Regulatory Filings - ELCON | Electricity Consumers Resource Council

Regulatory Filings

Post-Technical Conference Comments of the ITM Coalition, Docket No. AD22-8-000 (Transmission Planning and Cost Management) and Docket No. AD21-15-000 (Joint Federal-State Task Force on Electric Transmission)

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. AD21-10-000 (Modernizing Wholesale Electricity Market Design)

December 15, 2022

Reply Comments on Behalf of Electricity Consumers Resource Council (ELCON), Docket Nos. RM22-19-000 and RM21-3-000 (Incentives for Advanced Cybersecurity Investment and Cybersecurity Incentives)

November 22, 2022

Pre-Conference Statement of Travis Fisher President and CEO of the Electricity Consumers Resource Council (ELCON), Docket No. AD22-10-000l (Reliability Technical Conference)

November 10, 2022

Sector 8 Policy Input for the NERC Board of Trustees and Member Representatives Committee

November 7, 2022

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM22-14-000 (Improvements to Generator Interconnection Procedures and Agreements)

October 13, 2022

Comments of the ITM Coalition, Docket No. RM21-17-000 (Building for the Future through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection)

September 19, 2022

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM21-17-000 (Building for the Future Through Electric Regional Transmission Planning, Cost Allocation and Generator Interconnection)

August 17, 2022

Sector 8 Policy Input for the NERC Board of Trustees and Member Representatives Committee (August 17-18, 2022)

Initial Comments of the Electricity Consumers Resource Council (ELCON), Docket No. AD22-5-000 (Implementation of Dynamic Line Ratings)

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. PL18-1-000 (Certification of New Interstate Natural Gas Facilities) and Docket No. PL21-3-000 (Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews)

Comments of the Consumer Coalition for Electricity Rate Transparency, Docket No. RM22-5-000 (Rate Recovery, Reporting, and Accounting Treatment of Industry Association Dues and Certain Civic, Political and Related Expenses)

February 22, 2022

Initial Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM22-2-000 (Reactive Power Capability Compensation)

February 21, 2022

Sector 8 Policy Input for the NERC Board of Trustees and Member Representatives Committee (February 9-10, 2022)

February 1, 2022

Reply Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM21-17-000 (Building for the Future Through Electric Regional Transmission Planning, Cost Allocation and Generator Interconnection)

November 30, 2021

Sector 8 Policy Input for the NERC Board of Trustees and Member Representatives Committee (November 3-4, 2021)

October 21, 2021

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM21-17-000 (Building for the Future Through Electric, Regional Transmission Planning and Cost and Allocation and Generator Interconnection)

October 12, 2021

Reply Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM20-10-000 (Electric Transmission Incentives Policy Under Section 219 of the Federal Power Act)

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM21-14-000 (Participation of Aggregators of Retail Demand Response Customers in Markets Operated by RTOs and ISOs)

Sector 8 Policy Input for the NERC Board of Trustees and Member Representatives Committee (August 11-12, 2021)

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM20-10-000 (Electric Transmission Incentives Policy Under Section 219 of the Federal Power Act)

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. AD21-9-000 (The Office of Public Participation)

Joint Comments of the American Forest & Paper Association, Coalition of MISO Transmission Customers, Electricity Consumers Resource Council, Industrial Energy Consumers of America and PJM Industrial Consumer Coalition, Docket No. RM20-16-000 (Managing Transmission Line Ratings)

Sector 8 Input for the NERC Board of Trustees and Member Representatives Committee (February 3-4, 2021)

January 28, 2021

Notice of Intervention and Response of the Electricity Consumers Resource Council, Docket No. RM 20-19-000 (Equipment and Services Produced or Provided by Certain Entities Identified as Risks to National Security)

November 23, 2020

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. AD20-14-000 (Carbon Pricing in FERC-Jurisdictional Organized Regional Wholesale Electricity Markets)

November 16, 2020

Responses of the Electricity Consumers Resource Council (ELCON) to the Request for Information from the Department of Energy regarding Executive Order 13920

August 24, 2020

Sector 8 Input for the NERC Board of Trustees and Member Representatives Committee (August 19-20, 2020)

