97-504 ENR
CRS Report for Congress
Received through the CRS Web
Electricity Restructuring:
Comparison of S. 1401, H.R. 655, H.R. 1230,
S. 722, and H.R. 1960
Updated November 17, 1997
Larry Parker
Specialist in Energy and Environmental Policy
Environment and Natural Resources Policy Division
Congressional Research Service ˜ The Library of Congress

Electricity Restructuring: Comparison of S. 1401, H.R. 655,
H.R. 1230, S. 722, and H.R. 1960
Summary
Once considered the nation’s most regulated industry, the electric utility industry
is evolving into a more competitive environment. At the current time, the focus of
this development is the generating sector, where the advent of new generating
technologies, such as gas-fired combined cycle, has lowered both entry barriers to
competitors of traditional utilities and the marginal costs of those competitors below
those of some traditional utilities. This technological advance has combined with
legislative initiatives, such as the Energy Policy Act (EPACT) to encourage the
introduction of competitive forces into the electric generating sector.
The questions now are whether further legislative action is desirable to
encourage competition in the electric utility sector and how the transition between a
comprehensive regulatory regime to a more competitive electric utility sector can be
made with the least amount of economic and service disruption.
Five comprehensive restructuring bills have been introduced in the 105th
Congress to expand on the initiatives contained in EPACT and to build on the Federal
Energy Regulatory Commission’s (FERC) actions to encourage wholesale
competition. A “comprehensive approach” to utility restructuring involves three
components: (1) provisions for retail competition (called “retail wheeling”), which
permit retail consumers to choose from whom they obtain their electricity supplies;
(2) provisions reforming section 210 of the Public Utility Regulatory Policies Act
(PURPA), which provides cogenerators and small power producers a guaranteed
market for their power; and (3) provisions reforming the Public Utility Holding
Company Act (PUHCA), which regulates various financial transactions of holding
companies that have interests in public utility companies. S. 1401 (a refinement of
S. 237), introduced by Senators Bumpers and Gordon, H.R. 655, introduced by
Representative Schaefer, H.R. 1230, introduced by Representative DeLay, S.722,
introduced by Senator Thomas, and H.R. 1960, introduced by Representative
Markey, contain all three components.
The five bills differ significantly in various aspects of restructuring the electric
utility industry. With respect to retail competition, H.R. 1230 mandates its
implementation the soonest — January 1, 1999. S. 1401 provides the most time to
achieve retail competition — January 1, 2002. H.R. 655’s implementation date is
December 15, 2000. In contrast, S. 722, and H.R. 1960 contain no federal mandate
for retail competition; rather, they encourage the states to develop retail competition
programs. Likewise, each bill takes a different approach to “stranded” costs, that is,
investments made by a utility under the regulatory scheme that may not be recoverable
under competition. S. 1401 has detailed procedures to ensure stranded cost recovery
by affected utilities, including having the FERC exercise the authority if states fail to
provide for it. In contrast, H.R. 655, S. 722, and H.R. 1960 contain no federal
mandates with respect to stranded cost recovery, leaving that decision to the states.
Finally, H.R. 1230 not only contains no federal mandates with respect to stranded
cost recovery, but also prohibits states from imposing exit fees on departing
customers to provide for such a recovery.

