Let me know what you think:
 
Enron would like to compliment staff on their recommendations for the disclosure label calculations and offer one suggestion that would accommodate the purchase of clean, renewable resources.  As noted in our prior comment, we would like to reiterate the need for a methodology that recognized attribute contracts.  It is a growing practice to contract for the renewable or clean attributes of energy that have been generated onto the grid without purchasing the actual commodity power.  These attributes are typically referred to as certificates, "green tags" or "renewable energy credits".  All of these terms refer to the environmental benefits of clean power that have been generated onto the grid and may be traded, bought and sold separately from the underlying power commodity.  The ability to separate the attributes from the underlying power facilitates the ability for suppliers to offer clean renewable power in regions where it might not be conducive to site these resources.   The supplier can then pair the attributes with system power at the point of sale to Michigan customers.
 
This methodology greatly decreases the administrative reporting burden for suppliers and also provides a cost-effective form of verification for Commission staff.  Our specific recommendations for accounting for certificates are as follows. 
1. Allow suppliers to account for attribute purchases on their fuel labels by providing proper substantiation that the supplier owns the attributes.  Substantiation can be in the form of verification from an independent system operator of an attribute registry (e.g. Automated Power Exchange operating in California and the Midwest and recently awarded the contract for NePool to build their certificate based system; ERCOT) that the supplier has purchased the certificate and retired it on the behalf of the customer; a bilateral contract showing that the attributes are owned by the supplier, or any other method deemed appropriate by the Commission.
2. Suppliers can use the generation data from certificates that have been generated by independent certificate system administrators or generators to calculate the fuel type and emissions.   The certificate purchases would be weighed with other bilateral contracts and spot market purchases for purposes of calculating the label.
3.  In the event that the emissions data are not provided by the generator, suppliers will be able to use the most recent E-grid data to calculate the emissions.
 
There are several examples from other State Commissions for accounting for certificates purchases.  The following link shows the methodology that the Texas Public Utility Staff wrote for calculating labels with certificate purchases.  <http://www.puc.state.tx.us/rules/rulemake/22816/22816.cfm>
 
This modification to the label calculation will allow suppliers who are purchasing affordable clean to be delivered to the grid on behalf of their customers through certificate contracts to depict this on their fuel content label.  We appreciate your review of our comments.
 
Stacey Bolton
Environmental Strategies
Enron Corp
713-853-9916 direct 
713-303-2632 cell 
sbolton@enron.com <mailto:sbolton@enron.com>