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NASEO Energy Data & Security Committee

NASEO Response to EIA

September 8, 1998

John Colligan
Energy Information Administration
Coal and Electric Data and Renewables Division, EI-524
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, D.C. 20585-0650

Dear Mr. Colligan:

The National Association of State Energy Officials (NASEO) Ad Hoc Liaison Group appreciates the opportunity to respond to the Federal Register notice of July 17, 1998, on the U.S. Department of Energy's provisions for confidentiality of electric power data collected by the Energy Information Administration (EIA). The NASEO Ad Hoc Liaison Group consists of representatives of State Energy Offices and industry representation from the petroleum, propane and natural gas industries and supports the ongoing collection and publication of high quality data needed by the states and industries that serve them.

In general, we support the approach recommended by EIA. We agree with EIA that the parties should be required to justify how competitive harm will occur should information be disclosed. The move to a competitive market neither eliminates the need for data nor mandates a change in the manner in which it is collected. Competition functions most efficiently in a fair and open system with full disclosure of information on both the supply and demand sides.

Some states are concerned about the ability to obtain data from companies doing business in their state, but that are located (i.e., generation, headquarters, etc.) outside of the geographic borders. These states believe that in certain circumstances states may need access to confidential data from EIA. Therefore, EIA needs to insure that its confidentiality policy would permit states to access individual company data under specific conditions. EIA might consider using a memorandum of understanding between EIA and the requesting state to make individual company data available to the state, provided that the state could assure the continued confidentiality of the data under state law. States should be able to demonstrate that the information would remain confidential and that they have adequate legal authority to protect the information from disclosure, as a prerequisite to its release.

We appreciate the opportunity to comment on this confidentiality policy and urge EIA to carefully consider the manner in which this policy is crafted. Many of the existing and new participants in a restructured electric power industry may seek the adoption of policies which reduce their exposure to competitive pressures. This is contrary to the intent of open markets in which prices will be controlled by competitive pressures, and where the price information should be transparent for all market participants.

NASEO continues to support strongly the state level reporting of consistent and reliable, electricity supply, demand, and price information by EIA. This information is extremely useful, serves the public interest, and is most efficiently collected by the federal government. In cases where states need to collect more detailed information than EIA collects, we support the development of coordinated mechanisms that lead to more efficient and less burdensome data collection.
 

Sincerely,

Jeffrey R. Pillon, Chair
NASEO Ad Hoc Liaison Group
 

NASEO Ad Hoc Liaison Group Members Supporting this Letter

Diane DeVaul, Northeast Midwest Institute
Cheryl DeVol, Indiana Department of Commerce, Energy Policy Division
Ron Forsythe, Energy Division, Mississippi Dept. of Economic and Community Develop.
Tom Kelly, Energy Information and Analysis, California Energy Commission
Donald E. Milsten, State Service Program, Baltimore, Maryland
Jeffrey R. Pillon, Michigan Public Service Commission
John M. Stapleton, Kentucky Division of Energy
Tom Franks, State of Vermont Department of Public Service
 

cc:    Chester B. Smith, Chairman, NASEO
        Frank Bishop, Executive Director NASEO

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