August 19, 2020

Comments of the Electricity Consumers Resource Council (ELCON), American Chemistry Council (ACC), and American Forest & Paper Association (AF&PA), Docket No. RM20-10-000 (Electric Transmission Incentives Policy Under Section 219 of the Federal Power Act)

Statement of Travis Fisher President & CEO, Electricity Consumers Resource Council Panel 2: Electricity Demand and Transmission Planning, Docket No. AD20-17-000 (Impacts of Covid-19 on the Energy Industry)

Motion to Intervene and Comments of the Electricity Consumers Resource Council (ELCON), Docket No. AD20-14-000 (Carbon Pricing in FERC-Jurisdictional Organized Regional Wholesale Electricity Energy Markets)

Sector 8 Policy Input for the NERC Board of Trustees & Member Representatives Committee

Sector 8 Policy Input for the NERC Board of Trustees & Member Representatives Committee

January 21, 2020

Request for Rehearing of the Electricity Consumers Resource Council, FERC Docket Nos. EL16-49-000 & EL18-178

January 21, 2020

Request for Rehearing and Clarification of the PJM Consumer Representatives, FERC Docket Nos. EL16-49-000 & EL18-178

January 21, 2020

Comments of US Manufacturers on PURPA Notice of Proposed Rulemaking, Docket No. RM19-15

December 3, 2019

Comments of the Electricity Consumers Resource Council (ELCON), Docket NO. EL20-42-000 (New England Ratepayers Association)

December 3, 2019

Comments of the Joint Trade Associations, Docket No. AD19-18-000 (Joint Staff White Paper on Notices of Penalty Pertaining to Violations of Critical Infrastructure Protection Reliability Standards

October 28, 2019

ELCON Policy Input to the NERC Board of Trustees and Member Representatives Committee

October 22, 2019

Comments of Large Consumers on NERC Draft 2019 ERO Reliability Risk Priorities Report

October 4, 2019

Comments of Large Consumers to NERC on ERO Enterprise Long-Term Strategy

October 1, 2019

Comments of ELCON on DOE Request for Information on Enhancing the Resilience of Electric Infrastructure Systems Against Weather Events

August 23, 2019

Comments of ELCON, Docket No. AD19-13-000 (Reliability Technical Conference)

August 22, 2019

Protest Comments of ELCON and TIEC, Docket Nos. ER19-2522-000 and ER19-2523-000, Southwest Power Pool Exit Fees

August 22, 2019

ELCON Policy Input to the NERC Board of Trustees and Member Representatives Committee

Initial Comments of Associations, Docket No. PL19-4-000 (Inquiry Regarding the Commission’s Policy for Determining Return on Equity)

Initial Comments of Joint Commenters, Docket No. PL19-3-000 (Inquiry Regarding the Commission’s Electric Transmission Incentives Policy)

Consumer Trades FERC Letter Calls for Competitive Markets and Better RTO Governance

Comments of ELCON, Docket No. AD19-12-000 (Security Investments for Energy Infrastructure Technical Conference”)

ELCON Policy Input to the NERC Board of Trustees and Member Representatives Committee

National Emissions Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units-Reconsideration of Supplemental Finding and Residual Risk and Technology Review Proposed Rule 84 Fed. Reg. 2670 (February 7, 2019), EPA–HQ–OAR–2018–0794, Comments of the Electricity Consumers Resource Council

Comments of Large Consumers on NERC Five-Year Electric Reliability Organization Performance Assessment Report

Comments of ELCON, Docket No. RM19-2-000 (“Refinements to Horizontal Market Power Analysis for Sellers in Certain Regional Transmission Organization and Independent System Operator Markets”)

ELCON Comments on NERC Draft Supply Chain Risks Report

ELCON Policy Input to the NERC Board of Trustees and Member Representatives Committee

January 22, 2019

Comments of ELCON, AF&PA, and ACC, Docket No. RM19-5-000 (“Public Utility Transmission Rate Changes to Address Accumulated Deferred Income Taxes”)

January 22, 2019

Joint Letter of ELCON, APPA, LPPC, NRECA, and NRDC, Docket No. EL18-178-000 (“PJM Interconnection, L.L.C.”)

