Jul/Aug 2019 FSC Newsletter
An increasing push is being made today to require the periodic reporting of data on utility credit and collection activities and outcomes.
This issue explains the care that must be taken to assure that reports present uniformly defined data.
Illustrations are presented of how fundamental concepts (e.g., bills, payments) can be defined differently yielding substantively different results of an analysis.
May/Jun 2019 FSC Newsletter
This issue posits that one common fiction in the utility industry is the ability to compare the extent to which one utility performs in its collections simply by comparing the average dollars of arrears between utilities.
Using the "bills behind" statistic (also known as "weighted arrears") developed by the Pennsylvania PUC's Bureau of Consumer Services,
this issue applies the "bills behind" analysis to fifteen regulated gas and electric utilities for three years (2011, 2014, 2017) to determine how comparisons would differ.
It finds that collections performance, when accounting for the average level of the underlying bills, dramatically differs.
Mar/Apr 2019 FSC Newsletter
This issue examines the inherent conflict between the environmental compliance obligations imposed on local water/wastewater utilities, requiring extensive financial investments,
and the need to maintain bill affordability in order to collect sufficient revenue to repay the borrowing undertaken to meet those obligations.
The issue explains the affordability concerns expressed by the Rhode Island State Treasurer.
It also reviews the report which FSC prepared for the Baltimore City Council documenting, on an individual Census tract basis,
both the impact which Baltimore's environmental compliance spending has on bill affordability, and the adverse impact which that deterioration in affordability will have on bill collectability.
Jan/Feb 2019 FSC Newsletter
A low-income bill affordability program can generate benefits to the utility offering the program
even in those instances where the "benefits" do not exceed the "costs" of the program.
The difference lies in the distinction between "cost-effectiveness" analysis and "cost-benefit" analysis.
This issue explains the difference in analytic approaches.
Nov/Dec 2018 FSC Newsletter
The general approach to defining the affordability of utility bills is to examine bill burdens, bills as a percentage of annual household income.
This issue explains why care must be taken in any assessment of the affordability of a particular low-income program to ensure that collection outcomes that occur on a monthly basis
are not attributed to factors that are determined on an annual basis.
The issue explains how to ensure that the measurement of affordability is using the same scope as the definition of affordability.
Sep/Oct 2018 FSC Newsletter
Many times, stakeholders involved with discussions about the affordability, or unaffordability, of home energy and/or water bills treat affordability as though it were a toggle.
Under this approach, a bill is either affordable or it is not. This issue challenges that notion
and explains multiple dimensions of bill unaffordability (e.g., depth of unaffordability) which leads to new insights into how to address nonpayment of bills.
Jul/Aug 2018 FSC Newsletter
Many, if not most, state utility regulatory commissions in the United States today offer special protections against the disconnection of service for nonpayment
when there is a "medical necessity" for the service or a medical "emergency" facing the customer.
The question of whether one Rhode Island utility should be allowed to automatically recover the costs of implementing such a regulation,
and what factors go into determining such costs, is discussed in this issue.
May/Jun 2018 FSC Newsletter
The Philadelphia Water Department ("PWD") sought to implement a straight discount program to serve low-income customers.
The discount would make bills affordable to the extent that a customer had income equal to the average city-wide income coupled with consumption equal to the average city-wide consumption.
Disaggregating the city into neighborhoods called "Public Use Microdata Areas" ("PUMAs"), this issue explains and
quantifies the over- and under-payments that the PWD proposal would generate as a result of the degree to which income and bills in different parts of the City diverge from the city-wide average.
Mar/Apr 2018 FSC Newsletter
The financial impact to a municipal water utility of allowing low-income households to earn bill credits
toward arrearages that pre-exist the household's enrollment in a bill affordability program has long presented itself.
This issue reviews an analysis of low-income arrearages on the Philadelphia Water Department system
and how their earned "forgiveness" will affect actual cash received by the water utility.
Jan/Feb 2018 FSC Newsletter
This issue presents Part 3 of a three-part series that describes FSC's New Hampshire testimony regarding how to quantify and dollarize
the non-energy impacts of low-income energy efficiency investments. This issue focuses on how studies frequently under-value low-income NEIs.
Nov/Dec 2017 FSC Newsletter
This issue presents Part 2 of a three-part series that describes FSC's New Hampshire testimony regarding the non-energy impacts of low-income energy efficiency investments.
This issue focuses on presenting the dollarized low-income benefits found by various studies of NEIs around the nation.
Sep/Oct 2017 FSC Newsletter
This issue presents Part 1 of a three-part series that describes FSC's testimony before the New Hampshire Public Utilities Commission ("NHPUC")
regarding the non-energy impacts of low-income energy efficiency investments. This issue focuses on why NEIs should be taken into account.
Jul/Aug 2017 FSC Newsletter
This issue describes how local cost-of-living intersects with the level of home electric bills to affect any analysis of home energy affordability.
Using California data from the Census and from the Community Council for Economic Research ("C2ER"), of the American Chamber of Commerce Association ("ACCRA"),
FSC considers the impact of cost-of-living on home energy affordability.
May/Jun 2017 FSC Newsletter
One concern frequently expressed about bill affordability programs in which bills are set equal to an affordable percentage of income
is that such programs eliminate any incentive for customers to conserve energy.
This issue summarizes the various empirical evaluations that, over the past 30-plus years, have examined whether usage increases do, indeed, occur.
Mar/Apr 2017 FSC Newsletter
Utilities frequently use non-utility credit reports to establish creditworthiness for utility service and/or clean energy programs.
This issue discusses why the use of credit information from external information providers, not using utility payment experience,
is inappropriate, while unreasonably and disproportionately harming low-income households.
Jan/Feb 2017 FSC Newsletter
One question often posed in response to proposals to impose restrictions on a utility's authority to disconnect service to protected classes
is whether the protected customers will simply stop making payments.
