EEI > Issues & Policy > Testimony, Filings, and Briefs
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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
150325SheaCeqNepaClimateChangeGuidance.pdf3/25/2015Comments on the Council on Environmental Quality (CEQ) Revised Draft NEPA Guidance on Consideration of Greenhouse Gas
EEI comments in response to the revised draft guidance to provide federal agencies assistance and guidance in examining the potential effects of proposed actions and alternatives on greenhouse gas (GHG) emissions and the potential effects of climate change on the environmental consequences of proposed actions and alternatives when conducting environmental reviews under the National Environmental Policy Act (NEPA) (79 Fed. Reg. 77802, December 24, 2015).
150325RosenstockDoeResidentialDishwashersStandards.pdf3/25/2015NOPR on DOE's Energy Conservation Standards for Residential Dishwashers
EEI comments on the U.S. Department of Energy (DOE) notice of proposed rulemaking (NOPR) on energy conservation standards for residential (Docket # EERE-2014-BT-STD-0021 , 79 Fed. Reg. 76142, December 19, 2014).
150324KuhnSenateWotus-Ghgs.pdf3/24/2015Statement Before the Senate Committee on Appropriations on FY 2016 Appropriations Regarding WOTUS Proposed Rule and proposed guidelines to regulate GHGs
“Written Statement Submitted by Thomas R. Kuhn, President, Edison Electric Institute, Regarding Fiscal Year 2016 Appropriations Subcommittee on Interior, Environment, and Related Agencies, Senate Committee on Appropriations” regarding the Waters of the U.S. proposed rule and the proposed guidelines to regulate greenhouse gas emissions (GHGs) under Section 111(d) of the Clean Air Act (CAA).
150317SheaFwsNorthernLongEaredBat.pdf3/17/2015Comments on the FWS Notice of a Proposed Rule and Reopening of Comment Period on Listing the Northern Long-eared Bat Under the ESA Section 4(d)
EEI comments in response to the January 16, 2015 notice by the U.S. Fish and Wildlife Service (FWS) of a proposed rule under section 4(d) of the Endangered Species Act (ESA) and a reopening of the comment period for the proposed rule to list the northern long-eared bat (NLEB) as an endangered species under the Act (Docket No. FWS-R5-ES-2011-0024; 80 FR 2371, January 16, 2015).
150306McMahonFercRtoIsoPriceFormation.pdf3/6/2015Comments on Issues Raised in FERC’s Technical Workshops on Price Formation in Energy and Ancillary Services Markets Operated by RTOs and ISOs
EEI comments submitted pursuant to the Federal Energy Regulatory Commission’s (FERC’s) January 16, 2015 notice inviting post-technical workshop comments, and the February 9, 2015 notice granting extension of time, regarding the issues raised during the workshops in the proceeding on “Price Formation in Energy and Ancillary Services Markets Operated by Regional Transmission Organizations [RTOs] and Independent System Operators [ISOs]” (Docket No. AD14-14-000; 80 Fed. Reg., January 23, 2015).
150227RosenstockEpaDistributionTransformersDraftSpecification.pdf2/27/2015Comments on EPA’s Distribution Transformers Specification Draft
EEI comments on the U.S. Environmental Protection Agency’s (EPA’s) “Energy Star Distribution Transformers Draft Specification Framework” released in December 2014.
150220RosenstockDoeZeroEnergyBuildingsRfi.pdf2/20/2015Comments on DOE's Definition of Zero Energy Buildings RFI
EEI comments in response to the U.S. Department of Energy (DOE) Request for Information (RFI) for Definition of Zero Energy Buildings (Docket No. EERE-2014-BT-BLDG-0050; 80 Fed. Reg. 499, January 6, 2015).
150206DTEEnergyFercElectricReliability.pdf2/6/2015Statement at FERC’s Environmental Regulations and Electric Reliability, Wholesale Electricity Markets, and Energy Infrastructure Technical Conference
Written opening statement by Gerry Anderson, Chairman and CEO, DTE Energy, for the Edison Electric Institute (EEI), at the Federal Energy Regulatory Commission (FERC) ”Technical Conference on Environmental Regulations and Electric Reliability, Wholesale Electricity Markets, and Energy Infrastructure” (Docket No. AD15-4-000).