December 21, 2018

Supplemental Comments of AF&PA and ELCON, Docket No. AD16-16-000 (“Implementation Issues Under PURPA”)

December 1, 2018

Comments of ELCON and TIEC, Docket No. EL19-11-000 (“American Wind Energy Association, et al. v. Southwest Power Pool, Inc.”)

November 30, 2018

Reply Comments of PJM Consumer Representatives, Docket No. EL18-178-000 (“PJM Interconnection, L.L.C.”)

November 6, 2018

Emission Guidelines for Greenhouse Gas Emissions from Existing Electric Utility Generating Units, Proposed Rule 83 Fed. Reg. 44,746 (August 31, 2018), EPA-HQ-OAR-2017-0355, Comments of the Electricity Consumers Resource Council (ELCON)

October 31, 2018

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. EL18-178-000 (“PJM Interconnection, L.L.C”)

October 2, 2018

Post-Technical Conference Comments of ELCON, FERC Docket No. AD18-11-000 (“Reliability Technical Conference)

September 7, 2018

Supplemental Comments of ELCON et al. (“U.S. Manufacturers”), Docket No. AD16-16-000 (“Implementation Issues Under PURPA”)

Reply Comments of ELCON et al. (“US Manufacturers”), FERC Docket No.AD18-7-000 (“Grid Resilience in RTOs and ISOs”)

ELCON et al. (“Trade Association”) Policy Input for the NERC Board of Trustees

Comments of APPA, ELCON, LPPC, NRECA, and TAPS, Docket No. RM17-13-000 (“Supply Chain Risk Management Reliability Standards”)

Coalition Letter to FERC Chairman and Commissioners, Re: Electricity Market Principles

Comments of APPA, ELCON and TAPS, Docket No. Rm18-2-000 (“Cyber Security Incident Reporting Reliability Standards”)

February 26, 2018

ELCON Policy Input to the NERC Board of Trustees and Member Representatives Committee

January 30, 2018

Comments of NRECA and ELCON, Docket No. RM16-22-000 (“Coordination of Protection Systems for Performance During Faults and Specific Training for Personnel Reliability Standards”)

January 29, 2018

Comments of ELCON et al., FERC Docket No. RM18-1-000 (“Grid Reliability and Resilience Pricing”)

October 23, 2017

Sector 8 Policy Input for the NERC Board of Trustees and Member Representatives Committee; August 9-10, 2017 Meeting in Ottawa, Canada

Motion to intervene of the Electricity Consumer Resource Council (ELCON) and comments in support of petitioner, Docket No. EL17-75-000 (“Advanced Energy Economy”)

Pre-Conference Statement of John P. Hughes, President & CEO, ELCON, Docket No. AD17-8-000 (“Reliability Technical Conference”)

Post-Technical Conference Comments of ELCON, Docket No. AD17-11-000 (“State Policies and Wholesale Markets Operated by ISO New England Inc., New York Independent System Operator, Inc., and PJM Interconnection, LLC”)

Supplemental Brief of Petitioners and Petitioner-Intervenors, On Petitions for Review of Final Agency Action of the US EPA 80 Fed.Reg. 64,510 (October 23, 2015) and 81 Fed.Reg. 27,442 (May 6, 2016), In the United States Court of Appeals for the District of Columbia Circuit, No. 15-1381 (and consolidated cases)

Supplemental Brief of Petitioners and Petitioner-Intervenors, On Petitions for Review of Final Agency Action of the US EPA 80 Fed.Reg. 64,662 (October 23, 2015), In the United States Court of Appeals for the District of Columbia Circuit, No. 15-1363 (and consolidated cases)

ELCON Policy Input for the NERC Board of Trustees and Member Representative Committee

Comments of ELCON, Docket No. RM17-8-000 (“Reform of Generator Interconnection Procedures and Agreements”)

Comments of ELCON, Docket No RM17-2-000 (“Uplift Cost Allocation and Transparency in Markets Operated by Regional Transmission organizations and Independent System Operators”)

Comments of APPA, ELCON, NREC and TAPS, Docket No. RR15-2-005 (“North American Electric Reliability Corporation”)

Supplemental Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM16-6-000 (Essential Reliability Services and the Evolving Bulk-Power System – Primary Frequency Response)

