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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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| 1/31/2012 | Comments on the NHTSA Draft Environmental Impact Statement, CAFE Standards for Passenger Cars and Light Trucks, Model Years 2017-2025 | EEI comments on the Draft Environmental Impact Statement (EIS) issued by the National Highway Traffic Safety Administration (NHTSA) concurrently with the 2017 and Later Model Year Light-duty Vehicle GHG Emissions and Corporate Average Fuel Economy (CAFE) Standards issued jointly by NHTSA and the Environmental Protection Agency (EPA) (Docket No. NHTSA-2011-0056, 76 Fed. Reg. 74854, 75352, December 1, 2011). | | 1/11/2012 | Joint Reply Brief of Petitioners and Intervenors Filed in the U.S. Court of Appeals-DC Regarding EPA's 1-Hour Primary National Ambient Air Quality Standard (NAAQS) for Sulfur Dioxide (SO2) | Joint reply brief of state petitioners, non-state petitioners (including the Utility Air Regulatory Group (UARG, including member EEI)) and supporting intervenors filed in the United States Court of Appeals for the District of Columbia Circuit case “National Environmental Development Association’s Clean Air Project, et al., Petitioners, v. United States Environmental Protection Agency, et al., Respondents” on petitions for review of final agency actions of the United States Environmental Protection Agency (EPA), regarding the 1-hour primary national ambient air quality standard (NAAQS) for sulfur dioxide (SO2) (U.S. Court of Appeals-DC Case No. 10-1252 (Lead) and Consolidated Cases). | | 1/5/2012 | Joint NHA-EEI Comments on FERC’s Annual Charges for Use of Government Land NOPR | Joint comments of the National Hydropower Association (NHA) and EEI on the U.S. Federal Energy Regulatory Commission (FERC) notice of proposed rulemaking (NOPR) on annual charges for use of government land (Docket No. Rm11-6-000; 76 Fed. Reg. 72134, November 22, 2011). | | 12/30/2011 | UARG Comments on the Second Review Draft of EPA’s Integrated Science Assessment for Ozone and Related Photochemical Oxidants | Comments of the Utility Air Regulatory Group (UARG, including member EEI) on the Second External Review Draft of the U.S. Environmental Protection Agency’s (EPA’s) Integrated Science Assessment (ISA) for Ozone and Related Photochemical Oxidants (Docket ID No. EPA–HQ–ORD–2011–0050; 76 Fed. Reg. 60820, 60821/1, September 30, 2011; Extension: 76 Fed. Reg. 72919, Nov. 28, 2011). | | 12/30/2011 | Comments on DOE’s Alternative Fueled Vehicle Credit Program (Subpart F) Modification NOPR | EEI comments on the U.S. Department of Energy (DOE) notice of proposed rulemaking (NOPR) on the “Alternative Fuel Transportation Program: Alternative Fueled Vehicle Credit Program (Subpart F) Modification and Other Amendments” (Docket # EERE-2011-OT-0066, RIN 1904-AB81; 76 Fed. Reg. 67288, October 31, 2011). | | 12/23/2011 | UARG Comments on EPA’s Proposed Consent Decree, Clean Air Act Citizen Suit | Comments of the Utility Air Regulatory Group (UARG, including member EEI) on the U.S. Environmental Protection Agency’s (EPA’s) notice of “Proposed Consent Decree, Clean Air Act Citizen Suit” pursuant to section 113(g) of the Clean Air Act (CAA) (Docket ID No. EPA-HQ-OGC-2011-0929; 76 Fed. Reg. 75544, December 2, 2011). | | 12/19/2011 | Comments on FERC’s Technical Conference on Penalty Guidelines, Recommending Increasing Transparency and Compliance | EEI comments following the Federal Energy Regulatory Commission’s (FERC’s) Technical Conference on Penalty Guidelines, held on November 17, 2011, recommending implementation of guidelines that are consistent with FERC’s goals of increasing transparency and enhancing greater emphasis on company compliance (Docket No. PL10-4-000). | | 12/19/2011 | Comments on NIST’s Visiting Committee on Advanced Technology Draft Report and Recommendations Regarding a National Public Safety Broadband Network | EEI comments submitted in response to the National Institute of Standards and Technology’s (NIST’s) Visiting Committee on Advanced Technology (VCAT) request for comments on its draft report and recommendations, issued November 21, 