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STATE OF NEW HAMPSHIRE BEFORE THE PUBLIC UTILITIES COMMISSION
IN RE:
RATE MECHANISM FOR Docket No. DE 07-064 ENERGY EFFICIENCY
MEMORANDUM REGARDING SCOPE OF PROCEEDING SUBMITTED BY INTERVENOR CAMPAIGN FOR RATEPAYERS RIGHTS
On June 18, 2007, the Public Utilities Commission (“Commission”) held a prehearing conference in the above-captioned docket. Following the prehearing conference, Commission staff (“staff”) and parties attended a technical session to discuss a possible schedule for the docket proceedings, positions of the parties, as well as scope of the proceeding. The parties provided differing views regarding the scope of this docket. Due to the lack of agreement on this issue by the parties, Campaign for Ratepayers Rights (“CRR”) submits to the commission the following comments for consideration. According to the Order of Notice, the Commission opened this docket “to investigate the merits of instituting, for electric utilities, appropriate rate mechanisms, such as revenue decoupling, which would have the effect of removing obstacles to, and encouraging investment in, energy efficiency.” CRR is concerned with the practical effects that such a new rate mechanism may have on utility consumers. To this end, it seems appropriate that investigations or testimony regarding any effects of a decoupled system be considered within the scope of this investigation. In the Order of Notice, the Commission stated twelve questions for which answers are sought during the course of this docket. Question #10 reads: “What alternatives are there (such as real time or critical peak pricing) to revenue decoupling which achieve similar policy goals?” CRR agrees with the Commission that alternatives to revenue decoupling must be considered before proposing any changes in utility rate mechanisms. However, all effects of such alternatives – both those directly related to energy efficiency efforts as well as those related to other concerns – must be considered. Some parties have expressed concern regarding the effects that revenue decoupling (or alternatives) will have on consumers, utilities, future energy efficiency initiatives, and other related interests. CRR believes that this docket is the appropriate venue to express such concerns to the Commission. WHEREFORE, CRR respectfully requests that the Commission allow for a scope of proceeding that is broad enough to allow parties to study, testify or comment on effects and concerns of revenue decoupling that may not be directly related to energy efficiency efforts. Respectfully submitted For Campaign for Ratepayers Rights,
/s/ Patrick J. Arnold Patrick J. Arnold, Executive Director Campaign for Ratepayers Rights P.O. Box 563 Concord, NH 03302 (443) 848-8358
Dated: July 2, 2007
CERTIFICATE OF SERVICE
I hereby certify on this 2nd day of July 2007, a copy of the foregoing is being forwarded to all persons on the service list.
/s/ Patrick J. Arnold Patrick J. Arnold
Dated: July 2, 2007 |