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March 5, 2003

 

 

Representative Donald Berry

Utilities and Energy Committee

100 State House Station

Augusta, ME  04333

 

Re:       Follow-up to LD 298, An Act to Define Standard-offer Service as a Service of Last Resort

 

Dear Representative Berry:

 

During the Public Hearing of LD 298, it became apparent that the primary concern of many stakeholders is that the Maine Public Utilities Commission would initiate a “green offer” that would compete with products – either existing or future -- being sold by open market competitors.  I would like to clarify the Commission’s position regarding a green offer.

 

The Commission discussed a Commission-sponsored green offer in its Standard Offer Report submitted to the Committee in December 2002 (the relevant pages are attached to this letter).  We produced the report and conducted the underlying investigation at the direction of the Legislature (P.L. 2002 ch. 528).  The law required us to investigate the question: “Beginning March 1, 2005, should any standard-offer provider selected by the commission pursuant to subsection 2 be required to offer at least one standard-offer service that is composed entirely of renewable resources as defined in section 3210?”  When the question was posed and our report was written, there was no widespread green product and many persons (including members of the Committee, members of the Commission, and others) were concerned that a green product would not develop through an active retail market.  Within that context, our report recommended that the Legislature authorize (but not require) the Commission to establish a green offer after March 1, 2005. 

 

There are important aspects to this recommendation.  First, we commented in the report that we were “concerned that the green offer could have the effect of slowing the development of a competitive market for other green products.”  We stated that we “would act quickly to phase out the green offer if green markets appeared to be developing elsewhere or if there is evidence that the green offer is inhibiting the development of such markets.”  Recently, Maine Interfaith Power and Light (MIPL) introduced a green product (an event that we greeted with enthusiasm).  We would not support offering a Commission-sponsored product that competed with an active MIPL product.

 

In addition, the legislative authorization recommended in the report would not become effective until March 1, 2005.  Our report states: “since we do not propose to initiate a green option until March 1, 2005, the Commission should have the discretion not to establish a green offering if a private market had developed for green power by that time, or if a green market existed only for certain classes, to exclude those classes from the Commission’s offering.”  Furthermore, existing standard offer contracts are effective until 2005 and might be voided or revised if an event such as a Commission-sponsored green product occurred, reinforcing the wisdom of waiting until 2005 to offer a Commission-sponsored green offer.  Until then, the Commission would be happy to monitor the progress of Maine’s green market and report back to the Committee annually on its progress.

 

Finally, we believe that we likely do not have the authority to establish a green offer under current law.  In any case, as stated in our report, “it is the Commission’s view that such a program should not be implemented without explicit legislative authority.”  We do not intend to carry out such a significant action without direct Legislative approval.                

 

We continue to oppose the overly broad wording of LD 298 as written or as amended at the public hearing.  However, we are neither for nor against a bill that authorizes or prohibits a Commission-sponsored green offer in 2005 or earlier. 

 

                                                                        Sincerely,

 

 

                                                                        Marjorie R. McLaughlin

                                                                        Legislative Liaison

 

 

 

cc.        Members of the Utilities and Energy Committee

            Jon Clark