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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
141120RosenstockDoeCommercialWaterHeatingStandards.pdf11/20/2014Comments on DOE’s Request for Information on Energy Conservation Standards for Commercial Water Heating Equipment
EEI comments in response to the U.S. Department of Energy (DOE) request for information (RFI) for “Energy Conservation Standards for Commercial Water Heating Equipment” (Docket # EERE-2014-BT-STD-0042; 79 Fed. Reg. 62899, October 21, 2014).
141114CWA-WOTUS-14-11-14-EPA-CorpsNOPR-EEI.pdf11/14/2014Comments on the EPA-Corps Waters of the United States Under the Clean Water Act Proposed Rule
EEI comments in response to the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (Corps) proposed rule to define “Waters of the United States” under the Clean Water Act (CWA), 33 U.S.C. §§ 1251 et seq., and its various water quality standards and permitting programs (Docket Number EPA-HQ-OW-2011-0880; 79 Fed. Reg. 22187, April 21, 2014; with extensions of comments deadline at: 79 Fed. Reg. 35712, June 24, 2014; and 79 Fed. Reg. 61590, October 24, 2014).
141106LougheryFwsVoluntaryConservationActions.pdf11/6/2014Comments on the FWS Draft Policy Regarding Voluntary Prelisting Conservation Actions
Comments and recommendations of the National Endangered Species Act Reform Coalition (NESARC), including member EEI, regarding the U.S. Fish and Wildlife Service (FWS) draft “Policy Regarding Voluntary Prelisting Conservation Actions.”
141103FamaFercPerformanceMetricsData.pdf11/3/2014Comments on Performance Metrics for ISOs, RTOs and Regions Outside of ISOs and RTOs
EEI comments in response to the Federal Energy Regulatory Commission (FERC) notice issued August 26, 2014, seeking comments on the collection of performance metric information from independent system operators (ISOs), regional transmission organizations (RTOs), and public utilities in regions outside ISO and RTO regions (Docket No. AD14-15-000).
141016SheaEpaCO2ModifiedReconstructedEGUs.pdf10/16/2014Comments on EPA’s Proposed Rule on Standards for Carbon Dioxide Emissions from Modified and Reconstructed Electric Utility Generating Units (EGUs) under Section 111(b) of the Clean Air Act (CAA)
EEI comments on the U.S. Environmental Protection Agency (EPA) proposed rule entitled “Carbon Pollution Standards for Modified and Reconstructed Stationary Sources: Electric Utility Generating Units” issued under section 111(b) of the Clean Air Act (CAA) (Docket No. EPA-HQ-OAR-2013-0603; 79 Fed. Reg. 34,960, June 18, 2014).
141010OwensDoeQuadrennialEnergyReview.pdf10/10/2014Second Set of Comments on the Public Meetings Process Regarding DOE’s Quadrennial Energy Review (QER)
EEI’s second set of comments, and accompanying materials, regarding the U.S. Department of Energy’s (DOE’s) Quadrennial Energy Review (QER), as a response to some, but not all, views shared throughout the public meeting process, and in response to other efforts currently under way at DOE in parallel or in conjunction with the QER process.
141001McMahonFercNaturalGasTradingPlatform.pdf10/1/2014Comments on FERC’s Request Regarding an Electronic Information and Trading Platform for Natural Gas
EEI comments in response to the Federal Energy Regulatory (FERC) Commissioner Philip D. Moeller’s request for comments on the issues raised during the September 18, 2014 meeting on developing an electronic information and trading platform for natural gas (Docket No. AD14-19-000).
140918RosenstockDOTCommercialDriversLicense.pdf9/18/2014Comments on FMCSA's Minimum Training Requirements for Entry-Level Commercial Drivers’ License Applicants Rulemaking Process NOI
EEI comments on the notice of intent (NOI) for a negotiated rulemaking process for minimum training requirements for entry-level commercial drivers’ license applicants issued by the U.S. Department of Transportation (DOT), Federal Motor Carrier Transportation Administration (FMCSA) (79 Fed. Reg. 49044, August 19, 2014).
140808RosenstockNhtsaVehicleFuelEfficiency.pdf8/8/2014Comments on NHTSA’s Intent to Prepare an EIS for New CAFE Standards
EEI comments on the National Highway Traffic Safety Administration’s notice of intent to prepare an environmental impact statement on new Corporate Average Fuel Economy (CAFE) standards for medium-  and heavy-duty trucks (Docket No. NHTSA-2011-0056, 79 FR 38842, July 9, 2014).
140729ComerFercOpenAccessInterconnection.pdf7/29/2014Comments on FERC Interconnection Customer’s Interconnection Facilities (ICF) NOPR
EEI comments on the Federal Energy Regulatory Commission’s (FERC’s) notice of proposed rulemaking on  “Open Access and Priority Rights on Interconnection Customer’s Interconnection Facilities” (ICIF) – a change  to waive the open access transmission tariff (OATT), the open access same-time information system (OASIS), and standards of conduct requirements for public utilities that own, control or operate ICIF (Docket No. RM14-11-000, 79 Fed. Reg. 31061, May 15, 2014).
