SPEER submitted comments on Monday to the Texas PUC, saying the efficiency industry should be allowed to compete head-to-head with new generation. Comments were submitted by Doug Lewin of Good Company Associates, who serves as the organization’s Executive Director. It is time that efficiency measures like insulation, lighting and efficient motors and appliances, as well as demand response, should be able to participate directly in the market and get compensated. If the ERCOT energy market were opened to efficiency, incremental savings could compete against incremental generation. Where efficiency proves more cost effective, Texans win not only lower prices but also the side benefits of reduced transmission and distribution costs, reduced demand for water, and less air and water pollution. Today the state supports limited efficiency incentive programs through investor owned utilities, which are aimed at generating incremental savings, but they are disconnected from the electric market. Direct participation would allow the market to choose the appropriate mix of efficiency and new generation.