Letter to Chairman LaFleur et al RM16-6-000

Trade Associations (ELCON et al.), Docket No. AD17-9-000 (“Foundation for Resilient Societies”)

February 21, 2017

ELCON and PGC urging Trump Administration to fill openings on the Federal Energy Regulatory Commission

February 7, 2017

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM16-6-000 “(Essential Reliability Services and the Evolving Bulk-Power System—Primary Frequency Response)”

January 24, 2017

Comments of ELCON et al. (“The Associations”), Revisions to the Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas (GHG) Permitting Regulations and Establishment of a Significant Emission Rate (SER) for GHG Emissions Under the PSD Program, Proposed Rule, Docket ID No. EPA–HQ–OAR–2015–0355, 81 Fed. Reg. 68,110

December 16, 2016

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM16-21-000 “(Modifications to Commission Requirements for Review of Transactions under Section 203 of the Federal Power Act and Market-Based Rate Applications under Section 205 of the Federal Power Act)”

November 28, 2016

Post-Technical Conference Comments of the Electricity Consumers Resource Council (“ELCON”), Docket No. AD16-16-000 “(Implementation Issues Under the Public Utility Regulatory Policies Act of 1978)”

November 7, 2016

Comments of ELCON et al. (“The Associations”), Clean Energy Incentive Program Design Details, Proposed Rule, Docket ID No. EPA–HQ–OAR–2016–0033, 81 Fed. Reg. 42,940

November 1, 2016

Opening Brief of Non-State Petitioners, On Petitions for Review of Final Agency Action of the United States Environmental Protection Agency, 80 Fed.Reg.64,510 (Oct.23, 2015) and 81 Fed.Reg. 27,442 (May 6, 2016), In the United States Court of Appeals for the District of Columbia Circuit, No. 15-1381 (and consolidated cases)

October 13, 2016

Post-Technical Conference Comments of the Electricity Consumers Resource Council (“ELCON”), Docket No. AD16-18-000 “(Competitive Transmission Development Technical Conference)”

October 3, 2016

Comments of the Electricity Consumers Resource Council (“ELCON”) and the American Forest and Paper Association (“AF&PA”), Docket No. RM16-17-000 “(Data Collection for Analytics and Surveillance and Market-Based Rate Purposes)”

September 19, 2016

Comments of ELCON et al. (“The Associations”), Protection of Visibility: Amendments to Requirements for State Plans, Proposed Rule, Docket ID No. EPA-HQ-OAR-2015-0531, 81 Fed. Reg. 26,942

August 10, 2016

Request for Clarification of the Edison Electric Institute, the American Public Power Association, the Electric Power Supply Association, the Electricity Consumers Resource Council, and the Large Public Power Council, Docket No. RM15-25-000 “(Availability of Certain North American Electric Reliability Corporation Databases to the Commission)”

Opening Statement of John P. Hughes President & CEO Electricity Consumers Resource Council (ELCON), Docket No. AD16-18-000 “(Competitive Transmission Development)”

Comments of ELCON, FERC Document No. RM16-6-000 (“Essential Reliability Services and the Evolving Bulk-Power System-Primary Frequency Response”)

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM16-6-000 “(Essential Reliability Services and the Evolving Bulk-Power System—Primary Frequency Response)”

Additional Comments of the Edison Electric Institute, the National Rural Electric Cooperative Association, the Electric Power Supply Association, and the Electricity Consumers Resource Council, Docket No. RM15-14-000 “(Revised Critical Infrastructure Protection Reliability Standards)”

Comments of EEI, NRECA, EPSA and ELCON, FERC Docket No. RM15-14-000 (“Revised Critical Infrastructure Protection Reliability Standards”)

Reply Brief of Petitioners on Core Legal Issues, On Petitions for Review of Final Agency Action of the United States Environmental Protection Agency, 80 Fed.Reg.64,510 (Oct.23, 2015), In the United States Court of Appeals for the District of Columbia Circuit, No. 15-1381 (and consolidated cases)

Opening Brief of Petitioners on Core Legal Issues, On Petitions for Review of Final Agency Action of the United States Environmental Protection Agency, 80 Fed.Reg.64,510 (Oct.23, 2015), In the United States Court of Appeals for the District of Columbia Circuit, No. 15-1381 (and consolidated cases)

