Comment on FR Doc # 2012-17784

Although you may not have this option, the proposed regulation should primarily focus on making generation more efficient by encouraging demand-side management and leveling peaks. This will benefit all consumers, keeping costs down and delaying new generation. As for renewables: What will be the future focus with the new found abundance of natural gas? As for loans to consumers for energy efficiency measures: If you had the choice, I would recommend that you delete this from the regulation because it is time consuming and costly. We are in a pilot project with a local agency to serve 75 consumers. It is very labor intensive. Even though the contractors are performing the installations, we have spent over $80,000 on 34 consumers. And, our costs will continue at some level until the last loan is paid, some 15 years from now. The proposed regulation looks even more labor intensive with the various plans and reporting. The fluctuating interest rate needs to be fixed, at least annually. And given our experience with the pilot, I don't think you can set the administrative fee high enough to recover the costs. Since the cooperative will bear the financial risk, it can't win. If you lend to only the most creditworthy consumers, you are lending to folks who should have access to funds elsewhere. If you lend to lowest income folks who may need the energy efficiency measures the most, how much does your risk go up? And if you write off bad loans, all consumers pay even if they were never eligible to participate in the program. By encouraging energy efficiency without impacting generation efficiency, the cooperative has no way to recover lost revenue. If you liken this scenario to a doughnut shop, it's like asking the doughnut shop owner to meet the customers at the shop entrance and ask them to buy fewer doughnuts. Eventually, the owner has to raise the price per doughnut to cover the fixed costs. We all end up paying more for less.