Restructuring the electric utility industry poses substantial risks to low-income and hard-to-serve customers. Advocates for these customers believe that competition is likely to increase rates, decrease service, and reduce consumer protections for low-income consumers.

Universal service protections flowing out of electric restructuring legislation and regulatory decisions have uniformly incorporated mechanisms to fund universal service assistance. These funding mechanisms provide dollars for rate affordability assistance, crisis assistance, and low- income energy efficiency.

Universal service decisions have also addressed the issue of ensuring that low-income and hard-to- serve customers will have some company to provide service to them. These service providers are often known as a "provider of last resort." Different provider of last resort models have been advanced. FSC recommends a model based on reinsurance facility concepts in personal lines of insurance.

A third universal service issue addressed in electric restructuring decisions involves the ongoing "obligation to serve" or "duty to serve" by distribution utilities and by competitive service providers. The duty to serve traditionally requires a supplier of electricity to serve all those who seek service, on reasonable and nondiscriminatory terms, and at reasonable rates. FSC recommends a continuation of the duty to serve for distribution utilities and the imposition of a duty to serve on competitive generation providers.