Public Service Commission .md.us



January 5, 2001

Felecia L. Greer, Executive Secretary

Public Service Commission of Maryland

William Donald Schaefer Tower

6 St. Paul Street – 16th Floor

Baltimore MD 21202-6806

RE: PSC Case No. 8738

Emissions Disclosure

Dear Ms. Greer:

In accordance with the Commission’s directive for comments on the Second Report of the Emissions Disclosure Working Group Report (filed October 3, 2000), as set forth in your letter of November 21, 2000, the Maryland Department of the Environment (“the Department”) submits for filing the enclosed original and fourteen (14) copies of the Department’s comments on this topic. Also enclosed is a diskette for electronic filing of same.

Should you have any questions concerning this information, please feel free to contact me at 410-631-3255.

Sincerely,

Ann Marie DeBiase, Director

Air and Radiation Management Administration

AMD/DMG/dg

Enclosure

STATE OF MARYLAND

DEPARTMENT OF THE ENVIRONMENT

BEFORE THE

PUBLIC SERVICE COMMISSION

In the Matter of the Commission’s )

Inquiry into the Provision and ) Case No. 8738

Regulation of Electric Service ) Emissions Disclosure

INITIAL COMMENTS BY THE

MARYLAND DEPARTMENT OF THE ENVIRONMENT

ON THE SECOND REPORT OF THE

EMISSIONS DICLOSURE WORKING GROUP

January 5, 2001

1. Disclosure Labels. The Department of the Environment (“the Department”) believes that the emissions and fuel mix disclosure labels could be improved and encourages the Commission to require electricity suppliers to make changes based on stakeholder feedback. Additionally, the Department encourages the Commission to undertake continued public education efforts aimed at helping customers understand the contents of the labels. Furthermore, to facilitate customers’ efforts to compare electricity suppliers based on environmental characteristics, it is important that the information provided on all labels be available in a central location, e.g., the website of the Office of the Attorney General.

2. Verification Procedures. The Department believes that uniform verification procedures should be established that apply to all electricity suppliers regardless of energy source (i.e., fuel mix). This will make review of the information submitted easier for the Commission and ensure a similar reporting burden for all electricity suppliers.

3. Regional Approach. The Department supports a regional approach, such as could be obtained through a PJM-wide tracking system, to emissions and fuel mix tracking. A regional approach will help to ensure that the emissions and fuel mix information reported on the disclosure labels is uniform, consistent, and accurate and will prevent double counting of electricity sources. Additionally, the Emissions Disclosure Working Group reached consensus that data received from PJM would require no further verification. This would reduce the burden on each electricity supplier to verify its emissions and fuel mix characteristics and reduce the administrative burden on Commission staff to review and confirm the information submitted.

Respectfully submitted,

Ann Marie DeBiase, Director

Air and Radiation Management Administration

CERTIFICATE OF SERVICE

I HEREBY CERTIFY on this ___ day of January, 2001 that a copy of the Maryland

Department of the Environment’s Comments has been either hand-delivered or mailed first class

postage prepaid to all parties of record.

______________________________________

Ann Marie DeBiase, Director

Air and Radiation Management Administration

Maryland Department of the Environment

2500 Broening Highway

Baltimore, MD 21224

(410) 631-3255

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