This issue discusses recent research examining whether shutoff restrictions protecting customers with medical emergencies result in an increase in utility bill nonpayment.
Nov/Dec 2016 FSC Newsletter
The Earned Income Tax Credit (EITC) is commonly referred to as the nation's largest anti-poverty program.
This issue reviews the literature documenting that households receiving EITC benefits use those additional dollars,
in large part, to pay utility bills, including past-due utility bills.
Sep/Oct 2016 FSC Newsletter
This issue reviews recent research finding that the receipt of federal SNAP assistance (formerly known as Food Stamps)
has the effect of reducing unpaid utility bills by a substantial percentage.
The issue discusses why this might occur and how utilities might promote Food Stamp enrollment.
Jul/Aug 2016 FSC Newsletter
This issue describes the considerable learning that has occurred for service providers ranging from health care,
to early childhood education, to housing, to social service, to health insurance, and beyond on how to reach "hard to reach" populations.
May/Jun 2016 FSC Newsletter
A practice that has long been considered deceptive and abusive in the mortgage, credit card and banking industries has recently reared its head in the public utility industry as well.
The practice involves re- sequencing the "posting order" of consumer payments.
In short, the practice re-orders consumer transactions, and posts payments against those transactions out of the sequence in which they were incurred,
in order to maximize the late fee revenue that can be charged to consumers.
This issue explains the law and economics behind a prohibition of such re-sequencing practices by utilities.
Mar/Apr 2016 FSC Newsletter
The cold weather disconnection of natural gas service to an elderly Michigan customer resulted in that customer's death by hypothermia.
The disconnection occurred despite specific regulations providing cold weather shutoff protections to aging utility customers.
This issues explains that while the utility relied on what it deemed to be an offer of assistance included in the text of its winter shutoff notice,
numerous factors would have placed a reasonable utility on notice that the shutoff notice would not generate a customer contact.
In addition, the issue explains how the utility affirmatively declined to solicit information on the make-up of the customer's household
during weeks and months leading up to, and immediately after, the commencement of the cold weather protections
when such information would have notified the utility of the applicability of the shutoff restrictions.
Jan/Feb 2016 FSC Newsletter
One clear impact of a low-income bill affordability program is the extent to which such a program improves the "price signals" delivered to inability-to-pay customers through utility rates.
This issues discussed why as a general rule, utility bills represent an ineffective means to send price signals to low- income customers.
Low-income customers, particularly customers with bill burdens exceeding a prescribed level, pay less than their entire bill.
As a result, a low-income customer's inability-to-pay for utility service substantially distorts the price signal that consumer receives.
When customers cannot afford to pay their utility bills, in other words, price signals are not effective.
Improving affordability facilitates rather than impedes price signaling.
Nov/Dec 2015 FSC Newsletter
An ongoing debate today questions whether all customer sectors receive their fair share of utility energy efficiency dollars.
This issue presents the second part of a two-part series taking a closer look at questions relating to the distribution of utility usage reduction investments in affordable multi-family housing.
The discussion concludes that a principled basis in law and economics for explicitly considering the equity of utility investments in multi-family energy efficiency
can be found in "environmental justice" doctrine.
Sep/Oct 2015 FSC Newsletter
Utility investment in energy usage reduction programs today is viewed as a wise investment.
Despite its many benefits, there is an ongoing debate questioning whether all customer sectors receive their fair share of utility investment dollars.
This issue presents the first part of a two-part series taking a closer look at those questions involving "fairness,"
particularly as they relate to the distribution of utility usage reduction investments in affordable multi-family housing.
Jul/Aug 2015 FSC Newsletter
More and more proposals today involve developing an On Bill Repayment (sometimes referred to as On-Bill Financing, or OBF) regime
through which utility customers can finance energy efficiency investments.
This issue reviews OBF programs and concludes that, irrespective of the extent to which, if at all, a utility might seek to develop an OBF program for non-residential customers,
OBF is inappropriate for residential ratepayers.
May/Jun 2015 FSC Newsletter
Late payment charges are frequently a component in a public utility's arsenal of responses to residential nonpayment and late payment.
However, both the level of a late payment charge and the decision to impose a late payment charge may not be appropriate in all situations.
This issue presents an annotated model state utility commission regulation that governs when late charges should be allowed and how much they should be.
Mar/Apr 2015 FSC Newsletter
Fisher, Sheehan and Colton (FSC) was recently asked to prepare an annotated model state utility commission regulation
governing the disconnection of service to properties where the customer was not also the resident of the premises which would lose service.
This issue presents FSC's model regulation governing service disconnections to residential tenants.
Jan/Feb 2015 FSC Newsletter
As proposals expand to provide ratepayer-funded rate affordability assistance today --places such as Colorado and Illinois have added affordability programs in recent years--
one question that arises involves the reaction of members of the public who are called upon to pay for such programs.
This issue summarizes a series of public opinion surveys documenting the extent to which, if at all, the public is willing to pay increased rates to fund affordability programs.
Nov/Dec 2014 FSC Newsletter
Despite its many benefits, there is an ongoing debate regarding the equities of utility investments in usage reduction programs.
The debate questions whether all customer sectors receive their fair share of utility investment dollars. Employing principles of environmental justice,
FSC recently authored a white paper taking a closer look at those questions involving "fairness,"
particularly as they relate to the distribution of utility usage reduction investments in affordable multi-family housing.
Sep/Oct 2014 FSC Newsletter
A proposed inclining block rate structure (IBR) delivers affordability benefits to low-income customers even outside the confines of a low-income discount.
This issue explains the testimony that FSC recently filed with the Minnesota public utilities commission,
in an Xcel Energy electric rate case on behalf of the Energy CENTS Coalition, supporting the inclining block rate structure proposed by the Minnesota Center for Environmental Advocacy (MCEA).
Jul/Aug 2014 FSC Newsletter
The Low-Income Home Energy Assistance Program (LIHEAP) is one of the critical sources of direct federal fuel assistance in the nation today.