2011, regarding desirable properties of a national public safety broadband network (PSBN). | | 12/19/2011 | Petition for Reconsideration of the FMCSA Final Rule on Restricting the Use of Cellular Phones by Drivers of CMVs | EEI petition, submitted on behalf of its member companies, for reconsideration of the Federal Motor Carrier Safety Administration’s (FMCSA’s) final rule, which restricts the use of cellular phones by drivers of commercial motor vehicles (CMVs) (Docket No. FMCSA-2010-0096; 76 Fed. Reg. 75470, December 2, 2011). | | 12/16/2011 | Comments on the FCC’s Notice Regarding the Southern Company Services, Inc. Petition on the Open Internet and Broadband Industry Practices | EEI comments in response to the Federal Communications Commission (FCC) public notice regarding the petition for clarification or reconsideration filed by Southern Company Services, Inc. (Southern) on behalf of itself and its operating affiliates “In the Matter of Preserving the Open Internet, Broadband Industry Practices” (GN Docket No. 09-1 91 and WC Docket No. 07-52; 76 Fed. Reg. 747210, December 1, 2011). | | 12/15/2011 | Letter to House Permanent Select Committee on Intelligence in Support of H.R. 3523, the "Cyber Intelligence Sharing and Protection Act of 2011" | Letter from EEI President Thomas R. Kuhn to the Honorable Mike Rogers, Chairman, House Permanent Select Committee on Intelligence, U.S. House of Representatives, in support of H.R. 3523, the "Cyber Intelligence Sharing and Protection Act of 2011," as an important step in assisting the nation's critical infrastructure sectors to prevent, deter and mitigate the array of cyber threats. | | 12/14/2011 | Comments on the PCAOB’s Concept Release on Auditor Independence & Audit Firm Rotation | EEI comments on the Public Company Accounting Oversight Board's (PCAOB’s) Concept Release on Auditor Independence & Audit Firm Rotation, and specifically on whether mandatory auditor rotation would significantly enhance auditor independence, objectivity, and professional skepticism, as well as any other methods that may address PCAOB concerns. | | 12/14/2011 | Request for a Three-Month Waiver from the FMCSA Final Rule on Restricting the Use of Cellular Phones by Drivers of CMVs | EEI request for a waiver, for a period of three months from the effective date of January 3, 2012, from the Federal Motor Carrier Safety Administration’s (FMCSA’s) final rule, which restricts the use of cellular phones by drivers of commercial motor vehicles (CMVs) (Docket No. FMCSA-2010-0096; 76 Fed. Reg. 75470, December 2, 2011). | | 12/9/2011 | Post FERC Technical Conference Comments on Reliability Matters Regarding EPA’s Utility MACT Rule | EEI comments on the Federal Energy Regulatory Commission (FERC) Reliability Technical Conference, held November 29 and 30, 2011, regarding reliability matters implicated by the Utility MACT rule proposed by the Environmental Protection Agency (Docket No. AD12-1-000). | | 12/9/2011 | Multi-Industry Letter to President Obama Urging Action to Ensure Electric Reliability Risks of EPA’s Final Utility MACT Rule Are Managed Effectively | Multi-industry letter signed by trade associations (including EEI), chambers of commerce and other entities, urging President Obama to ensure that electric reliability risks of the Environmental Protection Agency’s (EPA’s) Utility Maximum Achievable Control Technology (Utility MACT) final rule are managed effectively. | | 12/7/2011 | Comments on DOE's Proposed Determination to Treat Non-Compressor Residential Refrigeration Products as Covered Products | EEI comments on the U.S. Department of Energy's (DOE's) proposed determination to treat non-compressor residential refrigeration products as covered products under the energy conservation program for consumer products (Docket # EERE-2011-BT-DET-0072; 76 Fed. Reg. 69147 November 8, 2011). | | 11/30/2011 | Statement of Thomas Farrell, Chairman and CEO of Dominion Resources, on Behalf of EEI, for FERC Reliability Conference, Focusing on the Utility MACT Rule | Statement by Thomas F. Farrell, II, Chairman and CEO, Dominion, on Behalf of the Edison Electric Institute, for the FERC Reliability Conference, November 30, 