150127OdomSenateCyberSecurityInfoSharing.pdf1/27/2015Joint Industry Associations Letter, from Nearly Every Sector of the American Economy, Strongly Urging Quick Senate Passage of a Cybersecurity Information-Sharing Bill
Joint letter from EEI and 34 other energy and other industry associations, including the American Public Power Association (APPA), National Rural Electric Cooperative Association (NRECA), Large Public Power Council (LPPC), Utilities Telecom Council (UTC), GridWise Alliance and the American Gas Association (AGA), all representing nearly every sector of the American economy, and strongly urging the Senate to quickly pass a cybersecurity information-sharing bill.
150120McMahonFercPJMCapacityPricingMotion.pdf1/20/2015Motion to Intervene and Comments in the FERC’s PJM Interconnection, LLC Capacity Pricing Proceeding
Motion to intervene and comments of Edison Electric Institute in the Federal Energy Regulatory Commission (FERC) proceeding, “Reforms to the Reliability Pricing Market and Related Rules in the PJM Open Access Transmission Tariff and Reliability Assurance Agreement Among Load Serving Entities,” involving PJM Interconnection’s proposed reforms to the Reliability Pricing Model (Docket No. ER15-623-000; 79 Federal Register 77467).

150116ParikhCftcTradeOptionFormCompliance.pdf1/16/2015Joint Association Letter Requesting No-Action Relief Regarding the CFTC Trade Option Reporting Requirements
Joint letter from the Edison Electric Institute (EEI), American Gas Association, American Public Power Association (APPA), Electric Power Supply Association (EPSA), and National Rural Electric Cooperative Association (NRECA), on behalf of their members, requesting no-action relief regarding the CFTC trade option reporting requirements (17 C.F.R. § 32.3(b)(1)-(2)).
150115McMahonCftcForwardContractsGuidelines.pdf1/15/2015Joint Association Comments on the CFTC’s Proposed Interpretation Regarding Forward Contracts with Embedded Volumetric Optionality
Joint comments by the Edison Electric Institute (EEI), American Public Power Association (APPA), Electric Power Supply Association (EPSA), Large Public Power Council (LPPC), and National Rural Electric Cooperative Association (NRECA) calling on the Commodity Futures Trading Commission (CFTC) to expand upon its recent interpretation of guidelines governing forward contracts. (Release No. 33-9681, 34-73584, File No. S7-16-11; 79 Federal Register 69073, November 20, 2014).
150113McMahonCftcCommodityInterestCashForwardRecords.pdf1/13/2015Comments on the CFTC’s Records of Commodity Interest and Related Cash or Forward Transactions NOPR
EEI comments in response to the Commodity Futures Trading Commission’s (CFTC’s) notice of proposed rulemaking (NOPR) on records of commodity interest and related cash or forward transactions, specifically related to easing record-keeping burdens (RIN 3038-AE23; 79 Federal Register 68140, November 14, 2014).
141222RosenstockDoeHIDLampStandards.pdf12/22/2014Comments on DOE’s Notice of Proposed Determination for Energy Conservation Standards for High-Intensity Discharge Lamps
EEI comments on the U.S. Department of Energy’s (DOE's) notice of proposed determination for energy conservation standards for high-intensity discharge (HID) lamps (Docket #EE-2010-BT-STD-0043; 79 Fed. Reg. 62910, October 21, 2014).
141215RosenstockDoeFossilFuelConsumptionReduction.pdf12/15/2014Comments on DOE’s Fossil-Fuel Generated Energy Consumption Reduction for New Federal Buildings Proposed Rule
EEI’s comments and recommended technical changes in response to the U.S. Department of Energy’s (DOE's) proposal concerning energy conservation in newly built federal buildings and those undergoing major renovation (Docket #EERE-2010-BT-STD-0031; 79 Fed. Reg. 61694, October 14, 2014).
EEI_111(d)_Comments_Final_12012014.pdf12/1/2014Comments of the Edison Electric Institute on Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units
EEI comments are in response to EPA’s proposed Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units issued by the Environmental Protection Agency (Agency) in Docket No. EPA-HQ-OAR-2013-0602. 79 Fed. Reg. 34,830 (June 18, 2014). These comments also address the subsequently issued Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units; Notice of Data Availability, 79 Fed. Reg. 64,534 (Oct. 30, 2014).

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.
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