VBSR Vermont Businesses for Social Responsibility 60 Lake Street Suite 3G Burlington, VT 05401 802/862-8347 www.vbsr.org 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: Energy Efficiency Utility Budget Review Dear Ms. Hudson: This letter presents the comments of some of the businesses that comprise Vermont Businesses for Social Responsibility (VBSR) regarding the Energy Efficiency Utility budget review. The comments represent the position of VBSR and are intended to provide input to assist the Board with the task of setting the budget for the Energy Efficiency Utility (EEU) over the next three years. We recommend that the Public Service Board set a budget for the energy efficiency utility that will provide for the lowest state energy bill while aggressively seeking to lower electric energy consumption in Vermont through cost effective efficiency measures. Based on analysis of bill impacts done by the Department of Public Service and CVPS, we specifically recommend that the Board adopt a budget that provides the funding set forth in scenario #5, which increases the efficiency budget to $52 million by 2008. This scenario provides the greatest bill savings as a result of reduced energy demand and is commensurate with purchasing additional power at $ 0.03 per kWh. As businesses, we are committed to socially responsible business practices and ensuring our decisions provide customers with the best service or product at the lowest cost, including environmental and social factors in that equation. In terms of cost, reducing our exposure, both as businesses and as a state, to the volatile electric market in the northeast will benefit our businesses and the health of the Vermont economy. With the pending expiration of two-thirds of Vermont’s electricity contracts in the coming decade, it is important to take action now to limit the amount of power that will need to be bought on the open market. Energy efficiency investments today provide one of the best hedges against future volatility in the electricity market. If we begin now on the projected trajectory of scenario #5a Vermonters will avoid the annual purchase of an estimated 1.7 million MWh by 2015. Vermont would avoid purchasing or building roughly 200 MW worth of generation. Additionally, the investment would save Vermonters an estimated $129 million in the year 2015 alone, compared to the base case scenario. Investment in efficiency measures at the level outlined in scenario #5 would also provide additional utility system stability and reliability while increasing the amount of money that would continue to circulate in the Vermont economy rather than flow to out-of-state power generators. Finally, we support the amortization of the energy efficiency investment as this would more accurately spread the cost over the project’s savings horizon and mitigate the rate impact of this investment. Thank you for your consideration of these comments. We encourage the Board to take this important opportunity to put Vermont on a path to reducing our electric demand and our energy bills. Sincerely, Vermont Businesses for Social Responsibility Burlington East Haven Wind Farm Montpelier Gardener’s Supply Burlington Global Resource Options White River Junction Green Mountain Coffee Roasters Waterbury Native Energy, LLC Charlotte Seventh Generation Burlington Small Dog Electronics Waitsfield Stephanie Lahar and Associates Montpelier