionFacilitiesCoordination.pdf2/24/2012Comments on DOE’s NOPR on Implementing Federal Power Act Section 216(h), Regarding Coordination of Federal Authorizations for Siting and Permitting Interstate Electric Transmission Facilities
EEI comments in response to the U.S. (DOE) notice of proposed rulemaking (NOPR) for implementing Federal Power Act (FPA) section 216(h), which was enacted as part of section 1221 of the of 2005 (EPAct),
110912OwensFercTransmissionInvestmentNoi.pdf9/12/2011Comments on FERC’s NOI Regarding Promoting Transmission Investment Through Pricing Reform
EEI comments in response to the Federal Energy Regulatory Commission’s (FERC’s) notice of inquiry (NOI) on promoting transmission investment through pricing reform under Order No. 679, regarding implementation of section 1241 of the Energy Policy Act of 2005 (EPAct 2005) (Docket No. RM 11-26-000; 76 Fed. Reg. 30869, May 27, 2011).
081020ComerDoeSiting.pdf10/10/2008Comments on Interim Final and Proposed Rules on DOE's Lead Agency Responsibilities for Siting Interstate Electric Transmission Facilities
EEI comments on the interim final and proposed rules implementing new Federal Power Act (FPA) section 216(h), enacted as part of section 1221 of the Energy Policy Act of 2005 (EPAct05), concerning DOE's “lead agency” responsibilities for siting interstate electric transmission facilities (73 Fed. Reg. 54456, Sept. 19, 2008; and, 73 Fed. Reg. 54461, Sept. 19, 2008).
080716RosenstockDoeVending.pdf7/16/2008Comments on Energy Conservation Standards for Refrigerated Bottled or Canned Beverage Vending Machines ANOPR
EEI comments on DOE's advanced notice of proposed rulemaking (ANOPR), "Energy Conservation Standards for Refrigerated Bottled or Canned Beverage Vending Machines" (Docket No. EERE-2006-STD-0125; 73 Fed. Reg. 34094, June 16, 2008).
080501OwensSenatePUHCA.pdf5/1/2008Statement before Senate hearing on electric utility holding company regulation
EEI statement by David K. Owens, EEI Executive Vice President, Business Operations, before the United States Senate Committee on Energy and Natural Resources hearing to examine the adequacy of state and federal regulatory structures for governing electric utility holding companies, May 1, 2008.
080415EEIHouseEnergyCorridors.pdf4/15/2008Statement on the West-wide Energy Corridor Process
EEI Statement on “The West-wide Energy Corridor Process: State and Community Impacts” submitted for the Joint Hearing Record of the Subcommittee on Energy and Mineral Resources and the Subcommittee on National Parks, Forests, and Public Lands, April 15, 2008.
080324ComerFERCBlanketAuthorizationsRehearing.pdf3/24/2008Request for Rehearing and Clarification of FERC Order on Blanket Authorization Under FPA
EEI Request for Rehearing and Clarification of FERC Final Rule on Blanket Authorization Under Federal Power Act (FPA) Section 203 (Order No. 708, Docket No. RM07-21).
080214ComerDOESection368PEIS.pdf2/14/2008EEI Comments on Draft PEIS for the Designation of Western Energy Corridors
EEI comments in response to the draft programmatic environmental impact statement (PEIS) prepared by the Departments of Energy, the Interior, Agriculture, and Defense in support of the proposed designation of energy corridors on federal land in 11 Western states DOE/EIS-0386), as required by Section 368 of the Energy Policy Act of 2005 (EPAct05).
080205LougheryDOEWesternCorridorsDPEIS.pdf2/5/2008Oral Statement on Western Energy Corridors Draft PEIS
Oral Statement of Richard M. Loughery, EEI Director, Environmental Activities at the February 5, 2008 public hearing in Washington, DC on the Western Energy Corridors Draft Programmatic Environmental Impact Statement (PEIS).