2011, focusing on local and regional reliability impacts that may be caused by the condensed compliance deadlines for EPA regulations including the Utility MACT (Mercury and Air Toxics) rule (Prefiled 11/22/11; Docket No. RC11-6-000). | | 11/28/2011 | Comments on EPA’s Proposed Revisions to Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone, Modifying the CSAPR | EEI comments in response to the U.S. Environmental Protection Agency (EPA) proposed “Revisions to Federal Implementation Plans To Reduce Interstate Transport of Fine Particulate Matter and Ozone” rule which would modify the final Cross-State Air Pollution Rule (CSAPR) published on August 8, 2011, with an effective date of October 7, 2011 (Docket No. EPA-HQ-OAR-2009-0491; 76 Fed. Reg. 63860, October 14, 2011). | | 11/23/2011 | Comments on the IASB's Agenda Consultation 2011, Supporting High Quality Accounting Standards and a Convergence of Efforts with the FASB | EEI comments on the Intemational Accounting Standards Board's (IASB's) Agenda Consultation 2011, supporting the issuance of high quality global accounting standards that provide transparency in financial reporting and meet the needs of investors and other users, and strongly encouraging the continuation of convergence efforts with the Financial Accounting Standards Board (FASB). | | 11/18/2011 | Comments on DOE's Residential Building Energy Codes Cost Analysis RFI | EEI comments in response to the Request for Information (RFI) on the U.S. Department of Energy (DOE) residential building energy codes cost analysis (Docket # EERE-2010-BT-BC-0046; 76 Fed. Reg. 56413, September 13, 2011). | | 11/17/2011 | Letter to the House and Senate Leadership Requesting a 4-year Extension of the PTC | Letter signed by 369 signatories, including EEI, and sent to the House and Senate leadership and all Hill offices, asking for a four-year extension of the renewable energy production tax credit (PTC) which currently expires at the end of next year. | | 11/15/2011 | Letter to the Senate Urging Support of the Barrasso/Heller Amendment Regarding Federal Jurisdiction Over Waters Under the Clean Water Act (CWA) | EEI President Tom Kuhn letter to the U.S. Senate urging support of the Barrasso/Heller amendment to the Energy and Water Appropriations bill which would prevent the Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (Corps) from finalizing or implementing controversial changes expanding federal jurisdiction over waters under the Clean Water Act (CWA). | | 11/10/2011 | Coalition Letter Strongly Urging Senators to Vote for H.R. 674 to Repeal the 3% Withholding Tax Mandate | Letter from the Government Withholding Relief Coalition, including member EEI, sent to the members of the U.S. Senate, strongly urging passage of H.R. 674, bipartisan legislation to fully repeal the 3% Withholding Tax mandate enacted in Section 511 of the "Tax Increase Prevention and Reconciliation Act of 2005" (P. L. 109-222). | | 11/3/2011 | Letter Expressing Industry Support of H.R. 3035, the "Mobile Informational Call Act of 2011," which amends the "Telephone Consumer Protection Act" (TCPA) | EEI President Tom Kuhn letter, sent to Congressmen Terry and Towns, expressing the industry's support for their bill, H.R. 3035, the "Mobile Informational Call Act of 2011," which amends the "Telephone Consumer Protection Act" (TCPA) by enacting revisions to facilitate delivery of time-sensitive consumer information to mobile devices while continuing to protect wireless consumers from unwanted telemarketing calls. | | 11/3/2011 | Coalition Letter to Senate Urging Passage of H.R. 674 to Repeal the 3% Withholding Tax Mandate | Letter from the Government Withholding Relief Coalition, including member EEI, sent to the members of the U.S. Senate, strongly urging passage of H.R. 674, bipartisan legislation to fully repeal the 3% Withholding Tax mandate enacted in Section 511 of the "Tax Increase Prevention and Reconciliation Act of 2005" (P. L. 109-222). |
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| 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). | | 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). |
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