The LIHEAP statute allows the President to "release" emergency or "contingency" funds if the President finds that any one of several statutorily-prescribed conditions exists.
This issue describes a mechanism recently prepared by FSC to track the compounded impact of fuel prices and weather on the adequacy of LIHEAP in any given year.
This Fuel Assistance Tracking Mechanism (FATM) is presented as a useful tool in deciding whether and to what extent the release and distribution of LIHEAP contingency funds is merited.
May/Jun 2014 FSC Newsletter
The public health consequences of service terminations sometimes require that service terminations for nonpayment be delayed or avoided.
This issue presents an annotated model regulation regarding "medical certificates" that FSC has prepared for consideration by state regulators.
Mar/Apr 2014 FSC Newsletter
One of the primary ways to reduce home energy bills, and thus improve affordability, for low-income households is through the pursuit of energy conservation measures.
One measure commonly recommended is the reduction of hot water temperatures in the home to 120 degrees (F).
This issue explains why while reducing hot water temperature to 120 degrees at the tap may be appropriate, reducing temperatures to 120 degrees in the tank may have adverse public health consequences.
Jan/Feb 2014 FSC Newsletter
The discussion in this issue outlines some of the problems that FSC identified with utility allowances that had been promulgated for a Hawaii project-based Section 8 development using an "engineering" analysis.
FSC reports that the promulgation of a utility allowance through an "engineering" analysis cannot be completely divorced from actual consumption levels by public or Section 8 tenants.
The reasonableness of an "engineering" analysis can, and must, be tested against the usage actually occurring within the tenant population.
Nov/Dec 2013 FSC Newsletter
As resources become tighter for distribution as home energy assistance, one eligibility limitation that some program administrators seek to impose involves an assets test.
Through an assets test, an otherwise income-eligible household might be excluded from receiving assistance if they own assets with a value beyond prescribed limits.
This issue sets forth the basis for concluding that for the federal Low-Income Home Energy Assistance Program (LIHEAP), use of an assets test in eligibility determinations is inappropriate.
In any event, the use of an assets test is difficult (and expensive) to administer and contrary to public policy.
Sep/Oct 2013 FSC Newsletter
This issue examines whether state utility commissions are authorized to review the Red Flags Plans of public utilities.
It concludes that assertions that state regulatory oversight of identity theft prevention by public utilities is pre-empted by the FCRA is not well-founded.
Regulatory commissions can assert jurisdiction under the traditional "just and reasonable" test for reviewing the provision of utility service,
so long as state commission action is not inconsistent with conduct required by the Fair and Accurate Credit Transactions Act.
Under FaCTA, states remain free to impose further requirements and prohibitions in areas in which the federal law is silent, as well as supplemental requirements and prohibitions.
Jul/Aug 2013 FSC Newsletter
This issue provides information on ways in which utilities have engaged in storm response and storm preparedness actions specifically as those actions relate to public communication with residential customers.
Providing adequate communication during storm events is generally found to be a customer service obligation of a state's utilities.
The discussion is based on a review of more than 50 storm preparation assessments from around the nation.
May/Jun 2013 FSC Newsletter
In response to the growing use of Social Security Numbers (SSNs) in the crime of identity theft, state regulators should take steps to control the collection and dissemination of SSNs by public utilities.
This issue reviews comments filed by FSC urging the Minnesota PUC to join the growing consensus that institutions such as public utilities that have collected SSNs in the past should refrain from,
or be prohibited from, collecting SSNs in the future, and that Minnesota utilities should be directed to seek out alternatives to the collection and use of SSNs.
Mar/Apr 2013 FSC Newsletter
One aspect of utility bills --be they water, natural gas or electricity-- that places a substantial financial burden on low-income households is the cash security deposit that is required
when a customer cannot establish "creditworthiness" to the satisfaction of a utility. This issue presents an annotated model regulation governing cash security deposits
that FSC prepared for consideration by state regulators. It covers issues ranging from when to ask for deposits (for new and existing customers), to when to refund deposits,
to how to set the level of deposits, to the availability of non-cash deposit alternatives.
Jan/Feb 2013 FSC Newsletter
The inability-to-pay utility bills often leads to the disconnection of service for low-income customers.
This issue presents an annotated model regulation that FSC has prepared for consideration by state regulators governing the disconnection of service for nonpayment,
including the timing and type of pre-disconnection notices.
Nov/Dec 2012 FSC Newsletter
The Maryland Public Service Commission (PSC) has been considering a legislative directive to make programmatic recommendations on how to address low-income home energy affordability.
In work for the Maryland Office of Peoples Counsel (OPC), Fisher, Sheehan & Colton (FSC) was asked to assess what business improvements would be "bought"
through implementation of a rate affordability program. This issue presents the FSC analysis on that question.
Sep/Oct 2012 FSC Newsletter
The focus of low-income energy assistance is frequently, if not generally, on "preparing for cold weather."
The concern behind such efforts is to ensure that no-one freezes to death because of their low-income status.
The discussion in this issue, however, notes various tasks that low-income service providers should undertake in various seasons.
A "to-do" list for each season is presented.
Jul/Aug 2012 FSC Newsletter
Utilities in more than half of all states in the United States have adopted low-income rate affordability programs of one sort or another.
Since these programs, by and large, are not funded through utility profits, state legislatures and regulatory commissions have created a variety of cost recovery mechanisms.
This issue summarizes the major cost-recovery options that have been adopted by states for low-income assistance programs.
May/Jun 2012 FSC Newsletter
One ongoing concern for advocates and service providers in the low-income energy field involves the difficulties
in generating price support and consumer protections for users of bulk fuels. Bulk fuels include fuels such as propane, fuel oil, and liquefied natural gas (LNG).
Despite the difficulties, there are specific strategies that can be pursued to ensure that the issue of affordable home energy is not limited simply to regulated utilities.
