declining natural gas supplies and the uncertainties in supply and price of petroleum. Du Pont is taking steps now to maximize its use of coal as boiler fuel where feasible. We suggest

that the comprehensive coal substitution bill addressed herein be amended to:

Cover only steam generating boilers each

having a design firing rate of at least 100MM
BTU per hour;

Establish priority categories for conversion
to coal such that the largest boilers will be
required to convert first and thereby achieve
the greatest benefit at a more economical price;
Gas boilers also should convert first if other
considerations limit the number of feasible

conversions;

Permit plants to burn coal while installing
pollution control equipment as long as primary
ambient air quality standards are being met.
More effectively distinguish between steam
generating boilers and process heaters and
waste incinerators; and

Phase in conversion to coal gradually over a

reasonable number of years.

We hope these comments prove constructive and of

value in your consideration of this bill. Thank you for this

opportunity to present our views.

While the National Electric Reliability Council has responded to certain of the 40 questions which were printed in the Congressional Record of May 20, 1975, with regard to Senate Bill 1777, "National Petroleum and Natural Gas Conservation and Coal Substitution Act of 1975," we felt there was additional information we could provide from our region that would be helpful.

We have reviewed the list of "Questions and Policy Issues" and are submitting herein information and comments on the questions we feel qualified to answer. If we can be of further assistance, please let us know.

Very truly yours,

O.A. Lenty

Owen A. Lentz
Executive Manager

OAL: jb
Enclosure

MEMBERS OF EAST CENTRAL AREA RELIABILITY COORDINATION AGREEMENT Appalachian Power Company The Cincinnati Gas & Electric Company The Cleveland Electric Illuminating Company Columbus and Southern Ohio Electric Company Consumers Power Company The Dayton Power & Light Company The Detroit Edison Company Duquesne Light Company East Kentucky Rural Electric Cooperative Indiana & Michigan Electric Company Indiana Kentucky Electric Corporation Indianapolis Fower & Light Company Kentucky Power Company Kentucky Utilities Company Louisville Gas and Electric Company Monongahela Power Company Northern Indiana Public Service Company Ohio Edison Company Ohio Power Company Ohio Valley Electric Corporation Pennsylvania Power Company - The Potomac Edison Company Public Service Company of Indiana, Inc. Southern Indiana Gas and Electric Company The Toledo Edison Company West Penn Power Company.

RESPONSES TO QUESTIONS RECORDED

IN CONGRESSIONAL RECORD OF MAY 20, 1975

RELATING TO

S. 1777, "NATIONAL PETROLEUM AND NATURAL GAS CONSERVATION
AND GAS SUBSTITUTION ACT OF 1975"

BY

EAST CENTRAL AREA RELIABILITY COUNCIL (ECAR)

The members of ECAR (see Attachment A), being engaged in the

generation, transmission, and sale of electric power and energy in the east central area of the United States, which covers all or portions of Michigan, Indiana, Ohio, Kentucky, Pennsylvania, Virginia, West Virginia, and Maryland, have established ECAR, a regional coordination council with the primary objective of reliability and adequacy of electric bulk power supply. The following comments and/or information contained in the listing of Questions and

are offered on the questions, as noted,

Policy Issues which were issued by the Public Works Committee.

Senate Bill S. 1777 uses the word "conservation" in the title.

The word "conservation" can be used in regard to programs and procedures for recycling of replaceable resources such as wood, water, and air to assure a continuing supply. "Conservation" may also be viewed as husbanding a non-replenishable resource such as we consider gas or oil, i.e., utilizing one resource for a specific purpose to reduce or eliminate the use of another resource such that the latter is available for a higher priority use and/or available for a longer time period. The word "conservation" in Senate Bill S. 1777 is undoubtedly being used in the latter context. However, as a general comment, we believe the proposed legislation is misnamed and should be retitled. We view the legislation as formulating a "national energy policy" on the use of fossil fuels. The basic need for such a policy is to establish an environment in which electric utilities can move ahead in supplying the nation's electric power needs and in which other energy suppliers and energy users can proceed with confidence.

As a nation we need to establish policies as to the best use of fossil fuel during the time period we have available to develop other energy sources and to reach decisions on use and further development of nuclear power. The elimination of the many present conflicting national policies and the establishment