Jonathan A. Aldrich 966A Mail drop 1000 River Street Essex Junction, VT 05452 May 17, 2006 Via e-mail Susan M. Hudson, Clerk Vermont Public Service Board Chittenden Bank Building, Fourth Floor 112 State Street, Drawer 20 Montpelier, Vermont 05620 Re: Act 61 EEU Budget Review and Comments Dear Ms. Hudson: This letter presents the comments of International Business Machine Corporation (IBM) on the data submitted to date on the task of setting the budget for the Energy Efficiency Utility. We recommend that the EEU budget for 2006, 2007 and 2008 should remain at its current level of $17.5M for the reasons stated in our letter dated May 3, 2006 same subject. Several parties questioned the data and the avoided cost approach. We also recommend that a workshop be scheduled to discuss avoided costs. We recommend that the Board make the EEU budget and avoided cost decisions jointly. The following are suggested Public Service Board policy directions for the EEU: 1. The Board should instruct the EEU to return 100% of the contributed dollars to the customers that participate in the C and I Customer Credit Program. Returning 100%, rather than 70%, of the dollars will maximize the benefit of the current funds that are spent directly on energy conservation projects. 2. The Board should direct the EEU to develop alternative methods to fund energy conservation projects. Programs that utilize shared savings and or performance contracting could help commercial and industrial customers fund additional energy conservation projects without burdening other rate payers. 3. The Board should appoint a special committee to evaluate the EEU business process with an eye toward ensuring that the energy savings results are maximized and optimized. Thank you for this opportunity to present our comments. Sincerely, Jonathan Aldrich Energy Manager