Non-U.S. observers, curious about the success of U.S. utilities in promoting energy efficiency among customers, wonder whether the experiences of these utilities are applicable outside the U.S. Among other things, these observers are concerned about the degree to which U.S. utility promotion of customer energy efficiency appears to depend on the unique form of state-directed rate-regulation practiced in the U.S. This paper suggests that, while undoubtedly influential, rate-regulation is only one of many ways for transforming utilities from sellers of electricity as a commodity to providers of energy service. The suggestion is illustrated by descriptions of the customer energy efficiency activities of several U.S. public power utilities, which are not rate-regulated by state agencies. While we believe these activities provide important examples of how non-rate regulated by state agencies. While we believe these activities provide important examples of how non-rate regulated, non-U.S. utilities can become more actively involved in the promotion of customer energy efficiency, we also acknowledge that transforming utilities into providers of energy services does not happen automatically. More typically, an initiating event is required, either external to the utility (such as another form of government intervention) or internally (such as a large impending resource need).