E-M:/ [Fwd: Urgent request for Energy Efficiency in MI]

[Phil Shepard <shepard@acd.net>]

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Enviro-Mich message from Phil Shepard <shepard@acd.net>
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-------- Original Message --------
Subject: 	Urgent request for Energy Efficiency in MI
Date: 	Thu, 16 Dec 2004 12:05:44 -0500
From: 	Phil Shepard <shepard@acd.net>
To: 	o2-michigan <o2-michigan@lists.riseup.net>



[Stanton attachment deleted due to restrictions of listserver; available 
on request.]

Dear Energy Efficiency Advocate,

The Michigan Public Service Commission recently issued a very 
significant order in a Detroit Edison Rate Case (U-13808). The order 
creates an excellent opportunity to encourage the Detroit Edison Company 
(Edison) to implement a new kind of energy efficiency program called 
PAYS®. "PAYS®" (or "Pay-As-You-Save™") is the legally registered 
trademark for a new and elegant financing mechanism designed by Harlan 
Lachman and Paul Cillo of The Energy Efficiency Institute. Detailed 
information is available from the non-profit PAYS America website 
<www.paysamerica.org> (www.paysamerica.org). PAYS® is a unique and 
powerful approach to developing a vibrant market for cost effective 
energy efficiency measures. It can do even better for energy efficiency 
what the home mortgage has done historically for home ownership: make it 
available to everyone, regardless of income level, while actually saving 
money on utility bills from the start.

We will explain more below, but first, and this is very urgent, WE NEED 
YOUR HELP. The first step in making PAYS® a reality in Michigan is to 
convince the PSC and Edison that there is strong support for it. So, we 
urge you to join us by sending a letter that communicates your desire 
that a PAYS® program be implemented by Edison in response to the ruling 
in Case No. U-13808. Getting Edison to form such a program would set an 
important precedent for Michigan’s other utilities to do the same.

Below, we review the Commission Order, what the Letter needs to contain, 
to whom it should be sent, and related matters, and explain the 
essential PAYS® concept.

Commission Order

The Order says:

"Finally, the Commission will not direct Detroit Edison to conduct any particular program beyond that already discussed above. However, the Commission stands willing to approve such a tariff [a true PAYS®tariff], should Detroit Edison follow up on the Staff's suggestion. The Commission finds that implementation of a PAYS® tariff could bring a competitive advantage to those energy suppliers willing to undertake such a program. ACCORDINGLY, THE COMMISSION DIRECTS DETROIT EDISON TO MEET WITH INTERESTED PARTIES WITHIN 120 DAYS FROM THE DATE OF THIS ORDER TO DISCUSS THE IMPLEMENTATION OF A PROGRAM CONTAINING THE ESSENTIAL ELEMENTS OF THE PAYS® CONCEPT. Detroit Edison should include any tariff proposal for which there is substantial agreement in its next general rate case application.

... [from Commission's FINDINGS paragraphs]
d. Detroit Edison should be directed to meet with interested parties to discuss the implementation of a program containing the essential elements of the PAYS® concept . . . . DETROIT EDISON SHOULD INCLUDE ANY TARIFF PROPOSAL FOR WHICH THERE IS SUBSTANTIAL AGREEMENT IN ITS NEXT GENERAL RATE CASE APPLICAITON. The company should also be directed to file a report with the Commission no later than March 15, 2005.

{Caps are ours.}

To effectively seize the opportunity this order presents, a significant 
number of energy experts and community advocates need to declare in 
writing their interest in participating in the discussion of PAYS® 
implementation with Edison.

Letter Details

Content

The letter should state that

1. You and any relevant group you represent are very interested in the 
Commission Order in Case No. U-13808 regarding a PAYS® program.
2. You believe the PAYS® system can make an enormous difference for 
Michigan residents, businesses and taxpayers by creating a marketplace 
where customers want to buy and pay for cost effective efficiency products.
3. You or your group want to be part of collaborative effort to be held 
as soon as possible to develop “substantial agreement” on a tariff 
proposal for “a program containing the essential elements of the PAYS® 
concept.”

