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
151230Eei-IndustryFercConnectedEntityData.pdf12/30/2015Joint Industry Group Expedited Motion for the FERC To Suspend The Proposed Rule and Issue A New/Revised/Supplemental Notice Of Proposed Rulemaking on the Collection of Connected Entity Data from RTOs and ISOs
Joint Expedited Motion of the American Forest & Paper Association (AF&PA), Canadian Electricity Association (CEA), Commercial Energy Working Group (CEWG), Edison Electric Institute (EEI), Electricity Consumers Resource Council (ELCON), Electric Power Supply Association (EPSA), Independent Power Producers of New York, Inc. (IPPNY), Industrial Energy Consumers Group (IECG), International Energy Credit Association (IECA) and the Retail Energy Supply Association (RESA) (collectively, “Industry Groups”), on behalf of their members, requesting that the Federal Energy Regulatory Commission (FERC) suspend the comment date established in its notice of proposed rulemaking (NOPR)12 and extended by Technical Conference Order regarding the Collection of Connected Entity Data from Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs) (Docket No. RM15-23-000; 80 Fed. Reg. 71755, November 17, 2015).
151130McMahonFercRtoSettlementIntervals-ShortagePricing.pdf11/30/2015Comments on FERC’s NOPR on Settlement Intervals and Shortage Pricing in Markets Operated by RTOs and ISOs
EEI comments in response to the Federal Energy Regulatory Commission’s (FERC’s) notice of proposed rulemaking (NOPR) on settlement intervals and shortage pricing in markets operated by regional transmission organizations (RTOs) and independent system operators (ISOs) (Docket No. RM15-24-000; 80 Fed. Reg. 58393, September 29, 2015).
151117RosenstockEpaElectricVehicleSupplyEquipment.pdf11/17/2015Comments on EPA’s electric vehicle supply equipment (EVSE) Draft 2 Test Method
EEI comments on the U. S. Environmental Protection Agency's (EPA's) Draft 2 Test Method (Rev. Oct-2015) and the October 21, 2015 webinar slides addressing the test methods for electric vehicle supply equipment (EVSE).
151116BartholomotFercMarketBasedRatesMotion.pdf11/16/2015Rehearing And Motion To Stay Regarding Refinements To FERC’s Market-Based Rates Rule
EEI request for rehearing and motion for stay regarding the Federal Energy Regulatory Commission’s (FERC’s) rule on refinements to policies and procedures for market-based rates (MBR) for wholesale sales of electric energy, capacity and ancillary services by public utilities (Docket No. RM14-14-000; 80 Fed. Reg. 67056, October 30, 2015).
151030ParikhCftcClearedSwapsReporting.pdf10/30/2015Joint Association Comments on CFTC’s Swap Data Recordkeeping and Reporting Requirements NOPR
Joint comments of the Edison Electric Institute (EEI) and the Electric Power Supply Association (EPSA) in response to the Commodity Futures Trading Commission’s (CFTC's) notice of proposed rulemaking (NOPR) on amendments to the swap data recordkeeping and reporting requirements for cleared swaps (RIN 3038-AE12; 80 Fed. Reg. 52544, August 31, 2015).
151014RosenstockDoeResidentialFurnaceStandardsNoda.pdf10/14/2015Comments on DOE’s Energy Conservation Standards for Residential Furnaces NODA
EEI Comments on the U.S. Department of Energy’s (DOE’s) Office of Energy Efficiency and Renewable Energy (EERE) notice of data availability (NODA) on energy conservation standards for residential furnaces (Docket # EERE-2014-BT-STD-0031; 80 Fed. Reg. 55038, September 14, 2015).
151001RosenstockEpa-NhtsaVehicleEmissions-FuelEfficiencyStandards.pdf10/1/2015Comments on the Joint EPA-NHTSA Proposed Rule for Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles
EEI comments on the Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration (NHTSA) proposed rule for greenhouse gas emissions and fuel efficiency standards for medium- and heavy-duty engines and vehicles (Docket Nos. EPA-HQ-OAR-2014-0827; NHTSA-2014-0132; 80 Fed Reg. 40137, July 13, 2015).
150921FamaFercCipSupplyChainReliabilityStandards.pdf9/21/2015Joint Trade Association Comments on FERC’s Reliability Standards for Critical Infrastructure Protection (CIP) and Supply Chain Management NOPR
Comments of the Edison Electric Institute (EEI), the American Public Power Association (APPA), National Rural Electric Cooperative Association (NRECA), Electric Power Supply Association (EPSA), Electricity Consumers Resource Council (ELCON), Transmission Access Policy Study Group (TAPS), and the Large Public Power Council (LPPC), submitted to the Federal Energy Regulatory Commission (FERC) in response to the notice of proposed rulemaking (NOPR) on reliability standards for critical infrastructure protection (CIP) and supply chain management (Docket No. RM15-14-000; 80 Fed. Reg. 43354, July 22, 2015).
150908IngramFercLargeGeneratorInterconnectionProcedures-Agreement.pdf9/8/2015Comments Submitted to FERC Opposing AWEA’s Petition for a NOPR on the Pro Forma Large Generator Interconnection Procedures (LGIP) and Pro Forma Large Generator Interconnection Agreement
EEI comments, on behalf of its members, submitted to the Federal Energy Regulatory Commission (FERC) in opposition to the petition for a notice of proposed rulemaking (NOPR) filed by the American Wind Energy Association (AWEA) regarding the threshold for a rulemaking to revise provisions of the pro forma large generator interconnection procedures (LGIP) and pro forma large generator interconnection agreement (LGIA) as proposed therein (Docket No. RM15-21-000, June 19, 2015).