140702RosenstockEpaWaterHeaterSpecification.pdf7/2/2014Comments on EPA’s ENERGY STAR® Water Heater Specification
EEI comments submitted to the U.S. Environmental Protection Agency (EPA) on the “Final Draft 1 Version 3.0 ENERGY STAR® Water Heater Specification.”
140702McMahonCftcSwapsSpecialEntities.pdf7/2/2014Comments on the CFTC’s Proposed Rule on Utility Operations-Related Swaps with Utility Special Entities
EEI comments on the Commodity Futures Trading Commission’s (CFTC’s) Proposed Rule regarding the Exclusion of Utility Operations-Related Swaps with Utility Special Entities from De Minis Threshold for Swaps with Special Entities (RIN 3038-AE19; 79 Fed. Reg. 31238, June 2, 2014).
140616RosenstockDoeBuildingsEnergyEfficiency.pdf6/16/2014Comments on DOE’s Preliminary Determination on ASHRAE Standard 90.1 to Improve Energy Efficiency in Commercial Buildings
EEI comments on the U.S. Department of Energy’s (DOE’s) Preliminary Determination Regarding Energy Efficiency Improvements in ANSI/ASHRAE/IES Standard 90.1-2013: Energy Standards for Buildings, Except Low-Rise Residential Buildings (Docket No. EERE-2014-BT-DET-0009, 79 Fed. Reg. 27778, May 15, 2014).
140610OwensFercQerInfrastructureVulnerabilities.pdf6/10/2014Comments on DOE’s QER Initial Public Meetings Covering Infrastructure Resilience and Vulnerabilities ‐ Cyber, Physical, Climate, Interdependencies
EEI initial comments, and accompanying materials, in response to the first phase of the U.S. Department of Energy’s (DOE’s) Quadrennial Energy Review (QER), covering the initial public meetings on “Infrastructure Resilience and Vulnerabilities ‐ Cyber, Physical, Climate, Interdependencies,” held April 11, 2014, April 21, 2014, and May 27, 2014.
140603McMahonFercThirdPartyAncillaryServices.pdf6/3/2014Comments Regarding FERC’s Workshop on Reactive Supply and Voltage Control, and Regulation Frequency Response Ancillary Services
EEI comments, submitted on behalf of its members operating in bilateral markets outside of regional transmission organizations (RTO) and independent system operators (ISO), pursuant to the Federal Energy Regulatory Commission’s (FERC’s) April 14, 2014, Supplemental Notice of Workshop, regarding Third –Party Provision of Ancillary Services including Reactive Supply and Voltage Control, and Regulation Frequency Response Services (Docket No. AD14-7-000).
140527McMahonCftcSwapDataReporting.pdf5/27/2014Comments on the CFTC Review of Swap Data Recordkeeping and Reporting Requirements
EEI comments on the Commodity Futures Trading Commission’s (CFTC's) reporting and recordkeeping rules regarding the use of swaps to hedge and mitigate commercial risk (RIN 3038-AE12; 79 Fed. Reg. 16689, March 26, 2014). 
140515McMahonFercWinterRtoIsoPerformanceTechConf.pdf5/15/2014Post FERC Technical Conference Comments Regarding Winter 2013-2014 RTO and ISO Operations and Market Performance
EEI post technical conference comments submitted in response to the Federal Energy Regulatory Commission’s (FERC’s) notice of technical conference on Winter 2013-2014 operations and market performance in regional transmission organizations (RTOs) and independent system operators (ISOs) (Docket No. AD14-8-000, February 21, 2014).
140513GreyHousePbgcPensionPremiums.pdf5/13/2014Joint Letter to the House Urging PBGC to Oppose Pension Premium Increases
Joint letter signed by 68 companies and associations, including EEI, that was sent to members of the U.S. House of Representatives urging members to oppose any efforts to further increase premiums paid to the Pension Benefit Guaranty Corporation (PBGC) by sponsors of single-employer defined benefit plans.
140513GreySenatePbgcPensionPremiums.pdf5/13/2014Joint Letter to the Senate Urging PBGC to Oppose Pension Premium Increases
Joint letter signed by 68 companies and associations, including EEI, that was sent to members of the U.S. Senate urging members to oppose any efforts to further increase premiums paid to the Pension Benefit Guaranty Corporation (PBGC) by sponsors of single-employer defined benefit plans.

140509SheaEpaEguGhgStandards.pdf5/9/2014EEI Comments Regarding EPA’s Proposed Rule on Greenhouse Gas Standards for New Electric Generating Units
Comments Of The Edison Electric Institute On the U.S. Environmental Protection Agency (EPA) proposed rule on ‘The Standards Of Performance For Greenhouse Gas Emissions From New Stationary Sources:  Electric Utility Generating Units” under section 111(b) of the Clean Air Act (Docket No. EPA-HQ-OAR-2013-0495; 79 Fed. Reg. 1430, January 8, 2014).
