Part B – Pre-filed Testimony of John Howat 
THE OFFICE OF EDUCATION, OUTREACH, ANDENFORCEMENT 

BEFORE THE PUBLIC UTILITIES REGULATORY AUTHORITY OF CONNECTICUT

PURA Investigation into Distribution )

System Planning of the Electric Distribution )

Companies – New Rate Designs ) Docket 17-1203RE11

and Rate Reviews )

DIRECT TESTIMONY AND EXHIBITS OF 

JOHN HOWAT 

ON BEHALF OF 

April 26, 2021 
I. Introduction............................................................................................................ 1 

II. Affordability Challenges........................................................................................ 7 

III. Low-Income Utility Payment Difficulties and the Threat to Health and Safety 

from Loss of Service....................................................................................................... 17 

IV. Bill Affordability Programming .......................................................................... 22 

V. Analysis of Prospective Tiered Discount Program Costs and Benefits............... 36 

VI. Conclusions.......................................................................................................... 43 

TABLE OF CONTENTS 

EXHIBITS 

Exhibit JH-1 – Testimony, and Comments of John Howat 

Exhibit JH-2 – Eversource Disconnections by Zip Code 

Exhibit JH-3 – Eversource Bill Impact Estimates 

Exhibit JH-4 – United Illuminating Bill Impact Estimates 
1 I. Introduction 

2 Q. PLEASE STATE YOUR NAME, JOB TITLE, EMPLOYER AND 

3 BUSINESS ADDRESS. 

4 A. My name is John Howat. I am a Senior Policy Analyst at the National Consumer 

5 Law Center (“NCLC”), 7 Winthrop Square, Boston, Massachusetts 02110. The 

National Consumer Law Center is a non-profit law and policy advocacy 

organization using expertise in consumer law and energy policy to advance 

consumer justice, racial justice, and economic security for low-income families 

and individuals in the United States. 

6 

7 

8 

9 

10 

11 Q. PLEASE DESCRIBE YOUR PROFESSIONAL BACKGROUND AND 

12 EXPERIENCE. 

13 A. Over the past 21 years at NCLC, I have managed a range of regulatory, 

legislative, and advocacy projects across the country in support of low-income 

consumers’ access to utility and energy-related services. I have been involved 

with the design and implementation of energy affordability and efficiency 

programs, regulatory consumer protections, transportation electrification, rate 

design, home energy improvement financing, issues related to metering and 

billing, credit scoring and reporting, energy burden and demographic analysis. 

In addition, I have presented at national conferences, including for the National 

Community Action Partnership, National Community Action Foundation, 

National Association of Regulatory Utility Commissions, and National 

Association of State Utility Consumer Advocates, National Energy Assistance 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

1 
1 Directors Association, National Energy and Utility Affordability Coalition, and 

2 the National Governors Association. 

3 

4 I am the co-author of Access to Utility Service, a law and policy manual published 

by NCLC, and the 2016 Lawrence Berkeley National Laboratory report, 

“Recovery of Utility Fixed Costs: Utility, Consumer, Environmental and 

Economist Perspectives.”1 I am the primary author of “Home Energy Costs: The

New Threat to Independent Living for the Nation’s Low-Income Elderly,”2 

“Tracking the Home Energy Needs of Low-Income Households through Trend 

Data on Arrearages and Disconnections,” 3 “Rethinking Prepaid Utility Service: 

Customers at Risk,”4 and “Public Service Commission Consumer Protection Rules 

and Regulations: A Resource Guide.”5 My list of filings before state regulatory 

commissions is included as Attachment JH-1. 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 I have been professionally involved with energy program and policy issues since 

1981. Prior to joining the Advocacy Staff at National Consumer Law Center, I 

consulted with a broad range of public and private entities on issues related to 

utility industry restructuring. Previously, I worked as Research Director of the 

Massachusetts Joint Legislative Committee on Energy, Economist with the 

Electric Power Division of the Massachusetts Department of Public Utilities, and 

Director of the Association of Massachusetts Local Energy Officials. I have a 

Master’s Degree from Tufts University’s Graduate Department of Urban and 

16 

17 

18 

19 

20 

21 

22 

2 
 

1 Environmental Policy and a Bachelor of Arts Degree from The Evergreen State 

2 College. 

3 

4 Q. HAVE YOU TESTIFIED PREVIOUSLY BEFORE STATE PUBLIC 

5 UTILITIES COMMISSIONS? 

6 A. I have presented testimony before utility regulatory commissions in Alabama, 

7 Arizona, California, Idaho, Illinois, Indiana, Louisiana, Maryland, Massachusetts, 

Missouri, New Mexico, Nevada, North Carolina, Pennsylvania, Rhode Island, 

South Carolina, Texas, Vermont, Virginia, Washington State, and Wisconsin. A 

list of my Testimony delivered over the past 21 years is attached as Exhibit JH-1. 