070906ComerFercHoldingCompanySecurities.pdf9/6/2007Comments on FERC's Blanket Authorization Under FPA Section 203 NOPR
EEI comments in response to FERC's blanket authorization under Federal Power Act (FPA) section 203 notice of proposed rulemaking (NOPR) (Docket No. RM07-21-000; 72 Fed. Reg. 41640,  July 31, 2007).
070906ComerFercAffiliateTransactions.pdf9/6/2007Comments on FERC's Cross-Subsidization Restrictions on Affiliate Transactions NOPR
EEI comments in response to FERC's cross-subsidization restrictions on affiliate transactions notice of proposed rulemaking (NOPR) (Docket No. RM07-15-000; 72 Fed. Reg. 41644 on July 31, 2007).
070823OwensFercGasTransparencyReply.pdf8/23/2007Reply Comments on FERC's Natural Gas Transparency NOPR
Reply comments of EEI and the Alliance of Energy Suppliers regarding FERC's Notice of Proposed Rulemaking (NOPR) on the transparency provisions of section 23 of the Natural Gas Act (NGA), which was added by the transparency provisions of the Energy Policy Act of 2005 (EPAct 2005) (Docket Nos. RM07-10-000 and AD06-11-000, 72 Fed. Reg. 20791, April 19, 2007).
070820ComerDoeEnergyEfficientProducts.pdf8/20/2007Comments on DOE Federal Procurement of Energy Efficient Products NOPR
EEI comments on DOE's notice of proposed rulemaking (NOPR) on the federal procurement of energy efficient products (Docket No. RIN 1904-AB68; 72 Fed. Reg. 33696, June 19, 2007).
070711LauderdaleFercGasTransparency.pdf7/11/2007Comments on FERC's Natural Gas Transparency NOPR
Comments of EEI and the Alliance of Energy Suppliers regarding FERC's Notice of Proposed Rulemaking (NOPR) on the transparency provisions of section 23 of the Natural Gas Act (NGA), which was added by the transparency provisions of the Energy Policy Act of 2005 (EPAct 2005) (Docket Nos. RM07-10-000 and AD06-11-000, 72 Fed. Reg. 20791, April 19, 2007).
070612HincheyMurthaWolf.pdf6/12/2007Joint Letter Opposing Hinchey-Murtha-Wolf Amendment
Letter sent to Members of the House of Representatives by EEI, the American Public Power Association, American Wind Energy Association, the National Rural Electric Cooperative Association, and the Nuclear Energy Institute in opposition to the Hinchey-Wolf-Murtha amendment to FY 2008 Energy and Water Appropriations denying DOE funding for making national interest electric transmission corridor designations under EPAct 2005.
070612HR2337TransmissionSiting.pdf6/12/2007Joint Letter Supporting Motion to Strike Title I and Title II of H.R. 2337
Letter sent to Members of the House Committee on Natural Resources  by EEI, the American Public Power Association, and the Western Business Roundtable, urging lawmakers to support a motion to strike Title I and Title II of H.R. 2337, the “Energy Policy Reform and Revitalization Act of 2007”  (includes Section 103 which raises new barriers to the siting of electric transmission lines).
070603ComerDoeEiaForms.pdf6/3/2007Comments on Proposed Revisions to Electric Power Survey Forms
EEI comments on EIA's proposed revisions to electric power survey forms EIA-411, 423, 767, 826, 861, 906, 920 and 923 (72 Fed. Reg. 16337, April 4, 2007).
070601FangStateCar4climate.pdf6/1/2007Comments on the Draft Fourth U.S. Climate Action Report
EEI comments on the draft fourth U.S. Climate Action Report for submission, pursuant to articles 4.2 and 12 of the Framework Convention on Climate Change (FCCC) and the decision of the FCCC’s Conference of the Parties at its eighth session (Decision 4/CP.8), to the FCCC’s secretariat (72 Fed. Reg. 25676, May 4, 2007; extension granted at 72 Fed. Reg. 27349, May 15, 2007).
