March 27, 2007
Susan Hudson, Clerk
Vermont Public Service Board
120 State St.
Montpelier, VT 05620
RE: EEU Participation in the Forward Capacity Market
Dear Ms. Hudson:
Conservation Law Foundation (CLF) and Vermont Public Interest Research Group
(VPIRG) continue to support Efficiency Vermont participating in the Forward Capacity
Market (FCM) and using any funds collected from the FCM to acquire additional energy
efficiency resources.
On October 24, 2006, CLF and VPIRG submitted comments with these recommendations
to the Public Service Board (Board) (see attached comments). These comments
addressed Efficiency Vermont’s participation in the FCM and were not limited only to
the transition period. Kindly accept these comments for consideration of the EEU’s
participation in the FCM.
Efficiency Vermont should participate in the FCM
For the reasons outlined in the comments submitted in October, Efficiency Vermont
should continue to participate in the FCM. It is the logical entity to bid capacity acquired
from the efficiency measures it puts in place. This is true for the transition period, as
well as for the first and later auctions. Efficiency Vermont’s participation in the FCM
during the transition period demonstrates its ability and suitability to continue this work.
Funds collected should be used to acquire additional efficiency resources
Funds collected from the FCM by Efficiency Vermont should be used for additional
efficiency measures. As noted in the October 24 comments, the Board recognized in its
EEU budget order that an even higher level of funding is justified and would still acquire
available and cost effective energy efficiency measures. The Board declined to order a
higher increase until it reviewed the possibility for other funding mechanisms, such as
amortization, that would reduce the rate impact. Capacity payments received from
participation in the FCM are a funding source with no additional rate impact. They
should offset any limited administrative costs for participation, and then be used to fund
additional efficiency measures. These funds are paid by ratepayers for energy efficiency
and should be used to continue and expand efficiency efforts. This keeps these funds
working to meet growing demand with low cost efficiency, reduce pollution and
greenhouse gas emissions and keep Vermont’s energy costs as low as possible.
Thank you for your consideration of these comments.
Sincerely,
Sandra Levine
Conservation Law Foundation
James Moore
Vermont Public Interest Research Group