Contents
Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Legislative Proposals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Retail Competition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
PURPA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
PUHCA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
List of Tables
Table 1: Summary of Major Provisions of S. 1401, H.R. 655, H.R. 1230, S. 722 and
H.R. 1960 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Electricity Restructuring: Comparison of
S. 1401, H. R. 655, H.R. 1230, S. 722,
and H.R. 1960
Overview
Once considered the nation’s most regulated industry, the electric utility industry
is evolving into a more competitive environment. At the current time, the focus of
this development is the generating sector, where the advent of new generating
technologies, such as gas-fired combined cycle, has lowered both entry barriers to
competitors of traditional utilities and lowered the marginal costs of those competitors
below those of some traditional utilities. This technological advance has been
combined with legislative initiatives, such as the Energy Policy Act of 1992 (EPACT),
to encourage the introduction of competitive forces into the electric generating sector.
The questions now are whether further legislative action is desirable to encourage
competition in the electric utility sector and how the transition between a
comprehensive regulatory regime to a more competitive electric utility sector can be
made with the least amount of economic and service disruption.
The Federal Power Act (FPA) and the Public Utility Holding Company Act
(PUHCA) of 1935 established a regime of regulating electric utilities that gives
specific and separate powers to the states and the federal government. State
regulatory commissions address intrastate utility activities, including wholesale and
retail rate-making. State authority currently tends to be as broad and as varied as the
states are diverse. At the least, a state public utility commission will have authority
over retail rates, and often over investment and debt. At the other end of the
spectrum, the state regulatory body will oversee many facets of utility operation.
Despite this diversity, the essential mission of the state regulator is the establishment
of retail electric prices. This is accomplished through an adversarial hearing process.
The central issues in such cases are the total amount of money the utility will be
permitted to collect and how the burden of the revenue requirement will be distributed
among the various customer classes (residential, commercial, and industrial).
Under the Federal Power Act, federal economic regulation addresses wholesale
transactions and rates for electric power flowing in interstate commerce. Federal
regulation followed state regulation and is premised on the need to fill the regulatory
vacuum resulting from the constitutional inability of states to regulate interstate
commerce. In this bifurcation of regulatory jurisdiction, federal regulation is limited
and conceived to supplement state regulation. The Federal Energy Regulatory
Commission (FERC) has the principal functions at the federal level for the economic
regulation of the electric utility industry, including financial transactions, wholesale

CRS-2
rate regulation, interconnection and wheeling of wholesale electricity, and ensuring
1
adequate and reliable service. In addition, to prevent a recurrence of the abusive
practices of the 1920s (e.g., cross-subsidization, self-dealing, pyramiding, etc.), the
Securities and Exchange Commission (SEC) regulates utilities’ corporate structure
and business ventures under the Public Utility Holding Company Act (PUHCA, Title
1 of the Federal Power Act).
This regulatory regime changed little between 1935 and 1978. Beginning in
1978, primarily in response to the “oil crisis,” laws were passed to encourage the
development of alternative sources of power. The Public Utility Regulatory Policies
Act of 1978 (PURPA) was established in part to augment electric utility generation
with more efficiently produced electricity and to provide equitable rates to electric
consumers. Section 210 of PURPA requires that a public utility purchase the power
produced by qualifying facilities (QFs, generally small producers and cogenerators2).
In addition to PURPA, the Fuel Use Act of 1978 (FUA) helped QFs become
established. Under FUA, utilities were not permitted to use natural gas to fuel new
generating technology. QFs, which are by definition not utilities, were able to
combine the availability of natural gas and new, more efficient generating technology,
such as combined-cycle, with a regulatory system that provided them with a captive
market that priced their product at their local utility’s “avoided cost.” The
introduction of new generating technologies lowered the financial threshold for
entrance into the electricity generation business and shortened the lead time for
constructing new plants. FUA was repealed in 1987, but by this time QFs and small
power producers had already gained a portion of the total market for electricity
supply.
This influx of QF power challenged the cost-based rates that previously guided
wholesale transactions. Before implementation of PURPA, FERC approved
wholesale interstate electricity transactions based on the seller’s costs to generate and
transmit the power. As more nonutility generators entered the market in the 1980s,
these cost-based rates were challenged. Since nonutility generators typically do not
have enough market power to influence the rates they charge, FERC began approving
certain wholesale transactions whose rates were a result of a competitive bidding
process. These rates are called market-based rates.
Most recently, the Energy Policy Act of 1992 (EPACT) furthered competition
in electricity supply by removing several regulatory barriers to entry into electricity
generation. Specifically, EPACT provides for the creation of new entities, called
“exempt wholesale generators” (EWGs), that can generate and sell electricity at
wholesale without being regulated as utilities under PUHCA. Under EPACT, these
EWGs are also provided with a way to assure transmission of their wholesale power
to a wholesale purchaser. However, EPACT does not permit the FERC to mandate
that utilities transmit EWG power to retail consumers (commonly called “retail
1 Wheeling is the transmission of electric power from one party to another party via a
third party that does not own or directly use the power being transmitted.
2 Cogeneration is the simultaneous production of electric power and thermal energy (i.e.,
steam). Cogeneration plants are considered qualifying facilities under PURPA.