8 

9 

10 

11 

12 Q. ON WHOSE BEHALF ARE YOU TESTIFYING? 

13 A. I am testifying on behalf of the Connecticut Public Utilities Regulatory 

14 Authority’s (“PURA”) Office of Education, Outreach and Enforcement (“EOE”). 

15 

16 Q. WHAT ARE THE PURPOSES OF YOUR TESTIMONY? 

17 A. The purposes of my testimony are to (1) address issues related to the affordability 

of home electricity service and the need in Connecticut for enhanced affordability 

programming, (2) identify and describe appropriate programmatic responses to 

affordability challenges, (3) provide cost and benefit estimates of companyspecific “tiered discount” and “straight discount” programs, and (3) recommend 

that PURA direct Eversource and United Illuminating (“UI”) to submit detailed 

plans to implement tiered discount programs for income-eligible residential 

18 

19 

20 

21 

22 

23 

3 
1 customers to operate in conjunction with effective arrearage management 

2 programs. 

3 

4 Q. PLEASE SUMMARIZE YOUR KEY POINTS AND 

5 RECOMMENDATIONS. 

6 A. Testimony that follows will present evidence demonstrating the following: 

7  Low-income households served by Eversource and UI carry heavy 

home electricity burdens, much higher than those households with 

more stable, higher income. 

8 

9 

10  Eversource’s and UI’s low-income, “hardship” customers carry past 

due account balances in greater numbers and at higher levels than 

“general residential” customers who have not been identified as 

having income that would qualify them to participate in the 

Connecticut Energy Assistance Program or other available meanstested energy assistance programs. 

11 

12 

13 

14 

15 

16  UI and Eversource hardship customer arrearage rates are 2- to 3-

17 times higher than those of general residential customers. 

18  The average dollar values of arrearages is much higher for hardship 

customers and has increased over the past year since the onset of the 

COVID-19 pandemic. 

19 

20 

21  Examination of Eversource zip code level disconnections reveals a 

strong correlation between race and disconnections. (UI was unable 

to provide zip code level disconnections data.) 

22 

23 

4 
1  For many families and households in Connecticut, income in excess 

of 300% of the federal poverty guidelines is required to pay for the 

most basic necessities. 

 Nearly 35% of Connecticut’s population lives at or below 300% of 

poverty. 

 Elevated rates of low-income service disconnections and bill 

payment pressures pose a threat to the health and safety of customers. 

 Unaffordable home energy bills lead many low-income households 

to resort to unsafe and unhealthy means of heating their homes, or to 

forego other basic necessities to retain access to utility service. 

 Distinct from the straight discount program design, the tiered 

discount approach brings the electricity burdens of the lowest-income 

participants to a level that is more manageable than that which would 

be provided under the straight discount model. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 Based on these findings, I will recommend the following: 

16  PURA should direct Eversource and UI to implement low-income 

customer affordability programs that meet the following objectives: 

o Serves all residential electricity customers at or below 60% of the 

state median income eligible to participate in the Low Income 

Home Energy Assistance Program (“LIHEAP”);

o Lowers program participants’ electricity burdens to an affordable 

level; 

17 

18 

19 

20 

21 

22 

5 
1 o Promotes regular, timely payment of electric bills by program 

participants; 

o Comprehensively addresses payment problems associated with 

program participants’ current and past-due bills; 

o Is funded through a mechanism that is reliable while providing 

sufficient resources to meet policy objectives over an extended 

timeframe; and 

o Is administered efficiently and effectively. 

2 

3 

4 

5 

6 

7 

8 

9  PURA should direct Eversource and UI to expeditiously develop and 

file plans to implement tiered discount programs modeled after those 

currently operating in New Hampshire. Development of 

implementation plans should be in collaboration with EOE and other 

stakeholders. 

 Program benefits levels should be set to reduce participant payments 

to achieve target electricity burden levels of either 

o 5% for all participants, or 

o 4% for non-heating customers and 6% for electric heating 

customers. 

 Eversource and UI should continue to offer arrearage management 

programs operating in conjunction with tiered low-income rates. 

 Program funding should come from non-bypassable, uniform 

volumetric charges – approved prior to program implementation – on 

all UI and Eversource customers. 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

6 
 

1 The term “electricity burden” refers to the proportion of household income devoted to electric bill 

payment. 

1  Administrative structures and procedures that apply to the state’s 

LIHEAP should be “piggybacked” onto any new electricity

affordability program to create administrative efficiencies. 