February 19, 2016

Application of Business Associations for Immediate Stay of Final Agency Action Pending Appellate Review, Directed to the Honorable John G. Roberts, Jr., Chief Justice of the United States And Circuit Justice for the United States Court of Appeals for the District of Columbia Circuit, In the Supreme Court of the United States, State of West Virginia, State of Texas, et al. v. US EPA

January 27, 2016

Comments of ELCON et al. (“The Associations”), Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units Constructed on or Before January 8, 2014; Model Trading Rules; Amendments to Framework Regulations, Proposed Rule, Docket ID No. EPA–HQ– OAR–2015–0199, 80 Fed. Reg. 64,966

January 21, 2016

Comments of Electricity Consumers Resource Council (“ELCON”), American Chemistry Council (“ACC”), and Council of Industrial Boiler Owners (“CIBO”), Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units Constructed on or Before January 8, 2014; Model Trading Rules; Amendments to Framework Regulations – Proposed Rule – 80 Fed. Reg. 64,966, EPA–HQ–OAR–2015–0199

January 21, 2016

Comments of ELCON, Docket No. RM 15-24-000 (“Settlement Intervals and Shortage Pricing in Markets Operated by RTOs and ISOs”)

November 30, 2015

Comments of the Edison Electric Institute, the American Public Power Association, National Rural Electric Cooperative Association, Electric Power Supply Association, electricity Consumers Resource Council and Transmission Access Policy Study Group, Docket No. RM14-8-000 et al. (“Protection System Maintenance Reliability Standard”)

November 20, 2015

ELCON et al Letter to FERC Opposing Technical Conference on PURPA

November 18, 2015

Additional Comments of The Edison Electric Institute, American Public Power Association, Electricity Consumers Resource Council, and National Rural Electric Cooperative Association, Docket No. RM15-11-000 “(Reliability Standards for Transmission System Planned Performance for Geomagnetic Disturbances)”

November 4, 2015

Additional Comments of EEI, APPA, ELCON, and NRECA, Docket No. RM15-11-000 (“Reliability Standards for Transmission System Planned Performance for Geomagnetic Disturbances”)

November 4, 2015

Motion to Intervene Out-of-Time, or In the Alternative, Participate as Amicus Curiae, and Comments of the Electricity Consumers Resource Council (“ELCON”) and Joint Consumers, FERC Docket No. ER07-1069-006 (“American Electric Power Service Corp.”)

October 28, 2015

Comments of the Edison Electric Institute, the American Public Power Association, National Rural Electric Cooperative Association, Electric Power Supply Association, Electricity Consumers Resource Council, Transmission Access Policy Study Group, and the Large Public Power Council, Docket No. RM15-14-000 “(Reliability Standards for Critical Infrastructure Protection and Supply Chain Management)”

September 21, 2015

Joint Comments of EEI, APPA, NRECA, EPSA, ELCON, TAPS, and LPPC, FERC Docket No. RM15-14-000 (“Reliability Standards for Critical Infrastructure Protection and Supply Chain Management”)

September 21, 2015

Protest and Comments of the Electricity Consumers Resource Council (“ELCON”) and Joint Consumers, Docket No. EL15-86-000 “(ITC Grid Development LLC)”

August 27, 2015

Protest and Comments of the Electricity Consumers Resource Council (ELCON) and Joint Consumers, FERC Docket No. EL15-86-000 (ITC Grid Development LLC)

August 27, 2015

Motion to Intervene, Answer, and Comments of the Electricity Consumers Resource Council (“ELCON”), Docket No. EL15-86-000 “(ITC Grid Development LLC)”

August 24, 2015

Comments of ELCON et al. (“The Associations”), Approval and Promulgation of Implementation Plans; Arkansas; Regional Haze and Interstate Visibility Transport Federal Implementation Plan, Proposed Rule, Docket ID No. EPA-R06-OAR-2015-0189, FRL-9924-85-Region-6,

Press Release on Clean Power Plan

Comments of the Edison Electric Institute, American Public Power Association, Electricity Consumers Resource Council, the Electric Power Supply Association, Large Public Power Council, and the National Rural Electric Cooperative Association, Docket No. RM15-11-000 “(Reliability Standards for Transmission System Planned Performance for Geomagnetic Disturbances)”