This issue describes a recent report that FSC prepared for the Community Action Partnership Association of Idaho (CAPAI) addressing initiatives directed toward users of propane gas.
Mar/Apr 2012 FSC Newsletter
Pennsylvania's "Responsible Utility Consumer Protection Statute" went into effect in December 2004.
Since then, the Pennsylvania PUC has filed biennial reports on the outcomes generated by that statute with the state legislature.
This issue examines the Third Biennial Report to the Legislature in concluding that the statute has interfered with access to utility service,
particularly during critical cold-weather months, without generating positive improvements in collection outcomes.
Jan/Feb 2012 FSC Newsletter
Under state law, Massachusetts natural gas and electric utilities operate "Arrearage Management Programs" (AMPs).
All utilities offering AMPs file annual data on the success of the plans in reducing low-income arrears.
This issue examines the most recent year's data (2010) in concluding that the Massachusetts AMPs fail far more frequently than they succeed
in helping low-income customers retire their arrears and fall short in generating substantive improvement in payment performance.
Nov/Dec 2011 FSC Newsletter
States continue to struggle with the issue of how, if at all, to provide "high cost support" to promote the affordability of telephone service in rural areas.
This issue reviews FSC testimony finding that the affordability of local telephone service in rural areas should be determined on a percentage of income basis.
An empirical review of telephone rates in Pennsylvania leads to the recommendation that an appropriate affordability benchmark for rural telephone service can be set at 0.75% of income.
Sep/Oct 2011 FSC Newsletter
One of the necessary tools to make available in responding to unpaid utility bills is the deferred payment arrangement (DPA).
This issue presents an annotated model DPA regulation that FSC prepared for consideration by state regulators.
Jul/Aug 2011 FSC Newsletter
"Utility allowances" provided to Section 8 tenants are a critical component of the nation's affordable housing program.
This issue reviews the adequacy of Section-8 utility allowances in Pennsylvania,
finding that those allowances do not comply with federal law and the HUD process for ensuring compliance routinely fails.
May/Jun 2011 FSC Newsletter
Considerable dispute exists over whether low-income status is affirmatively associated with low-use status.
This issue identifies cautions that must be considered when a utility bases conclusions on data derived from a study of "median incomes" in its service territory.
Mar/Apr 2011 FSC Newsletter
Housing affordability and home energy costs march hand-in-hand. This issue reviews an analysis of rental affordability in Pennsylvania
and discusses how low rents do not ensure affordability when routinely coupled with higher than normal energy costs.
Jan/Feb 2011 FSC Newsletter
Opponents of affordable rate programs for low-income customers frequently offer a set of ideologically-based objections.
This issue directly addresses three "myths" about low-income rates.
Nov/Dec 2010 FSC Newsletter
Determining the business benefits of utility rate affordability programs for low-income customers can learn much from the "business cases" built for other social programs.
This issue considers the lessons learned for utilities from "social" programs addressing things such as workplace safety, employee and board governance diversity, and multi-culturalism.
Sep/Oct 2010 FSC Newsletter
Some utilities oppose affordable rates for low-income customers as being "social ratemaking" best left to legislatures.
This issue explains the elements of a "business case" and asserts how the adoption of a low-income program is in a utility's own self-interest.
Jul/Aug 2010 FSC Newsletter
Two primary designs exist for a low-income affordable rate program: a discount program and a percentage of income program.
This issue explains the design of each and identifies the policy and program differences.
May/Jun 2010 FSC Newsletter
Energy efficiency investments directed toward lower income households can serve an important affordable housing function in Pennsylvania.
This issue explains how efficiency investments in first time home buyer programs can supplement other affordable housing programs in significant ways.
An energy efficiency partnership directed toward first time homebuyers involves every stakeholder making a contribution and every stakeholder receiving a benefit.
Mar/Apr 2010 FSC Newsletter
Utilities often seek energy efficiency strategies that leverage the benefits of utility expenditures beyond
that which might otherwise be generated through a 100% funded, direct install utility program.
This issue explains how Pennsylvania utilities might do that by promoting energy efficient utility allowances for the state's Section 8 housing units.
Jan/Feb 2010 FSC Newsletter
Utilities unquestionably benefit from the delivery of federal LIHEAP assistance. This issue discusses an under-utilized
energy assistance program, involving HUD utility allowances for public and assisted housing, that can provide both
basic assistance for monthly bills and crisis assistance.
Nov/Dec 2009 FSC Newsletter
In the world of utility collections, more is not always better. With shutoff notices in particular, several tests
should be applied to determine the propriety of engaging in such activities. Utilities that over-notice the disconnection
of service both impede the effectiveness of the notice and contribute to payment problems that need not exist.
Sep/Oct 2009 FSC Newsletter
One consumer protection commonly inserted into state public utility commission regulations restricting the disconnection
of service involves the protection of customers facing serious medical conditions. This issue discusses barriers to
the effective use of medical certificates and how utility regulators should respond.
Jul/Aug 2009 FSC Newsletter
Budget-billing is generally considered to be an effective tool for certain limited income customers to use in avoiding
short-term arrears on utility bills. This issue identifies barriers that impede the use of budget billing and discusses
how to address those barriers.
May/Jun 2009 FSC Newsletter
Under the Food Stamp program's excess shelter deduction, to the extent that a household's total shelter costs exceed
50%of the household's income, the amount of the excess is deducted from household income. As income goes down, the
amount of Food Stamps to which a household is entitled goes up. The Standard Utility Allowance (SUA) can be used to
establish household utility expenditures irrespective of the household's actual utility costs. This issue examines
certain issues in setting SUAs to ensure that SUAs accurately capture the utility costs associated with households
with high shelter costs.
Mar/Apr 2009 FSC Newsletter
What constitutes a "best-in-class" low-income utility rate affordability program? This issue summarizes
the findings of a 2008 FSC report that identifies best-in-class criteria and applies those criteria to eight different
utility programs throughout the nation.