2 

3 

4 

5 II. Affordability Challenges 

6 Q. PLEASE PROVIDE EVIDENCE OF AFFORDABILITY CHALLENGES 

FACED BY LOW-INCOME CUSTOMERS OF EVERSOURCE AND 

UNITED ILLUMINATING. 

7 

8 

9 A. Many low-income customers struggle to maintain basic electricity service. Lowincome bill payment challenges experienced by Eversource’s and UI’s lowincome customers are partially explained through examination of federal poverty 

guidelines, data relative to income required by various family types to pay for 

basic necessities, residential customer expenditure data, and credit and collections 

data. Review of these data sets demonstrates that low-income households carry 

heavy home electricity burdens1

, much higher than those households with more 

stable, higher income. For example, as illustrated below, a two-person household 

income at 100% of the federal poverty level in the UI service territory shoulders 

an electricity burden that is more than 5 times higher than that of a household with 

annual income of $100,000. 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

7 
Figure 1 

 

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29.4% 

10.9% 

8.4% 7.2% 5.4% 3.8% 2.3% 1.9% 

0.0% 

5.0% 

10.0% 

15.0% 

20.0% 

25.0% 

30.0% 

35.0% 

Unequal Burdens 

Electricity Expenditures as a Proportion of Household 

Income: 

United Illuminating 

 

1 

2 

3 Sources: 2021 Poverty Guidelines, UI-EOE 3. 

In addition to receiving bills that are very high relative to household income, 

Eversource’s and UI’s low-income, “hardship” customers carry past due account 

balances in greater numbers and at higher levels than “general residential” 

customers who have not been identified as having income that would qualify them 

to participate in the Connecticut Energy Assistance Program or other available 

means-tested energy assistance programs. The charts below, based on Eversource 

and UI responses to EOE discovery requests, show the gap in arrearage rates 

between general residential customers and hardship customers for both 

companies.2 

4 

5 

6 

7 

8 

9 

10 

11 

12 

2 Please note that the charts illustrating UI arrearage rates and levels reflect only those customers with 

seriously past due accounts of 60 days or more. Eversource was unable to compile a response reflecting 

8 
60+ Day Residential Arrearage Rate - United Illuminating 

90% 

80% 

70% 

60% 

50% 

40% 

30% 

20% 

10% 

0% 

2019 2020 

General Residential Hardship 

Jan 

Feb 

Mar 

Apr

May 

Jun

Jul

Aug

Sep 

Oct 

Nov

Dec 

Jan 

Feb 

Mar 

Apr

May 

Jun

Jul

Aug

Sep 

Oct 

Nov 

Dec 

--------------------------~,-----~------

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

Residential Arrearage Rate - Eversource Electric 

2019 2020 2021 

General Residential Hardship 

Jan 

Feb 

Mar 

Apr

May 

Jun

Jul

Aug

Sep 

Oct 

Nov

Dec 

Jan 

Feb 

Mar 

Apr

May 

Jun

Jul

Aug

Sep 

Oct 

Nov

Dec 

Jan 

Feb 

 

1 Figure 2

2 

3 Source: Eversource-EOE 2, 3. 

4 Figure 3 

5 

6 Source: UI-EOE 2, 3 

arrearages by vintage. Thus, the charts illustrating Eversource residential customer arrears reflect all 

accounts, rather than those only of customers with accounts 60 days or more past due. 

9 
Average Residential $ Arrearage - Eversource Electric 

$6,000 

$2,000 

$1,000 

$3,000 

$4,000 

$5,000 

$0 

2019 2020 2021 

General Residential Hardship 

Jan 

Feb 

Mar 

Apr

May 

Jun

Jul

Aug 

Sep 

Oct 

Nov

Dec 

Jan 

Feb 

Mar 

Apr

May 

Jun

Jul

Aug 

Sep 

Oct 

Nov

Dec 

Jan 

Feb 

1 The graphs above show that over the past 2 years, hardship customer arrearage 

rates are at least 2- to 3-times higher than those of general residential customers. 

As discussed in greater detail below, the gaps in arrearage rates are directly 

attributable to household income and expense circumstances, and income that is 

inadequate to pay for basic monthly necessities. 

2 

3 

4 

5 

6 

7 In addition to a gap in arrearage rates between low-income and non-low-income 

electricity customers, the Companies’ data show that the average dollar value of 

low-income household arrearages is also far higher than that of their higherincome counterparts. This dynamic is illustrated in the charts below. 