Joint Comments of EEI, APPA, ELCON, EPSA, LPPC, and NRECA, FERC Docket No. RM15-11-000 (“Reliability Standards for Transmission System Planning Performance for Geomagnetic Disturbances”)

Press Release in Response to Supreme Court Ruling on EPA Regs

Comments of the Electricity Consumers Resource Council (ELCON), Docket No. RM15-2-000 “(Third-Party Provision of Primary Frequency Response Service)”

Comments of the Electricity Consumers Resource Council, FERC Docket No. RM15-2-000 (“Third-Party Provision of Primary Frequency Response Service”)

Comments of ELCON et al. (“The Associations”), Approval and Promulgation of Implementation Plans; Texas and Oklahoma; Regional Haze State Implementation Plans; Interstate Transport State Implementation Plan to Address Pollution Affecting Visibility and Regional Haze; Federal Implementation Plan for Regional Haze and Interstate Transport of Pollution Affecting Visibility, Proposed Rule, Docket ID No. EPA-R06-OAR-2014-0754, FRL-9920-11-Region-6

Technical Workshop Comments of ELCON, FERC Docket No. AD14-14-000 (“Price Formation in Energy and Ancillary Services Markets Operated by RTOs and ISOs”)

Comment of the Electricity Consumers Resource Council, Docket No. RR15-4-000 (“North American Electric Reliability Corporation: Petition for Approval of Risk Based Registration Initiative Rules of Procedure Revisions”)

January 1, 2015

Motion to Intervene and Comments of American Public Power Association, Electricity Consumers Resource Council, Large Public Power Council, National Rural Electric Cooperative Association, and Transmission Access Policy Study Group Regarding Reliability Assurance Initiative (RAI), FERC Docket No. RR15-2-000 (“North American Electric Reliability Corporation”)

December 3, 2014

Comments of ELCON et al (the “Associations”), Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generation Units, Proposed Rule, Docket ID No. EPA-HQ-OAR-2013-0602; FRL-9910-86-OAR, 79 Fed. Reg. 34,830 (June 18, 2014)

December 1, 2014

John Anderson’s Statement on EPA’s “111 (d) Rule”

December 1, 2014

Comments of the Electricity Consumers Resource Council, Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generation Units, Proposed Rule, Docket ID No. EPA-HQ-OAR-2013-0602; FRL-9910-86-OAR, 79 Fed. Reg. 34,830 (June 18, 2014)

November 26, 2014

Protest of Advanced Energy Management Alliance, FERC Docket No. EL14-55-000 (“FirstEnergy Service Co. v PJM Interconnection LLC”)

October 22, 2014

Carbon Pollution Standards for Modified and Reconstructed Stationary Sources: Electric Utility Generating Units, Docket ID No. EPA–HQ–OAR–2013–0603; FRL–9910-00-OAR, 79 Fed. Reg. 34,960

October 17, 2014

Comments of EEI, EPSA, and ELCON, FERC Docket No. RM14-15-000 (“Physical Security Reliabilty Standard”)

September 8, 2014

ELCON Policy Input for the NERC Board of Trustees & Member Representatives Committee

ELCON Policy Input for the NERC Board of Trustees & Member Representatives Committee

Joint Letter to FERC, Docket No. AD13-7-000 (“Centralized Capacity Markets in Regional Transmission Organizations and Independent System Operators”)

February 1, 2014

Joint Motion to Intervene, Protest and Initial Comments of the Electricity Consumers Resource Council, FERC Docket No. RD14-2-000 (“North American Electric Reliability Corporation”)

January 21, 2014

Generator Verification Reliability Standards, Docket No. RM13-16-000

January 15, 2014

ELCON Comments on Frequency Response and Frequency Bias Setting Reliability Standard and Market Implications of Frequency Response and Frequency Bias Setting Requirements, Docket Nos. RM13-11-000 & AD13-8-000

September 30, 2013

Joint Letter to FERC by ELCON et al., Opposing Petition of WIRES for Statement of Policy and EEI Report on Transmission ROEs

