Vermont's storms are getting more expensive. The data is in GMP's own filings.
To justify its storm-related spending requests, Green Mountain Power submitted Exhibit GMP-MB-2 in the current rate case — a decade-long record of storm costs spanning FY2015 through FY2025. The data, sworn to by GMP Vice President of Operations Michael Burke, tells a stark story about what climate change is doing to Vermont's grid — and what Vermonters are being asked to pay for it.[1]
The numbers are striking. In FY2023, GMP incurred $53.6 million in total storm costs — 2.6 times the 11-year average of $20.5 million. FY2024 followed at $47.0 million, the second-highest year on record. Together, those two years account for nearly half of the entire $225.5 million in storm costs GMP recorded over eleven fiscal years.[1]
Major storm expense alone — the category handled separately through the MSRF mechanism — totaled $45.2 million in FY2023 and $23.6 million in FY2024. The $6 million annual pre-collection was never designed to cover events of this magnitude. It was meant to smooth customer bills — to collect in calm years so major storms wouldn't spike bills in bad ones. In practice, the worst storm years in GMP's recorded history occurred while the fund was being built.[1],[2]
GMP acknowledges the trend. In testimony, Burke cited projections from NOAA and the Vermont State Climatologist to support the argument that storm severity will continue increasing — the same argument GMP is using to justify its $8.6 million Zero Outage Initiative adjustment in FY2027 rates. But that argument cuts in two directions: if storms are getting worse, the case for maintaining a storm reserve fund — rather than eliminating it — is stronger, not weaker.[2],[3]
What ratepayers paid — and what GMP is required to explain
The Major Storm Restoration Fund was created as a separate line item on Vermont customer bills, authorized by the Vermont Public Utility Commission as part of GMP's Multi-Year Regulation Plan. Beginning in FY2023, GMP collected $6 million per year from customers specifically to pre-fund major storm restoration costs.[4],[5]
$18M+ Estimated total collected from Vermont ratepayers, FY2023–FY2026The fund ran for three full fiscal years through FY2025 at $6M annually, and collected through September 30, 2026. That places total collections in the range of $18–24 million, depending on the FY2026 collection amount. GMP has not published a complete accounting.[4],[5],[6]
In its FY2027 rate case, GMP confirmed that the MSRF "pre-collection of storm costs has not exceeded the amount actually needed for Major Storms in any year since then." That claim — if accurate — would mean more was spent each year than was collected. But GMP offered no table, no year-by-year breakdown, and no verification. The assertion appears in a discovery response, not in sworn testimony.[6]
Provide a table showing: actual MSRF amounts collected since inception by year; actual total major storm costs incurred in the same period; amounts of MSRF funds expended against those costs; and the remaining storm costs recovered through rates — "or the information so that such a table can be created."
A pointer to quarterly adjustor filings in the ePUC docket system across two separate case numbers — and an objection stating the information is "already available to the Department." No table. No year-by-year breakdown. No verification of the fund's collection vs. expenditure history. The attachments referenced were not included in the discovery response document.
The Department of Public Service — Vermont's ratepayer advocate — asked exactly the right question. GMP's response was technically compliant and substantively evasive: it pointed to public records that exist but require navigating two separate regulatory dockets to assemble. That is precisely the kind of procedural maneuver that makes utility rate cases opaque to everyone except the parties with resources to participate in them full-time.
The one-sentence disclosure — and what it hides
GMP's FY2027 Rate Filing Schedules — Exhibit GMP-LD-RB-3, filed January 16, 2026 — contain the formal disclosure of the MSRF's elimination. It appears in Schedule G, titled "Additional Bill Adjustors." The complete text reads:[4]
"The Major Storm Restoration Fund, previously established as a separate line item on the bill, in a total amount of $6 million annually from customers, will cease on September 30, 2026."
One sentence. No accounting of what was collected. No accounting of what was spent. No explanation of what happens to the regulatory liability balance. No rationale beyond the description that it will "cease."
A second disclosure — equally buried — appears in Schedule C25, a sub-schedule of regulatory amortizations.[4] That schedule lists dozens of regulatory assets and liabilities being adjusted for the rate year. Among them, line item 25366~MAJOR STORM RESTORATION FUND shows a test-year balance of $5,982,000 — nearly $6 million — being amortized to zero by the end of FY2026.
