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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" tab.
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| 5/17/2013 | Comments on DOE's Interim Technical Support Document and Meeting for High-Intensity Discharge Lamps | EEI comments on the U.S. Department of Energy (DOE) “Interim Technical Support Document” and public meeting (April 2, 2013) for high-intensity discharge lamps (Docket # EERE-2010-BT-STD-0043; 78 Fed. Reg. 13566, Feb. 28, 2013). | | 5/6/2013 | Comments Regarding EIA’s Triennial Review of Existing Electricity Survey Forms, and Newly Proposed Balancing Authority Form | EEI comments in response to the U.S. Energy Information Administration (EIA) notice regarding its 2014 triennial review of existing electricity survey forms EIA-63B, 411, 826, 860, 860M, 861, and 923 with changes, along with a three year authorization of a newly proposed balancing authority operations form, EIA-930 (78 Fed. Reg. 14521, Mar. 6, 2013). | | 5/2/2013 | Comments on DOE’s Efficiency Standards for Commercial and Industrial Fans and Blowers | EEI comments on the notice of public meeting and availability of framework document for commercial and industrial fans and blowers regarding the U.S. Department of Energy (DOE) energy conservation standards program (Docket # EERE-2013-BT-STD-0006; 78 Fed. Reg. 7306, Feb. 1, 2013). | | 5/2/2013 | Comments on DOE’s Efficiency Standards for Commercial and Industrial Pumps | EEI comments on the notice of public meeting and availability of framework document for commercial and industrial pumps regarding the U.S. Department of Energy (DOE) energy conservation standards program (Docket # EERE-2011-BT-STD-0031; 78 Fed. Reg. 7304, Feb. 1, 2013). | | 4/29/2013 | Comments on Incentives and Other Public Policy Recommendations For Private Sector Engagement Regarding Cybersecurity and Critical Infrastructure | EEI comments submitted to the National Telecommunications and Information Administration, U.S. Department of Commerce, on incentives and other public policy recommendations for robust private sector engagement in the cybersecurity framework and a strong government-industry partnership in defense of critical infrastructure. | | 4/29/2013 | Joint EEI/APPA/NRECA Comments Regarding DOE’s NOPR on Energy Conservation Standards for Residential Water Heaters | Joint Edison Electric Institute (EEI), American Public Power Association (APPA) and National Rural Electric Cooperative Association (NRECA) comments on the U.S. Department of Energy (DOE) “Energy Conservation Program: Notice of Proposed Rulemaking (NOPR) for Energy Conservation Standards for Residential Water Heaters” (Docket Number: EERE–2012–BT–STD–0022; 78 Fed. Reg. 12969, Feb. 26, 2013). | | 4/25/2013 | Statement at FERC Technical Conference on Coordination Between Natural Gas and Electricity Markets | Statement of Lin Franks, Senior Strategist, Indianapolis Power & Light Company, on Behalf of the Edison Electric Institute, on the coordination between natural gas and electricity markets, at the April 25, 2013 FERC Technical Conference (Docket No. AD12-12-000). | | 3/11/2013 | Comments on DOE's Commercial Building Energy Asset Score RFI | EEI comments on the U.S. Department of Energy (DOE) request for information (RFI) on the commercial building energy asset score (78 Fed. Reg. 9042, Feb. 7, 2013). | | 3/8/2013 | Letter to the Federal Reserve on the "Predominantly Engaged in Financial Activities" Definition | EEI letter to the Board of Governors of the Federal Reserve System (FRS) in response to the proposed rulemaking on the definition of "Predominantly Engaged in Financial Activities" regarding Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. | | 3/8/2013 | Joint EEI-NRECA-APPA-EPSA Comments to the CFTC in Support of the Working Group Request Regarding the Compliance Date for Reporting Trade Options | Joint comments by Edison Electric Institute (EEI), the National Rural Electric Cooperative Association (NRECA), the American Public Power Association (APPA) and the Electric Power Supply Association (EPSA) to the Commodity Futures Trading Commission (CFTC) in