8 

9 

10 

11 Figure 4 

12 

13 Source: Eversource-EOE 2, 3 

10 
 

$2,500 

Average 60+ Day Residential $ Arrearage - United 

Illuminating 

$500 

$1,000 

$1,500 

$2,000 

$0 

2019 2020 

Jan 

Feb 

Mar 

Apr

May 

Jun

Jul

Aug

Sep

Oct 

Nov

Dec 

Jan 

Feb 

Mar 

Apr

May 

Jun

Jul

Aug

Sep 

Oct 

Nov 

Dec 

General Residential Hardship 

 

1 Figure 5 

2 

3 Source: UI-EOE 2, 3. 

4 Perhaps attributable the economic impacts of the COVID-19 pandemic, the 

average dollar value of arrears has increased substantially, particularly for 

hardship customers of both companies, beginning in March, 2020. However, even 

before the onset of COVID-19, the average dollar value of arrear was, 

unsurprisingly, much greater for those households struggling to make ends meet. 

5 

6 

7 

8 

9 

10 Q. ARE THERE RACIAL JUSTICE RAMIFICATIONS OF 

11 UNAFFORDABLE ELECTRIC BILLS? 

12 A. Yes. In addition to the arrearage data describes above, I examined zip code level 

disconnections data by provided by Eversource.3 

 This examination entailed 

matching zip code-level American Community Survey race and population data 

13 

14 

3 UI was unable to provide data on service disconnections by zip code. 

11 
 

 

 

 

 

TotDisconnRate PercentNonWhite 

TotDisconnRate Pearson Correlation 1 .774** 

Sig. (2-tailed) .000 

N 248 236 

PercentNonWhite Pearson Correlation .774** 1 

Sig. (2-tailed) .000 

N 236 245 

1 with the zip code-level disconnections data provided by Eversource. I then 

calculated total disconnections by zip code over the period from January 2019 –

February 2021 and created a ratio of total disconnections to total residential 

accounts for each of the zip codes served by Eversource. Finally, I sorted and 

ranked zip codes by percent of the population consisting of people of color and 

Latinx people (Non-white population). 

2 

3 

4 

5 

6 

7 

8 The data show a striking correlation between race/ethnicity and service 

disconnections. The table provided as Exhibit JH-2 shows that among the 20 zip 

codes with the highest disconnections ratio, 12 were among the top 20 zip codes 

with the highest people of color/Latinx populations. The top 20 disconnection 

ratios and the top 20 non-white population cells are shaded in the table provided in 

Exhibit JH-2 to more clearly illustrate the relationship between race and service 

disconnections. 

9 

10 

11 

12 

13 

14 

15 

16 As illustrated below, the correlation analysis of the race and disconnections data 

shows a strong relationship between the two variables, with a correlation 

coefficient of .774. 

17 

18 

Correlations 

**. Correlation is significant at the 0.01 level (2-tailed).

12 
1 These findings and their unequivocal racial equity ramifications place added 

emphasis on the need for enhanced utility bill affordability in Connecticut. 

Reversing the inequities that are ‘baked into’ the existing home energy security

landscape requires purposive corrective action. 

2 

3 

4 

5 

6 Q. WHY ARE LOWER INCOME HOUSEHOLDS SOMETIMES LATE IN 

7 PAYING THEIR UTILITY BILLS? 

8 A. For most customers with past due accounts, there is simply insufficient income to 

pay for basic necessities such as rent, food, clothing, childcare, and health care. 

Understanding low-income household utility arrearages, and designing programs 

and credit and collection protocols that effectively reduce past due accounts, 

requires examination of income and expense realities faced by households lacking 

sufficient income to make ends meet. The “Self-Sufficiency Standard” provides 

an analytical framework for conducting such an examination. 

9 

10 

11 

12 

13 

14 

15 

16 Q. WHAT IS THE SELF-SUFFICIENCY STANDARD? 

17 A. Over the past 20 years, a number of alternatives to the traditional poverty 

measurements have been developed by analysts interested in overcoming 

shortcomings of the traditional, federal poverty measurement. These 

shortcomings include inability to account for locational price differences, family 

or household composition, and the true cost of a basic necessity “basket of 

goods.” One alternative measure is the “Self-sufficiency Standard,” developed 

primarily by Diana Pearce of the University of Washington. 

18 

19 

20 

21 

22 

23 

13 
 

1 The Self-sufficiency Standard entails a calculation of the amount of income 

required to meet basic needs. Self-sufficiency budgets are calculated for a range of 

family compositions, from one adult with no children, to one adult with one 

infant, one adult with one preschooler, up to two-adult families with six teenagers. 

The self-sufficiency budget includes the cost of only the most basic necessities, 

including food, housing (including home energy service), health care, childcare, 

transportation, and clothing. There is nothing for entertainment, vacations, or 

other “non-essential” items. The Standard is calculated by city/town using 

publicly-available data sources, including HUD Fair Market Rents, USDA Low 

Cost Food Plan, the National Household Travel Survey and other sources. The 

Self-sufficiency Standard has thus far been calculated for 169 Connecticut cities 

and towns. Calculations of the Standard incorporate geographic variations in 

costs and cost variation by family composition. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 A Self-sufficiency Standard report was prepared for the Connecticut Office of 

Health Strategy and the Connecticut Office of the State Comptroller in 2019.4  I 

calculated the figures in the tables below using microdata included with the report 

and 2019 poverty guidelines from the U.S. Department of Health and Human 

Services. 