Jan/Feb 2009 FSC Newsletter
The Iowa Utilities Board recently proposed regulations allowing electric utilities to install "service limiters"
in the homes of customers who had defaulted on deferred payment plans. This issue reviews the comments of the Iowa
Department of Human Rights explaining how and why such technology presents unreasonable health and safety risks to
Nov/Dec 2008 FSC Newsletter
National Grid, a natural gas utility serving New England, recently proposed to double the monthly customer charge
it charges residential heating customers. This issue explains the testimony filed on behalf low-income intervenors
urging that the customer charge proposal is neither consistent with economic theory nor reflective of the fixed charges
which small users impose on the utility system.
Sep/Oct 2008 FSC Newsletter
Portland General Electric Company (PGE) recently proposed a revenue decoupling mechanism in an electric rate case
before the Oregon state utility commission. This issue discusses why low-income intervenors, represented by the Community
Action Partnership of Oregon (CAPO) opposed the decoupling proposal as contrary to the interests of low-income customers.
It explains why CAPO urged that the PGE decoupling mechanism be disapproved or, if not disapproved in its entirety,
what modifications should be ordered in the proposal.
Jul/Aug 2008 FSC Newsletter
While it is universally acknowledged that home energy is an essential of modern life today, a recent study finds that
the potential loss of home energy service either through involuntary disconnections or voluntary deprivation has public
health consequences far beyond those historically discussed. This issue discusses the results of Iowa's inclusion
of energy affordability questions in its 2007 Behavioral Risk Factor Surveillance System ("BRFSS") survey.
May/Jun 2008 FSC Newsletter
Inverted block "Lifeline" rates present one mechanism for addressing rate affordability issues without special "low-income"
rates. This issue discusses how to address a "hardship alleviation" objective through rates, while at the same time
serving the public purpose of improving cost-reflectivity.
Mar/Apr 2008 FSC Newsletter
Policymakers throughout the country have addressed a number of regulatory and legal issues that are common to programs in their adoption, design and implementation.
This issue reports on the completion of a multi-state study of the authorization, design and evaluation of low-income programs in thirteen states.
Jan/Feb 2008 FSC Newsletter
As residential customers in states that have adopted retail choice face substantial price increases arising due to the expiration of price caps that have protected customers
for the past several years, increasing pressure will be brought to try to mitigate those price increases through the aggregation of low-income customers who receive benefits
through a variety of fuel assistance programs. This issue explains how state experiences to date have found that fuel assistance programs and
aggregation initiatives do not fit well together
Nov/Dec 2007 FSC Newsletter
The analysis presented below summarizes an examination of selected low-income affordability programs currently in operation around the United States as determined by the
author to be best-in-class. The purpose of the assessment was three-fold: (1) To articulate a set of standards by which to measure the design and operation of a low-
income rate affordability program; (2) To identify a set of design decisions and implementation practices that favorably distinguish particular programs from their low-
income counterparts in other states or service territories; and (3) To apply those standards, design decisions, and implementation practices to a set of programs to
determine their prevalence among best-in-class programs.
Sep/Oct 2007 FSC Newsletter
Increasingly, inverted block rates are being proposed by electric utilities and environmental advocates as a mechanism through which to provide incentives for customers to
conserve power. This issue of the FSC Newsletter considers recent testimony finding, however, that such an inverted block rate structure will harm low-income consumers if
the initial block is not appropriately structured.
Jul/Aug 2007 FSC Newsletter
Three Indiana utilities have operated low-income rate affordability programs for the past three years. The objectives of the programs, was to respond to spiraling natural
gas prices that resulted in corresponding increases in arrears, service disconnections, and bad debt. This issue examines the impacts that Indiana's low-income utility
rate affordability programs did, in fact, have on the disconnection of service for nonpayment.
May/Jun 2007 FSC Newsletter
State utility commission regulations almost universally require utilities to consider "ability to pay" in negotiating
a deferred payment plan through which to pay an arrears. This issue of the FSC Newsletter considers multiple facets of "ability
to pay" and concludes that "ability to pay" means more than simply "income."
Mar/Apr 2007 FSC Newsletter
An increasing number of utility industry stakeholders are today recognizing the benefits of generating uniform
annual reports of credit and collection data for all natural gas and electric utilities within a state. Based
on its second year of reporting, the Coalition to Keep Indiana Warm identified a set of recommendations that
would benefit both customers and companies. This issue summarizes those recommendations.
Jan/Feb 2007 FSC Newsletter
Energy efficiency investments can improve the affordability of low-income energy bills. This issue discusses
how improvements in furnace efficiency will also generate substantial benefits to developers of affordable housing
by preventing the diversion of household resources from paying housing costs to paying spiraling energy bills
Nov/Dec 2006 FSC Newsletter
Low-income utility rate discounts are designed to make bills more affordable. This issue presents evaluation
results documenting the impacts on customers payments generated by two Indiana natural gas universal service
Sep/Oct 2006 FSC Newsletter
HUD utility allowances provide an important source of energy assistance to low-income tenants. This issue discusses
how to evaluate the utility allowance provided by your local housing authority to determine whether the electric
usage provided for indoor lighting is adequate.
Jul/Aug 2006 FSC Newsletter
Spiraling fuel prices in recent years have given rise to state utility regulatory commissions finding a public health
and safety crisis and ordering the public utilities in their jurisdiction to take emergency action in response. This
issue examines the emergency actions taken by eight different state commissions.
May/Jun 2006 FSC Newsletter
Increasing utility companies are proposing to institute or increase monthly late fees directed toward residential
customers. This issue looks at the late fee proposal of one Massachusetts telephone company and concludes that the
proposed late fee was not justified on either cost or policy grounds.
Mar/Apr 2006 FSC Newsletter
This issue provides information with respect to the propriety of an automatic enrollment mechanism for telephone Lifeline
service in light of privacy concerns over the use of information on participation in certain public benefits programs.