support of the request for no-action relief extending the compliance date for reporting trade options submitted by the Commercial Working Group (Working Group) on March 1, 2013. | | 3/8/2013 | Joint EEI-NRECA-APPA-EPSA-AGA Comments to the CFTC in Support of the Working Group Request Regarding the Reporting Date for Swap Transactions | Joint comments by Edison Electric Institute (EEI), the National Rural Electric Cooperative Association (NRECA), the American Public Power Association (APPA), the Electric Power Supply Association (EPSA), and the American Gas Association (AGA) in support of the Request for No-Action Relief Extending the current April 10, 2013 compliance date for reporting swap transactions under Parts 43, 45, and 46 of the Commodity Futures Trading Commission’s (Commission) regulations submitted by the Commercial Working Group (Working Group) on March 1, 2013. | | 3/4/2013 | Comments on DOE's RFI on Air Conditioning and Heating Equipment Standards | EEI comments on the U.S. Department of Energy (DOE) request for information (RFI) on “Energy Conservation Program: Energy Conservation Standards for Small, Large, and Very Large Commercial Package Air Conditioning and Heating Equipment” (Docket No. EERE-2013-BT-STD-0007; 78 Fed. Reg. 7296, Feb. 1, 2013). | | 2/28/2013 | Comments on DOE's Efficiency Standards Notice on Commercial and Industrial Compressors | EEI comments on the U.S. Department of Energy (DOE) notice of proposed determination for commercial and industrial compressors as covered equipment, regarding efficiency standards (Docket # EERE-2012-BT-DET-0033; 77 Fed. Reg. 76972, Dec. 31, 2012). | | 2/20/2013 | Letter in response to the Bicameral Task Force on Climate Change Letter from Representative Waxman and Senator Whitehouse | EEI letter in response to a letter from Representative Henry Waxman and Senator Sheldon Whitehouse, co-chairs of the Bicameral Task Force on Climate Change, soliciting ideas for actions the federal government can take to address climate change and to discuss the power sector's actions that have reduced, and will continue to reduce, greenhouse gas (GHG) emissions. | | 2/15/2013 | Comments Before the FCC Superstorm Sandy Field Hearing Regarding Challenges to Communications Networks and Network Resiliency | Comments of Edward H. Comer, Vice President, General Counsel and Corporate Secretary, Edison Electric Institute before the Federal Communications Commission (FCC) Superstorm Sandy Field Hearing, New York, New York, February 5, 2012, to examine new challenges to the nation’s communications networks, and to help provide recommendations and action to improve network resiliency (Filed with the FCC on February 15, 2013). | | 2/14/2013 | BG&E Statement on Behalf of Exelon, EEI, and EPSA, Before the House Permanent Select Committee on Intelligence, Regarding Cybersecurity Information Sharing | Statement of Kenneth W. DeFontes, Jr., President and Chief Executive Officer, Baltimore Gas & Electric (BG&E), on behalf of Exelon Corporation, the Edison Electric Institute (EEI), and the Electric Power Supply Association (EPSA), before the House Permanent Select Committee on Intelligence United States House of Representatives, on securing the North American electric grid against cyber threats and the Cyber Intelligence Sharing and Protection Act (CISPA). | | 2/11/2013 | Comments 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). | | 1/7/2013 | Comments on EPA’s Proposed Reconsideration of Certain New Source Issues Relating to the Mercury and Air Toxics Standards (MATS) Final Rule and the New Source Performance Standards Rule (Utility NSPS) | EEI comments on the proposed “Reconsideration of Certain New Source and 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;” relating to the mercury and air toxics standards (MATS) final rule and the new source performance standards rule (Utility NSPS) (Docket Nos. EPA-HQ-OAR-2009-0234 and EPA-HQ-OAR-2011-0044; 77 Fed. Reg. 71323, November 30, 2012). | | 12/13/2012 | Memorandum of Intervenor-Defendants USWAG and NMA, Filed with the U. S. District Court for DC, on Behalf of EPA, Regarding the EPA Proposed RCRA Rule on Coal