May 17, 2006
Susan Hudson, Clerk
Public Service Board
Drawer 20, 112 State Street
Montpelier, VT 05602-2701
RE:
EEU Proposed Budget
Dear Ms. Hudson:
We are writing to reiterate our concerns about increasing the Energy Efficiency Charge and
to encourage the Board to not increase the budget for Efficiency Vermont, as expressed in
our "Comments on the Vermont Electric Energy Efficiency Potential Study" prepared by Dr.
Jonathan Lesser, dated May 3. Rather, the Board should consider alternative policy
approaches that can help increase efficiency investments without increasing the rates paid
by Vermonters, particularly commercial and industrial customers already facing increasing
energy costs and other burdens to doing business in Vermont.
Although some neighboring states are currently experiencing rates that are higher than
those in Vermont, our rates are substantially higher than much of the rest of the country. A
number of Vermont utilities are asking for rate increases, and other energy costs continue
to increase as well. This high-cost electricity environment, along with all the other high
costs to doing business here, contributes to depressed wages and job opportunities and the
continued loss of jobs and investments to other states.
In this environment, no one understands and appreciates the value of energy efficiency
more than we and our members. Nevertheless, both realizing the benefits of efficiency and
actually remaining in business are not simply a question of increasing the EEU budget and
the EEC.
Efficiency investments must be balanced with the many other investments and other needs
facing Vermont employers. Moreover, efficiency investments must be made and financed in
a truly affordable, effective, and efficient manner that does not cause undue harm to
individual businesses or the economy generally.
The fundamental fact that prudent efficiency investments can ultimately pay for themselves
presents any number of possible policy approaches that do not require increasing costs for
customers who are not in a position to make sufficient investments themselves such that
any usage reductions will offset rate surcharges.
We and our members are intimately familiar with these realities and with the economic
consequences of taking missteps in our efforts to move forward. The current budget review
process before the Board is an excellent opportunity to forgo increases in the EEC and to
begin work on alternative approaches that can better achieve the efficiency and economic
goals toward which we should all be working. This process should also recognize and
incorporate other and larger developments transforming the efficiency landscape, including
continued market transformation and even developments like the recently enacted
appliance efficiency statute.
At the very least it would be prudent for the Board to take more time to consider thoroughly
what alternatives can be developed. There is no compelling reason to make a mid-year
adjustment to the EEU budget on the timetable currently being contemplated when further
deliberations can yield a result that better balances the costs and opportunities before us.
Thank you for your consideration of these concerns and suggestions. We look forward to
the opportunity to work further with the Board and other participants as this process moves
ahead.
Sincerely,
Associated Industries of Vermont
Greater Burlington Industrial Corporation
Home Builders and Remodelers Association of Vermont
International Business Machines, Inc.
Lake Champlain Regional Chamber of Commerce
Vermont Business Roundtable
Vermont Chamber of Commerce
Vermont Grocers' Association
Vermont Retail Association
Vermont Ski Areas Association
cc:
Service List