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**Tennessee Valley Authority**, 1101 Market Street, Chattanooga,
Tennessee 37402-2801

June 4, 2002

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, DC 20585

Dear Ms. Vernet:

Re: [Voluntary Reporting of Greenhouse Gas Emissions, Reductions, and
Carbon]{.underline} [Sequestration]{.underline}, 67 *Fed. Reg.* 30370
(May 6, 2002)

The Tennessee Valley Authority (TVA) respectfully submits the following
comments in response to the above-referenced notice of inquiry (NOI) and
request for comment from the Department of Energy (DOE). TVA is the
nation's largest public power provider with a service territory that
includes all or part of seven states in the Tennessee Valley Region,
providing power to large industries and 158 power distributors that
serve about 8.3 million customers.

In Fiscal Year (FY) 2001, TVA produced more than 156 billion
kilowatt-hours of electricity, relying on an outstanding transmission
system and a unique mix of fossil, hydro, nuclear an renewable power
generation. In FY 2001, TVA fossil plants produced 64 percent of the
total generation within the system, followed by nuclear power with 29
percent, hydro with one percent, combustion turbines with one percent,
and renewables less than one percent.

TVA is also responsible for the integrated management on the Tennessee
River system's streams, reservoirs, and adjacent lands for water supply,
flood control, navigation, power generation, environmental health,
wildlife habitat and recreation. The Tennessee River is the nation's
fifth largest river system.

TVA appreciates the opportunity to submit comments on the issues raised
in the NOI in preparation for DOE's recommendations to the President
pursuant to his 120-day directive to the DOE Secretary. We also look
forward to additional opportunities to comment as DOE develops more
detailed revisions to the current GHG registry or to 1605(b) existing
voluntary guidelines.

Jean E. Vernet, Esq.

Page 2

June 4, 2002

Given the relatively short time frame to prepare detailed comments on
such an important topic, TVA is providing DOE with our concept of the
broad principles that we hope will guide development of a revised
voluntary reporting mechanism for greenhouse gas emissions, reductions,
and carbon sequestration. TVA is a participating member of the Electric
Power Industry Climate Initiative (EPICI) and endorses the more detailed
comments and suggestions being submitted by EPICI in response to the
NOI.

**Location of the Registry**

TVA supports the objectives for an enhanced national registry outlined
in the President's Global Climate Change Initiative. We support
continuing to house the registry within DOE, and believe that the
President's objectives can best be met by enhancing the existing EIA
1605(b) registry, rather than creating an entirely new system. The
enhanced registry should continue to serve the purposes outlined in the
original enabling legislation as well as the objectives outlined in the
President's plan.

**Nature of the Registry**

TVA believes that the goal of the Climate Change Initiative is to
include all approaches that contribute to reducing the greenhouse gas
intensity of the United States over the next ten years. Thus we strongly
encourage DOE to retain the flexible, voluntary attributes of the
current registry to encompass all approaches that reduce, avoid, or
sequester greenhouse gases. TVA believes that "a ton is a ton" when it
comes to greenhouse gases, and that the atmosphere is indifferent to
tons that are avoided, sequestered, reduced or otherwise offset.

**Credit for Existing Activities and Prior Programs**

TVA has been a participant in the voluntary reporting of its greenhouse
gas emissions under the Climate Challenge Program since 1994. For
calendar year 2000, TVA reported reducing, avoiding, or sequestering
some 30.2 million tons relative to the modified reference case
emissions. We would encourage DOE to recognize the efforts of TVA and
others to make these reductions, and provide transferable credit for
these activities as we transition into reporting and registry under the
Climate Change Initiative.

TVA appreciates the opportunity to submit these comments and looks
forward to further, active participation with DOE on these and other
issues related to implementing the President's Global Climate Change
Initiative.

Sincerely,

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John W. Shipp, Jr., P.E.

General Manager

Environmental Policy and Planning