Response Letter to Comments Documenting Meeting with OMB

Appendix D

EIA Letter to OMB
Documenting August 18, 2010 Meeting and
Giving EIA’s Recommendations on the Comments Received
In Response to Federal Register Notice
Vol. 75, No. 129, DOCID: fr07jy10-50
Published July 7, 2010

Ms. Christine Kymn
Desk Officer for DOE
Office of Information and Regulatory Affairs
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503

RE: Clearance of EIA's 2011 Electric Power Survey Forms

Dear Ms. Kymn:
This letter documents our August 18, 2010 meeting. In that meeting we reviewed with OMB the
comments it received on the 2011 clearance of the U.S. Energy Information Administration's (EIA)
electric power survey forms. The letter covers the same ground as our meeting, except that it provides
more detail and includes EIA's response to the comments from CenterPoint Energy (which EIA did not
receive until August 23).
The letter is divided into two parts. The first part provides EIA's response to the comments received by
OMB. The second part discusses other changes EIA would like to make to the surveys.

EIA's Recommendations on the Comments Received by OMB
Five sets of comments were received by OMB: From the Edison Electric Institute (EEl), the Northeast
Energy Efficiency Partnership (NEEP), the Consortium for Energy Efficiency (CEE), CenterPoint Energy,
and the U.S. Geological Survey (USGS). Each set of comments is addressed below except for the NEEP
submission, which was simply a statement supporting the CEE comments.
In addition to responding to comments, we also discuss the impact of EIA's recommended responses on
respondent burden. This discussion is framed in terms of any change from the burden estimate
specified in our original submission to OMB.

Comments from EEl and EIA Response
Several of the comments from EEl and other parties relate to the EIA-411 survey. Note that EIA does not
directly collect the EIA-411 data. The information is collected from its members by the North American
Electric Reliability Corp. (NERC), the official FERC-designated {{electric reliability organization." NERC
reviews the data and then completes the EIA-411 survey on behalf of its members. The data submitted
on the EIA-411 by NERC also includes information from its new Transmission Availability Data System
(TADS), which collects data on transmission system outages.

Printed

Comment: OMB should delay lowering the EIA-411 reporting thresholds for transmission facilities and
require additional justification for any change.
Current EIA Proposal: This comment relates to collection of transmission system maps
(Schedule 5 of the EIA-411 surveyL information on existing and planned transmission lines
(Schedule 6L data on transmission line outages (Schedule 7), and power flow cases (Schedule 8).
The current reporting threshold is all transmission facilities with a capacity of 230 kilovolts (kV)
or greater. The new threshold would be 100 kV and greater.
Under EIA's original proposal to OMB, the new reporting thresholds for Schedules 5, 6, and 8
would be effective in 2011. In the case of Schedule 7, the change in the reporting threshold
would be delayed until 2014 for alternating current (AC) facilities (which constitute the vast
majority of the transmission system) to give respondents time to update their data collection
and reporting systems. The change would be effective in 2011 for the small direct current (DC)
component of the transmission system.
EIA Response: EIA recommends no change to its current proposal, with the one exception noted
below. The information in Schedules 5 through 8 is needed to characterize the national
transmission system and measure its reliability. Lowering the threshold to 100 kV as proposed
by EIA will bring the data collection into line with current regulatory trends and the actual
operational characteristics of the transmission system. Many key transmission facilities have
capacities lower than the current threshold of 230 kV. Indicative of this, on March 18, 2010,
FERC issued a Notice of Proposed Rulemaking, proposing to include all electric transmission
facilities 100kV and above in the definition of the IIbulk electric system" over which FERC
exercises reliability oversight. Also note that utilities filing the annual Form 1 report with FERC
routinely identify as "necessary for wholesale transmission service" facilities with capacities
below 230 kV and in some cases as low as 69 kV.
Transmission maps, power flow cases, and data on existing and planned transmission system
projects are already collected by NERC for facilities below 200 kV. No additional burden is
imposed by formalizing the submission of that data to EIA. In fact, an earlier commenter noted
that since NERC already collects transmission data at the 100 kV level, this should not pose any
extra burden to Form EIA-411 filers.
For Schedule 7 (outage data), EIA recognizes that including transmission lines from 100 to 230
kV will create additional burden on respondents because this information is not currently
included in TADS. However, many transmission facilities have capacities in that range and EIA
cannot effectively characterize the full bulk power system without gathering data on those
facilities. As already proposed to OMB, EIA is willing to delay mandatory Schedule 7 data
collection for AC facilities from 100 to 230 kV until the next forms clearance cycle. This would
allow NERC time to adjust its TADS data collection to include facilities below 230 kV.
Additionally, and as a change to its original proposal to OMB, EIA will revisit the 100 kV
threshold with stakeholders and OMB prior to 2014 if FERC decides not to adopt the 100 kV
threshold for its definition of the bulk power system. For further discussion of this point, see
EIA's response to the comments of CenterPoint Energy (below).