ELCON Comments on Small Generator Interconnection Agreements and Procedures

ELCON’s Answer in Support of Motion for an Extension of Time and Request for Shortened Comment Period and Expedited Action

Comments of EEI, APPA, ELCON, NRECA, TAPS, EPSA and LPPC, Docket No. RC11-6-004 (North American Electric Reliability Corporation –FFT Compliance Filing)

Motion to Intervene and Comments of ELCON et al, FERC Docket No. RR13-2-000 (“North American Electric Reliability Corporation”)

Request for Rehearing and Clarification of the Transmission Access Policy Study Group (TAPS) and the Electricity Consumers Resource Council (ELCON), FERC Docket Nos. RM12-6-000 & RM12-7-000 (“Revisions to Electric Reliability Organization Definition of Bulk Electric System and Rules of Procedure”)

January 22, 2013

Comments of the Electricity Consumers Resource Council, FERC Docket Nos. RM11-24-000 and AD10-13-000 (“Third Party Provision of Ancillary Services etc.”)

September 7, 2012

ELCON Comments on Revised Definition of Bulk Electric Systems and Exceptions Process, FERC Docket Nos. RM12-6-000 and RM12-7-000

September 4, 2012

Comments of EEI, APPA, ELCON, NRECA, TAPS, EPSA and LPPC, FERC Docket No. RC11-6-002 (“North American Electric Reliability Corporation”)

Comments of ELCON, Docket No. AD12-1-000 (“Commission Role Regarding Environmental Protection Agency’s Mercury and Air Toxics Standards”)

February 29, 2012

Comments of Dr. John Anderson at the FERC Technical Conference on Reliability, FERC Docket. No AD12-1-000

November 29, 2011

Joint Trade Associations’ Comments in Support of NERC CIPS Version 4, FERC Docket No. RM11-11-000 (“North American Electric Reliability Corporation”)

November 21, 2011

Comments of Join Commenters, Promoting Transmission Investment through Price Reform, Docket No. RM11-26-000

September 13, 2011

Comments of ELCON Promoting Transmission Investment through Price Reform, Docket No. RM11-26-000 

September 13, 2011

Transmission Planning and Cost Allocation by Transmission Owning and Operating Public Utilities, Docket No. RM10-23-000

August 25, 2011

Notice of Inquiry on Third-Party Provision Ancillary Services: Accounting and Financial Reportings for New Electric Storage Technologies, Docket Nos. RM11-24-000, AD10-13-000

August 25, 2011

Comments of the Electricity Consumers Resource Council (ELCON), FERC Docket No. RM11-7-000 (Frequency Regulation Compensation in the Organized Wholesale Power Markets

Comments of the Electricity Consumers Resource Council, Docket No. RM10-11-000 (“Integration of Variable Energy Resources)

Statement of John Anderson at FERC Technical Conference on BPS Reliability

February 8, 2011

North American Electric Reliability, Docket No. RR09-6-000 2010

January 24, 2011

Request for Rehearing of Industrial Customers, FERC Docket No. ER10-1791 (“Midwest Independent Systems Operator, Inc.”)

January 8, 2011

Comments on Bulk Electric System (BES) Concept Document, Electricity Consumers Resource Council

January 1, 2011

Supplemental Notice of Proposed Rulemaking and Notice of Technical Conference, FERC Docket RM10-17-000

October 13, 2010

Comments of ELCON and Associated Industrial Groups, FERC Docket No. RM10-23-000 (“Transmission Planning and Cost Allocation”)

September 29, 2010

Joint Comments of APPA, ELCON, et all, FERC Docket No. RM10-23-000 (“Transmission Planning and Cost Allocation”)

September 29, 2010

Protest of Industrial Customers to MISO Transmission Cost Allocation Proposal, FERC Docket No. ER10-1791-000

September 10, 2010

Midwest Independent Transmission System Operator, Inc., Docket No. ER09-1049-000

August 27, 2010

Comments of ELCON, FERC Docket No. AD10-13-000, Request for Comments Regarding Rates, Accounting and Financial Reporting for New Electric Storage Technologies 

August 10, 2010

Comments of Joint Consumer Advocates on FERC-NERC Relations, Docket No. AD10-14-000 

