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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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| 11/16/2009 | Comments on Proposed Annual Transmission Planning and Evaluation Report | Comments of the Edison Electric Institute (EEI), on behalf of its members, in response to the Federal Energy Regulatory Commission (FERC) notice of proposed information collection activities (FERC-715) entitled “Annual Transmission Planning and Evaluation Report” (Docket No. IC09-715-000; 74 Fed. Reg. 47566, September 16, 2009). | | 11/13/2009 | Comments on IASB Exposure Draft on Rate-Regulated Activities | EEI comments on the lnternational Accounting Standards Board (IASB) Exposure Draft (ED), proposing an lnternational Financial Reporting Standard (IFRS) that addresses the issue of the appropriate accounting for rate-regulated activities. | | 11/9/2009 | Comments on the Risk Review of the National Ambient Air Quality Standards for Particulate Matter | Comments of the Utility Air Regulatory Group (UARG, including member EEI) on EPA's "Risk Assessment to Support the Review of the PM [Particulate Matter] Primary National Ambient Air Quality Standards: External Review Draft" (September 2009) (Docket ID No. EPA-HQ-OAR-2007-0492; 74 Fed. Reg. 46589, September 10, 2009; comment period extended at 74 Fed. Reg. 51148, October 5, 2009). | | 11/9/2009 | Comments on the Visibility Review of the National Ambient Air Quality Standards for Particulate Matter | Comments of the Utility Air Regulatory Group (UARG, including member EEI) on the "Particulate Matter Urban-Focused Visibility Assessment—External Review Draft" (September 2009) regarding EPA's national ambient air quality standards (NAAQS) (Docket ID No. EPA-HQ-OAR-2007-0492; 74 Fed. Reg. 46589, September 10, 2009; comment period extended at 74 Fed. Reg. 51148, October 5, 2009). | | 10/28/2009 | UARG Comments on EPA's BART ANPR for Two Power Plants | Comments of the Utility Air Regulatory Group (UARG, including member EEI) on EPA's advanced notice of proposed rulemaking (ANPR) on “Assessment of Anticipated Visibility Improvements at Surrounding Class I Areas and Cost Effectiveness of Best Available Retrofit Technology (BART) for Four Corners Power Plant and Navajo Generating Station” (74 Fed. Reg. 44313; EPA–R09–OAR–2009–0598; 40 CFR Part 49). | | 10/27/2009 | SMUD Statement for Industry Coalition at House Hearing on Cyber Security | Statement of John DiStasio, General Manager and CEO of the Sacramento Municipal Utility District (SMUD), on behalf of a broad industry coalition, including the American Public Power Association (APPA), Large Public Power Council (LPPC), National Association of Regulatory Utility Commissioners (NARUC), North American Electric Reliability Corporation (NERC), Canadian Electricity Association(CEA), Edison Electric Institute (EEI), Electricity Consumers Resource Council, Electric Power Supply Association (EPSA), and Transmission Access Policy Study Group, for the House Energy and Environment Subcommittee hearing on “Protecting the Electric Grid: H.R. 2165, the Bulk Power System Protection Act of 2009, and H.R. 2195.” | | 10/26/2009 | Comments on Proposed Suspension and Modification of Nationwide Permit (NWP) 21 | EEI comments on proposed suspension and modification of Nationwide Permit (NWP) 21, which authorizes surface coal mining activities under Clean Water Act section 404, in six Eastern states effective immediately (74 Fed. Reg. 34311, July 15.2009; RIN 071 0-ZA04). | | 10/16/2009 | Joint Motion Requesting Judicial Review to Resume Regarding the Ozone NAAQS | Joint motion to govern further proceedings of the State of Mississippi, the National Association of Home Builders, the Ozone NAAQS Litigation Group, and the Utility Air Regulatory Group (UARG, including member EEI) in the case “State of Mississippi, et al., Petitioners, v. United States Environmental Protection Agency, Respondent,” filed in the United States Court of Appeals for the District of Columbia Circuit, requesting judicial review to resume regarding the ozone national ambient air quality standards (NAAQS) rule (December 23, 2008) (Case No. 08-1200, and Consolidated Cases). | | 10/13/2009 | UARG Comments on the Particulate Matter ISA and Its Annexes | Comments of the Utility Air Regulatory Group (UARG, including member EEI) on the "Second External Review Draft of the Integrated Science Assessment (ISA) for Particulate Matter" (July 2009) and its annexes (Docket ID No. EPA-HQ-ORD-2007-0517). | | 10/7/2009 | Joint Association Statement for House Hearing on OTC Derivatives Reform | Joint statement submitted on behalf of the energy association end-users group, spearheaded by EEI, for the House Financial Services Committee hearing on the proposed reform of over-the-counter (OTC) derivatives markets. | | 10/2/2009 | Coalition Letter to All Members of Congress Urging Them to Preserve Access to Reasonably Priced OTC Derivatives | Letter from the Coalition for Derivatives End-Users, consisting of over 170 companies and trade associations, including 21 EEI member companies and EEI, sent to all members of Congress, supporting efforts by Congress to improve transparency, accountability and stability in the nation’s financial markets, but strongly urging policymakers to preserve the ability of companies to manage their individual risk exposures by ensuring access to reasonably priced OTC derivatives. | | 10/1/2009 | Joint Association and Company Letter Urging Passage of Pension Plan Funding Relief Legislation | Joint letter to all members of the U.S. Congress, signed by over 190 companies, associations and charitable organizations, including 45 EEI member companies, EEI and NEI, urging them to enact legislation this year to provide much needed relief for both single employer and multiemployer pension funds. | | 9/24/2009 | UARG Comments on OTC Draft Control Measures Including Standards for EGUs | Stakeholder comments on behalf of the Utility Air Regulatory Group (UARG, including member EEI) on the potential control measures, including performance standards for boilers serving electric generating units (EGUs), being considered by the Ozone Transport Commission's (OTC's) Stationary and Area Source (SAS) Committee. | | 9/17/2009 | Petition for a Writ of Certiorari in the Supreme Court Seeking FERC Transmission Siting Authority Along NIETCs | On petition for a writ of certiorari to the United States Court of Appeals for the Fourth Circuit in the matter of "Edison Electric Institute; American Public Power Association; National Rural Electric Cooperative Association; American Wind Energy Association; Allegheny Power; Trans-Allegheny Interstate Line Co.; and San Diego Gas & Electric Co., Petitioners, v. Piedmont Environmental Council, et al., Respondents," filed in the Supreme Court of the United States, seeking FERC authority to site transmission lines along DOE's national interest electric transmission corridors (NIETCs). | | 8/31/2009 | Comments on EPA's Proposed ICR for MACT Emissions Standards for Coal- and Oil-Based EGUs | EEI comments on EPA's proposed information collection request (ICR) for national emission standards that reflect the maximum achievable control technology (MACT) level for coal- and oil-based electric utility steam generating units (EGUs); EPA ICR No. 2362.01 (Docket ID No. EPA–HQ–OAR–2009–0234; 74 Fed. Reg. 31725, July 2, 2009). | | 8/24/2009 | UARG Comments Opposing Grandfathering Provision of EPA's Proposed PM 2.5 NSR Rule | Comments of the Utility Air Regulatory Group (UARG, including member EEI) on EPA’s proposed rule to extend the administrative stay of the permit “grandfathering” provision of the new source review (nsr) implementation rules for the PM2.5 (fine particulate matter) National Ambient Air Quality Standards (NAAQS) (EPA Docket No. EPA-HQ-OAR-2003-0062; 74 Fed. Reg. 36427, July 23, 2009). | | 8/19/2009 | Brief of Industry Coalition, Including UARG, Regarding North Carolina Court Order About TVA Emissions As Public Nuisance | Brief of Amici Curiae for the Chamber of Commerce of the United States of America, National Association of Manufacturers, American Petroleum Institute, Public Nuisance Fairness Coalition, Utility Air Regulatory Group (UARG, including member EEI) and American Forest & Paper Association in support of defendant-appellant in “State of North Carolina ex rel. Roy Cooper, Attorney General, Plaintiff-Appellee, v. Tennessee Valley Authority, Defendant-Appellant, State of Alabama, Intervenor-Appellant," filed in the United States Court of Appeals for the Fourth Circuit, on appeal from the United States District Court for the Western District of North Carolina, regarding TVA emissions classified as a public nuisance (Case No. No. 09-1623). | | 7/29/2009 | Joint Association Letter Urging Passage of Pension Plan Funding Legislation | Joint letter signed by 36 trade associations, including EEI, sent to all members of Congress, and to key officials at the Departments of Labor and Treasury, urging them to enact legislation that will promote our nation’s economic recovery and reinvestment, while securing sound long-term pension plan funding. | | 7/21/2009 | Statement of Steven T. Naumann at House Hearing on Securing the Electric Grid | Statement of Steven T. Naumann, Vice President, Wholesale Market Development, Exelon Corporation, on behalf of the Edison Electric Institute (EEI) and the Electric Power Supply Association (EPSA), before the Subcommittee on Emerging Threats, Cybersecurity, and Science and Technology, Committee on Homeland Security, United States House of Representatives, hearing: “Securing the Modern Electric Grid from Physical and Cyber Attacks.”
