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Testimony, Filings and Briefs

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November 30, 2021
Reply Comments of the Edison Electric Institute under RM21-17.
 (PDF)
EEI reply comments on the advance notice of proposed rulemaking ("ANOPR") issued under docket no. RM21-17. Among other things, the reply comments urge that in any rulemaking, the Commission should: a) Encourage the participation of regions, b) Allowing regions flexibility in implementation, c) retain the principles outlined in Order Nos. 890 and 1000, in conjunction with reinstating the federal right of first refusal (“ROFR”), d) move away from first-come-first-served generator interconnection, and e) refrain from imposing any additional oversight re: the transmission planning process.
General
Federal Energy Regulatory Commission (FERC)
October 12, 2021
Initial Comments of the Edison Electric Institute re: Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection under Docket No. RM21-17-000
 (PDF)
Initial EEI comments on the advance notice of proposed rulemaking ("ANOPR") issued under docket no. RM21-17 addressing whether changes are needed to the Commission’s transmission planning, cost allocation or generator interconnection processes in light of the evolving fuel mix for electric generation and growing interest in greater use of cleaner energy resources. Generally, comments support scenario planning and regional flexibility.
General
Federal Energy Regulatory Commission (FERC)
October 4, 2021
Request for Rehearing of the Edison Electric Institute re: Central Hudson Gas & Electric et al. v. New York Independent System Operator under Docket No. EL21-66.
 (PDF)
EEI seeks rehearing of the Sept. 3 Order Denying Complaint and asking the Commission to reconsider its decision to deny the New York Transmission Owners ("NYTOs") Complaint, and instead grant the NYTOs’ request to revise the existing funding methodology applicable to System Upgrades. Argues that the Order Denying Complaint is arbitrary and capricious, and an abuse of discretion.
Transmission (General)
Federal Energy Regulatory Commission (FERC)
October 4, 2021
Request for Rehearing of the Order Rejecting Rate Filing under Docket No. ER21-1647
 (PDF)
EEI request for rehearing of Sept. 3 order rejecting New York Transmission Owners ("NYTOs") filing seeking to amend the NYISO Tariff to allow the NYTOs to provide initial funding for System Upgrade Facilities and System Deliverability Upgrades.
Transmission (General)
Federal Energy Regulatory Commission (FERC)
September 27, 2021
EEI Comments on Climate Change, Extreme Weather, and Electric System Reliability under Docket No. AD21-13-000.
 (PDF)
EEI responses regarding the issues surrounding the threat to electric system reliability posed by climate change and extreme weather events as described in the “Notice Inviting Post-Technical Conference Comments” (the “Post-Technical Conference Notice”) issued by the Federal Energy Regulatory Commission (“Commission”) on August 11, 2021, in docket no. AD21-13.
Reliability
Federal Energy Regulatory Commission (FERC)
September 20, 2021
EEI Comments in Response to Staff White Paper and RTO/ISO Reports on the Participation of Hybrid Resources in Markets under AD20-9.
 (PDF)
Comments expressing support for the participation of hybrid resources on a comparable basis with other resources in the market and urging the Commission to allow RTOs/ISO and other regions to work with stakeholders to develop appropriate market rule changes.
Market Behavior Rules
Federal Energy Regulatory Commission (FERC)
September 2, 2021
Request to Extend the Temporary Waiver to Modify the Existing AFUDC Rate Calculation in Response to the Ongoing COVID-19 Emergency
 (PDF)
Joint EEI/AGA request to  grant an extension until March
31, 2022, of its temporary waiver allowing jurisdictional entities to use a methodology for  calculating the Allowance for Funds Used During Construction (“AFUDC”) rate that would  remove the distorting effects of temporary increases in the amount of short-term debt needed in  response to the COVID-19 emergency by using a simple average of the historical short-term debt
balance for the year ended 2019, while leaving all other aspects of the AFUDC rate formula  (including the use of current-period short-term debt cost rates) unchanged (the “AFUDC Rate
Calculation Waiver”).
Accounting & Reporting Requirements
Federal Energy Regulatory Commission (FERC)
August 16, 2021
Request for Rehearing of Edison Electric Institute and WIRES. Docket No.
 (PDF)
Joint filing of request for rehearing of Order on
Paper Hearing issued July 15, 2021 denying The Dayton Power and Light Company’s (“Dayton”) request  for a 50 basis point incentive to its authorized return on equity (“ROE”) to reflect Dayton’s continued membership in a Regional Transmission Organization (“RTO”). EEI and Wires submitted request on basis that the Commission erred in relying on an improper reading of FPA Sec. 219 and basing Dayton's eligibility for the RTO adder on the voluntariness of its participation in PJM.
Transmission Incentives
Federal Energy Regulatory Commission (FERC)
July 28, 2021
"EEI Comments re: PJM Transmission Owners Proposal for PJM Tariff Revisions to Implement Transmission Owners’ Funding of Network Upgrades, Docke No ER21-2282
 (PDF)
EEI comments supporting filing by the PJM Transmission owners to amend the PJM Interconnection, L.L.C. tariff to adopt a Transmission Owner option to elect to fund the capital cost of network upgrades necessary to accommodate generator interconnections.
Regional Transmission Organizations
Federal Energy Regulatory Commission (FERC)
July 26, 2021
EEI Reply Comments re: Electric Transmission Incentives Policy Under Section 219 of the Federal Power Act, Docket No. RM20-10.
 (PDF)
EEI reply comments articulating disagreement with commenters supporting the proposal to limit the  availability of the incentive for joining and turning over operational control of a utility’s  transmission facilities to a Transmission Organization to a period of three years after joining. EEI states that the proposal is contrary to section 219 of the Federal Power Act (“FPA”) and does not recognize the significant ongoing risks and responsibilities that utilities take on by participating in a Transmission Organization.
Incentives
Federal Energy Regulatory Commission (FERC)
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