John Anderson’s Presentation at FERC Technical Conference on NERC

ELCON Calls for Improved NERC-FERC Communications (Press Release) 

Enforcement of Statutes, Orders, Rules and Regulations, Docket No. PL10-4-000 

Demand Response Compensation in Organized Wholesale Energy Markets, Docket No. RM10-17-000

Revision to Electric Reliability Organization Definition of Bulk Electric System, Docket No. RM09-18-000

North American Electric Reliability Corporation, Docket No. RR09-6-000 

Integration of Variable Energy Resources, Docket No. RM10-11-000 

Electricity Market Transparency Provisions of Section 220 of the Federal Power Act, Docket No. RM10-12-000 

Final Comments of the Electricity Consumers Resource Council, Docket No. RM09-16-000 

Reply Comments of the American Public Power Association and the Electricity Consumer Resource Council, Docket No. AD10-5-000

Post-Conference Comments of the Electricity Consumer Resource Council 

Initial Comments of the American Public Power Association and The Electricity Consumers Resource Council, Docket No. AD10-5-000

Initial Comments of Consumer Commenters, Docket No. AD10-5-000

PJM Interconnection LLC, Docket No. EL05-121-006 

February 5, 2010

Reply Comments of the Electricity Consumers Resource Council, FERC Docket No. AD09-8-000 (“Transmission Planning Process Under Order No. 890”)

December 9, 2009

National Action Plan on Demand Response, Docket No. AD09-10-000 

December 8, 2009

Standards for Business Practices and Communications Protocols for Public Utilities, Docket No. RM05-5-017 

November 24, 2009

Transmission Planning Processes Under Order No. 890, Docket No. AD09-8-000

November 24, 2009

Supplemental Comments of the Electricity Consumers Resource Council, FERC Docket No. PL09-4-000 (Smart Grid Policy)

ELCON Comments on Order 719 Compliance Filings 

Comments of the Electricity Consumers Resource Council, FERC Docket No. PL09-4-000 (Smart Grid Policy)

Motion to Intervene and Comments of the Electricity Consumers Resource Council, Docket Nos. ER09-1048-000 et al. (“California Independent Systems Operator Corporation et al.”)

Motion to Intervene and Comments of the Electricity Consumers Resource Council, FERC Docket No. ER09-412-000 (PJM Interconnection LLC”)

January 9, 2009

Comments of ELCON et al., Docket Nos. RM07-19-000 & AD07-7-000 (“Wholesale Competition in Regions with Organized Electric Markets”)

Comments of ELCON and AISI, Docket No. RM07-11-000 (“Applicability of Federal Power Act Section 215 to Qualify Small Power Production and Cogeneration Facilities”)

Second Supplemental Comments of the Electricity Consumers Resource Council, Docket No. RM06-10-000 (“New PURPA Section 210(m) Regulations Applicable to Small Power Production and Cogeneration Facilities”)

October 1, 2006

Comments of the Electricity Consumers Resource Council, Docket No. RM04-7-000 (“Market-Based Rates for Wholesale Sales of Electric Energy, Capacity and Ancillary Services by Public Utilities”)

Supplemental Comments of the Electricity Consumers Resource Council, Docket No. RM06-10-000 (“New PURPA Section 210(m) Regulations Applicable to Small Power Production and Cogeneration Facilities”)

Reply Comments of Electricity Consumers Resource Council and American Forest & papers Association, Docket No. RM06-10-000 (“New PURPA Section 210(m) Regulations Application to Small Power Production and Cogeneration Facilities”)

Initial Comments of the Electricity Consumers Resource Council, Docket No. RM06-10-000 (“New PURPA Section 210(m) Regulations Applicable to Small Power Production and Cogeneration Facilities”)

February 1, 2006

Comments of ELCON et al. Docket No. RM06-4-000 (“Promoting Transmission Investment Through Pricing Reform”)

January 1, 2006

Comments of ELCON and AISI, Docket No RM05-36-000 (“Regulations Governing Small Power Production and Cogeneration Facilities”)

November 1, 2005

Post Technical Conference Comments of the Electricity Consumers Resource Council, Docket No. PL02-4-000 (“Compensation for Generating Units Subject to Local Market Power Mitigation in Bid-based Markets”)

February 1, 2004