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Testimony, Filings and Briefs

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June 25, 2021
EEI Comments re: Notice of Proposed Rulemaking re: Electric Transmission Incentives Policy Under Section 219 of the Federal Power Act
 (PDF)
EEI Comments noting the Commission's departure from best practice and the requirements of FPA § 219 in proposing to remove the RTO/ISO participation incentive for all utilities except those that newly join a Transmission Organization, and limiting said incentive to a period of three years. Urges the Commission not to move forward with the proposal, and to continue granting the incentive to all utilities that join and remain in a Transmission Organization.
Regional Transmission Organizations
Federal Energy Regulatory Commission (FERC)
June 7, 2021
EEI and EPSA Comments re: Data Collection for Analytics and Surveillance and Market-Based Rate Purposes Under Docket No. RM16-17-000
 (PDF)
Comments agreeing with the Commission that utilities owned by a common investor are not affiliates per 18 CFR § 35.36(a)(9)(iv) so long as said investors remain under conditions imposed in its section 203(a)(2) blanket authorization order. Comments also question the need for certain data collection, and proposing changes to the Commission's proposal should it nonetheless require said collection."
Accounting & Reporting Requirements
Federal Energy Regulatory Commission (FERC)
June 1, 2021
Comments of EEI re: Safe Harbor Policy for Data Providers to Price Index Developers Under Docket No. RM20-7
 (PDF)
Comments sharing the Commission’s interest in ensuring that natural gas price indices continue to be reliable and transparent and supporting the Commission’s proposal to codify its safe harbor policy.
Natural Gas
Federal Energy Regulatory Commission (FERC)
May 26, 2021
Statement by Emily Fisher on Transmission and the Clean Energy Transformation
 (PDF)
Climate
Congress
May 17, 2021
Comments of the National Hydropower Association and the Edison Electric Institute re: Financial Measures for Hydroelectric Projects under RM21-9
 (PDF)
NHA and EEI comments contending that there is no need to change extant policies and regulations re: hydropower project financial assurance, and that the prevailing case-by-case approach should be retained.
Hydroelectric Licensing
Federal Energy Regulatory Commission (FERC)
May 10, 2021
Post-Technical Conference Comments of the Edison Electric Institute re: Offshore Wind Integration in RTOs/ISOs under AD20-18.
 (PDF)
EEI post-technical conference comments offering suggestions concerning the integration of offshore wind power in RTOs and ISOs. Comments broadly urge the Commission to allow regional flexibility, and suggest that scenario-based transmission planning may be appropriate in some areas.
Incentives
Federal Energy Regulatory Commission (FERC)
May 7, 2021
Motion to Intervene and Comments of the Edison Electric Institute re: Complaint of New York Transmission Owners Re: Self-Funding Filed Pursuant to FPA Sec. 206 under EL21-66.
 (PDF)
EEI comments in support of the FPA Sec. 206 complaint filed by the New York Transmission Owners seeking a Commission determination that the existing funding limitation in the NYISO tariff for network transmission upgrades needed to accommodate generator interconnection requests is unjust and unreasonable, and requesting a Tariff amendment implementing a transmission owner funding mechanisms for certain interconnection-related network upgrades.
Transmission (General)
Federal Energy Regulatory Commission (FERC)
May 7, 2021
Motion to Intervene and Comments of the Edison Electric Institute re: Complaint of New York Transmission Owners Re: Self-Funding Filed Pursuant to FPA Sec. 205 under ER21-1647.
 (PDF)
EEI comments in support of the FPA Sec. 205 complaint filed by the New York Transmission Owners seeking a Commission determination that the existing funding limitation in the NYISO tariff for network transmission upgrades needed to accommodate generator interconnection requests is unjust and unreasonable, and requesting a Tariff amendment implementing a transmission owner funding mechanisms for certain interconnection-related network upgrades.
Transmission (General)
Federal Energy Regulatory Commission (FERC)
May 6, 2021
Reply Comments of the Edison Electric Institute re: Cybersecurity Incentives under RM21-3.
 (PDF)
EEI reply comments responding to certain arguments that parties raised in their initial comments regarding an electric utility’s commitment and motivation to invest in cyber-security investments; the role of North American Electric Reliability Corporation (“NERC”) standards; the Commission’s ability to propose the incentives under sections 205 and 206 of the Federal Power Act (“FPA”); and the need for additional verification mechanisms.  
Cybersecurity and Emergency Response
Federal Energy Regulatory Commission (FERC)
April 26, 2021
Edison Electric Institute Motion to Intervene and Protest of Petition for Rulemaking to Amend the Unified System of Accounts' Treatment of Industry Association Dues
 (PDF)
EEI response to petition for rulemaking filed by the Center for Biological Diveristy asking Commission to modify the Unified System of Accounts (USofA) to change the account in which utilities record association dues paid in order to prevent customers from "subsidizing" lobbying activity. EEI responds that the Petition is without merit and factually incorrect, and should be denied.
Federal Energy Regulatory Commission (General)
Federal Energy Regulatory Commission (FERC)
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