It concludes that concerns expressed about whether federal privacy law prohibits the exchange of information are not
Jan/Feb 2006 FSC Newsletter
As natural gas and electric prices continue to spiral, an increasing number of utility stakeholders are taking notice
of the affordability impacts that arise for low-income households. Many persons, however, while they can cite various
stories of the adverse impacts of unaffordable energy on particular households, have never had occasion to develop
a comprehensive Home Energy Affordability Needs Analysis. This issue presents a template of what such a Needs Analysis
Nov/Dec 2005 FSC Newsletter
The Government of Toronto proposed to allow landlords, without the consent of tenants, to retrofit multi-family rental
units with electrical sub-meters. This issue explains why while increasing the efficiency of energy usage in residential
rental dwellings is a laudable goal, such conversions will likely impose higher costs on tenants without generating
a cost-effective reduction in energy consumption.
Sep/Oct 2005 FSC Newsletter
As state and local policymakers, in addition to nonprofit and public utility staff, seek to find additional ways in
which to offer energy assistance to low-income customers facing crisis situations with home heating bills, consideration
of the benefits of creating a statewide fuel fund is in order. This issue describes research prepared for the Iowa
Community Action Association (ICAA) reviewing the operation of statewide fuel funds across the nation and providing
answers to commonly asked questions.
Jul/Aug 2005 FSC Newsletter
The Iowa Utilities Board (IUB) has mandated that all Iowa utilities create a "customer contribution fund"
through which utility customers may donate money to support private financial assistance for low-income households.
Unfortunately, these customer contribution funds for Rural Electric Cooperatives have been less effective than perhaps
they might be. This issue describes a proposal to increase funding by asking REC customers to donate some or all of
their annual patronage capital credits to their local customer contribution fund.
May/Jun 2005 FSC Newsletter
In an effort to quantify the need for energy assistance, Fisher, Sheehan & Colton (FSC) has developed a model
that estimates the "home energy affordability gap" for the entire country. Introduced in April 2003 (using
2002 energy prices), FSC found in that initial Home Energy Affordability Gap analysis that the annual "affordability
gap" reached roughly $18.2 billion. In May 2005 (using 2004 energy prices), FSC released the third annual Home
Energy Affordability Gap analysis. This issue describes how FSC found that the shortfall between actual home energy
bills and affordable home energy bills had increased to $20.1 billion, an increase of eleven percent (11%) in just
Mar/Apr 2005 FSC Newsletter
One issue that faces a local government seeking to establish a water affordability program is how to define what level
of water bills is "affordable." This issue reviews existing literature on defining what "water burden"
(bill as percent of income) is considered "affordable," particularly with reference to the work of the National
Drinking Water Advisory Council's Small Systems Working Group.
Jan/Feb 2005 FSC Newsletter
In recent years, the unaffordability of water/sewer bills in the City of Detroit has become a substantial problem.
To address these issues, in January 2005, FSC presented a proposed water affordability program to the Detroit Water
and Sewerage Department (DWSD) on behalf of the Michigan Poverty Law Program/Michigan Legal Services and their clients.
This issue describes that water rate affordability program presented to DWSD.
Nov/Dec 2004 FSC Newsletter
State and local jurisdictions receiving federal funds through the Community Development Block Grant (CDBG) or HOME
Investment Partnership (HOME) programs must file planning documents with HUD called Consolidated Plans. This issue
describes comments that FSC filed in six different states urging the respective states to include a discussion of
energy prices in their Consolidated Plans. In addition, in each state, FSC recommended three specific remedies for
the state to include as a "strategy" to combat the adverse impacts that rising energy prices have on affordable
Sep/Oct 2004 FSC Newsletter
Households living with incomes between 135% and 150% of the Federal Poverty Level lack sufficient resources to obtain
affordable telephone service without Lifeline assistance. This issue describes comments prepared by FSC on behalf
of NASUCA describing why the Federal Communications Commission should increase Lifeline income eligibility from 135%
to 150% of the FPL.
Jul/Aug 2004 FSC Newsletter
Large natural gas users directly contribute to the unaffordable natural gas heating prices faced by the poor. This
issue explains testimony presented by FSC explaining why the industrial use of natural gas, as well as spiraling use
of gas in electricity generation (used largely by industrial and commercial customers), are substantive contributors
to the unaffordability of winter heating fuels used by low-income residential consumers.
May/Jun 2004 FSC Newsletter
More than a quarter million Missouri households face a daily struggle to cope with energy poverty - an excessive energy
cost burden that frequently affects their health and well-being. This issue explains an FSC study for the National
Low-Income Energy Consortium (NLIEC) that documents how, in addition to threatening the ability to retain service,
unaffordable home energy contributes substantially to hunger, inadequate housing, educational underachievement, health
and safety dangers, and the inability to retain employment among low-income Missouri consumers.
Mar/Apr 2004 FSC Newsletter
Some state utility commissions limit enrollment in the state's telephone Lifeline program to those low-income
households that do not subscribe to vertical services in addition to basic local service. This issue reviews a report
prepared for the Pennsylvania Office of Consumer Advocate documenting that low-income households carefully budget
their telecommunications expenditures without such prohibitions. The report further looks at the special need that
low-income disabled customers have for vertical telecomm services and at how a waiver of a prohibition on such services
might be mandated as a "reasonable accommodation" under the federal Americans With Disabilities Act (ADA).
Jan/Feb 2004 FSC Newsletter
Missouri Gas Energy (MGE) customers receiving energy assistance through that company's Experimental Low-Income
Rate (ELIR) improved their payment patterns relative to low-income customers that did not receive such rate assistance.
This issue explains FSC's evaluation of the ELIR program, and examines how the ELIR affected the completeness,
timeliness, and regularity of payments.