CRS-3
wheeling”), an activity that remains under the jurisdiction of state public utility
commissions.
In line with EPACT, FERC issued a Notice of Proposed Rulemaking, since
called the Mega-NOPR, to allow more competition in the generation sector by ending
the utilities’ transmission dominance. On April 24, 1996, FERC issued two final rules
on transmission access. In issuing its final rule, FERC concluded that these Orders
will “remedy undue discrimination in transmission services in interstate commerce and
provide an orderly and fair transition to competitive bulk power markets.” Under
Order 888, the Open Access Rule, transmission owners are required to offer both
point-to-point and network transmission services under comparable terms and
conditions that they provide for themselves. The rule provides a single tariff
providing minimum conditions for both network and point-to-point services and the
non-price terms and conditions for providing these services and ancillary services.
FERC Order 888 also allows for full recovery of so-called stranded costs from
wholesale customers wishing to leave their current supply arrangements. With the
introduction of competition, utilities have been concerned that construction costs that
they incurred under their monopoly service territory agreements may not be
recovered. These costs, called stranded costs, can be viewed as a transition problem
resulting from the movement from a comprehensive regulatory regime to a more
competitively based electric generating sector. The utilities’ current investments in
electric generating facilities are based on a “regulatory bargain” where utilities are
obligated to serve wholesale customers through contractual arrangements and
obligated to serve retail customers through their monopoly franchise rights. In return
for providing service on demand, the regulatory authorities ensured financial integrity
by permitting the utilities to recover, over a multi-year period, prudently incurred
costs plus a reasonable rate of return. This system has been upset by the emergence
of competitive forces in the electric generating system driving outside parties to build
facilities that can generate electricity at lower cost than many utilities’ embedded
generating costs, competitive forces that national policy is nurturing and encouraging.
For some utilities, this shift in policy results in some of their investments, although
prudently incurred under the regulatory system, potentially becoming uneconomic or
“stranded” by the new market pricing mechanism. For example, utilities built nuclear
capacity, some of which turned out not to be needed, which cost much more than
comparable gas-fired capacity. In a competitive market, the cost of this capacity may
be “stranded” by the availability of the lower cost gas-fired capacity. As a result,
those utilities would have a difficult time recovering their capital investment in the
higher cost nuclear facility.
Order 889, the Open Access Same-time Information System (OASIS) rule,
establishes standards of conduct to ensure a level playing field. It requires utilities to
separate their wholesale power marketing and transmission operation functions, but
does not require corporate divestiture of assets. FERC also issued a new Notice of
Proposed Rulemaking that requests comments on whether the single tariff contained
in the final open access rule should be replaced with a capacity reservation tariff that
would indicate how much transmission is available at any given time.

CRS-4
Legislative Proposals
Five comprehensive utility restructuring bills have been introduced in the 105th
Congress to expand on the initiatives contained in EPACT, and to build on FERC’s
actions. In general, these “comprehensive” approaches to utility restructuring have
three components: (1) provisions for retail competition (commonly called “retail
wheeling”), which would permit retail consumers to choose from whom they obtain
their electricity supplies; (2) provisions reforming section 210 of PURPA, which
provides cogenerators and small power producers a guaranteed market for their
power; and (3) provisions reforming PUHCA, which regulates various financial
transactions of large holding companies having interests in public utility companies.
S. 1401, introduced by Senators Bumpers and Gordon, H.R. 655, introduced by
Representative Schaefer, H.R. 1230, introduced by Representative DeLay, S. 722,
introduced by Senator Thomas, and H.R. 1960, introduced by Representative
Markey, contain all three components.
The criteria used in this report to compared these bills were derived from a CRS
analysis of the basic issues surrounding electricity restructuring.3 The five initiatives
summarized here — S. 1401, H.R. 655, H.R. 1230, S. 722 and H.R. 1960
4