Combustion Residual (CCR) Facilities | Memorandum of intervenor-defendants Utility Solid Waste Activities Group (USWAG, including member EEI) and National Mining Association (NMA), in reply to plaintiffs’ responses to intervenor-defendants’ joint motion for summary judgment, filed with the United States District Court for the District Of Columbia, in the case “Appalachian Voices, et al., Plaintiffs, v. Lisa P. Jackson, in her official capacity as Administrator, United States Environmental Protection Agency, Defendant, and Utility Solid Waste Activities Group, and National Mining Association, Intervenor-Defendants” regarding the Environmental Protection Agency (EPA) proposed Resource Conservation and Recovery Act (RCRA) rule on coal combustion residual (CCR) disposal facilities (Civil Action No. 1:12-cv-00523-RBW consolidated with 1:12-cv-00585-RBW 1:12-cv-00629-RBW). | | 11/30/2012 | Reply Comments Regarding FCC Rules on Public Safety Broadband Communications | Reply comments of the Edison Electric Institute, on behalf of its member electric utilities, submitted to the Federal Communications Commission (FCC) in the matter of “Amendment to Part 90 of the Commission’s Rules,” “Implementing a Nationwide, Broadband, Interoperable Public Safety Network in the 700 MHz Band,” and “Service Rules for the 698-746, 747-762 and 777-792 MHz Bands” (WP Docket No. 07-100, PS Docket No. 06-229, WT Docket No. 06-150, respectively). | | 11/6/2012 | Motion for Intervention Regarding the Initial Decision on NorthWestern Corporation’s Schedule 3 Charges | Motion for intervention out of time and comments of the Edison Electric Institute addressing the adverse policy implications of the initial decision regarding regarding Northwestern Corporation’s Schedule 3 charges (Docket Nos. ER10-1138-001, ER12-316-000; September 21, 2012; (consolidated)). | | 10/29/2012 | Comments on DOE’s EV Everywhere Grand Challenge Initial Framing Document | EEI comments on the U.S. Department of Energy’s (DOE’s) “EV Everywhere: A Grand Challenge in Plug-In Electric Vehicles; Initial Framing Document” (77 Fed. Reg. 51983, August 28, 2012). | | 10/26/2012 | Comments on the RGGI Design Concepts Paper Regarding the CO2 Budget Trading Program | EEI comments on the "RGGI Program Review – Program Design Concepts" presentation paper regarding the CO2 Budget Trading Program, as required by the Regional Greenhouse Gas Initiative (RGGI) Memorandum of Understanding (MOU). | | 10/23/2012 | Joint Brief of Petitioners in “Utility Air Regulatory Group, Petitioner, v. Environmental Protection Agency, Respondent,” on New Source Performance Standards, Regarding EPA’s MATS Rule | Joint brief of petitioners on petition for review of final agency action (77 Fed. Reg. 9304, Feb. 16, 2012) in the United States Court of Appeals for the District of Columbia Circuit case “Utility Air Regulatory Group, Petitioner, v. Environmental Protection Agency, Respondent,” on new source performance standards (NSPS), regarding EPA’s “National Emission Standards for Hazardous Air Pollutants From Coal- and Oil-Fired Electric Utility Steam Generating Units” (MATS rule) (Case No. 12-1166 (consolidated with Nos. 12-1366 and 12-1420)); the Utility Air Regulatory Group (UARG) includes member EEI. | | 10/23/2012 | Joint Brief of Petitioners in “White Stallion Energy Center, LLC, et al., Petitioners, v. United States Environmental Protection Agency, et al., Respondents," Regarding EPA’s MATS Rule | Joint brief of state, industry, and labor petitioners on petition for review of final agency action (77 FR 9304, Feb. 16, 2012) in the United States Court of Appeals for the District of Columbia Circuit case White Stallion Energy Center, LLC, et al., Petitioners, v. United States Environmental Protection Agency, et al., Respondents," regarding EPA’s “National Emission Standards for Hazardous Air Pollutants From Coal- and Oil-Fired Electric Utility Steam Generating Units” (MATS rule) (Case No. 12-1100 (and consolidated cases)); the Utility Air Regulatory Group (UARG), a joint petitioner, includes member EEI. |
