Allen Desbiens

I retired from PSNH/Eversource in 2021 after nearly 40 years working directly on NH regulatory issues with the PUC, PUC Staff and the Office of Consumer Advocate (OCA). I was part of the utility team that developed the NH Pilot Program which was designed to foster a competitive energy market for NH retail electric customers. I was directly involved with the restructuring of the NH utility industry and the implementation of restructured energy markets that followed that effort. The amendments to NH law that were required to enable this transition were carefully crafted to ensure cost recovery by the utilities of certain so-called "stranded costs", and to also protect ratepayers from rates that could be deemed excessive and not in compliance with NH law. NH-RSA 374:F is one of those key laws that were carefully crafted to protect all affected parties and allow competition to begin. The PUC's misguided attempt to rewrite NH legislative history - and intent - and randomly push default power supply costs to non-default service customers will likely not survive a legal challenge and flys in the face on NH electric competiton. The PUC should know that if defalut rates are consistently higher than competitive rates this will create an incentive for retail customers to move off default service - EXACTLY what the legislature and regulators hoped would eventually occur in 1999 when competitive markets were enacted! The PUC is taking a well-intentioned law and twisting it's use for a purpose for which it was nver intended - do not let them do it!