Comment: OMB should not approve collecting transmission outage information on the EIA-411 (Schedule
7) which is duplicative of information collection on the OE-417 survey.

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Current EIA Proposal: The OE-417 survey, the "Electric Emergency Incident and Disturbance
Report," collects data on major outages and other power system disturbances. The report is
made to DOE's Office of Electricity Delivery and Energy Reliability (OE) within 1 to 6 hours of
occurrence, depending on the type of incident, with a final report due to OE within 48 hours.
(OE routinely forwards data received on the OE-417 to EIA.) In contrast to this emergency
information, Schedule 7 of the EIA-411 would collect information on both routine and
emergency situations, using a different set of criteria (consistent with NERC's TADS system) than
the OE-417.
EIA Response: EIA recommends no change to its current proposal. The Form OE-417 serves a
very different purpose, and covers a very different dataset, than Schedule 7 of the Form EIA411:
•

•

The OE-417 survey functions as a real-time notification to the Federal Government of
electric emergencies, incidents, and disturbances, including ongoing updates until the
incident has been resolved. Additionally, Form OE-417 is a regulatory requirement that
obligates all respondents to provide information to DOE on an individually identifiable
basis.
In contrast, the Form EIA-411 is a statistical report that collects topically similar
information, but at a different level of detail, and which covers the electric power
industry at the regional and subregional levels. NERC completes Schedule 7 primarily by
using its TADS database on transmission outages.

EEl's proposal would, in effect, require NERC to remove the OE-417 incident data from the
standard TADS database before NERC completes Schedule 7. This would increase the
respondent burden on NERC. Moreover, to create a complete national picture, EIA would then
have to reintroduce the OE-417 data into the TADS data provided by NERC; this would be
cumbersome and inefficient.

Comment: OMB should not approve duplicative reporting of green pricing and net metering data in the
EIA-826 and EIA-861 surveys.

Current EIA Proposal: The EIA-826 survey collects data on a electric power sales, revenues, and
related topics from a sample of electric utilities and other market entities. The EIA-861 collects
annual data from the firms in the sample plus the rest of the universe of respondents. Both
surveys, as proposed, will collect information on green pricing and net metering activities.
EIA Response: EIA recognizes EEl's concern with duplicative reporting and recommends the
following revised approach.
EIA has historically found that when EIA-826 monthly respondents re-submit sales and revenue
data on the EIA-861 annual collection there are often significant revisions. Because the
collection of monthly green pricing and net metering data on the EIA-826 will be new for 2011,
EIA does not know whether or not similar revisions will occur with this data. Accordingly, when
the revised surveys are launched in 2011, EIA proposes to collect the green pricing and net
metering data on both surveys. If there are no significant differences between the green pricing
and net metering data collected on the monthly and annual surveys EIA will cease the annual
collection of this information for the monthly respondents. (We will not be able to complete
this comparison until mid-2012 due to differences in the reporting cycles for the EIA-826 and

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EIA-861 surveys.) Otherwise EIA will continue to collect these data on the monthly and annual
forms.

Comment: OMB should not approve EIA's proposal to collect energy displaced by net metered customers
on the EIA-826 and EIA-861 surveys.

Current EIA Proposal: The data item at issue essentially asks the responding utility to provide
the amount of electricity generated by the net metered facility (for example, solar panels on a
reside nce )-.
EIA Response: EIA recognizes EEl's concern with the feasibility of respondents providing this
data and recommends the following revised approach.
EEl's comment is well-founded because many net metered facilities, especially small ones, do
not have the dual metering or advanced metering infrastructure (AMI, or {{smart meters"}
needed to collect the generation from the facility. EIA's revised proposal is:
Rather than requesting displaced energy, the forms will be changed to request the
amount of electricity sold by the net metered facility back to the utility when such
information is available (Le., the respondents who do not have these data will not be
asked to develop new estimates to respond to this question). We believe that utilities
are more likely to have this information than displaced energy.
2. This and the other net metered data will be requested only for facilities of 2 megawatt
(MW) capacity and less, in order to focus the questions on small-scale self-generation.
Other EIA surveys collect data on large-scale self-generation, such as industrial
combined heat and power (CHP) plants.
3. We intend to review the categories of generation technologies used to collect netmetering data. For example, the currently proposed "CHP/Cogen" and "Biomass"
categories overlap and need to be restated. We may also want to add "Wind" as a
technology that is used fairly often in net metering applications.
1.