070528RosenstockDoeWaterHeaters.pdf5/28/2007Comments regarding the Draft Criteria for ENERGY STAR Residential Water Heaters
EEI comments regarding the Draft Criteria for ENERGY STAR Residential Water Heaters that was published on May 2, 2007.
070524BoddieSenateEfficiencyTax.pdf5/24/2007Statement Before the Senate on Energy Efficiency Tax Incentives
EEI statement for the record before the Senate Finance Subcommittee on Energy, Natural Resources & Infrastructure on the topic of “Energy Efficiency: Can Tax Incentives Reduce Consumption?”
070524ComerAppeals-3rdOsha.pdf5/24/2007Brief in EEI v. Occupational Safety & Health Administration
Brief of petitioner EEI in the United States Court Of Appeals for The Third Circuit court case, Edison Electric Institute, Petitioner, v. Occupational Safety & Health Administration, Department Of Labor and Elaine L. Chao, Secretary, United States Department Of Labor, Respondents, for review of hexavalent chromium final rule (Case No. 06-2604).
070523KuhnHouseCorridors.pdf5/23/2007Letter to Congressman Rahall on Section 103 of HR 2337 on Energy Corridors for Transmission Siting
EEI President Tom Kuhn letter to Congressman Rahall expressing concern with Section 103 of HR 2337, the "Energy Policy Reform and Revitalization Act of 2007," which repeals Section 368 of the "Energy Policy Act of 2005" (EPAct), which requires the designation of energy corridors across federal lands to assist in the future siting of transmission facilities.
070518BartholomotAppeals-DcCamr.pdf5/18/2007Joint Brief in State of New Jersey, et al., v. U.S. Environmental Protection Agency
Joint brief of state respondent-interveners, industry respondent-interveners and state amicus, including EEI, in State of New Jersey, et al., Petitioners, v. United States Environmental Protection Agency, Respondent, in the U.S. Court of Appeals for the District of Columbia Circuit, on petition for review of the EPA final Clean Air Mercury Rule (CAMR) (Case No. 05-1097; and consolidated cases).
070517HoldsworthRGGIMultiPrelimRpt.pdf5/17/2007Comments on Initial Report of the RGGI Emissions Leakage Multi-State Working Group
EEI comments on the preliminary report of Multi-State Working Group evaluating potential emissions leakage in RGGI.
070515EeiCongressDividends.pdf5/12/2007Letter to House and Senate Supporting Reduced Tax Rates on Capital Gains and Dividends
Letter highlighting the success of the 2003 tax law that reduced tax rates on capital gains and dividends, signed by 81 companies and organizations, including EEI and 32 of its member companies, and sent to all members of the House and Senate.
070430OwensFercConduct.pdf4/30/2007Reply Comments in Standards of Conduct for Transmission Providers NOPR
EEI reply comments in response to the Notice of Proposed Rulemaking (NOPR) on standards of conduct for transmission providers (Docket No. RM07-1-000).
070424EeiHouseGreenhouseGases.pdf4/24/2007Response to Barton-Hastert Letter of March 20, 2007
EEI responses to climate policy questions sent to EEI by Representatives Barton and Hastert of the House Energy and Commerce Committee and Energy and Air Quality Subcommittee.
070413ComerFtcLabeling.pdf4/13/2007Comments on FTC's Appliance Labeling Proposed Rule
EEI comments on FTC's appliance labeling rule amendments (R511994, 16 CFR Part 305, 72 FED. REG. 6834, February 13, 2007).
070411MohlStbRail.pdf4/11/2007Statement at STB Public Hearing on Rail Capacity and Infrastructure Requirements
Statement of William M. Mohl, Vice President, Commercial Operations, Entergy Services, Inc., on behalf of EEI, at the Surface Transportation Board (STB) public hearing on "Rail Capacity and Infrastructure Requirements" held April 11, 2007 (STB Ex Parte No. 671).
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