**Lynn I. Ratzell**

Manager-Environmental

**PPL Services Corp.**

Two North Ninth Street

Allentown, PA 18101-1179

Tel. 610-774-5466 Fax 610-774-5930

<liratzell@pplweb.com>

June 5, 2002

Ms. Jean E. Vernet, Esq.

Office of Policy and International Affairs

Office of Electricity and Natural Gas Analysis

PI-23, Attention: Voluntary Reporting Comments

U.S. Department of Energy

Forrestal Building

Room 7H-034

1000 Independence Avenue, S.W.

Washington, D.C. 20585

Voluntary Reporting of Greenhouse Gas Emissions, Reductions, and Carbon
Sequestration

[67 Fed. Reg. 30370 (May 6, 2002)]{.underline}

Dear Ms. Vernet:

PPL Corporation respectfully submits the following comments to the
above-referenced notice of inquiry (NOI) and request for comment from
the Department of Energy (DOE). PPL Corporation is a global energy
company that generates electricity at power plants in Pennsylvania,
Maine and Montana; markets wholesale or retail energy in select U.S.
states and Canada; and delivers electricity to nearly six million
customers in Pennsylvania, the United Kingdom and Latin America. PPL\'s
four principal business subsidiaries are PPL Electric Utilities, PPL
EnergyPlus, PPL Generation and PPL Global.

From 1991 through 2000, PPL completed a ten-year commitment to DOE to
file reductions under the 1605(b) program, registering a variety of GHG
emissions reduction actions in the DOE database. Most of the actions
taken during that period are ongoing and they continue to reduce GHG
emissions every year. Examples are: (1) new generating capacity with
reduced or zero CO~2~ emissions replacing higher emitting fossil
generation, (2) efficiency improvements on existing fossil generating
capacity, and (3) retirement of older, less efficient and higher
emitting generating units.

The President\'s February 14, 2002, direction to the Secretary of Energy
recommended reforms \"to ensure that business and individuals that
register reductions are not penalized under a future climate policy, and
to give transferable credits to companies that can show real emission
reductions.\" We strongly endorse this goal and encourage DOE to build
upon the work that was done in the previous 1605(b) program.
Specifically, we look forward to commenting on and reviewing proposals
to verify the baselines used by the prior program, and to preserve
credit for the reductions achieved in the 1990s. We are particularly
concerned with preserving credit for the ongoing GHG reductions that
continue to accrue from these past actions. We acknowledge that concerns
that have been raised about the validity of the reductions reported in
the past program. Examples are double counting of reductions, leakage,
verification and ownership issues. We look forward to reviewing specific
and detailed proposals to resolve these issues in such a way that these
reductions may become transferable credits in any future program.

With the advent of competition in the wholesale electrical generation
markets, we continue to seek out ways to improve our existing generation
and to add new, low-emitting, efficient generation to our mix. We hope
that the new GHG reporting program will be implemented in a way to
provide an added incentive to pursue these improvements by documenting
and preserving GHG reduction benefits that occur.

Electric Power Industry Climate Initiative (EPICI) has filed extensive
and detailed discussion of the specific issues that were identified for
comment in the NOI. PPL supports these comments, particularly the
following general concepts:

(1) The reporting requirements should be flexible with more rigor
    required to qualify for transferable credits, baseline protection
    and credit for past actions. Less rigor can be required for general
    GHG reporting to encourage wider participation in the program.
    Reductions qualifying for transferable credits would be a subset of
    the overall register.

(2) For reductions qualifying for transferable credits, reporting of
    reductions should be on a project or facility basis, with
    protections against double counting and leakage, and clarification
    of ownership. Entity-wide reporting should be optional. Given the
    geographic and technical diversity of PPL\'s businesses, a too
    restrictive entity-wide reporting requirement would create a
    disincentive for reporting. Complexities in reporting GHG emissions
    from relatively minor emitting businesses could create a
    disincentive for participation by our most significant GHG emitters.

(3) The guideline should allow the option to preserve the baseline
    (1987-1990) for the original 1605(b) program so that ongoing credit
    is possible for actions taken in the program.

(4) Safeguards should be put in place to protect confidential and
    proprietary data that must be submitted to verify GHG claims.

PPL appreciates the opportunity to comment and looks forward to further
discussion and work with DOE & EIA on the development of this new
program.

Sincerely,

![](media/image1.png){width="2.8in" height="0.64375in"}

Lynn Ratzell