Remarks of Peter A. Bradford

From a regulatory standpoint, the concept of a BTU tax is multi-faceted. The recognition of some efficiency and security concerns will reverberate positively in the debate over environmental externalities and will give a boost to DSM and renewable resources. The tax is clearly an operating expense. Operating expenses are clearly recoverable. If the tax passes on the schedule proposed, utilities will have ample time to file to recover in rates any portion that does not go through the various automatic adjustment clauses. The disadvantages of the BTU tax are discussed