Nov/Dec 2003 FSC Newsletter
In June 2003, the U.S. Department of Housing and Urban Development (HUD) published a revised Public Housing Occupancy
Guidebook, adopting virtually all of the modifications relating to the calculation of utility allowances proposed
by FSC. This issue presents the new modifications relating to utility allowances included in the revised HUD Guidebook
and reviews the factual and policy basis for proposing the modifications in the first instance.
Sep/Oct 2003 FSC Newsletter
In determining income eligibility for low-income energy assistance programs, including rate affordability and rate
discount programs, public utilities may not count the value of Food Stamps received by a low-income household as “income.”
This issue presents FSC's analysis of the applicability of the federal Food Stamp statute, which provides that
“the value of benefits that may be provided under this chapter. . .shall not be considered income or resources
for any purpose under any Federal, State or local laws, including but not limited to, laws relating to taxation, welfare,
and public assistance programs, and no participating State or political subdivision thereof shall decrease any assistance
otherwise provided an individual or individuals because of the receipt of benefits under this Chapter.”
Jul/Aug 2003 FSC Newsletter
In an effort to quantify the gap between “affordable” home energy bills and “actual” home
energy bills, Fisher, Sheehan & Colton (FSC) has developed a model that estimates the “home energy affordability
gap” on a county-by-county basis for the entire country. FSC found that the annual “affordability gap”
for 2002 reached roughly $18.2 billion and that federal fuel assistance provided through the Low-Income Home Energy
Assistance Program (LIHEAP) covered just a fraction of that gap.
May/Jun 2003 FSC Newsletter
The delivery of low-income energy efficiency assistance can serve an important affordable housing function in Colorado.
This issue describes a recent FSC analysis which found that efficiency investments can: (1) increase the number of
low-income households that qualify for first time home ownership opportunities, holding income and purchase prices
constant; (2) increase the value of the home (and thus presumably the size or quality of the home) that a low-income
first time home owner can afford to buy, holding income constant; and (3) provide substantial economic subsidies to
first time homebuyers not only by providing positive cash flow on a month-to-month basis, but also by effectively
reducing interest rates or effectively reducing the overall purchase price of the home.
Mar/Apr 2003 FSC Newsletter
The delivery of low-income home energy assistance in Colorado provides a wide range of economic benefits to the state.
Frequently thought of exclusively as a way to prevent unpaid utility bills, and to preserve service against termination
for nonpayment, in fact, low-income energy assistance can also be viewed as a strategy to promote economic development
and employment (particularly in low-income communities). Energy assistance serves as an economic stimulant for the
Colorado economy in three distinct ways. In total, the Fiscal Year 2002 distribution of energy assistance in Colorado:
(1) created more than $103 million in economic activity; (2) generated more than $37 million in added earnings for
Colorado workers; and (3) supported more than 2,300 jobs for the state.
Jan/Feb 2003 FSC Newsletter
Low-income utility payment problems have a discernible empirical link to both temperature and energy prices. This
issue discusses an FSC study, based on 46 months of data from the State of Iowa, that documents the link between high
energy prices, cold temperatures and low-income payment troubles. The study then presents an FSC model that projects
the change in payment patterns based on changes in temperature and prices and assesses the cost impacts to a utility
from protecting against those changes through a “capped bill” program.
Nov/Dec 2002 FSC Newsletter
Pre-conditioning the extension of Iowa's winter shutoff moratorium on the receipt of federal fuel assistance
has the effect of disproportionately denying winter health and safety protections to Iowa's Hispanic community.
While not doing so overtly, the requirement that the winter utility shutoff moratorium extends only to households
certified eligible for LIHEAP has the effect of excluding Hispanics at a rate that is much higher than is merited
by their presence in the Iowa population. As a result, the statute may run afoul of explicit federal prohibitions
banning discrimination based on race in the extension of consumer credit.
Sep/Oct 2002 FSC Newsletter
Customers of a municipal water utility have the right to be offered deferred payment arrangements through which to
pay their arrears, even if that utility is not regulated by a state public service commission. This issue explains
three rationales for requiring a municipal water utility to offer deferred payment arrangements: (1) payment plans
are required by the utility's contract with its customers; (2) payment plans are required by the commercially
reasonable standards of the utility trade; and (3) disconnecting utility service without offering a payment plan is
an “unfair” trade practice under state statutes.
Jul/Aug 2002 FSC Newsletter
When state legislatures and public utility commissions adopt programs to redress the unaffordability of home energy,
the question of which other customers may legitimately be called upon to pay for such programs presents itself. This
analysis considers why all customer classes should bear some responsibility for a share of any charge that supports
affordability programs. These charges may involve a system benefit charge imposed on all customer classes. They may
alternatively be imposed by the allocation of the costs of such programs over the rates of all customer classes.
May/Jun 2002 FSC Newsletter
Home energy bills represent one of the highest annual expenditures in a consumer's budget. Consumers devote
roughly 20% of their total shelter expenditures, and 7% of all household expenditures, to utility service. This issue
discusses how a buying club for consumers that use fuel oil as their primary heating source can reduce consumer bills
by hundreds of dollars of per member per year, while at the same time generating a financial surplus for the buying
club that can be used for initiatives such as low-income fuel assistance and/or weatherization.
Mar/Apr 2002 FSC Newsletter
Standard regulations adopted by utility regulators around the country provide that a utility shall take into account
"ability to pay" in deciding what payment plans are "reasonable." The phrase "ability to
pay" is often treated as being synonymous with "level of income." This issue documents why taking into
account the "ability to pay" should involve more than simply taking into account income level. The stability
of income is one additional aspect of ability-to-pay, particularly for the working poor.
Jan/Feb 2002 FSC Newsletter
Public utilities often argue that a moratorium on winter utility shutoffs results in customers stopping or substantially
reducing the payments which they would otherwise make toward their winter bills. This issue discusses an FSC study,
based on 38 months of utility payment records from roughly 3,000 LIHEAP recipients in central and northwest Iowa,
which finds that the data does not support the conclusion that Iowa's low-income customers stop making their winter
bill payments when protected by a winter shutoff moratorium.
