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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
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).
140228ComerDoeDistributedSolarEnergyCosts.pdf2/28/2014Comments on DOE’s RFI on the Value of Solar Energy Regarding Net Benefits and Costs of Distributed Solar Energy
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 1, “Net Benefits and Costs of Distributed Solar Energy” (RFI DE-FOA-0001070).

140228ObenshainEpaUndergroundInjectionControl.pdf2/28/2014Joint EEI-ACCCE-NMA-CURC Comments on EPA’s Underground Injection Control Program
Joint comments of EEI, the American Coalition for Clean Coal Electricity (ACCCE), the National Mining Association (NMA) and the Coal Utilitization Research Council (CURC) on the Environmental Protection Agency’s (EPA’s) draft underground injection control (UIC) program guidance on transitioning class II to class VI wells (EPA-816-P-13-004).
140226SheaOmbSocialCostCarbon.pdf2/26/2014Comments on OMB's Social Cost of Carbon Technical Update
EEI comments submitted to the Office of Information and Regulatory Affairs (OIRA), of the Office of Management and Budget (OMB), on the technical support document (TSD), "Technical Update of the Social Cost of Carbon for
Regulatory Impact Analysis Under Executive Order No. 12866" (Docket ID OMB-OMB-2013-0007).
140220McMahonFercImm-PjmComplaint.pdf2/20/2014Motion To Intervene in FERC's PJM Interconnection, L.L.C. Proceeding
Motion To Intervene And Comments Of Edison Electric Institute in the Federal Energy Regulatory Commission (FERC) proceeding, "Independent Market Monitor of PJM v. PJM Interconnection, L.L.C. (Docket No. EL14-20-000) .


140207RosenstockDoeGeneralServiceLamps.pdf2/7/2014Comments on DOE’s Energy Conservation Standards for General Service Lamps
EEI comments on the U.S. Department of Energy’s (DOE’s) Framework Document for “Energy Conservation Standards for General Service Lamps,” part of the Energy Efficiency Program for Consumer Products, and discussed at the public workshop that was held on January 14, 2014 (78 Fed. Reg. 73737, December 9, 2013).
140207McMahonCftcDerivativesPositionLimits.pdf2/7/2014Joint EEI-EPSA Comments on CFTC’s Position Limits for Derivatives Proposed Rule
Joint comments and recommendations by EEI and the Electric Power Supply Association (EPSA) provided in response to the Commodity Futures Trading Commission (CFTC) notice of proposed rulemaking (Proposed Rule) concerning position limits on derivatives (RIN 3038–AD99, 78 Fed. Reg. 75680; December 12, 2013).
140206HoldsworthEpaEguGhgStandards.pdf2/6/2014Statement at EPA's Public Hearing on Proposed GHG Standards for New Electric Generating Units
EEI statement at the U.S. Environmental Protection Agency's (EPA's) public hearing on proposed greenhouse gas (GHG) standards for new electric generating units, addressing natural gas unit compliance, the lack of an explicit exemption for simple-cycle combustion turbines, and EPA’s determination regarding carbon capture and storage (CCS).

140124OwensFercZeroRateReactivePowerSchedules.pdf1/24/2014Joint EEI and AWEA Comments on FERC’s Zero Rate Reactive Power Rate Schedules
Joint comments of the Edison Electric Institute (EEI) and the American Wind Energy Association (AWEA) pursuant to the Federal Energy Regulatory Commission’s (FERC’s) December 17, 2013, notice allowing post-workshop comments on zero rate reactive power rate schedules (Docket No. AD14-1-000).
140123ComerDoeRenewablePowerSurveyTriennial.pdf1/23/2014Comments on EIA’s Request for OMB's Triennial Review of EIA's Existing and New Electricity and Renewable Power Survey Forms
EEI comments in response to the U.S. Department of Energy Energy Information Administration (EIA) request for the Office of Management and Budget's (OMB's) triennial review to renew approval of EIA’s existing electricity and renewable power survey forms EIA-63B, 411, 826, 860, 860M, 861, 861S, and 923 with changes, and to approve a new form EIA-930, under the Paperwork Reduction Act (78 Fed. Reg. 77667, December 24, 2013).
140121RosenstockDoeResidentialWaterHeaters.pdf1/21/2014Comments on DOE’s NOPR and Public Workshop on Standards for Residential and Commercial Water Heaters
EEI comments on the U.S. Department of Energy (DOE) “Energy Conservation [Standards] Program for Consumer Products and Certain Commercial and Industrial Equipment: Test Procedures for Residential and Commercial Water Heaters” notice of proposed rulemaking (NOPR) and the discussion at the public workshop held on December 6, 2013 (Docket # EERE-2011-BT-TP-0042; 78 Fed. Reg. 66202, November 4, 2013).