16 

17 

18 

19 

20 

4 Pearce, “The Self-Sufficiency Standard for Connecticut 2019,” October 2019. 

(http://www.selfsufficiencystandard.org/Connecticut) 

14 
Family Composition Median Connecticut SelfSufficiency Wage - 2019 

Ratio of 2019 SelfSufficiency Wage to 

Poverty 

1 Adult $26,011 208.3% 

1 Adult, 1 Preschooler $55,286 326.9% 

1 Adult, 1 Teenager $35,325 208.9% 

2 Adults, 1 Infant, 1 

Preschooler $85,677 332.7% 

2 Adults, 2 Schoolagers $65,320 253.7% 

2 Adults, 1 Teenager $45,409 212.9% 

Household Median Connecticut Self- Ratio of 2019 Self-Sufficiency 

Size Sufficiency Wage - 2019 Wage to Poverty 

1 $26,011 208.3% 

2 $46,207 273.3% 

3 $60,889 285.5% 

4 $77,242 300.0% 

5 $93,040 308.4% 

6 $111,366 322.0% 

7 $127,205 326.1% 

8 $138,057 317.9% 

1 Table 1 

Connecticut Self-Sufficiency Wage by Selected Household 

Composition 

2 Source: NCLC calculation using Connecticut Self-Sufficiency Standard microdata 

3 (http://www.selfsufficiencystandard.org/sites/default/files/selfsuff/docs/CT2019_a 

4 ll_families.xlsb) 

5 

Table 2 

Connecticut Self-Sufficiency Wage by Household Size 

6 Source: NCLC calculation using Connecticut Self-Sufficiency Standard microdata 

(http://www.selfsufficiencystandard.org/sites/default/files/selfsuff/docs/CT2019_all_families.xl 

sb) 

7 

8 

9 

15 
 

1 Table 2 shows that the amount of income needed for a range of family types to 

pay for basic necessities exceeds 2- to 3-times the federal poverty guidelines. 

While there are considerable cost-of-living disparities across Connecticut cities 

and towns, Table 2 indicates that for a single adult, the median income level 

needed to make ends meet is 208% of poverty. A single adult with a preschoolaged child needs income of 326% of the poverty level to get by. Similarly, Table 3 

shows the median self-sufficiency wage required in Connecticut by household size 

and shows that the average-sized household in Connecticut5 requires income at 

nearly 300% of the federal poverty level to pay for the most basic necessities. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 Q. HOW MANY PEOPLE IN CONNECTICUT LIVE BELOW 300% OF THE 

12 FEDERAL POVERTY LEVEL? 

13 A. Based on the Census Bureau data highlighted in Table 4, below, nearly 35% of the 

Connecticut population lives below 300% of the poverty level. Thus, for many 

families, particularly those with young children, basic economic survival presents 

a great challenge. The Census Bureau estimates reveal that nearly 413,000 

Connecticut residents live below 300% of the poverty level. 

14 

15 

16 

17 

18 

19 

20 

21 

5 The Connecticut average is 2.51 persons per household. American Community Survey Table B25010. 

16 
Income to Poverty Ratio Population Percent Cumulative 

Percent 

Total: 3,460,446 100.0% 

Under .50 161,001 4.7% 4.7% 

.50 to .74 82,418 2.4% 7.0% 

.75 to .99 103,730 3.0% 10.0% 

1.00 to 1.24 102,917 3.0% 13.0% 

1.25 to 1.49 116,635 3.4% 16.4% 

1.50 to 1.74 114,822 3.3% 19.7% 

1.75 to 1.84 38,574 1.1% 20.8% 

1.85 to 1.99 69,929 2.0% 22.8% 

2.00 to 2.99 413,701 12.0% 34.8% 

3.00 to 3.99 408,594 11.8% 46.6% 

4.00 to 4.99 360,168 10.4% 57.0% 

5.00 and over 1,487,957 43.0% 100.0% 

Q. PLEASE DESCRIBE THE THREAT TO HEALTH AND SAFETY FROM 

LOSS OF ELECTRIC SERVICE. 

1 Table 3 

Ratio of Income in 2019 to Poverty: 

Connecticut 

2 

3 In summary, examination of reliable data describing the income and expense 

circumstances of Connecticut families and households reveals that for many, 

struggles to stay current on utility bill payments are rooted in the lack of income to 

pay for basic necessities. For those that struggle to survive economically, enhanced 

programming to limit home energy bills would be a welcome relief while reducing 

pressure on utility uncollectible account balances. 

