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NASEO Energy Data & Security Committee |
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May 14, 2001 Mr. John G. Colligan RE: Agency Information Collection Activities: Proposed Collection; Comment Request Dear Mr. Colligan: The National Governors' Association (NGA), the National Association of Regulatory Utility Commissioners (NARUC), the National Association of State Energy Officials (NASEO), and the National Association of State Utility Consumer Advocates (NASUCA) respectfully object to the Energy Information Administration's (EIA) proposal, as currently drafted, to treat certain data received by EIA from electric power plants as confidential. We file this joint letter in addition to the individual comments filed by our organizations to stress our strong opposition to the proposal as written. Our members are currently involved in all stages of the process of restructuring. Despite each state's unique position, the need for timely, adequate data is universal. Whether a state continues with a traditional regulatory structure or is implementing competitive retail markets, state officials must have accurate and timely data to ensure that energy markets within their jurisdiction are functioning appropriately and that consumers are adequately protected. EIA's proposal as drafted would affect individual state consumer protection policies, market monitoring initiatives, environmental programs and renewable energy initiatives within the states. EIA data and reports are viewed as the definitive source of objective, reliable information on the energy sector. In fact, EIA has a statutory duty pursuant to the Federal Energy Administration Act of 1974 (Pub. L. No. 93-275, 15 U.S.C. 761 et seq.) to carry out a centralized, comprehensive, and unified energy information program to collect, evaluate, assemble, analyze, and disseminate information on energy resource reserves, production, demand, technology, and related economic and statistical information. Given EIA's unique position as an independent data collection agency, states have relied on EIA information to assist them in the development of their own energy policies. For example, in the area of traditional rate regulation, states have found EIA databases to be neutral sources of information that are seldom questioned when used in testimony by regulatory staff, consumer advocates, or other intervenors in base rate proceedings, fuel cost recovery cases, and utility company merger cases. As our country grapples with what Secretary of Energy Spencer Abraham has called an "energy crisis," the need to ensure healthy and competitive markets could not be more acute. Limiting access to electric generation data, energy resource information, energy production, demand, and technology data in individually-identifiable form specific to a state or its neighboring region can seriously impair state regulatory, energy, economic development or environmental protection agencies' efforts to understand and to solve local market dysfunction and delivery problems and to address state energy needs and policy development. By limiting state access to data collected by the EIA, the current proposal undermines an individual state's ability to protect consumers from unjust and unreasonable electricity rates, and hinders the state's ability to promote robust economic development and address vital state interests. While our respective organization's individual comments detail more specifically the reasons why EIA should reconsider and withdraw its misguided proposal, our joint letter of objection emphasizes the need for the federal government to assist the states in their efforts to promote sound energy policy. The current proposal if adopted will ultimately hinder our members' ability to achieve the goal of energy security. For this reason, we urge EIA to reconsider and withdraw the Agency Information Collection Activities: Proposed Collection; Comment Requests. Sincerely,
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