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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
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).
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).
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).
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