4 

5 

6 

7 

8 

9 III. Low-Income Utility Payment Difficulties and the Threat to Health and 

10 Safety from Loss of Service 

11 

12 

13 A. Electricity service is widely considered to be a necessity of life and essential to 

public health and safety. In addition to providing everyday functions, secure, 

17 

14 
 

1 reliable electricity service is critical in avoiding health and safety risks by 

providing safe lighting, heat,6 cooling, power for medical devices, refrigeration of 

food and medications, and fuel for electric cooking appliances and electrically 

heated hot water. 

2 

3 

4 

5 

6 Elevated rates of low-income service disconnections and bill payment pressures 

pose a threat to the health and safety of customers as well as the communities in 

which we live. 

7 

8 

9 

10 Q. HOW DO LOW-INCOME HOUSEHOLDS BALANCE RETAINING 

HOME ENERGY SERVICE WITH PAYING FOR OTHER BASIC 

NECESSITIES? 

11 

12 

13 A. The National Energy Assistance Directors’ Association’s (“NEADA”) National 

Energy Assistance Survey outlines the steps that many individuals and families 

must take in order to afford basic utility services, often at a risk to their own 

health.7 The NEADA survey includes households that received assistance from 

the Low Income Home Energy Assistance Program (“LIHEAP”). In most states, 

this includes homes earning at or below 150% of the federal poverty level, but in 

some states includes those earning 60% or less of the state median income, or 

those enrolled in programs such as Temporary Assistance for Needy Families, 

14 

15 

16 

17 

18 

19 

20 

6 Electricity is required for electric resistance space heating and to operate a boiler or furnace fueled by 

natural gas or heating oil. 

7 National Energy Assistance Directors’ Association, National Energy Assistance Survey (Nov. 

2011), available at 

http://neada.org/wp-content/uploads/2013/05/NEA_Survey_Nov11.pdf. 

18 
 

1 food stamps, Social Security Insurance, or similar assistance.8  The NEADA 

survey found that in vulnerable homes, “[b]ecause of the difficultly they faced in 

paying their utility bills as many as 37% went without medical or dental care, and 

34% did not fill a prescription or took less than their full dose of prescribed 

medication.”9 Many individuals reported making difficult or even dangerous 

decisions when addressing unaffordable energy costs: 39% closed off part of their 

home; 23% kept the home at a temperature they felt was unsafe or unhealthy; 21% 

left their home for part of the day; 33% used their kitchen stove or oven to provide 

heat; and 24% went without food for at least one day.10 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 Q. WHAT HARM MAY OCCUR WHEN A HOUSEHOLD EXPERIENCES 

12 LOSS OF HOME ENERGY SERVICE? 

13 A. As noted in a report from AARP and others, “[i]t is common for a household that 

is denied electricity to turn to alternative and often dangerous means of providing 

light and heat in the home .... There are instances reported every year of the 

deaths of children and adults due to the use of a candle in a dwelling without 

electricity or heat.”11 

14 

15 

16 

17 

8 National Energy Assistance Directors’ Association, 2009 National Energy Assistance Survey 

(Apr. 2010), at 1-2, 

available at: http://neada.org/wp-content/uploads/2013/03/2010-04-

19NEADA_2009_Survey_Report.pdf. 

9 Id. at 2. 10 Id. at 5 (Table II). 11 AARP, National Consumer Law Center, National Association of State Utility Consumer Advocates, 

Consumers Union, and Public Citizen, The Need for Essential Consumer Protections: Smart Metering 

Proposals and the Move to Time-Based Pricing (Aug. 2010), at 17, available at 

http://energy.gov/sites/prod/files/oeprod/DocumentsandMedia/NASUCA_Smart_Meter_White_Paper.pdf 

. 

19 
 

1 When candles are used for light in the absence of electricity, there is additional 

risk of fatal fire, according to the National Fire Protection Association 

(“NFPA”).12 An example of fatalities caused by a candle fire after a utility shutoff was the case of Tashika Turner, who lost three of her young children in a 

candle fire in New York in October, 2013, one day after her electric utility 

disconnected service for non-payment.13 

2 

3 

4 

5 

6 

7 

8 In addition to safe lighting, electric service is required to operate most indoor 

cooling and heating equipment. Loss of such equipment can have fatal 

consequences. Extreme heat leads to deaths and illnesses that are preventable 

when people are able to stay cool indoors. From 1979 through 2003, excessive 

heat exposure caused at least 8,000 deaths in the United States.14 In 2001, 300 

deaths in the United States were attributed to excessive heat exposure.15 

9 

10 

11 

12 

13 

14 

15 According to the US Department of Health and Human Services, Centers for 

Disease Control and Prevention, “[a]ir conditioning is the strongest protective 

factor against heat-related illness.”16 In cold weather, young children and the 

16 

17 

12 In a report entitled “Home Candle Fires,” NFPA reviewed fire service reports and news clips about 117

identified fatal home candle fires in 2005 - 2010 that resulted in a total of 177 civilian fire deaths. 