significantly differ in the emphasis each takes in restructuring the electric utility
industry. The issues and differing approaches are briefly summarized below.
Retail Competition
Retail competition refers to the ability of retail consumers to obtain their electric
services from anyone they choose. Currently, such a scheme would entail a
competitive generation market combined with a regulated transmission and
distribution system. The transmission and distribution system currently are not
considered amenable to competition, so that part of the electricity supply system
would be regulated to provide customers access to the competitively based generation
on a reasonable and nondiscriminatory basis. FERC Orders 888 and 889 represent
FERC’s attempt to achieve this competition on a wholesale level. However, FERC
does not have jurisdiction over retail competition, as explicitly stated in EPACT.
Currently, that is under the jurisdiction of the states.
The bills summarized here address the retail competition issue differently. S.
1401 has a federal mandate requiring retail competition by January 1, 2002, with
enforcement provided through the federal courts, not by any assumption of authority
by FERC. However, the bill has detailed procedures to ensure stranded cost recovery
by affected utilities, including having the FERC exercise the authority if states fail to
3 Parker, Larry B. Electric Utility Restructuring: Overview of Basic Policy Questions.
CRS Report 97-154 ENR. January 28, 1997.
4 Introduced in November 1997, S. 1401 is a refined and enlarged version of S. 237,
introduced by Senator Bumpers in January 1997. Besides moving up the date for retail
competition from December 15, 2003 to January 1, 2002, S. 1401 has substantial provisions
on the Bonneville Power Administration (BPA) and the Tennessee Valley Authority (TVA)
not included in S. 237.

CRS-5
provide for it. S. 1401 also has detailed provisions establishing Independent System
Operators (ISOs) and to ensure reliability, and enhance efficiency and competition.
H.R. 655 mandates retail competition by December 15, 2000. The bill provides
for states and nonregulated utilities to choose to implement this requirement
themselves or have the FERC exercise that authority. But the bill contains no federal
mandates with respect to stranded cost recovery or establishment of ISOs. Decisions
with respect to stranded cost recovery and reliability are left to the states.
H.R. 1230 mandates retail competition by January 1, 1999, with FERC given
general authority to implement the provisions of the bill. The bill contains no federal
mandates with respect to stranded cost recovery, and prohibits states from imposing
exit charges for such a recovery on customers deciding to leave a utility system.
FERC has authority to ensure transmission reliability under H.R. 1230; states have
authority to ensure local distribution reliability.
In contrast to the above proposals, S. 722 and H.R. 1960 contain no federal
mandate or deadline for implementing a retail competition program. S. 722 clarifies
that the state have jurisdiction over retail electric supply, excluding interstate
transmission, and includes reciprocity requirements to ensure that utilities in states
without a retail competition program may not take retail customers away from utilities
in states that do have a retail competition program. The bill contains no federal
mandates with respect to stranded cost recovery or establishment of ISOs. Decisions
with respect to stranded cost recovery and reliability are left to the states.
H.R. 1960 encourages states to initiate retail competition by making certain
federal actions contingent on state action. Specifically, H.R. 1960 makes the
suspension of both PUHCA and PURPA contingent on state certification that a utility
is complying with competitive requirements in the bill. The bill contains no federal
mandates with respect to stranded cost recovery, leaving that decision to the states.
H.R. 1960 does provide for FERC to oversee a self-regulating national Electric
Reliability Council designed to protect system reliability.
PURPA
Section 210 of PURPA is commonly called the mandatory purchase requirement.
With a comprehensive approach to competitive electric markets embedded in these
bills, the mandatory purchase requirement of section 210 of PURPA is considered by
many to be outdated. Under S. 1401, section 210 would cease to apply to new
generating facilities or new contracts as of January 1, 2002. Under H.R. 655 and
H.R. 1960, section 210 would not apply to new contracts for utilities that have been
deemed by their state regulatory commissions as providing for retail competition on
a competitive and nondiscriminatory basis. H.R. 1960 contains detailed provisions for
states to follow in making this certification. Under H.R. 1230, section 210 would not
apply to a utility the state determines provides retail competition on an open and
nondiscriminatory basis. Finally, S. 722 provides that section 210 of PURPA would
not apply to new facilities that begin commercial operation after the date of
enactment, unless a power purchases contract had been entered into before
enactment. All five bills contain language that grandfather or protect existing
contracts under PURPA, although they differ in detail. Also, S. 1401, H.R. 655, and

