August 2, 2002

William F. Stephens Director, Division of Energy Regulation State Corporation Commission P. O. Box 1197 Richmond, Virginia 23218-1197

Dear Mr. Stephens:

In response to your letter dated July 22, 2002, soliciting feedback as to whether the data detailed in “Senate Bill 684” is currently reported to other agencies or organizations, enclosed are the comments of Old Dominion Electric Cooperative and the Virginia, Maryland and Delaware Association of Electric Cooperatives (the “Cooperatives”). The Cooperatives appreciate the opportunity to provide this input.

The information described in §1A of the legislation request the following electric generation data for the period commencing January 1, 1996 and ending December 31, 2001:

A. An inventory of generating units located within the control area of the utility, including size, location, fuel type, heat rates, and megawatts of each unit;

B. The historical generating capabilities of each unit compared to actual operating parameters, including hours a unit was offline reasons therefore, forced and planned curtailment levels, and hourly generation by unit, and

C. Total hourly load in the control area compared to the total hourly load in Virginia.

RESPONSE: Old Dominion Electric Cooperative co-owns generating facilities located within the Commonwealth. Under the existing facility operating agreements with Dominion Virginia Power, the co-owner, Dominion Virginia Power files on behalf of Old Dominion such data as requested in A, B, and C with several federal agencies including Federal Energy Regulatory Commission (FERC), Securities and Exchange Commission (SEC), and the Department of Energy (DOE).

The following information is filed with the FERC:

1. Assets including proposed peaking units 2. Financials 3. Market Power purchases agreements 4. In-service electric plant statistics including type, installed capacity, net generation, total cost and expenses, fuel type, production and allowances. 5. Environmental pollution control devises, allowances, credits and associated cost. 2

The following information is currently filed with the SEC: 3

1. Financials 2. Type of generation units 3. Generation mega-watt hours for in-service facilities. 4. Power purchase contracts 5. Operating revenues and expenses 6. Power sales to members

The following data includes in-service and planned facilities and is currently filed with DOE: 1. Type of co-generator 2. Planned effective date for any projects 3. Ownership information 4. Prime- mover 5. Fuel Type 6. Summer and winter rates when on line 7. Capacity

Once filed with the above commissions and agencies, all reported data is available to the public. All reports currently filed will continue.

Section 1B of the legislation request the following electric transmission data:

A. Individual line transfer capabilities at control area interfaces;

B. Aggregate transfer capabilities, including the degree to which the capabilities were reserved and the actual use of such capabilities.

C. Hours during which bulk transmission facilities offline and the reasons therefore;

D. Hourly flows into and out of the control areas

RESPONSE: At this time, none of the 13 utility consumer services cooperatives serving members in Virginia own any transmission facilities. The cooperatives are considered transmission dependent utilities (“TDU”) and as such do not record or have access to the types of data requested. This type of information is routinely provided by those utilities owning transmission in the Commonwealth.

Sections 1C and D are not applicable to the Cooperatives. None of the Cooperatives own gas transmission nor are they authorized to furnish natural gas service in Virginia.

The Cooperatives appreciate this opportunity to provide the requested input and look forward to continuing the process of effectively responding to the mandates of “Senate Bill 684”.

Sincerely,

Anita G. Lester Governmental Affairs Coordinator