PURA’s Notice of Request for Written Comments in Docket No. 17-12-03RE11 PURA Investigation into Distribution System Planning of the Electric Distribution Companies - New Rate Design and Rates Review. Send your comment before the July 15th deadline!

BACKGROUND:

We need an equitable low-income discount rate of electricity as a critical part of a larger strategy to make energy more affordable for low-income, energy burdened households as Connecticut moves toward a cleaner and more efficient grid.

Connecticut has one of the highest electricity rates in the nation, and the impact of high rates is inequitable. The statewide average energy burden (household energy expenditures like electric, gas, heating fuel divided by annual household income) is 3%, while most of our cities experience rates of 6% or higher. Household energy burden that's higher than 6% is considered energy burdened and anything above 10% is considered severe.

Low-income households, renters and homes with older appliances, and electric heating, are more likely to experience higher energy burden. This can mean choosing between food and electricity bills. Two studies in the last year have illustrated the impacts of high energy burden in Connecticut. The Trinity College Action Lab reported on the energy burden in Hartford’s Upper Albany neighborhood where the average energy is 7.6% but can be as high as 27%. "Energy Insecurity in Connecticut,” a study coordinated by Operation Fuel, Vermont Law School and Yale University, further explores the data on energy burdened residents and the impact energy burden has on health and well-being. Both studies interviewed residents to learn the impact of energy burden on individuals.

Additionally, the health and climate costs associated with burning fuels inside buildings is also disproportionately felt by low-income households.

To address these issues, we recommend the following  as PURA continues to develop this policy:

• PURA should establish an equitable low-income discount rate
• Connecticut should join other states in establishing a low-income discount rate & set a lower target for energy burden. PURA established a target that enables residential customers to spend no more than six percent of their household income on building energy costs. A six percent energy burden target would not be an equitable outcome, and would not lessen social inequities. It would maintain the disproportionate impact of energy burden. PURA needs to aim for a more equitable three percent target.
• Low-income discount rate should be easily accessible
• PURA should ensure that low-income customers can easily access the low-income discount rate, such as automatic enrollment for residents enrolled in other means-tested programs.
• Other energy assistance programs should not be reduced
• The establishment of a low-income discount rate should be an addition to existing energy assistance programs, not a replacement for any existing programs.
• PURA should minimize the impact on rates through energy efficiency and other mechanisms. PURA has decided other ratepayers will absorb the costs associated with the discount rate; to lessen the impact on rates, we need to require the utilities to drive down consumption through energy efficiency and other mechanisms.

Pairing energy efficiency with the low-income discount rate will further reduce costs for low-income customers and will also reduce the overall impact to rates. Energy burdened households are keenly aware of what needs to be done to reduce electricity use, but often have little control over the efficiency of their homes either because they rent or because they cannot afford the upfront costs of energy saving home upgrades and new, more efficient appliances. The utilities should provide services through the energy efficiency program and by fully funding the cost of resilience based energy retrofits (such as home energy audit, weatherization, insulation, appliance and space and water heater replacement). Efficiency upgrades should include replacement of any appliances and equipment determined to be inefficient with the most efficient, all-electric alternatives. Doing so will have the added benefits of helping to meet Connecticut’s greenhouse gas reduction law, and reduce indoor air pollution and associated health costs.

• We also recommend that PURA explore other mechanisms to reduce energy use to coordinate with the low-income discount rate.
• PURA should end reconnection fees

Reconnection fees are unnecessary penalties on people already struggling to pay their bills. We urge PURA to end the practice of reconnection fees.

• PURA should consider an all-electric discount rate

Due to our state’s high electric rates, fuel switching from natural gas to using electric heat pumps often results in higher utility bills (unless combined with solar). In the majority of the country, the opposite is true; electrification with heat pumps results in lower energy bills. Regardless of utility rates, electrification results in lower energy consumption, lower fossil fuel emissions, and reduced health impacts from which our disadvantaged communities can benefit the most. Because fuel switching provides our state so many benefits, PURA should investigate ways to make this an attractive and financially sustainable option for our residents to implement solar and heat pump combinations which will allow energy equity and protect both people and the environment we live in