The
UNIVERSITY
of VERMONT
J. Michael Gower
Vice President for Finance & Administration
and University Treasurer
May 17, 2006
Ms. Susan M. Hudson, Clerk
Vermont Public Service Board
Chittenden Bank Building, Fourth Floor
112 State Street, Drawer 20
Montpelier, Vermont 05620
Re:
Establishment of the Energy Efficiency Utility Budget and Resulting Energy Efficiency
Charge
Dear Ms. Hudson:
The University of Vermont (the “University”) submits the following comments on the
policies to guide the Public Service Board (the “Board”) in the establishment of a budget for the
Energy Efficiency Utility (the “EEU”) and attendant Energy Efficiency Charge (“EEC”).
As the Board is aware, many Vermont electric utility customers are experiencing rapid
increases in their cost for energy, including electricity and fuels. These increases are significant,
and are placing substantial economic strain on the ability of the University to meet its energy
needs. Against this backdrop, the University supports strategic investments in conservation and
efficiency when the investments reduce costs over the long-term. Similarly, the University
believes that Vermont needs to consider new electrical generation sources, including combined
heat and power (“CHP”) projects as an energy efficient strategy.
However, ongoing planning efforts to implement the energy policy goals of Act 61 have
not been comprehensive enough. For example, issues associated with the development of CHP
projects have stalled, as have strategies to target conservation efforts towards those locations
where they would be most beneficial. There has been little consideration of an exemption from
the EEC as an incentive for customers, especially institutional and commercial customers, to
make significant investments in energy efficiency. Moreover, the University understands that the
Vermont Department of Public Service (the “DPS”) has recently filed new avoided costs to be
used by the EEU in the delivery of system-wide demand side management programs, and that
these avoided costs have yet to be approved by the Board for such purposes.
In prior submissions, the University has suggested ways to integrate energy efficiency
implementation, including CHP, into the work of the EEU and the delivery of conservation
services by the Burlington Electric Department. The University believes that the integration of
these energy efficiency strategies into the utility planning process needs more development
348 Waterman Building, 85 So. Prospect Street, Burlington, VT 05405-0160
Telephone: (802) 656-0219, Fax: (802) 656-1363
Equal Opportunity / Affirmative Action Employer
before commentators can provide meaningful input on the budget for the EEU and resulting
EEC.
In summary, the University hopes that the DPS’s recommendation on the EEU budget
will address the need for an overall strategy on energy efficiency, including alternative energy
generation sources and geographically-targeted efficiency efforts as described in these comments.
The University also hopes that the Board will resolve the issues associated with CHP
development and a customer EEC exemption at the same time that it considers the EEU budget.
Given the high and rising cost of energy, customers need to understand how all parts of the
process of planning and acquiring electric supplies are being integrated to ensure that the results
are providing electric service at least-cost as contemplated under 30 V.S.A. § 218c. The
University believes that more planning work needs to be done before the Board can make the
necessary determination on the EEU budget and the EEC.
The University appreciates the opportunity to comment and thanks the Board for its
efforts to pursue this issue collaboratively. If you have questions concerning this submission,
please do not hesitate to contact me.
Respectfully submitted,
J. Michael Gower
Vice President for Finance and Administration
and University Treasurer
cc:
Act 61 Service List
348 Waterman Building, 85 So. Prospect Street, Burlington, VT 05405-0160
Telephone: (802) 656-0219, Fax: (802) 656-1363
Equal Opportunity / Affirmative Action Employer