25366~MAJOR STORM RESTORATION FUND Test Year FY2025: $5,982,000 Adjustment: ($5,982,000) Rate Year FY2027: $0 Note: "Amortization complete in Fiscal 2026"
This entry — which most ratepayers and many stakeholders would never encounter without knowing precisely where to look — reveals that as of September 30, 2025 (the test year end date), GMP was carrying approximately $5.98 million of MSRF collections as a regulatory liability on its books. That's the closest thing to a fund balance disclosure in any of the rate case filings. It is presented not as a highlighted disclosure, but as one line in a 32-line amortization table.[4]
Pre-fund storm costs
Total storm costs: $6.8M and $9.8M respectively. Major storm costs handled through the existing adjustor mechanism. No dedicated pre-collection fund.
Fund launches — coinciding with worst storm year on record
GMP begins collecting $6M annually from customers. In the same year, GMP incurs $53.6M in total storm costs — including $45.2M in major storm expense, 2.6× the 11-year average. The $6M collection covers roughly 13% of total costs incurred.
Collected: $6M | Major storm costs: $45.2MSecond-highest storm year on record
$47.0M in total storm costs; $23.6M in major storm expense. Collection continues. GMP does not publish a MSRF balance or drawdown report in rate case filings.
Collected: $6M | Major storm costs: $23.6MCosts return near average
$15.1M total storm costs; $7.5M in major storm expense. The regulatory liability balance stands at $5.98M at year-end — the only public fund balance figure in the rate case record.
Collected: $6M | Liability balance (year-end): $5.98MGMP files rate case — fund elimination disclosed in one sentence
Schedule G of Exhibit GMP-LD-RB-3 contains the complete public disclosure. Schedule C25 contains the fund's $5.98M balance in a 32-line regulatory amortization table. No standalone accounting is provided.
DPS asks for the accounting. GMP declines to provide it.
In responses to Department of Public Service interrogatories, GMP objects to providing a year-by-year fund accounting table, pointing instead to quarterly adjustor filings across two docket numbers. The attachments are not included in the discovery response document.
Fund ceases. Regulatory liability amortized to zero.
Per GMP's filing, the MSRF ends. Going forward, major storm costs are recovered through a pass-through adjustor after a $1.2M deductible. Customers bear essentially all major storm costs — without the pre-collection cushion — in a period GMP's own witnesses describe as one of increasing storm severity.
7.5% rate increase takes effect
GMP's requested increase includes 1.04% for the Zero Outage Initiative and 0.57% for Energy Storage Systems — resilience investments GMP says will reduce future storm costs. The mechanism for measuring and verifying those savings remains, in GMP's own words, "inherently difficult" and still under development.
The deductible shift — and what it means for your bill
When the MSRF ends, GMP's exposure to major storm costs changes in a specific way. Under the new structure, GMP absorbs the first $1.2 million of any qualifying major storm event. Everything above that threshold flows directly to customers through the Major Storm Adjustor — a separate, pass-through mechanism outside base rates.[6]
In years like FY2023 — when major storm expense reached $45.2 million — that $1.2 million deductible is functionally irrelevant. Customers would bear $44 million of a $45 million major storm year. The pre-collection mechanism was at least an attempt to smooth those spikes by collecting in advance. Without it, a severe storm year will translate directly and immediately into adjustor charges on customer bills.
GMP's argument is that its Zero Outage Initiative investments will reduce future storm costs enough to offset this risk. In testimony, VP Burke stated that data from the EJ-G7 circuit showed meaningful outage reduction following resilience improvements. GMP's expert witness confirmed savings will be "passed through directly to customers" — but also acknowledged that measuring those savings is "inherently difficult and will not be exact," and that the methodology "could be further refined."[3],[7]
The Vermont Public Utility Commission is being asked to accept, on GMP's word, that a fund elimination is justified by savings that GMP has not yet developed a reliable method to measure. That may ultimately prove correct. But it is a prediction, not a demonstrated result — and the burden of proof in a rate case rests with the utility.[3]
Meanwhile, GMP's total cost of service to Vermont ratepayers in FY2027 is proposed at $890.8 million, against current revenues of $828.7 million — a gap of $62.2 million driving the 7.5% increase. The return on utility rate base embedded in that cost of service is $158.4 million — the single largest line item after purchased power — calculated on a $2.16 billion rate base at a weighted average cost of capital of 7.34%, with an allowed return on equity of 9.94%.[4]