The areas of net metering, green pricing, and other aspects of distributed and renewable
generation are rapidly changing. EIA intends to conduct a thorough review of these topics and
will propose changes as appropriate for the surveys for the next survey clearance cycle.
Impact on Respondent Burden of EIA's Recommended Responses to EEl's Comments: We believe that
our recommended responses will cause no measurable increase in respondent burden and may in fact
reduce burden. The change from collecting displaced energy to collecting energy sold by net metered
systems (only when the information is available) may reduce respondent burden. If we are able to cease
collecting net metering and green pricing information on the monthly forms the result will certainly be
a reduction in burden from our original estimate for this clearance.

Comments from CEE and EIA Response
CEE provides a set of general comments ("Comment 1") which cover in brief the same ground as its
more detailed comments. The following discussion addresses the detailed comments. The CEE
comments are all on the EIA-861 survey, primarily Schedule 6 ("Demand-Side Management
Information") and its instructions.
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CEE Comment 2: EIA should define the term "DSM Program Manager" and use the term consistently.

Current EIA Proposal: "DSM Program Manager" is a new term used for the first time in the 2011
survey. The term refers to non-utility providers of DSM programs.
EIA Response: EIA agrees with the comment and will modify the instructions accordingly.

CEE Comment 3: The collection of commercial and industrial information on the actual effects of DSM
programs (Schedule 6A) should be merged into a single category. This is because "program
administrators commonly have difficulty separating out the costs and savings of commercial and
industrial programs./I

Current EtA Proposal: The current proposal continues the long-standing practice of collecting
these data on the EIA-861 by utility customer class: Residentiat Commercial, Industrial, and
Transportation.
EIA Response: EIA recommends no change to its current proposal. DSM data have been

collected and reported in these categories for many years. The categories are standard for use
within the utility industry and by State utility regulators, and have been adopted by (not created
by) EIA. Although there is admittedly some gray area between large commercial and small
industrial establishments, these sectors primarily consist of establishments which can be clearly
differentiated (e.g., a shopping center is clearly commercial and a refinery is industrial).
Merging the industrial and commercial categories would unnecessarily eliminate data that
policy makers and analysts need to be able to distinguish how DSM programs impact each
customer class.

CEE Comment 4: Rename the header for Schedule 6A from "Actual Effects" to "Energy Savings./I CEE
believes the term "actual effects 1/ is vague and misleading in respect to the reliability of the reported
data.
EIA Response: EIA recommends no chqnge to its current proposal. The current heading has

been used for many years without causing any apparent problems with data collection. If
anything, changing the heading may create unnecessary ambiguity for some respondents.

CEE Comments 5 and 6:
•
•

"Incremental effectsl/ and "annual effects 1/ should be defined as net savings and a definition of "net
savings" added to the instructions. (CEE "Comment 5/1)
EIA should add a question specifying whether the savings reported are net or gross, and a definition
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of gross savings should be added to the instructions. (CEE "Comment 6 )

Current EtA Proposal: The instructions (page 10) as proposed, and used in past surveys, provide
detailed guidance on how respondents should answer the questions. Net effects are explicitly
referenced in the instructions as written.
EIA Response: We believe the current instructions already adequately describe the information

requested, and by accepting another CEE recommendation (see "Comment 8") the instructions
will be improved. Moreover, the definitions suggested by CEE could add ambiguity to the

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instructions rather than clarity; for example, the CEE-proposed definition of net savings includes
terms (such as lithe total change in load") which could be interpreted as an element of gross
savings.

CEE Comment 7: Add a question to the survey that will specify whether the data provided on energy
savings are based on a forecast or on the report of one or more evaluators; delete the part of question
78 that asks for the name of independent evaluators.
Current EIA Proposal: The survey as proposed asks whether savings estimates were verified by
an independent evaluator, but does not directly address the issue of how the savings were
estimated (Schedule 6A, question 7b). As noted above, when an independent evaluation has
been performed the survey requests the name of the evaluator.
EIA Response: We agree that the survey should better differentiate the type of savings
estimates provided. We will add an appropriate question, although the format may differ from
that specifically suggested by CEE. (We believe the terminology suggested by CEE, referring to
"ex-ante" and "ex-post" evaluations, may be unclear to some respondents.) We also agree that
the part of question 7b requesting the name of evaluation company can be deleted.

