January 5, 2001
Felecia L. Greer, Executive Secretary
Public Service Commission of Maryland
William Donald Schaefer Tower
6 St. Paul Street, 16th Floor
Baltimore, Maryland 21202-6806
Re: Case No. 8738
Joint Utility Reply Comments on Emissions Disclosure
Dear Ms. Greer:
Baltimore Gas and Electric Company is pleased to submit an original and 14 copies of Joint
Utility Reply Comments of Allegheny Energy, Baltimore Gas and Electric Company, Conectiv,
and the Potomac Electric Power Company on the Emissions Disclosure Working Group Report.
Also enclosed is a copy of joint comments in electronic format.
If you have any questions, please feel free to contact me.
Respectfully submitted,
Odogwu Obi Linton
cc: Service List in Case No. 8738
BEFORE THE
PUBLIC SERVICE COMMISSION
OF MARYLAND
In the Matter of the Commission’s *
Inquiry Into the Provision and * Case No. 8738
Regulation of Electric Service *
Joint Utility Reply Comments on
Emissions Disclosure
On October 3, 2000, the Staff of the Public Service Commission (“Commission”) filed
the Second Report of the Emissions Disclosure Working Group (“EDWG”). The Commission
issued an Order on November 21, 2000, inviting interested parties to file comments on the Staff
Report on or before January 5, 2001. Pursuant to that Order, Allegheny Energy, Baltimore Gas
and Electric Company, Conectiv and the Potomac Electric Power Company (collectively referred
to as the “Companies”) hereby submit these comments.
The Companies wish to provide comments on two issues:
1. Third-Party verification, and;
2. Label Improvement.
Self-Certification by Electric Companies and Electric Suppliers is Adequate Since
the Data is Certified and Quality Assured Under Other Programs
Beginning on page 5 of the Report, third-party certification of company emission data is
discussed. The Companies are opposed to any third-party verification. Comprehensive emission
reporting requirements, complete with prescriptive quality assurance provisions are already in
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place to ensure that the data supplied are accurate and complete. Furthermore, significant federal
enforcement capabilities are already in place to ensure that the monitoring and reporting
requirements are followed. The statute did not contemplate the creation of a new emission
reporting system. The Companies, therefore, urge the Commission to refrain from mandating
additional certification.
Currently, generating utilities have verified power plant emissions and fuel mix data for a
number of government entities including the U.S. Environmental Protection Agency, the U.S.
Department of Energy Information Administration, the Federal Energy Regulatory Commission,
and the Maryland Department of Environment. The data provider certifies data to these agencies
under significant civil and criminal penalties for incomplete or inaccurate data. Other options
were discussed at the EDWG meetings and, in this Report, merely add another cost and
administrative burden without increasing the value of the data to consumers.
The Report at page 9 correctly points out that emission data must be combined with
energy data in a one-step calculation. Verification of this combination is a minor administrative
effort that can easily be handled by the Commission Staff.
The Companies also continue to recommend that the Commission order the continuation
of the EDWG to explore opportunities to implement the disclosure requirements throughout the
PJM. The EDWG should continue to participate in ongoing discussions among regional
stakeholders, including electric companies, suppliers and the utility regulatory bodies from each
of Maryland’s neighboring states to develop a standard disclosure approach. It is important that
the Companies are afforded specific opportunities to participate.
Label Improvement is Not Necessary at this Time
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The Companies do not believe that changes to the label are required at this time. While
the Report correctly states that EDWG members agreed that improvements were possible to the
label, two points provide clarification. One is that at an Administrative meeting in October, the
Commission approved the primary changes to the labels advocated by the EDWG. Secondly, the
EDWG agreed that it would further refine the labels after filing the October 1, 2000 Report with
the Commission if it became necessary in response to consumer feedback. None of the
Companies has experienced any call for such revisions. In fact, some of the Companies have
received no customer inquiries regarding the labels. Clearly, no changes are necessary at this
time.
The EDWG Report notes, at page 4, that the EDWG discussed compatibility with New
Jersey labeling requirements. However, the EDWG did not conclude that the Maryland
requirements should mirror the New Jersey requirements. Finally, the Companies supported
common ground with Delaware, the District of Columbia, Pennsylvania, Virginia and West
Virginia, as well as New Jersey during the discussions.
In conclusion, the Companies support the following consensus recommendations
contained in the Report:
a. “Emissions and fuel mix data provided by PJM does not need to be certified.” Report at page
5.
b. “Wholesale contracts for unspecified resources will use PJM or Allegheny control area data.”
Report at page 5.
c. The group agreed subsections ii) on pages 13 - 15 of the emission disclosure rules are
unnecessary and should be eliminated. This requirement requires documentation that
imported power was scheduled for transmission into the PJM control.
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The Companies appreciate the opportunity to submit these comments and will be
available to respond to questions at the hearing on January 16, 2001.
Respectfully submitted,
By: ______________________________
Odogwu Obi Linton
Attorney
Baltimore Gas and Electric Company
Legal Department
39 W. Lexington Street
Baltimore, MD 21201
(410) 234-5666
(410) 234-7043 Fax
odogwu.o.linton@bge.com
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 5th day of January 2001, a copy of the
foregoing Joint Utility Reply Comments of Allegheny Energy, Baltimore Gas and
Electric Company, Conectiv, and the Potomac Electric Power Company on the
Emissions Disclosure Working Group Report was mailed, postage prepaid, to all parties
listed on the official service list in this proceeding.
____________________________
________
Odogwu Obi Linton
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