From: Maurice Tucci Sent: October 3, 2003 4:41 PM To: IMO Consultation Subject: Input Requested on Economic Demand Response Pilot Program With respect to the questions posed in the MAC's Economic Demand Response Pilot document: 1) Which market segments should be targeted? Is there a priority and if so, why? 2) Of the barriers identified, which are critical? Are there any other critical barriers that we have not identified? I would like to provide the following comments: The EDA supports initiating pilot programs for all market segments. We recognize that if the goal is to obtain the most demand response in the shortest time, then the focus would be on larger customers. However, we believe it is also important to carry out work on small retail customer demand response because some experience with small retail customer pilot projects and some understanding of what is achievable with small customers will assist policymakers in making a more informed decision on what should happen to the retail price freeze after 2006. At this time small retail customers face the most barriers to responding to price signals. If pilot programs for smaller customers do not proceed, and barriers for smaller customers are not addressed then it can be argued that smaller customers have been put at a disadvantage compared to other customers With respect to barriers, we would like to point out that LDCs may be able to assist customer demand response through supporting infrastructure but it should be recognized that LDCs providing supporting activities may require funding / compensation from another party. Regards, ======================= Maurice Tucci, Senior Analyst, EDA Electricity Distributors Association