Nov/Dec 2001 FSC Newsletter
The inability to pay for home energy service generates substantial fire hazards for low-income households. This issue
documents the relationship between low-income status and fire deaths, injuries and property damage attributable to
home heating equipment. It discusses a role for the insurance industry in helping to provide low-income fuel assistance.
Sep/Oct 2001 FSC Newsletter
At the end of the 2000/2001 winter heating season, at least 4.3 million low-income households were at risk of having
their power cutoff because of an inability to pay their winter home energy bills. This issue discusses how promotion
of the federal Earned Income Tax Credit (EITC) by public utilities can bring additional resources to bear on unpaid
utility bills, thus helping both low-income customers and the utility companies which serve them.
Jul/Aug 2001 FSC Newsletter
Utility companies today are pushing to place more and more customers on meters that require customers to pay in advance.
This issue assesses the efficacy of prepayment meters for low-income households in accomplishing household budgeting
and energy usage reduction goals. It documents the existence of "hidden shutoffs" generated by the use of
prepayment meters in Great Britain.
May/Jun 2001 FSC Newsletter
The extent to which low-income customers have higher or lower energy consumption than residential customers as a whole
has significant utility rate design implications. This issue presents the available national and regional data on
the relationship between income, home energy consumption, and home energy expenditures. It documents that low-income
customers as a whole have substantially lower energy consumption than do customers on average.
Mar/Apr 2001 FSC Newsletter
When utilities provide refunds of overcharged monies, the question arises of whether the customers receiving the refunds
are the same customers who paid the overcharges in the first instance. This issue documents how, because of their
disproportionate mobility, low-income households disproportionately miss the refunds to which they are entitled and
suggests the use of cy pres principles to justify a set-aside of rate refunds for low-income programs.
Jan/Feb 2001 FSC Newsletter
Identifying low-income households and being able to deliver education and outreach to them is important, whether for
purposes of LIHEAP, or utility-funded low-income rates, or consumer protections. This issue identifies a host of potential
outreach and education partnerships, ranging from free and reduced school lunch programs, to the delivery of child
immunizations, to the delivery of smoke detectors in "distressed" communities.
Nov/Dec 2000 FSC Newsletter
The provision of utility allowances to residents of public and assisted housing subsidized through the U.S. Department
of Housing and Urban Development (HUD) is a major source of energy assistance to low-income households. These utility
allowances, however, systematically underpay tenants for their hot water consumption. This issue identifies and evaluates
factors to be used in determining an appropriate level of assistance to be paid for hot water.
Sep/Oct 2000 FSC Newsletter
Sharp escalations in home energy bills can be used to increase a low-income household's receipt of Food Stamps each
month. This issue explains the process for calculating the utility cost component of the "excess shelter deduction"
used in determining a household's eligibility for Food Stamps as well as the level of Food Stamps to which a household
Jul/Aug 2000 FSC Newsletter
PSNH mergers: right to individual consideration
New Jersey universal service: schools and libraries
Avista (Washington State) low-income electric rate
May/Jun 2000 FSC Newsletter
Missouri mergers: low-income outreach
New Hampshire low-income administration
Mobile home park abuses, damages or restitution?
Low-income electric/natural gas aggregation
Mar/Apr 2000 FSC Newsletter
One mechanism increasingly relied on today to enroll low-income households in multiple public assistance programs,
while avoiding the need for multiple application processes, involves the use of participation in one program to establish
eligibility for another. This issue considers how an exclusive reliance on participation in public benefit programs
as a means to establish eligibility for telephone Lifeline programs, without providing an additional alternative entrée
to Lifeline benefits based on a determination of income, may systematically exclude lawful immigrants from program
Jan/Feb 2000 FSC Newsletter
Colorado low-income merger settlement
Pennsylvania low-income natural gas settlement
Knowing inclusion of unenforceable lease terms
Nov/Dec 1999 FSC Newsletter
Public Service of Colorado merger
Alternative electric budget payment plans
Mobile home sales conflicts
Sep/Oct 1999 FSC Newsletter
Ameritech Ohio adopts technology fund
Occupational safety and volunteers
Delaware HERS education
Jul/Aug 1999 FSC Newsletter
Measuring electric restructuring impacts
Occupational exposure to TB in homeless shelters
Measuring electric restructuring impacts
Merger of Fleet Financial Services and Bank Boston
New Jersey natural gas restructuring
Evaluating mobile home fees
May/Jun 1999 FSC Newsletter
Bell Atlantic (Pennsylvania) Lifeline Services
Planning a consumer education program
Measuring LIHEAP's performance
Mar/Apr 1999 FSC Newsletter
Colorado legislature: electric competition
Funding local land trusts
Group homes for the disabled
Y2K and small energy efficiency contractors
Jan/Feb 1999 FSC Newsletter
HUD CDBG Performance Regulations
Mobile home park closures
Federal electric restructuring
Low-income "data mining" for utilities
Nov/Dec 1998 FSC Newsletter
Public Housing utility allowances: Tallahassee
Bankruptcy settlement: May Dept. Stores
Low-income energy efficiency
Sep/Oct 1998 FSC Newsletter
Natural gas prices by customer class
Bank fingerprinting of non-account-holders
Weatherization of group homes for the disabled
Jul/Aug 1998 FSC Newsletter
New Hampshire Electirc Assistance Program
Colorado rate affordability
Baseload energy efficiency in Iowa
Health purchasing cooperatives
Universal service performace measurement
Insurance industry role in energy efficiency
May/Jun 1998 FSC Newsletter
Virginia electric restructuring
Illinois mobile home fees
Affordable housing and education
Obligation to serve in competitive electric industry
Energy efficiency and first time homebuyers
LIHEAP performance measurement