***Ameren Services***

***Environmental, Safety & Health***

***P.O. Box 66149***

***St. Louis, MO 63166***

***314.554.2388 (Phone)***

***314.554.4182 (Facsimile)***

***prpike@ameren.com***

Stephen E. Calopedis

U.S. Department of Energy

Energy Information Administration, EI--81

1000 Independence Avenue, SW.

Washington, DC 20585

By email: *stephen.calopedis@eia.doe.gov*

**Re: [Comments on the Energy Information Administration's Revised Form
EIA-1605 and Draft Instructions. 70 *Fed. Reg.* 37798 (June 30,
2005]{.underline})**

Dear Mr. Calopedis:

Ameren is pleased to submit comments on Energy Information
Administration's (EIA) revised Form EIA-1605 for "Voluntary Reporting of
Greenhouse Gases." \[**[Federal Register]{.underline}**, June 30, 2005,
Volume 70, Number 125, Pages 37798-37800.\] Comments were due to be
submitted by August 29, 2005.

In a Federal Register notice to be published during the week of August
29 to September 2, 2005, EIA has cancelled the comment request. EIA
states that it "will instead wait for the process of developing the
general and technical guidelines to progress before soliciting comments
on revised draft versions of the Program's form and instructions." EIA
will "however, where appropriate, take into consideration comments
received in response to its June 29, 2005 Federal Register notice in
developing revised draft form and instructions." Ameren supports EIA in
the decision to cancel the comment request and plans to submit
additional comments on future drafts.

Ameren provides energy services to 2.3 million electric and 900,000
natural gas customers over nearly 64,000 square miles in Illinois and
Missouri. We have participated in the voluntary reporting of greenhouse
gases since 1995. Ameren is a member of the Edison Electric Institute
("EEI"), PowerTree Carbon Company, and Utility Solid Waste Activities
Group ("USWAG"), and as a member of these groups, we support the
comments that they are submitting on the revised form and instructions.

Our June, 2005 comments on DOE's Interim Final General Guidelines and
the Draft Technical Guidelines objected to the approach of having a
two-tiered reporting system for reporters and registers. This concept
ways does not truly add any of the attributes that the Agency is
striving for and could discourage future participation in the program
and thereby hinder industry's progress toward reducing emissions.

The development of the form and instructions is premature because there
was only one day separation between the submittal date for comments on
the Interim Final General Guidelines and draft Technical Guidelines and
the release notice for the form. The proposed EIA-1605 form should
represent EIA's interpretation of the Interim Final General Guidelines
and draft Technical Guidelines, but the Agency has yet to finalize the
General Guidelines and the Technical Guidelines that define the 1605(b)
reporting program. DOE could change the general and/or technical
guidelines resulting in changes to the form and instructions provided
for comment. Depending on the final version of the guidelines this
release could be a wasted effort on the Agency's part.

Reporting must be simplified, regardless of whether a two-tiered
reporting system is used or not the proposed form is too complicated and
it's difficult to determine what information must be submitted. Program
participants need a form or forms that are easy to understand and state
simply what level of information is needed for their reporting. The
level of complication in the proposed form could result in wasted effort
on the reporter's part and reduced reporting due to frustration by the
reporter.

In general Ameren believes that more effort is necessary to revise the
1605(b) program. We recommend that the Agency simplify the process and
provide clear direction. We participated in DOE's workshops on how to
improve the existing Voluntary Greenhouse Gas Reporting (1605b) Program
and believe that additional meetings of stakeholders with a willingness
to make changes could develop a program that provides accounting
consistency and greater participation in the reporting program.

We appreciate the opportunity to provide these comments. If you have any
questions, please contact me at (314) 554-2388.

Sincerely,

![](media/image1.png){width="1.3868055555555556in"
height="0.7784722222222222in"}

Paul R. Pike

Environmental Services Scientist