Also:
4. It is important that the Commission used the PAYS® trademark. Please 
use it in your letter and indicate that you understand the three key 
elements of PAYS® noted below.
5. If you or your group can commit to attending all meetings please note 
this in your letter. If you cannot take on actively participating 
yourselves, please designate one of these three people as your 
representative - Phil Shepard, David Gard, and Rev. Charles Morris. If 
you would like to participate but are unsure (e.g. due to possible 
scheduling conflicts) please indicate that you would like one of us to 
represent you if you are not able to attend.

(If you have difficulty getting "PAYS®" or "Pay-As-You-Save™" to appear 
as such in your letter, try copying from this email to your clipboard 
and pasting into the letter. Alternatively, you may use "PAYS(R)" as the 
nearest representation of "PAYS®".)

Letter Destination

The letter should be sent to:

Carolyn MacKool, Energy Assistance Manager
The Detroit Edison Company
3200 Hobson St.
Detroit, MI 48201

email: mackoolc@dteenergy.com
voice 313-256-6601
fax: 313-577-7229 

Please send copies of the letter to:

Sandra Philpott-Burke, Supervisor
Service Quality Section
Michigan Public Service Commission
P.O. Box 30221
6545 Mercantile Way, Suite 7
Lansing MI 48911-5990

and to

George Stojic, Director
Engineering & Service Quality Division
Michigan Public Service Commission
P.O. Box 30221
6545 Mercantile Way, Suite 7
Lansing MI 48911-5990

You may send an additonal copy to:

Jim Padgett, Governmental and Regulatory Affairs
The Detroit Edison Company
2000 2nd Ave
Detroit, MI 48201

We strongly urge that you send or fax hardcopy letters to MacKool. You 
may also email a courtesy copy to her. Please email your letter as well 
to Phil Shepard (shepard@acd.net) so we may keep track of responses and 
your choice regarding representation on the collaborative.

If it is at all possible for you to get your letter out before 
Christmas, we strongly urge you to do so. Otherwise, please send your 
letter as soon as possible after Christmas and call MacKool before 
Christmas to announce your intention to submit a letter of interest. We 
will contact Edison to convene the PAYS® collaborative early in January.

PAYS® Concept

With the PAYS® system, building owners or their tenants purchase and pay 
for money-saving energy efficiency products wtih no up-front payment and 
assume no debt obligation. Those who benefit from the savings pay for 
these products through a tariffed charge on their utility bill, but only 
for as long as they occupy the location where the products are installed 
and only for as long as the product functions. The monthly charge is set 
so that it is significantly lower than the product’s estimated savings 
and there are immediate net savings. The charge remains on the bill for 
that location until all costs are recovered. Like a loan, PAYS® allows 
for payment over time, but unlike a loan, the PAYS® obligation ends when 
occupancy ends or the product fails. PAYS® creates a marketplace in 
which people want to buy and pay for energy efficiency.

PAYS® has three key elements:
a) A tariff that assigns repayment of permanent measures to the meter 
location;
b) Billing and payment through a charge on the distribution utility bill 
with disconnection for non-payment; and c) Independent certification 
that the products and installations are appropriate and that estimated 
savings will exceed payments.

The attached excerpt from testimony of Thomas Stanton, PSC staff, 
further explains the concept and helps to give a feelng for the context. 
Additional material on the concept is available at www.paysamerica.org . 
Shepard will also supply upon request e-copies of i) testimony at a PSC 
hearing on PAYS® and its benefits, and ii) a conference paper that 
updates the discussion and addresses some questions of possible scope. 
Both of the latter are written particularly for the "lay" or non-expert 
reader.

In addition, Harlan Lachman (802-879-8895 or 802-238-7331, cell) and 
Paul Cillo (802-472-6222) invite you to call them with any relevant 
concerns. The letter campaign coordinators, Phil Shepard and David Gard 
(contact info below), wish to extend the same invitation.


We thank you profusely for your assistance in this matter.

For the Michigan PAYS® Coalition, we are,

Philip T. Shepard, Professor Emeritus, MSU
President, ESB Consulting, Inc.
shepard@acd.net
517-332-0761

David Gard
Michigan Environmental Council
davidmec@voyager.net
517-487-9539






--
Phil Shepard
shepard@acd.net
517-332-0761



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