131223RosenstockDoeResidentialFurnaceFans.pdf12/23/2013Comments on DOE’s NOPR and Public Workshop on Standards for Residential Furnace Fans
EEI comments on the U.S. Department of Energy (DOE) “Energy Conservation Program for Consumer Products: Energy Conservation Standards for Residential Furnace Fans” notice of proposed rulemaking (NOPR) and the discussion at the public workshop held on December 3, 2013 (Docket # EERE-2010-BT-STD-0011; 78 Fed. Reg. 64068, October 25, 2013).
131120SteckelbergHouseNaturalGasPipelineReform.pdf11/20/2013Letter to the House In Support of H.R. 1900, the Natural Gas Pipeline Permitting Reform Act
Dear Representative letter, sent on behalf of EEI’s member companies, in support of H.R. 1900, the Natural Gas Pipeline Permitting Reform Act, which would help expedite the construction of natural gas pipelines by providing for timely consideration of licenses, permits and approvals required under federal law.

131112RosenstockDoeCommercialRefrigerationEquipment.pdf11/12/2013Comments on DOE's NOPR on Commercial Refrigeration Equipment Standards
EEI comments on the U.S. Department of Energy’s (DOE’s) notice of proposed rulemaking regarding the energy conservation program for consumer products and certain commercial and industrial equipment, including standards for commercial refrigeration equipment (CRE) (Docket No. EERE-2010-BT-STD-0003; 78 Fed. Reg. 55890, September 11, 2013).
131018McMahonReliabilityFrequencyStandard.pdf10/18/2013Comments on FERC’s Market Implications of Frequency Response and Frequency Bias Setting Requirements NOPR and Extension
EEI comments in response to the Federal Energy Regulatory Commission's (FERC's) Notice of Request for Comment regarding the Notice of Proposed Rulemaking (NOPR) on Reliability Standard BAL-003-1, and the subsequent extension of time, issued on July 18, 2013 in the proceeding on market implications of frequency response and frequency bias setting requirements (Docket No. AD13-8-000).
130920SheaEpaSteamPlantELGs.pdf9/20/2013Comments on EPA's ELGs for the Steam Electric Power Generating Point Source Category
EEI comments in response to the U.S. Environmental Protection Agency’s (EPA’s) proposed rule on effluent limitation guidelines and standards (ELGs) for the steam electric power generating point source category (EPA–HQ–OW–2009–0819. FRL–9801–6;
EPA–HQ–RCRA–2013–0209; 78 Fed. Reg. 34431, June 7, 2013; notice extending the comment deadline, at:  78 Fed. Reg. 41907, July 12, 2013).
130911RosenstockDoeComputerDetermination .pdf9/11/2013Comments on DOE's Proposed Conservation Standards Determination for Computers
EEI comments on the U.S. Department of Energy's (DOE's) “Energy Conservation [Standards] Program for Consumer and Certain Commercial and Industrial Equipment: Notice of Proposed Determination of Computers as a Covered Consumer Product” (Docket # EERE-2013-BT-DET-0035; 78 Fed. Reg. 41873 (July 12, 2013).
130906McMahonCftcTAC-SDRMeeting.pdf9/6/2013Comments on the CFTC’s TAC Meeting Notice on Swap Data Repository Reporting
EEI comments in response to the Commodity Futures Trading Commission’s (CFTC’s) notice of the Technology Advisory Committee (TAC) meeting, held September 12, 2013, regarding data standardization in the context of swap data repository (SDR) reporting (78 Fed. Reg. 50040, August 16, 2013).
130826SheaEpaMatsStartupShutdown.pdf8/26/2013Comments on EPA’s Proposed Rule on the Reconsideration of Certain Startup/Shutdown Issues Regarding Emissions and Performance Standards for Electric Utility Steam Generating Units
EEI comments in response to the Environmental Protection Agency (EPA) proposed rule on “Reconsideration of Certain Startup/Shutdown Issues:  National Emission Standards for Hazardous Air Pollutants From Coal- and Oil-Fired Electric Utility Steam Generating Units and Standards of Performance for Fossil-Fuel-Fired Electric Utility, Industrial-Commercial-Institutional, and Small Industrial- Commercial-Institutional Steam Generating Units” (Docket Nos. EPA-HQ-OAR-2009-0234; EPA-HQ-OAR-2011-0044; 78 Fed. Reg. 38001, June 25, 2013).
130823McMahonFercElectricGasCommunications.pdf8/23/2013Comments on the FERC’s NOPR on Communication Between Natural Gas Pipelines and Electric Transmission Operators
EEI comments in response to the Federal Energy Regulatory Commission (FERC) notice of proposed rulemaking (NOPR) regarding communication of operational information between natural gas pipelines and electric transmission operators (Docket No. RM13-17-000; 78 Fed. Reg. 44900, July 25, 2013).
130819McMahonFercOattAncillaryServices.pdf8/19/2013Request for Clarification of Third-Party Provision of Ancillary Services Requirements under FERC’s Pro Forma OATT
EEI request for clarification of third-party provision of ancillary services; accounting and financial reporting for new electric storage technologies requirements under the Federal Energy Regulatory Commission’s (FERC’s) pro forma open-access transmission tariff (OATT) (Docket Nos. RM11-24-000; AD10-13-000; Order No. 784).
130802OwensFccProgenyScadaInterference.pdf8/2/2013Reply of the Utility Trade Associations Before the FCC In the Matter of Request by Progeny LMS, LLC, Regarding the Unacceptable Interference Standard for Licensed SCADA Devices
Reply of the Utility Trade Associations, Edison Electric Institute (EEI), Utilities Telecom Council (UTC), American Public Power Association (APPA), and National Rural Electric Cooperative Association (NRECA), before the Federal Communications Commission (FCC), “In the Matter of Request by Progeny LMS, LLC for Waiver of Certain Multilateration Location and Monitoring Service Rules and Progeny LMS, LLC Demonstration of Compliance with Section 90.353(d) of the Commission’s Rules," regarding the unacceptable interference standard for licensed supervisory control and data acquisition (SCADA) devices (WT Docket No. 11-49, Order, FCC 13-78, June 6, 2013).