140430RosenstockEpaWaterHeaterSpecifications.pdf4/30/2014Comments on EPA's Water Heat Specifications
EEI comments on the United States Environmental Protection Agency (EPA) “Draft 1 Version 3.0 ENERGY STAR® Water Heater Specification.”
140425McMahonCFTCDerivativeseliverable supply coalition letter.pdf4/25/2014Joint Coalition Letter on the CFTC’s Position Limits for Derivatives Deliverable Supply Proposal
Joint letter by a coalition of organizations, including EEI, sent to the Commodity Futures Trading Commission (CFTC), regarding position limits for derivatives, urging a determination on current estimated deliverable supply for each of the 28 physical commodities covered by the proposal (RIN No. 3038-AD99; 78 Fed. Reg. 75,680, December 12, 2013).
140423KuhnFercRtoIsoWinterPerformance.pdf4/23/2014Joint EEI-EPSA Letter Regarding the FERC’s Technical Conference on Winter 2013-2014 Operations and Market Performance in Regional Transmission Organizations and Independent System Operators
Joint letter from the Edison Electric Institute (EEI) and the Electric Power Supply Association (EPSA) commending the Federal Energy Regulatory Commission's (FERC's) Chairman LaFleur and fellow Commissioners for leadership and initiative in convening the technical conference on April 1, 2014, regarding Winter 2013-2014 Operations and Market Performance in Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs), specifically to examine lessons learned (Docket Number AD14-8-000).

140421RosenstockDoeComm-IndAirCompressors.pdf4/21/2014Comments on DOE’s Framework Document for Commercial and Industrial Air Compressors, and on the Public Meeting
EEI comments on the U.S. Department of Energy’s (DOE’s) energy conservation standards framework document for commercial and industrial air compressors, and also on the issues raised at the public meeting that was held on April 1, 2014 (Docket # EERE-2012-BT-STD-0040; 79 Fed. Reg. 6839, February 5, 2014).
140417McMahonCftcDodd-FrankEndUsers.pdf4/17/2014Joint Association Comments on the Roundtable for Dodd-Frank End User Issues
Joint comments by the Edison Electric Institute (EEI) and the Electric Power Supply Association (EPSA) on the Commodity Futures Trading Commission’s (CFTC’s) public roundtable, held on April 2, 2014, to discuss Dodd-Frank end user issues.

140328RosenstockDoeCommercialWaterHeatingRfi.pdf3/28/2014Comments on DOE’s RFI on Test Procedures for Commercial Water Heating Equipment
EEI comments on the U.S. Department of Energy’s (DOE’s) request for information (RFI) for “Energy Conservation Standards for Certain Commercial and Industrial Equipment: Test Procedures for Commercial Water Heating Equipment” (Docket # EERE-2014-BT-TP-0008; 79 Fed. Reg. 10999, February 27, 2014).
140320OwensOstpSpectrumPolicyRfi.pdf3/20/2014Comments on the OSTP’s Notice of Request for Information Regarding Agency Incentives to Share or Relinquish Spectrum
EEI comments, submitted on behalf of its member electric utilities, in response to the Office of Science and Technology Policy's (OSTP’s) notice of request for information (RFI) for developing recommendations "regarding market-based or other approaches that could give departments and agencies greater incentive to share or relinquish spectrum, while protecting the mission capabilities of existing and future systems that rely on spectrum use" (79 Fed. Reg. 9288).
140313RosenstockDoeResidential Boilers.pdf3/13/2014Comments on DOE's Standards for Residential Boilers NODA
EEI comments on the U.S. Department of Energy’s (DOE’s) notice of data availability (NODA) for “Energy Conservation Standards for Residential Boilers: Availability of Analytical Results and Modeling Tools” (Docket # EERE-2012-BT-STD-0047; 79 Fed. Reg. 8122, February 11, 2014).
140304FishmanFccTcpaPredictiveDialers.pdf3/4/2014Joint EEI-AGA Letter Supporting the Communications Innovators’ Petition for an FCC TCPA Declaratory Ruling Regarding Predictive Dialers
Letter by EEI and the American Gas Association (AGA), on behalf of their respective member companies, submitted to the Federal Communications Commission (FCC), in the matter of rules and regulations implementing the Telephone Consumer Protection Act of 1991 (TCPA), expressing support for the Communications Innovators’ (CI’s) petition for a declaratory ruling regarding predictive dialers (CG Docket No. 02-278).
140228ComerDoeSolarDeploymentModels.pdf2/28/2014Comments on DOE’s RFI on the Value of Solar Energy Regarding Innovative Solar Deployment Models
EEI comments on the U.S. Department of Energy’s (DOE’s) request for information (RFI) on net benefits and costs of distributed solar energy and innovative solar deployment models, DOE-EERE Category 2, “Innovative Solar Deployment Models”  (RFI DE-FOA-0001070).
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