| | 7/13/2009 | UARG Comments on EPA’s Proposed Revised Standards of Performance for Coal Plants | Comments of the Utility Air Regulatory Group (UARG, including member EEI) on EPA's Supplemental Proposal to the Proposed Revised Standards of Performance for Coal Preparation and Processing Plants (Docket EPA-HQ-OAR-2008-0260; 74 Fed. Reg. 25,304-27, May 27, 2009). | | 7/10/2009 | Joint Letter to Senators Regarding OTC Derivatives Markets Proposals | Joint association letter to all senators expressing concern with certain aspects of proposals to address oversight and transparency of over-the-counter (OTC) energy derivatives markets. | | 7/6/2009 | Letter to U.S. Senate on Climate Change Legislation | EEI President Tom Kuhn letter to Senate Majority Leader Harry Reid outlining the utility industry’s views on modifications considered important regarding the climate legislation (H.R. 2454) recently passed by the U.S. House of Representatives. | | 6/16/2009 | Joint Letter to Senators Urging Support for Coal Ash Regulation | Joint letter sent by the American Public Power Association (APPA), the Edison Electric Institute (EEI), the National Rural Electric Cooperative Association (NRECA), and the Utility Solid Waste Activities Group (USWAG) urging all Senators to co-sign a bipartisan letter (being circulated by Senators Conrad and Brownback) to Administrator Lisa Jackson calling on the Environmental Protection Agency (EPA) to promulgate first-of-their-kind federal regulations for coal combustion byproducts (CCBs), including coal ash, under Subtitle D of the Resource Conservation Recovery Act (RCRA). | | 6/12/2009 | Joint Letter Opposing S. 787, the Clean Water Restoration Act | Joint letter sent to members of the Senate Environment and Public Works Committee by the Waters Advocacy Coalition (WAC, including member EEI) requesting their opposition to S. 787, the “Clean Water Restoration Act,” which would apply the Clean Water Act (CWA) to “all interstate and intrastate waters,” leaving no water unregulated. | | 6/9/2009 | Testimony of Thomas F. Farrell II at House Hearing on the Allocation of Emissions Allowances | Written testimony of Thomas F. Farrell II, Chairman, President & CEO of Dominion Resources, on behalf of the Edison Electric Institute (EEI), before the United States House of Representatives Committee on Energy and Commerce Subcommittee on Energy and the Environment hearing on the allocation of emissions allowances under the American Clean Energy Security Act of 2009. |
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| 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). | | 11/20/2006 | Request for Clarification or Rehearing of FERC's PURPA Mandatory Purchase Obligation Final Rule | EEI request for clarification or, in the alternative, rehearing of FERC’s October 20, 2006, final rule concerning the new PURPA section 210(m) regulations applicable to small power production and cogeneration facilities (Docket No. RM06-10-000). | | 11/13/2006 | APPA and EEI Comments on FERC's Hydropower Licensing Settlements Policy Statement | Comments of the American Public Power Association and EEI on FERC's new policy statement on hydropower licensing settlements – invitation to submit comments (Docket No. PL06-5-000, 71 Fed. Reg. 56520, September 27, 2006). | | 10/18/2006 | Comments on Distribution Transformer Energy Conservation Standards NOPR | EEI comments on DOE's distribution transformer energy conservation standards NOPR (71 Fed. Reg. 44356, August 4, 2006, Docket No. EE-RM/STD-00-550). |
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