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./p>
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
programs.
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
well-founded.
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
should contain.
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
three years.
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
housing programs.
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
is entitled.
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
participation.
Jan/Feb 2000 FSC Newsletter
Colorado low-income merger settlement
Pennsylvania low-income natural gas settlement
LIHEAP integration
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
SBC/Ameritech merger
Public Housing utility allowances: Tallahassee
Bankruptcy settlement: May Dept. Stores
Low-income energy efficiency
Telecommunications competition
Sep/Oct 1998 FSC Newsletter
Natural gas prices by customer class
Hospital mergers
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