Don't Evaluate the Move. Evaluate the Position.
As soon as I saw Flexible Load Management in the filing, I knew we were going to have a problem.
The filing had gone through our normal review process. Our Regulatory Analyst concluded that an existing agreement protected our position. The Manager of Planning and Support concurred. Our General Counsel saw a potential issue but concluded that if concerns emerged, we could address them when the agreement came up for renewal. By the time it reached me, nobody was particularly alarmed. Just seeing Flexible Load Management appear in the filing got my attention.
Several years ago, Vermont's utilities and Efficiency Vermont spent considerable time debating who should operate Flexible Load Management programs. Eventually a compromise was reached, roles were defined, and the issue appeared settled. So when Flexible Load Management suddenly reappeared, my first question wasn't:
"What does this proposal do?"
It was:
"Why are we talking about this again?"
The filing contained two seemingly modest proposals. One involved developing analytics to evaluate program effectiveness. The other involved creating a communications protocol for operating the programs. Viewed individually, both seemed reasonable.
That was exactly what bothered me. If utilities were responsible for operating the programs, why would someone else need to develop the analytics used to evaluate them? If utilities were selecting their own software platforms and compensation mechanisms, why would someone else need to define how those systems communicate?
The more I thought about it, the less these proposals looked operational. They looked strategic.
The issue wasn't analytics. The issue was the capability analytics would create. The issue wasn't communications standards. The issue was the influence those standards would create.
Neither proposal transferred control today. But both created capabilities that could be used to argue control should be transferred tomorrow.
Most people were evaluating the proposal. I was evaluating the position. If those capabilities were approved, I could easily imagine the next conversation three years from now.
The organization controlling the analytics could argue that utility programs weren't performing effectively. The organization defining communications standards could argue that statewide consistency required a more centralized approach. The debate over who should operate the programs would return. Only this time with Efficiency Vermont in a much stronger position.
When I raised those concerns, some members of my staff thought I was reading too much into the filing. Others simply hadn't looked at it that way. That's understandable. They were evaluating the filing in front of them. I was evaluating where the filing might lead.
Organizations rarely achieve major strategic objectives through a single dramatic proposal. They advance through a series of smaller steps that appear reasonable when viewed individually. The significance only becomes visible when you evaluate the position those steps are creating.
That lesson was reinforced later in the proceeding. The Public Utility Commission asked a straightforward question: "What is the legal basis for providing these services?" The response caught my attention. Rather than focusing on legal authority, the filing largely described how the proposal would help utilities.
It was a good answer. To a different question. I've seen enough situations like that over the years to know that what people don't say can be every bit as informative as what they do.
Most people evaluate situations based on their impact today. They then look for ways to close loopholes, regain leverage, or undo advantages that already exist. Strategic thinking requires something different. It requires identifying the position created by today’s actions before it exists. Because once a position becomes established, the argument is often already over.
The move in front of you matters. The position behind it usually matters more.