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Testimony, Filings and Briefs

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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)
July 23, 2021
EEI Comments re: NOI re: Participation of Aggregators of Retail Demand Response Customers in Markets Operated by Regional Transmission Organizations and Independent System Operators under Docket No. RM21-14-000
 (PDF)
EEI comments responding to Notice of Inquiry ("NOI") on whether and how circumstances have changed since the  Commission established the DR opt-out; and whether the opt-out should be removed.
Distributed Energy Resources & Aggregation
Federal Energy Regulatory Commission (FERC)
July 1, 2021
EEI Post-Technical Conference Comments re: Electrification and the Grid of the Future
 (PDF)
EEI post-technical conference comments on the April 21, 2021 technical conference on how to prepare for an increasingly electrified future. The EEI comments urged the Commission to consider, during its deliberations on this matter: 1) The need for additional transmission infrastructure, 2) the unique needs of different regions, and 3) whether new policies have the potential to  impact the ability of states, distribution utilities, and local entities to encourage electrification and maintain the reliability of the distribution system.  EEI also provided responses to specific questions posed by the Commission.
Transmission Incentives
Federal Energy Regulatory Commission (FERC)
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)
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