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| 2/11/2013 | Comments 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). | | 2/24/2012 | Comments 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. Department of Energy (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 Energy Policy Act of 2005 (EPAct), regarding the coordination of the federal authorization process for the siting and permitting of interstate electric transmission facilities (76 Fed. Reg. 77432, December 13, 2011). | | 9/12/2011 | Comments 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). | | 10/20/2008 | Comments 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). | | 10/20/2008 | Comments on DOE's Framework Document and Workshop on Efficiency Standards for Residential Refrigeration and Freezer Equipment | EEI comments on the framework document and workshop (held September 29, 2008) on energy conservation standards for residential refrigerators, refrigerator-freezers, and freezers; directly resulting from passage of the Energy Independence and Security Act of 2007 (EISA 2007) (Docket No. EERE-2008-BT-STD-0012; 73 Fed. Reg. 54089, September 18, 2008). | | 7/16/2008 | Comments 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). | | 5/1/2008 | Statement 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. | | 4/15/2008 | Statement 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. | | 3/24/2008 | Request for Rehearing and Clarification of FERC Order on Cross-Subsidization Restrictions on Affiliate Transactions | EEI Request for Rehearing and Clarification of FERC Final Rule on Cross-Subsidization Restrictions on Affiliate Transactions (FERC Order 707; Docket No. RM07-15). | | 3/24/2008 | Request 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). | | 2/14/2008 | EEI 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). | | 2/5/2008 | Oral 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). | | 9/6/2007 | Comments 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). | | 9/6/2007 | Comments 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). | | 8/23/2007 | Reply 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). | | 8/20/2007 | Comments 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). | | 7/11/2007 | Comments 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). | | 6/12/2007 | Joint 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. | | 6/12/2007 | Joint 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). | | 5/23/2007 | Letter 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. | | 4/13/2007 | Comments 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). | | 3/30/2007 | Comments on DOE's Draft Distributed Generation (DG) Study | EEI comments on DOE's draft "Study of the Potential Benefits of Distributed Generation and Rate-Related Issues that May Impede Their Expansion," an analysis called for by Section 1817 of the Energy Policy Act of 2005 (EPAct) (72 Fed. Reg. 9318, March 1, 2007). | | 2/16/2007 | Comments on DOE's Scoping Document and Workshop to Develop Energy Conservation Standards for Battery Chargers and External Power Supplies | EEI comments regarding DOE's "Framework Document for Battery Chargers and External Power Supplies," and, the related scoping workshop held on January 24, 2007 (Docket No. EERE–2006–DET–0136 and/or RIN 1904–AB57; 71 Fed. Reg. 78389, December 29, 2006). | | 1/24/2007 | Comments on DOE's Energy Standards for New Federal Buildings Interim Final Rule | EEI comments on DOE's interim final rule, "Energy Standard For New Federal Commercial And Multi-Family High-Rise Residential Building And Energy Standards For New Federal Low-Rise Residential Buildings" (Docket No. EE-RM/STD-02-112; 71 Fed. Reg. 70275, December 4, 2006). | | 12/18/2006 | Request for Rehearing and Clarification of Order No. 689, Regulations for Filing Applications for Permits to Site Interstate Electric Transmission Corridors | EEI request for rehearing and clarification in response to FERC Order No. 689, the final rule concerning regulations for filing applications for permits to site interstate electric transmission corridors (Docket No. RM06-12-000, 71 Fed. Reg. 69440, December 1, 2006). |
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