Candles were used for light in the absence of power in 30, or one-quarter (26%), of these fires and in 60, 

or one-third (34%), of the associated deaths. Ahrens, Mary, “Home Candle Fires,” National Fire

Protection Association, December 2015, p. iv. 13 See, e.g. CNN, “Official: 3 children die in Bronx fire after candle lit,” 

http://www.cnn.com/2013/10/26/us/bronx-deadly-fire 14 National Weather Service, National Oceanic and Atmospheric Administration, 

https://www.weather.gov/arx/heatindex_climatology 15 Central Plains Area Agency on Aging, Avoid Hot Weather Health Emergencies, (July 20, 2011), 

accessible at: http://www.cpaaa.org/news-events/2011/7/20/avoid-hot-weather-health-emergencies.html. 16 Centers for Disease Control and Prevention, https://www.cdc.gov/disasters/extremeheat/faq.html. 

20 
 

1 elderly are particularly at risk for cold-related illness or death.17 Extreme heat is 

particularly dangerous for the elderly, the very young, and those with chronic 

health conditions.18 

2 

3 

4 

5 Loss of electric service also makes it difficult to manage chronic health 

conditions. In a 2007 report entitled “Unhealthy Consequences: Energy Costs and 

Child Health: A Child Health Impact Assessment of Energy Costs and the Low 

Income Home Energy Assistance Program,” researchers identified effects of high 

energy bills and utility disconnections on health and safety. A key finding of the 

report is that “[i]n addition to imposing general hardship, disconnected utilities 

make it difficult to manage chronic conditions such as asthma or diabetes, which 

require electricity to operate medical equipment or to refrigerate medications, 

such as insulin.”19 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 Utility shut offs are widely recognized grounds justifying the termination of rental 

leases.20 Low-income households fortunate enough to have secured limited 

federally subsidized housing benefits are particularly at risk, as a utility service 

16 

17 

17 U.S. National Institutes of Health, National Institute on Aging, Hypothermia: A Cold Weather Risk for 

Older People, Press Release (Jan. 16, 2009), available at https://www.nih.gov/news-events/newsreleases/hypothermia- cold-weather-risk-older-people. 18 U.S. Centers for Disease Control and Prevention, Extreme Heat Prevention Guide, 

available at https://www.cdc.gov/disasters/extremeheat/heat_guide.html. 

19 Smith, Lauren A., et al., “Unhealthy Consequences: Energy Costs and Child Health: A Child Health

Impact Assessment of Energy Costs and the Low Income Home Energy Assistance Program,” Child

Health Impact Working Group, April 2007, p. 7. 20 See, e.g Long Drive Apts. V. Parker, 421 S.E.2d 631 (N.C. App. 1992) (affirming trial court ruling that 

tenant had materially breached the lease by allowing the electricity in her apartment to be cut off during 

periods of freezing temperatures.) 

21 
 

1 shut-off constitutes grounds for eviction and the loss of the subsidy altogether.21 

In addition, loss of essential utility service results in other costs to the consumer, 

including spoiled food, lost wages, and the like; as well as other costs to society, 

such as hospital room emergency care, other health care costs, and credit and 

collection costs.22 

2 

3 

4 

5 

6 

7 In short, despite the rapid changes in energy and utility economics and technologies, 

8 affordable access to service remains a basic necessity of life. 

9 

10 IV. Bill Affordability Programming 

11 Q. PLEASE LAY OUT POLICY OBJECTIVES AND PROGRAM DESIGN 

PRINCIPLES OF AN EFFECTIVE LOW-INCOME ELECTRICITY 

AFFORDABILITY PROGRAM. 

12 

13 

14 A. As noted above, reliable electricity service is a necessity of life. Without 

electricity, residents cannot participate effectively in present-day society or be 

secure from threats to health and safety. All utility customers, including those 

with low incomes, should have access to reliable and secure sources of electricity. 

To help ensure home energy security for low-income residents, what is needed is 

an electricity affordability program that: 

15 

16 

17 

18 

19 

21 See, e.g. Crochet v. Housing Authority of City of Tampa, 37 F.3d 607, 613 (11th Cir. 1994) (referencing 

provision of public housing authority lease requiring tenants to maintain utility service as a condition of 

residency). 

