385 



acquisition fundamentally undermines the partnership and the 

 prospect for successfully carrying out the acquisition of the 

 first priority resource mandated under the Act. 



Policy stability 



Conservation resources are usually acquired over a fairly 

 prolonged time period. It simply takes time to weatherize 

 most of the houses in a utility's service area, to retrofit 

 the lighting in most office buildings and the motors in 

 manufacturing plants, or to change construction practice in 

 the residential and commercial sectors. As a consequence of 

 the lengthy "construction schedule" typical of most 

 conservation resources, these resources are peculiarly 

 vulnerable to instabilities in regional policies over time. 

 Over the past decade regional policies on such things as 

 capability-building, acquiring all cost-effective conservation 

 or all lost opportunities, contractual acquisition mechanisms, 

 acquisition levels and targets, availability of funding to 

 utilities of different types, cost-effectiveness tests and 

 other conservation guidelines have been anything but stable. 

 Instead, policies in these and related areas have been more 

 volatile than the stock market or the weather. 



The net result of the kinds of policy instabilities I am 

 talking about is that utilities have not been able to plan 

 for, market or operate conservation programs in a consistent 

 manner. The fits and starts which have marked conservation 

 delivery in the region are not conducive to achieving the 

 megawatt savings targets the region has set for itself. For 

 example, utility conservation staffing levels cannot fluctuate 

 radically from year to year so there is a tendency for 

 utilities not to staff up fully for planned ramp-ups in 

 conservation activity because experience tells them that 



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