CRS-6
H.R. 1960 contain a renewable energy set-aside program, although they differ in
details. H.R. 1230 and S. 722 contain no such provision.
PUHCA
PUHCA was enacted to prevent the abuses of the 1920s. However, with a
comprehensive approach to competitive electric markets, PUHCA is viewed by many
as an unnecessary impediment to competition. Concern about recurrence of the
earlier abuses is generally addressed through provisions providing for improved access
to company records by state commissions and FERC. S. 1401 would repeal and
replace PUHCA one year after enactment, while S. 722 would do so 18 months after
enactment. H.R. 655 would suspend PUHCA for utilities deemed by their state
regulatory commissions as providing for retail competition on a competitive and
nondiscriminatory basis. S. 1401, H.R. 655, and S. 722 would replace PUHCA’s
strictures with provisions enhancing federal and state commission access to company
records; however, only H.R. 655 and S. 722 make requests by state commissions
enforceable in federal courts. H.R. 1230, like H.R. 655, would suspend PUHCA
when the affected states determine that the company offers retail competition on an
open and nondiscriminatory basis. However, H.R. 1230 does not replace PUHCA
with any provisions enhancing federal or state access to company records. Finally,
H.R. 1960 would make suspension of PUHCA dependent upon state certification of
a utility's compliance with various competitiveness criteria. But, in contrast to the
other bills, H.R. 1960 would include substantially enhanced state and FERC authority
to oversee utility mergers, acquisitions, diversification efforts, and market power.
The reader should note that this is a brief summary of major provisions, not a
complete, comprehensive, word-for-word comparison of bills. Readers interested in
the precise language of a given provision should refer to the bill in question.5
5 For a more detailed (although not word-for-word) comparison of S. 237 (the previous
version of S. 1401) and H.R. 655, see Parker, Larry. Electric Restructuring: Comparison
of Major Provisions of S. 237 and H.R. 655.
CRS Report 97-314 ENR. February 28, 1997.

CRS-7
Table 1: Summary of Major Provisions of S. 1401, H.R. 655, H.R. 1230, S. 722 and H.R. 1960
Provision
S. 1401
H.R. 655
H.R. 1230
S. 722
H.R. 1960
Deadline for
January 1, 2002
December 15,
January 1, 1999
No federally
No federally
Retail
2000
imposed deadline
imposed deadline
Competition
Federal Role in
Federal mandate
Federal mandate
Federal mandate
No federal
No federal
Implementing
enforceable in
enforceable by
enforceable by
mandate. Retains
mandate. En-
Retail
federal courts
FERC
FERC
role in interstate
hanced utility
Competition
transmission
oversight,
environmental
and consumer
protection role
State Role in
Retains role in
Detailed state
Retains role in
Lead role in
Lead role in
Implementing
protecting the
implementation
protecting the
deciding on retail
deciding on retail
Retail
public interest,
requirements for
public interest,
competition
competition
Competition
and regulating
retail competition
and regulating
reforms. Retains
reforms based on
distribution and
along with
local distribution
role in protecting
detailed federal
retail transmission
retaining role in
service
public health and
provisions.
service
local distribution
safety
Enhanced role in
and consumer
utility oversight
protection
Transitional
Detailed
No requirement.
No requirement.
No requirement.
No requirements.
Concerns —
requirements for
States may
States may not
States may
Any stranded cost
Stranded Costs
stranded cost
choose to impose
impose an exit
choose to impose
recovery must be
recovery with
a charge to
charge to provide
a charge to
allocated in an
FERC serving as
provide for such
for such a
provide for such
equitable manner
a backstop
recovery
recovery
recovery
to all customer
classes

CRS-8
Provision
S. 1401
H.R. 655
H.R. 1230
S. 722
H.R. 1960
Structuring the
Detailed
State authority to
FERC to ensure
State authority to
Creates self-
Market —
provisions for
ensure reliability
transmission
ensure reliability
regulating utility
Reliability
ISOs, along with
reliability; states
councils under
state authority to
to ensure local
FERC oversight
ensure reliability
distribution
to protect
reliability
reliability
Structuring the
ISOs must be
PUHCA ceases to
Functional
PUHCA repealed
PUHCA ceases to
Industry —
independent
apply to a
divestiture of
18 months after
apply to a com-
Corporate
company when
transmission/
enactment and
pany when the
Structure
PUHCA repealed
the affected states
distribution and
replaced by
affected states
(including
1 year after
determine the
generation
enhanced federal
certify the com-
PUHCA)
enactment,
company offers
components
and state access
pany's compli-
replaced by
effective retail
to company
ance with federal
enhanced federal
competition.
PUHCA ceases to
records
retail competition
and state access
Replaced by
apply to a
and public benefit
to company
enhanced federal
company when
standards. Re-
records
and state access
the affected states
placed by en-
to company
determine the
hanced federal
“Ohio Power”
records
company offers
and state author-
provision to
effective retail
ity to oversee
permit state
competition
utility mergers,
review of affiliate
acquisitions,
transactions
affiliate relation-
ships, and diver-
sification efforts

