163 ACORN LANE ∎ COLCHESTER, VT 05446 ∎ VOICE (802)655-8454 ∎ FAX (802)655-8550 ∎ E-MAIL martin@gmpvt.com May 12, 2009 VIA EMAIL & FIRST CLASS MAIL Susan Hudson, Clerk Vermont Public Service Board 112 State Street, Drawer 20 Montpelier, Vt 05602 RE: Streetlighting Tariffs Dear Mrs. Hudson The following comments are provided by Green Mountain Power Corporation (“GMP”) in response to the Public Service Board’s (“Board”) April 15, 2009 memorandum requesting comments on GMP’s Street Lighting Tariffs and whether or not they present any barriers to local governments utilizing monies under the Energy Efficiency and Conservation Block Grant Program that is part of the American Recovery and Reinvestment Act of 2009. The Board’s specific request is for each utility to review its streetlight tariff, identify potential barriers to local government using efficient streetlights. Barriers were identified to include no option for customer-owned fixtures and no option for light emitting diodes (“LED”). GMP has been working diligently over the past year to find a suitable replacement for its mercury vapor streetlights. We believe that the time is right for LED street lighting and therefore have been in discussions with the Vermont Department of Public Service (“DPS”) in order to gain support to allow GMP to offer LED streetlights. GMP proposes to replace 100W and 175W mercury vapor lights with 30W and 50W LED lights, respectively. Attached is the latest redlined version of the proposed changes that would occur to our Rate 18 tariff. The changes are numerous as GMP is also clarifying the roles and responsibilities for both GMP and customers. Also under consideration is the elimination of our grandfathered Street–Area– Flood Lighting Rate 16 tariff and to merge these rates with our Outdoor Lighting Rate 18 tariff rates. Ideally, these changes would occur at the same time and we would file for approval of these changes early this summer. If the Board desires a more expeditious filing, GMP would seek to file the attached Rate 18 tariff which addresses the issue in question. GMP’s tariff allows for customer-owned streetlights. For several years, GMP’s Rate 18 has allowed for customer-owned lighting with or without maintenance services provided by GMP. Thank you for the opportunity to comment and to allow us to show our support of the use of efficient street lighting in the State of Vermont. We stand willing and able to assist any local government wishing to upgrade its lighting systems. If you have any questions about these comments or if we can provide additional information to assist the Board, please let me know. Sincerely, David P. Martin David P. Martin Attachment cc: Sarah Hofmann, DPS Ron Behrns, DPS