Comment submitted by Edison Electric Institute (EEI)

Summary: The Edison Electric Institute (EEI), representing U.S. investor-owned electric companies, supports the proposed rule but requests specific modifications to provide regulatory certainty and clarify applicability. They argue for the removal of the "unmanaged CRL" definition to avoid confusing and duplicative regulations, while also advocating for the reconsideration of zero-liquid discharge (ZLD) requirements due to technical and economic feasibility concerns.