150818FishmanFercEeiMotion-JointDispatchAgreement.pdf8/18/2015EEI Motion To Intervene Out Of Time and Motion for Clarification in Proceedings for Joint Dispatch Agreement and Tariff Revisions
EEI motion to intervene out of time and motion for clarification, on behalf of its member companies, submitted to the Federal Energy Regulatory Commission (FERC) in response to the order rejecting proposed joint dispatch agreement and tariff revisions in the proceedings for Public Service Company of Colorado, Black Hills/Colorado Electric Company (Docket No. ER15-237-003, Docket No. ER15-326-000, Docket No. ER15-295-002, Docket No. ER15-348-002 (Not Consolidated); 80 Fed. Reg. 25287, May 4, 2015).
150803Eei-IndustrySenateCybersecurityCisa.pdf8/3/2015Joint industry association letter urging passage of the Cybersecurity Information Sharing Act (CISA) of 2015
Joint letter from 9 industry organizations, including EEI, reiterating their support for cybersecurity information sharing and liability protection legislation and urging the Senate to promptly take up and pass S. 754, the Cybersecurity Information Sharing Act (CISA) of 2015.
150724RosenstockDoeResidentialFurnaceStandards.pdf7/24/2015Comments on DOE’s Energy Conservation Standards for Residential Furnaces NOPR
EEI comments on the U.S. Department of Energy (DOE) notice of proposed rulemaking (NOPR) on amending energy conservation standards for residential furnaces (Docket # EERE-2014-BT-STD-0031; 80 Fed. Reg. 13120, March 12, 2015; comment deadline extended from June 10 to July 10, 80 Fed. Reg. 28851, May 20, 2015).
150721Eei-PacncSenateCybersecurityInformationSharing.pdf7/21/2015Letter to the U.S. Senate urging Passage of the Cybersecurity Information Sharing Act of 2015
Letter from the Protecting America’s Cyber Networks Coalition, including member EEI, sent to the Members of the United States Senate urging the consideration and passage of S. 754, the Cybersecurity Information Sharing Act (CISA) of 2015.
150701RosenstockDoeResidentialBoilerStandards.pdf7/1/2015Comments on DOE’s NOPR for Energy Conservation Standards For Residential Boilers
EEI comments on the U.S. Department of Energy (DOE) notice of proposed rulemaking (NOPR) for energy conservation standards for residential boilers, (Docket # EERE-2012-BT-STD-0047, 80 Fed. Reg. 17222, March 31, 2015; comment deadline extended from June 1 to July 1 at 80 Fed. Reg. 28852, May 20, 2015).
150618KuhnHouseFccTelecommunicationsIssues.pdf6/18/2015Letter to House Subcommittee on Financial Services and General Government on FCC Telecommunications Issues
Letter from EEI President Thomas R. Kuhn, sent to Chairman Crenshaw, Subcommittee on Financial Services and General Government, Committee on Appropriations, U.S. House of Representatives, sharing EEI views on on three Federal Communications Commission (FCC) issues, including telecommunications policymaking.
150608RosenstockFercEeiMotion-VaughnWaterHeaters.pdf6/8/2015Motion to Intervene with FERC for Vaughn Thermal Corporation Petition Regarding A DOE Water Heater Standard
EEI motion to intervene and comments submitted to the Federal Energy Regulatory Commission (FERC) in support of Vaughn Thermal Corporation’s petition for review pertaining to a U.S. Department of Energy (DOE) energy conservation standard for residential water heaters, pool heaters and direct heating equipment issued in April 2010.
150511RosenstockDoeResidentialClothesDryers.pdf5/11/2015Comments on DOE’s Energy Conservation Standards for Residential Clothes Dryers RFI
EEI comments on the U.S. Department of Energy (DOE) request for information (RFI) on energy conservation standards for residential clothes dryers (Docket No. EERE-2014-BT-STD-0058; 80 Fed. Reg. 16309, March 27, 2015).
150508RosenstockDoeResidentialWaterHeaters,.pdf5/8/2015Comments on DOE’s Definition of Residential Water Heaters NOPR
EEI comments on the U.S. Department of Energy (DOE) notice of proposed rulemaking (NOPR) for the "Definitions of Residential Water Heaters," (Docket # EERE-2014-BT-STD-0045; 80 Fed. Reg. 18784, April 8, 2015).
150403OwensFercEpaCppTechnicalConference.pdf4/3/2015Supplemental Comments on Issues Raised at FERC’s Technical Conferences on the EPA’s Proposed Clean Power Plan, Addressing Environmental Regulations and Electric Reliability, Wholesale Electricity Markets, and Energy Infrastructure
EEI supplemental comments on the issues raised during the series of U.S. Federal Energy Regulatory Commission (FERC) technical conferences on the U.S. Environmental Protection Agency’s (EPA’s) proposed Clean Power Plan (CPP) issued on June 2, 2014.  These comments supplement the written statement and remarks of Gerard Anderson, on behalf of EEI, provided for the FERC’s February 19, 2015 national overview conference, and address environmental regulations and electric reliability, wholesale electricity markets, and energy infrastructure (Docket No. AD15-4-000).
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)).
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