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Jerrold Oppenheim
Theo MacGregor

57 Middle Street
Gloucester, Mass.
01930 USA

Other Works
By Greg Palast

Comment on decoupling
Massachusetts Department of Public Utilities, Docket 07-50
September 10, 2007
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Low Income Network responds to DPU inquiry to consider regulatory strategies to encourage demand-side resources.

SUMMARY: We recommend that the Department take no action in this docket because the existing incentive system has created some of the most successful efficiency programs in the country. The straw proposal would be unlikely to improve incentives to invest in efficiency because (a) unlike the existing system, it would not bear a specific relationship to efficiency efforts, (b) it would create new economic risks and shift risks that are more easily borne by utilities, including rate volatility, to families, (c) it would create a single issue rate mechanism, and (d) it could have substantial adverse impacts on low-income consumers.