CEE Comment 8: The description of "Incremental Effects" in the instructions (page 10) contains a
typographical error and can otherwise be simplified.
EIA Response: We will adopt CEE's alternative language, which improves the readability of the
instructions. The new language also fixes the typographical error.

CEE Comment 9: Respondents should be instructed to use annualized incremental effects when
calculating "Annual Effects.
/I

Current EIA Proposal: Schedule 6A collects data on the "Incremental Effects" and "Annual
Effects" of DSM programs. "Incremental Effects" are the effects caused by new programs or
new participants in existing programs. These effects are to be annualized; for example, if a
program began in July, the savings should be annualized as though the program began on
January 1 and continued for the entire year. The incremental effects are therefore an estimate

of how programs would have performed if they existed and had a full complement of
participants for the full calendar year.
The IlAnnual Effects" are to be computed without an annualization of part-year programs and
participants. This data item is intended to represent the actual impact of programs during a

calendar year.

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EIA Response: EIA recommends no change to its current proposal. The CEE proposal would
direct respondents to include the hypothetical annualized incremental effects of DSM in the
"Annual Effects" calculation. This change would convert the Annual Effects value from an
estimate of the actual impact from DSM programs in a calendar year to an amalgam of actual
and hypothetical values. This is not the intent of the question, and would deprive policy makers
and analysts of estimates of the real (rather than hypothetical) impact of DSM programs.

CEE Comment 10: Respondents should be directed in the EIA-861 instructions to the definitions of actual
and potential peak reduction in the EIA Glossary.
EIA Response: We will make this change to the instructions.

CEE "Other N Comment: EIA directs respondents to leave numeric data fields blank to indicate that the
field is Unot applicable" to the respondent. This is potentially ambiguous, and respondents should be
directed to make an entry (e.g., "NAH) that clearly indicates that a question is not applicable.
EIA Response: Although EIA agrees with the comment, implementation will require changes to
both the instructions and the Internet Data Collection system used by over 90 percent of EIA861 respondents. A change may not be simple to implement because introducing a text
response to a numeric data field can cause data processing problems, both for EIA and for
outside analysts who use the data. If we cannot implement a solution in time for the 2011
launch of the survey we will do so by the time the survey is released in 2012.

Impact on Respondent Burden of EIA's Recommended Responses to CEE's Comments: We believe that
our recommended responses will cause no measurable increase in respondent burden and may in fact
reduce burden. Three recommended responses are aimed at clarifying instructions. The question we
recommend adding - asking whether energy savings estimates are based on a forecast or an
independent evaluation-requires no quantitative research or analysis by the respondent, and the
information should be readily available to the staff that completes the surveys. Replacing blanks as an
indication that a question is "not applicable" may reduce clarifying call-backs from survey staff to
respondents.

Comments from USGS and EIA Response
As discussed below, EIA concurs with most of the comments made by USGS. In the following discussion
we have addressed in detail only those comments where we are recommending an approach different
from that of USGS.

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USGS
Comment No.
lo

2.

3.

5.

6.

7.

Summary of Comment
Respondents should be asked to specify the names
of the source and receiving sources of cooling
water when these are different (EIA-860 Schedule
6, Part F/ line Sa).
The term "Reclaimed Water (ex: treated
wastewater effluentY' should be changed to
alternative language proposed by USGS (EIA-860
Schedule 6/ Part F, line Sc).
USGS Comment 3: The note above the table on the
form is different from the note in the instructions.
Both should indicate that combined cycle plants
and nuclear plants of greater than 100 MW
nameplate capacity are included in the
requirement to report cooling system data. (EIA923/ Schedule 8 Part 0, Table of Cooling system
information, annual operations).
Add a feature to the cooling system annual
operations table to explicitly assign plant-level data
to the plant 10 (EIA-923, Schedule 8 Part 0/ Cooling
System 1.0).
"Average annual rate ll needs an explicit definition
for consistency of reporting, especially for plants
which do not withdraw water all year {Form 923,
Schedule 8, Part 0, Average Annual Rate of Cooling
Water}.
Change from collection of annual averages for
cooling water rates and temperatures to collection
of monthly data annually (Form 923, Schedule 8/
Part 0, Average Annual Rate of Cooling Water and
Maximum Cooling Water Temperature at Intake
and Outlet}.