130802RosenstockDoePortableACDetermination .pdf8/2/2013Comments on DOE's Proposed Conservation Standards Determination for Portable Air Conditioners
EEI comments on the U.S. Department of Energy's (DOE's) “Energy Conservation [Standards] Program for Consumer and Certain Commercial and Industrial Equipment: Proposed Determination of Portable Air Conditioners as a Covered Consumer Product” (Docket # EERE-2013-BT-STD-0033; 78 Fed. Reg. 40403, July 5, 2013).

130724McMahonHouseCftcFuture.pdf7/24/2013Statement at the House Hearing on The Future of the CFTC: End-User Perspectives
Statement of Richard McMahon, on behalf of the Edison Electric Institute, at the hearing on “The Future of the CFTC: End-User Perspectives” before the Subcommittee on General Farm Commodities and Risk Management, Committee on Agriculture, U.S. House of Representatives.
130722KuhnSenateCorporateTaxReform.pdf7/22/2013Letter To All U.S. Senators Commenting on Three Tax Provisions Critically Important To All Shareholder-Owned Electric Utilities
Letter sent to all U.S. senators supporting the goals of corporate tax reform, commending Senate Finance Committee Chairman Max Baucus and Ranking Member Orrin Hatch for their commitment to reform the tax code, and commenting on three tax provisions critically important to all shareholder-owned electric utilities.
130719ComerFercPurpaInterventionProtest.pdf7/19/2013Motion to Intervene and Protest in the Hydrodynamics Inc., et. al., Petition Regarding PURPA, Filed with FERC
EEI motion to intervene and protest in response to the Hydrodynamics, Inc., Montana Marginal Energy, Inc., and WINData, LLC, petition for enforcement and declaratory order regarding the implementation of the Public Utility Regulatory Policies Act of 1978 (PURPA), filed with the Federal Energy Regulatory Commission (FERC) (Docket No. EL13-73-000).

130628RosenstockDoeIntlEnergyConservationCode .pdf6/28/2013Comments on the DOE Participation in Development of the International Energy Conservation Code (IECC) Proposed Public Comments
EEI comments on the proposed public comments of the U.S. Department of Energy (DOE) regarding its participation in the process of developing the International Energy Conservation Code (IECC) (Docket # EERE-2012-BT-BC-0030; 78 Fed. Reg. 33838, June 5, 2013).

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