Public Service Commission (Demand-Side Management)
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- ALEXANDER CLEAVER, P.A.
- ON DEMAND-SIDE MANAGEMENT PROPOSALS
- COMMENTS ON NEW PROGRAM PROPOSALS
| October 18, 2000
Felecia L. Greer, Esq. Executive Secretary RE: Case No. 8738
Public Service Commission (Demand-Side Management)of Maryland 6 St. Paul Street Baltimore, Maryland 21202
Dear Ms. Greer:Enclosed for filing are the original and 14 copies of the Comments of Mid-Atlantic Petroleum Distributors Association on Demand-Side Management Proposals. Also enclosed is a Motion to Reject Extension of Filing Deadline. Electronic versions of both documents, in MSWord format, also are included. Sincerely,
Chantel O. Freedman, Esq.Counsel for Mid-Atlantic Petroleum Distributors’ Association, Air Conditioning Contractors of America-National Capital Chapter, and Maryland Alliance for Fair Competition cc: service list enclosures In the Matter of the Commission’s Inquiry * Into the Provision and Regulation of * Case No. 8738 Electric Service * (Demand Side Management) * * * * * * * * * * COMMENTS OF MID-ATLANTIC PETROLEUM DISTRIBUTORS ASSOCIATION ON DEMAND-SIDE MANAGEMENT PROPOSALSINTRODUCTION On May 12, 2000, the Public Service Commission of Maryland established a comment and hearing schedule covering three specific issues relating to demand side management (“DSM”) programs in the State of Maryland. Following the conclusion of the hearings in July, the Executive Secretary issued a letter on July 21, 2000. In the July 21 letter, the Commission stated that “there was a noticeable lack of detail regarding any proposed programs by the parties.” Letter, page 1. Therefore, the Commission made provision for program proponents to obtain information and to file programs, with accompanying detail on program cost-effectiveness, and environmental and job impacts. Id. Specifically, programs were to be filed with the Staff in August, followed by meetings and another set of written comments to be filed on October 18, 2000. The Mid-Atlantic Petroleum Distributors Association (“MAPDA”) filed Initial and Reply Comments in this proceeding over the summer. Those comments, in part, noted that program proponents failed to provide sufficient detail on their programs and failed to show that they were cost-effective. As seen below, the program proponents still have not provided information that would allow even an estimation of cost-effectiveness. MAPDA incorporates its earlier criticism of program proposals in this pleading, and offers the following additional material for the Commission’s consideration. COMMENTS ON NEW PROGRAM PROPOSALSSeveral parties have filed programs, contained in Staff’s Compilation of Programs dated October 6, 2000.1 However, MAPDA observes that MEA, NAESCO and Smeco did not provide details on the costs of their programs, much less cost-effectiveness analyses. MEA’s proposals in particular lack detail on the programs it wants implemented. Further, NEEP provided only recommended program funding levels, not cost-effectiveness analyses. As mentioned above, in its July 20 letter the Commission expressly requested details on program proposals. The Commission also directed proponents to “provide support for why they believe recommended programs are cost-effective.” Id., page 2. Since the proponents have not provided the Commission or the parties with any information on the cost-effectiveness of their proposals, MAPDA submits that the Commission should not adopt, or recommend adoption of, any new DSM programs from these parties. MAPDA believes that the Department of Energy’s ENERGY STAR® program has some promise. However, MAPDA is concerned that the program’s simple yet effective equipment efficiency standards and labels components could be turned into yet another misguided program requiring large expenditures of public funds for advertising, funding of the design and manufacturing processes, or other central planning intrusions into matters best left to the market. Accordingly, MAPDA withholds a blanket endorsement of ENERGY STAR®.
In closing, MAPDA respectfully requests the Commission to continue its move away from costly DSM subsidies and market distortions, and to adopt MAPDA’s recommendations as stated in these Comments and in its Initial and Reply Comments. MAPDA urges the Commission to recognize the problematic experiences with DSM programs in Maryland in the past, the fact that the programs were no longer cost-effective even before deregulation occurred, and that there is little credibility in the promises, still unsupported as of this date with cost-effectiveness information, that this time the programs can be done right. Respectfully submitted, ALEXANDER & CLEAVER, P.A. Gary R. Alexander Chantel O. Freedman Counsel for MID-ATLANTIC PETROLEUM DISTRIBUTORS ASSOCATION 54 State Circle Annapolis, Maryland 21401 (410) 974-9000 (410) 974-9002 (fax)
Chantel O. Freedman Counsel for Mid-Atlantic Petroleum Distributors Association 1 Program proposals were submitted by the National Association of Energy Service Companies (“NAESCO”), the Northeast Energy Efficiency Partnership (“NEEP”), Southern Maryland Electric Cooperative (“Smeco”) , and the Maryland Energy Administration (“MEA”). Additionally, the federal Department of Energy provided information on its ENERGY STAR® program. Directory: newIntranet -> Casenum Casenum -> In a memorandum dated July 16, 2001, the Technical Staff of the Commission filed its comments regarding this matter. Staff noted that the loan would consist of two amounts: $10,233,000 to be obtained from rus Casenum -> Mid-atlantic petroleum distributors association Casenum -> Case No. 8509(z) Casenum -> Reply brief of the staff of the maryland public service commission Casenum -> Hearing examiner's notice of extension of filing date Casenum -> Notice of revised procedural schedule Casenum -> 630 Martin Luther King Boulevard po box 231 Wilmington de 19899-0231 Casenum -> Registration Form Please forward this completed and signed application, and accompanying information to the following address Casenum -> Baltimore Gas And Electric Company By Casenum -> Request for investigation and petition for declaratory order against southern maryland electric cooperative, inc., Choptank electric cooperative and choptank home and business services, inc Download 18.51 Kb. Share with your friends:
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