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Testimony, Filings and Briefs

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April 15, 2020
200415 6 GHz Incumbent Stakeholder Letter
 (PDF)
We represent the public safety and critical infrastructure industries. This includes railroads, communications providers, electric, gas, water and wastewater utilities, along with power and offshore oil and gas producers. These industries collectively rely on approximately 100,000 fixed service links in the 6 GHz Band.
Federal Communications Commission (FCC) Oversight
Federal Communications Commission (FCC)
December 4, 2019
EEI Comments on FERC's Proposal to Modernize PURPA Regulations
 (PDF)
Docket No. RM19-15-000 – Qualifying Facilities Rates and Requirements
Docket No. AD16-16-000 – Implementation Issues Under the Public Utility Regulatory Policies Act of 1978
 
Comments in response to FERC's September 19, 2019 Notice of Proposed Rulemaking.
Public Utility Regulatory Policies Act (PURPA)
Federal Energy Regulatory Commission (FERC)
February 27, 2019
Perspectives On Protecting The Electric Grid From An Electromagnetic Pulse Or Geomagnetic Disturbance
 (PDF)
Statement of Scott I. Aaronson, Vice President, Security and Preparedness, Edison Electric Institute before the U.S. Senate Homeland Security and  Governmental Affairs Committee “Perspectives On Protecting The Electric Grid From An Electromagnetic Pulse Or Geomagnetic Disturbance” February 27, 2019
Cybersecurity and Emergency Response
U.S. Department of Homeland Security (DHS)
February 7, 2019
EEI Post-Technical Conference Comments
 (PDF)
Docket No. RM19-4-000 – Comments in response to the Notice of Proposed Rulemaking issued by the Commission that proposes revisions to its regulations to (1) to recognize that its approval is required under FPA section 203(a)(1)(B) only for acquisitions of jurisdictional facilities with a value of more than $10 million; and (2) to require notice to FERC by public utilities within 30 days of an acquisition of jurisdictional facilities with a value in excess of $1 million that does not require Commission approval.
Merger Authority
Federal Energy Regulatory Commission (FERC)
September 10, 2018
EEI Post-Technical Conference Comments
 (PDF)
Docket No. AD18-11-000 – Comments in response to the questions raised by the Commission during its July 31, 2018 Reliability Technical Conference and its August 9, 2018 Notice Inviting Post-Technical Conference Comments.
Reliability
Federal Energy Regulatory Commission (FERC)
September 6, 2018
Joint Trade Association Letter to Senator Markey on Grid Security
 (PDF)
Letter from EEI, APPA and NRECA in response to a letter from Senator Ed Markey (D-MA) to electric sector regarding grid security.
Cybersecurity and Emergency Response
Congress
July 23, 2018
Joint Trades Comments on Geomagnetic Disturbance Reliability Standard
 (PDF)
Docket No. RM18-8-000 – Comments in response to FERC’s May 17, 2018 Notice of Proposed Rulemaking.
Reliability
Federal Energy Regulatory Commission (FERC)
July 13, 2018
William J. Fehrman President and CEO Berkshire Hathaway Energy Statement on the Changing ERO Enterprise, Standards, and Reliability
 (PDF)
Docket No. AD18-11-000 – Statement of William J. Fehrman on behalf of EEI for Panel I of the July 31, 2018 Commission-led Reliability Technical Conference. 
Reliability
Federal Energy Regulatory Commission (FERC)
June 26, 2018
EEI Post-Technical Conference Comments on the Participation of DER Aggregations in Markets Operated by RTOs and ISOs
 (PDF)
Docket No. RM18-9-000 - EEI Post-Technical Conference Comments on the Participation of Distributed Energy Resources Aggregations in Markets Operated by Regional Transmission Organizations and Independent System Operators.
none
Federal Energy Regulatory Commission (FERC)
June 26, 2018
EEI Post-Technical Conference Comments Regarding Distributed Energy Resouces - Technical Considerations for the Bulk Power System
 (PDF)
Docket No. AD18-10-000. EEI Comments in response to questions raised by the Commission in its April 27, 2018 Notice Inviting Post Technical Conference Comments.
none
Federal Energy Regulatory Commission (FERC)
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