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completed changes to our largest oil-fired generating unit,

Brayton Point Unit No. 4, to enable it to burn natural gas. The changes include new high-efficiency low NO, burners. The gas conversion will result in significantly lower sulfur dioxide,

nitrogen oxides, and carbon dioxide emissions.

10% improvement will come from using non-utility generation predominantly fired by natural gas.

9% improvement will come from repowering our Manchester Street Station. We are replacing old oil-fired boilers with higher capacity, highly efficient natural gas-fired combined-cycle units. This project, expected to be in service in 1995, is an example of where capacity can be increased while decreasing most emissions.

6% improvement will come from new energy sources, including purchases of hydroelectric energy from Hydro-Quebec and repowering one of our existing hydroelectric_stations.

4% will come from continuing our conservation and load management programs. This will eliminate the need for about 850 MW of new generation and its air emissions.

Finally 5% will come from additional programs. For example, we are actively pursuing new initiatives to purchase generation from low or non-emitting renewable resources and to acquire emissions offsets for greenhouse gases and other air emissions.

With respect to limiting or reducing greenhouse gas emissions, all of the above programs play a role. Every Btu of natural gas that displaces residual oil reduces carbon dioxide emissions by about 29%. Every kWh of electricity

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produced by combined-cycle generation, rather than by a conventional boiler, reduces carbon dioxide emission by at least 15%. Every kWh generated by hydro rather than fossil-fuel reduces carbon dioxide emissions by 100%. Every kWh "saved" by conservation reduces carbon dioxide by 100%, assuming a fossil-fuel unit would have otherwise generated the energy.

Despite the first four types of improvements described above, little actual carbon dioxide tonnage reduction would likely occur because, as mentioned previously, our customers' total energy requirements are still projected to be 14% higher by the year 2000. Therefore, as part of NEESPLAN 3, we have included two innovative initiatives, dealing with renewable resources and emissions offsets, that I will now describe in more detail.

The "Green RFP" Renewable Resource Initiative

"Renewable resource" technologies are methods of generating electricity without consuming fossil fuel. We recently issued a Request for Proposal (RFP) to purchase up to 200,000,000 kWh annually (equivalent to about 40 megawatts of capacity) of energy from new low or non-emitting sources. The solicitation has come to be known as the "Green RFP."

The types of technologies that may be demonstrated in New England as a result of this solicitation include:

Advanced wind technology, reflecting improvements in durability and efficiency in recent years, and which emits no greenhouse gases.

Advanced biomass technology, which uses fast-growing wood supply as a fuel source. This produces no net increase in carbon dioxide emissions because the carbon dioxide intake

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through photosynthesis during tree growth offsets the release

of carbon dioxide when the wood is burned.

Landfill methane technology, which would combust a

greenhouse gas that is an order of magnitude more potent than carbon dioxide.10

Other improving technologies, such as solar energy and smallcapacity hydro, that emit no greenhouse gases.

There has been a substantial interest in our Green RFP. Developers of over 200 projects have expressed interest in the solicitation and may submit proposals by the April 1, 1992 due date.

The Offsets Program Initiative

"Offsets" refer to the control or counteraction of air emissions that occurs away from a particular electricity generating source. We believe that offsetting emissions may be less costly than controlling emissions at a particular source. For greenhouse gases, it makes no difference where such emissions are controlled.11

New England Electric plans to follow the recommendation of the National Academy of Sciences that utilities and others implement low-cost measures to mitigate the further buildup of greenhouse gases.

We are now developing a series of pilot programs to analyze how to offset greenhouse gases. 12 Our pilot programs, which are in various stages of development, may include:

1.

Forest Management--to enhance carbon dioxide "absorption" by supporting vegetation growth and improved forest management practices.

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2.

3.

4.

Chlorofluorocarbon Recycling/Reprocessing--to capture another gas that has been linked to global warming,13 by collecting old refrigerators and freezers from our customers and safely handling the CFC's and other waste products.

Methane Recovery at Coal Mines--to enhance the capture and use of methane otherwise emitted during coal mining; methane is considered to be a much more potent greenhouse gas than carbon dioxide, as previously mentioned.

Coal Ash Utilization for Cement--to recycle coal ash as a replacement raw material for cement, reducing carbon dioxide emissions that would otherwise occur."

5.

Marine Algae Fertilization--to enhance research on the concept

of stimulating carbon dioxide absorption in the oceans, which theoretically could absorb mega-tons of carbon dioxide.

The Environmental Collaborative will help us to evaluate proposals in those areas and we will also be exploring offsets for other air emissions, such as nitrogen oxides. We are also developing a pilot program to convert some of our gasoline fleet vehicles to also be able to use cleaner burning compressed natural gas.

Observations and Recommendations

The development of NEESPLAN 3 has yielded a number of observations that may be relevant to today's hearing:

1.

Greenhouse Gas Control Programs Must Be Combined with
Other Important Objectives

For example, in NEESPLAN 3, we have coupled an ambitious environmental goal with both a cost-control goal and

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an energy supply goal. We believe all three can be achieved,

and that focusing only on the environmental goal would be selfdefeating.

2.

Title XI of H.R.776 Is An Excellent Approach for Dealing with
Greenhouse Gases at This Time

We support Title XI, Greenhouse Warming of H.R.776, the proposed Comprehensive National Energy Policy Act. In particular, we support:

Section 1103, which requires the Secretary of Energy to inventory opportunities to expand and improve the efficiency of energy production and use. We believe one opportunity is to substitute electrotechnologies for fossil fuel technologies. Electrotechnologies such as electric-powered transportation and heat pumps can sometimes improve overall energy efficiency and reduce net carbon dioxide emissions.15

Section 1104, which requires an assessment of policies for reducing greenhouse gas emissions. These assessments track in many respects the evaluation criteria in our NEESPLAN 3 offsets pilot programs.

Section 1105, which establishes an accounting system for voluntary reductions of greenhouse gases, including in other countries. We would certainly want to receive credit for reductions due to our NEESPLAN 3 programs.