Promoting Electrotechnology Careers and Public Policy

February 27, 1998

The Honorable Robert W. Gee,
Assistant Secretary,
Office of Policy and International Affairs
Room 7C-016
Forrestall Building
1000 Independence Ave.
Washington, DC

Dear Secretary Gee,

This letter is an initial response by IEEE-USA Energy Policy Committee and its parent Technology Policy Council to the request for public comment on the recent draft DOE National Energy Strategy.

Before relating our brief initial comments, we wish to congratulate you and DOE on your appointment. We are aware of your accomplishments at the Texas Commission and your leadership in NARUC. DOE needs seasoned and experienced experts in senior positions and we are pleased that you have decided to join the DOE.

IEEE-USA represents nearly a quarter-of-a-million electrical engineers and computer scientists in the United States. The Energy Policy Committee was formed in part as a response to the energy crisis in the early 1970's. With the price of gasoline at record lows in real dollars, with the expanded production and the low cost of natural gas, and with the recent decline in the average price of electricity, we are extremely aware of the loss of public interest and political focus on current important energy issues.

Yet the vulnerability of the USA to new energy price shock has not disappeared. With the evolving restructuring of the electricity industry, local, regional and national vulnerability to the reliability and quality of electric service is at an all time high.

Not since the blackout of 1965 have we seen an event of the magnitude of the western blackouts that occurred in the summer of 1996. During the five to fifteen year period that will be required to transition the Nation's electricity enterprise to an open and competitive marketplace, there will be a real risk to the American economy as a result of a possible degradation in power quality and because of local and system-wide insecurity and unreliability issues.

The draft speaks directly to these issues. Yet the Department of Energy faces serious internal challenges as documented in recent national reviews such as the Yergin report. As a consequence, DOE is not in a position to efficiently address underlying and fundamental challenges to the security, reliability, quality and economic efficiency of the marketplace for and the physical system that generates, delivers and uses electricity.

The Energy Policy Act of 1992, a monumental bi-partisan undertaking, has been successful at encouraging wholesale market competition. Yet there is a body of opinion that points to the shift from an obligation to serve to an opportunity to profit as the fundamental cause of the western blackouts of 1996.

The strategy speaks to the intent of DOE to address the underlying obstacles to restructuring and nurture innovation, especially through private sector partnerships. Yet the reality is that DOE has stripped itself of essential expertise in these areas both at Headquarters and at the Laboratories. The Yergin report documents flaws in the management, excessive overheads, inadequate peer review and a near absence of practical industry oversight in critical areas critical to the electricity restructuring effort.

These comments by the national review of DOE are confirmed by the elimination of any budget in power systems T&D research at DOE more than two years ago. Further, the Power Marketing Authorities have also lost much of their technical talent in an effort to be come more competitive.

As the professional society responsible for standards and education in power as well as the publication of peer reviewed literature relevant to the diverse issues of the multi-national North American Power System, we are extremely concerned by the precipitous rush to retail access by the states, the inability of DOE to adequately address the technical issues and the absence of significant non-partisan expertise on this subject of electric utility restructuring. The consequence could prove to be actions by DOE or Congress that will lead to national legislation within the next two years which will fundamentally fail to meet the goals articulated in the draft energy strategy.

As a consequence of our study of these issues we question many specific components of the draft strategy document while generally agreeing with it's overall direction. Such a strategy will have little value if 1) It does not recognize the key tradeoffs between reliability, cost and environment and 2) It raises unrealistic expectations about the near-term contributions of new technologies and alternative energy resources. Unfortunately, the existing draft has serious weaknesses in both of these areas.

If you wish, we would be willing to elaborate on these concerns and contribute to the development of the details of the strategy. To begin to address these issues given the brevity of the response period, we submit the following attachments in addition to a list of our committee volunteers.

• A summary of an IEEE-USA Symposium on these issues from June of last year.

• The current set of position statements from IEEE-USA.

• The list of members of the IEEE-Energy Policy Committee and Technology Policy Council.

If you have any questions or need any additional information, please feel free to contact me. We look forward to assisting you and your staff in this important endeavor.

For the IEEE-USA Energy Policy Committee

Robert J. Thomas
Chairman

The Institute of Electrical and Electronics Engineers - United States of America
2001 L Street, N.W., Suite 700, Washington, DC 20036-5104
Office: (202) 785-0017 * Fax: (202) 785-0835 * E-mail: ieeeusa@ieee.org * Web: http://www.ieeeusa.org

| Top of Page | Energy Policy | Policy Log | Public Policy Forum | IEEE-USA |

Last Update: March, 1998

Staff Info Contact: Chris Brantley, c.brantley@ieee.org