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EIA Response
We concur with this change.

We concur with this change.

We concur with this change.

We concur with this change.

This issue is obviated by EIA's
agreement to collect monthly
detail (see response to Comment
7, immediately below).
We will make this change (i.e., as
part of the annual data
collection we will collect data for
each month rather than the
annual averages). We will also
collect the number of hours each
month a cooling system
operates, so that rates can
stated either in terms of total
hours in a month or operating
hours in a month.

USGS Comment 4 and Last Part of Comment 8: EIA should require the respondent to indicate whether a
reported cooling water flow rate or temperature is measured, estimated, or a mix. (EIA-923, Schedule

80)
EIA Response: Requesting whether every data element is measured or estimated would be
cumbersome to implement and burdensome on respondents. For example, if a power plant has
2 cooling systems (multiple systems at a plant are common) the respondent would have to make
this indication for 16 data entries. Also, adding multiple estimation indicators would complicate
the Internet Data Collection system response screen, perhaps to the point of confusion.
Our proposal is to ask whether the data was measured, estimated, or a mix for the cooling water
flow rates measurements as a block (encompassing four data entries per cooling system). We
would use the same approach for the block of water temperatures measurements (again
encompassing four data entries per cooling system). For a plant with 2 cooling systems, this
would reduce the number of measurement indicators from 16 to 4.
We will also ask the respondent to specify the type of measurement approach used. We will
contact USGS for a list of options.

USGS Comment 8: This comment has three parts, all of which apply to Form EIA-923, Schedule 8D:
•

Rep/ace the collection of seasonal peak intake and outlet water temperatures with monthly
average temperatures.

•

Request respondents to specify the pOints at which water temperatures are taken.

•

Respondents should be directed to indicate whether temperatures are measured or estimated.

EIA Response: With respect to the type of temperature data collected, we will either replace the
peak temperatures with monthly averages or ask for both monthly peaks and averages. (We are
currently trying to determine whether other respondents would want us to retain the peak
temperature information.)
In respect to requesting measurement points, we recommend rejecting this addition to the
survey. We believe it would be burdensome to respondents; that responses would likely be
inconsistent; it would be difficult for EIA to provide consistent guidance to respondents; and we
would have no effective way to edit the responses.
In respect to requesting whether temperatures are measured or estimated, see the response
above to USGS Comment 4.

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Impact on Respondent Burden of EIA's Recommended Responses to USGS Comments: We believe that
our recommended responses to the comments of USGS may cause a small increase in respondent
burden, on the order of 1 hour per typical respondent to the EIA-923 survey, Schedule 80. This increase
is attributable to: The recommendation that respondents be required to determine and specify whether
cooling water flow rates and temperatures are measured or estimated; the requirement to specify both
the source and receiving bodies for cooling water; the data entry time for providing monthly rather than
annual data; and the possible requirement that respondents provide both peak and average
temperatures rather than just one or the other.
As shown in Table 3 of the Supporting Statement for this clearance, 1,360 respondents are expected to
reply to Schedules 6, 7, and 8 of the EIA-923 survey. The original burden estimate for these schedules
assumed 3.4 hours per response for a total of 4,624 hours. If the burden increases by 1 hour per
respondent (i.e., by 1,360 hours) the new total for these schedules will be 5,984 hours. The total burden
hours for all surveys will increase from 145,429 hours to 146,789 (an increase of 0.9 percent).

Comments from CenterPoint Energy and

Response

Summary of CenterPoint Energy's Comments: CenterPoint's comments focus on differences between
the transmission systems outage data collected on Schedule 7 of the EIA-411 survey and the NERC TAOS
system for collecting transmission outage data. These differences are:
..

Inconsistencies between TAOS instructions and definitions and the instructions for the EIA-411
survey.

..

The EIA-411 collects information on planned ("non-automatic") and unplanned ("automatic")
transmission system outages. TAOS regularly collects data on automatic outages and is
temporarily collecting data on non-automatic outages. TAOS data collection on non-automatic
outages is scheduled for re-evaluation by NERC in 2015.

..

As discussed above, beginning in 2011 the EIA-411 survey will collect outage data for DC
transmission facilities down to 100 kV, and the same threshold will apply to AC transmission
facilities beginning in 2014. TAOS collects data for facilities 200 kV and higher.

