Comment submitted by Edison Electric Institute (EEI)
AnonymousSupportTrade association
Summary: The Edison Electric Institute (EEI), representing investor-owned electric companies, supports the proposed rule to clarify "begin actual construction" by distinguishing between pollutant-emitting activities and non-emitting components. They argue that these changes will provide regulatory certainty, reduce project delays, and help meet rising electricity demand while maintaining environmental safeguards.
Please find attached here the Edison Electric Institute's comments responsive to the proposed rule "Begin Actual Construction in the New Source Review (NSR) Preconstruction Permitting Program" (Docket ID No. EPA-HQ_OAR_2025-0618. EEI appreciates the opportunity to comment.