Testifying on behalf of the Environmental Defense Fund, former Public Utilities Commission of Ohio (PUCO) member Cheryl Roberto said during the Sub. S.B. 58 hearings that utilities sharing "senior management, investors and a board of directors with their affiliate competitive generation company and their affiliate federally regulated transmission company" is a corporate structure that "creates inherent and insurmountable conflicting mixed economic incentives," according to the Gongwer Ohio Report. Instead of functioning as "unbiased energy service procurement agents on behalf of the customer," unregulated generating affiliates "depend on perpetuating consumption of existing fossil-fueled electricity." FirstEnergy Corp., which is leading the charge to scale back the state's renewable energy and energy efficiency standards, has "acknowledged that its competitive energy services segment derives its revenue from the sale of generation which is exposed to market risk, including energy efficiency and demand response," according to her testimony.