CenterPoint recommends that EIA either eliminate Schedule 7 altogether from the EIA-411 survey and
rely on data provided by the TAOS system, or modify Schedule 7 so it more precisely matches TAOS.
CenterPoint also recommends that EIA not collect information on non-automatic outages until NERC
decides in 2015 whether or not to permanently add this information to TAOS. CenterPoint also objects
to reducing the collection threshold to 100 kV.
EtA Response: The purpose of the EIA-411, Schedule 7, is to collect critical data on the reliability

of the nation's transmission system. We have attempted to the extent possible to synchronize
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the EIA-411 with the TAOS system, but in two important respects, as noted by CenterPoint, the
EIA-411 and TAOS differ. First, EIA believes it is essential to collect information on "nonautomatic" transmission outages, such as planned outages for scheduled maintenance. This
information is necessary to develop a complete picture of the availability of transmission lines
and is also one indicator of the effort needed to keep the system operational.
Second, we believe that extending the collection of data down to the 100 kV threshold is
necessary to encompass elements of the grid essential to the operation of the bulk power
system. EIA recognizes this will create additional burden for the respondents who operate the
large AC system, and we have therefore recommended delaying implementation of this part of
the data collection until 2014 so that respondents can upgrade their data reporting systems.
Accordingly, EIA believes it would be imprudent to either eliminate Schedule 7 or rely entirely
on the current version of TAOS for reliability data. We do recommend to OMB the following
changes to EIA's proposal in response to CenterPoint's comments:
•

EIA will modify the instructions to the EIA-411 to eliminate all material differences with
the TAOS instructions and definitions. This may also involve some minor changes to the
survey form. These steps will facilitate directly translating data for the TAOS data
system into a response to the EIA-411.

•

EIA's proposal to collect data on the AC system down to 100 kV is predicated in part on
FERC's recent indication that it will use this threshold to define what constitutes the
bulk power system (i.e., the part of the transmission system over which FERC exercises
Federal reliability oversight). However, FERC has not made a final decision on this
threshold. EIA will therefore monitor FERC's decision making, and if FERC decides on a
different threshold (or a different method altogether for defining the bulk power
systemL EIA will revisit with stakeholders and OMB the 100 kV threshold prior to 2014.

These changes would have no measurable impact on respondent burden.

Other EIA Recommendations
As discussed at our August 18, 2010 meeting, there are two additional changes EIA recommends be
made to the surveys. These are discussed below.
Require Respondents to Provide the Regional Transmission Organization (RTO) Membership of Power
Plants and Power Sales Entities: We received a request to add this data element during the first round
of comments. The question would be added to the EIA-860 (power plants) and EIA-861 (power sales
entities) surveys. We initially rejected this suggestion. However, after further review we believe RTO
affiliation information should be added to the surveys due to the growing importance of RTOs in the
operation of transmission systems (a reliability issue) and in establishing wholesale power prices.
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The additional burden on respondents should be minimal. Respondents will typically know which if any
RTO their organization belongs. Moreover, because RTOs have known geographic footprints we can
restrict the choices available to the respondent through the Internet Data Collection system. For
example, in States where no RTO operates the system will have a pre-loaded response of "none." In
many other States only or three two responses are possible and these will be the only choices available
to the respondent. For example, in New Jersey the only possible responses are "none" and "PJM
Interconnection."
If approved, this new data item would be added to EIA-860 Schedule 2 and EIA-861 Schedule 2A.

Require Respondents to Provide the Planned Capacity of Repowered Generating Units: Generating
units are sometimes "repowered" by replacing major equipment, such as the combustion system, with
new equipment. Repowering projects are rare but do occur. The EIA-860 asks for data on these
projects. However, due to an oversight, the proposed survey does not request the megawatt capacity of
a repowered unit. This is an important piece of information and we recommend adding it to the survey.
There should be no increase in burden to the respondent since this information should be immediately
available to the staff that prepares the response.
If approved, this data item would be added to EIA-860 Schedule 3B, line 17d.
If you have any questions or need more information please contact either me ([email protected] or
202-586-5114) or Jason Worrall ([email protected] or 202-586-6075).

Sincerely,

Stan Kaplan
Director, Electric Power Division
U.S. Energy Information Administration

cc:

Scott Sitzer, Dean Fennell, Jim Diefenderfer,
Glenn McGrath, Jason Worrall, Renee Miller

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