CRS-9
Provision
S. 1401
H.R. 655
H.R. 1230
S. 722
H.R. 1960
Structuring the
Sec. 210 of
Sec. 210 of
Sec. 210 of
Sec. 210 of
Sec. 210 of
Industry —
PURPA does not
PURPA does not
PURPA does not
PURPA does not
PURPA ceases to
Corporate
apply to new
apply to a utility
apply to a utility
apply to new
apply to a utility
Transactions
facilities after
the state
the state
facilities after the
when the affected
(including
January 1, 2002
determines
determines
date of enactment
state certifies the
PURPA)
provides effective
provides effective
unless a power
utility's compli-
Existing contracts
retail competition
retail competition
purchase contract
ance with federal
are unaffected
had been entered
retail competition
Existing contracts
Contracts as of
into beforehand
and public benefit
are unaffected
the date of
standards
enactment are
Existing contracts
unaffected
are unaffected
Existing contracts
are unaffected

CRS-10
Provision
S. 1401
H.R. 655
H.R. 1230
S. 722
H.R. 1960
Structuring the
TVA fence is
Purchasers of
No specific
All transmitting
Except for
Industry —
removed if in
Power Marketing
provisions
utilities are
existing arrange-
Public Power
U.S. interests;
Administration
subject to FERC
ments, TVA and
purchase con-
(PMA) power
with respect to
PMAs may not
tracts with TVA
may not resell
any wholesale
provide retail
may be termi-
that power
transmission
service to custo-
nated on 1-year
outside their
service
mers outside their
notice after
distribution area
areas unless retail
January 1, 2001;
Study of tax
competition is
privatization
benefits of public
available to all
study required.
and investor-
customers within
owned power
such area
BPA regional
governing body
authorized.
Authorized BPA
compliance with
FERC open ac-
cess rules and
participation in a
ISO shall not
threaten U.S.
Treasury receipts.
Non-economic
EPA study of air
States may assess
No specific
States may assess
President to pre-
Issues —
pollution
charges to fund
provisions
charges to fund
vent advantage to
Environment
standards and
environmental
environmental
utilities whose
electricity
programs
programs
plants emit exces-
restructuring by
sive amount of
January 1, 2000
sulfur dioxide,
nitrogen oxides,
and carbon
dioxide

CRS-11
Provision
S. 1401
H.R. 655
H.R. 1230
S. 722
H.R. 1960
Non-economic
Renewable set-
Renewable set-
States may permit
States may assess
Renewable set-
Issues —
aside requirement
aside requirement
consumer choice
charges to fund
aside requirement
Renewable
and trading
and trading
with regard to
renewable energy
and trading
Energy
program
program
renewable energy
programs
program
Non-economic
States may assess
States may assess
States may assess
States may assess
As part of the
Issues — Other
charges to fund
charges to fund
charges to
charges to fund
certification
public benefit
public benefit
continue universal
public benefit
process, states
programs, such as
programs, such as
service protection
programs, such as
must generally
universal service
universal service
for customers
universal service
assess charges to
protection for
protection for
protection for
fund public bene-
customers, low-
customers, low-
States retain
customers, low-
fit programs, such
income energy
income energy
authority over
income energy
as low-income
assistance, R&D
assistance, and/or
conservation,
assistance, R&D
services, renew-
programs, and
environmental,
R&D, and other
efforts, and
able energy and
energy efficiency
renewable,
programs deemed
environmental,
energy efficiency
and conservation
efficiency,
appropriate by the
renewable energy,
conservation, or
state
energy efficiency
other such
or conservation
programs
programs