22 National Association of State Utility Consumer Advocates, Encouraging State Legislatures and State 

Public Utility Commissions to Institute Programs to Reduce the Incidence of Disconnection of 

Residential Gas and Electric Service Based on Nonpayment (June 28, 2011), available at 

https://nasuca.org/encouraging-state-legislatures-andstate-public-utility-commissions-to-instituteprograms-to-reduce-the-incidence-of-disconnection-of-residential-gasand-electric-service-based-onnonpayment-2011-01/. 

22 
1  Serves all residential electricity customers at or below 60% of the state 

median income eligible to participate in the Low Income Home Energy 

Assistance Program (“LIHEAP”);

 Lowers program participants’ electricity burdens to an affordable level;

 Promotes regular, timely payment of electric bills by program participants; 

 Comprehensively addresses payment problems associated with program 

participants’ current and past-due bills; 

 Is funded through a mechanism that is reliable while providing sufficient 

resources to meet policy objectives over an extended timeframe; and 

 Is administered efficiently and effectively. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 Q. PLEASE PROVIDE RECOMMENDATIONS REGARDING ELIGIBILITY 

13 GUIDELINES, PARTICIPATION AND ENROLLMENT. 

14 A. Income eligibility for participation in a discount program should be capped at no 

less than the LIHEAP income-eligibility guideline, currently 60% of the state 

median income. 

15 

16 

17 

18 All households receiving or eligible for benefits through the federal LIHEAP 

should be automatically enrolled in the electric affordability program. In the 

event that the electricity affordability program’s participation level does not 

exceed any enrollment ceiling that may be established, consenting households 

receiving benefits from other means-tested benefit programs (e.g., SNAP, 

19 

20 

21 

22 

23 
Q. PLEASE DESCRIBE YOUR RECOMMENDATIONS REGARDING 

INCORPORATION OF AN ARREARAGE MANAGEMENT 

COMPONENT INTO AN AFFORDABLE BILL PAYMENT PROGRAM. 

1 Medicaid) should also be automatically enrolled in the electricity affordability 

2 program. 

3 

4 Q. PLEASE PROVIDE RECOMMENDATIONS REGARDING PROGRAM 

5 BENEFITS. 

6 A. Affordability program participants should receive benefits in the form of 

discounted electric rates on their electric bills. The goal of the program should be 

to substantially lower the electricity burden of all participants. To meet these 

objectives, I recommend that one of the following be funded and implemented: 

 A tiered discount setting payments at a targeted electricity burden level of 

approximately 5%; or 

 4% for non-heating customers and 6% for electric heating customers. 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 A. To sustain participants’ affordability and home energy security, program design 

must be comprehensive in its approach to dealing with both participants’ current 

bills and arrearage balances. Affordability objectives of energy assistance 

programs that discount current bills, but fail to address preprogram arrears, are 

undermined by the requirement that participants must add arrearage payoff to that 

of the current bill. In other words, incorporating arrearage management helps 

ensure that a portion of the household energy burden reductions that come from 

discounted current bills is not simply “given back” as customers pay off

24 

18 

19 

20 

21 

22 

23 

24 
1 outstanding balances. Similarly, energy assistance programs that focus entirely o

retirement of arrears but not on the affordability of current bills are unlikely to 

result in long-term household energy security. If current bills are not affordable, 

there is a strong likelihood that arrears will simply re-accrue after balances are 

initially retired. 

n 

2 

3 

4 

5 

6 

7 In order to enhance the effectiveness of discounts on current bills and promote 

timely program participant payments going forward, I recommend that companies 

continue to offer arrearage write-down, or management programs, in conjunction 

with tiered low-income rates. Effectively promoting regular bill payment entails 

ensuring that total payments are affordable. A program that is intended to 

promote regular, timely payments by participants through reduction of electricity 

burdens to an affordable level is rendered less effective by a requirement that 

participants pay an amount in addition to the affordable current bill. Simultaneous 

payment of pre-existing arrears and the discounted electric bill therefore runs 

counter to the policy objective of promoting regular, timely payments by program 

participants. 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 There are two basic models of low-income utility arrearage management that have 

been implemented in the United States. One entails the write-down of customer 

arrears over time after a series of timely payments on current bills. The other 

model entails the retirement of arrearage balances in full on a one-time basis. The 

one-time “forgiveness” model is administratively straightforward, but entails a 

25 

20 

21 

22 

23 
1 large initial outlay of program cash resources. Write-downs over a period of 12 

months may provide customers with an enhanced incentive to keep up with 

current bills (as long as they are affordable), while placing less strain on program 

cash flow. I recommend that the Companies continue to implement arrearage 

management programs that allow low-income rate participants to write down onetwelfth (1/12) of a pre-program overdue balance with each timely payment of a 

current bill. 

2 

3 

4 

5 

6 

7 

8 

9 Q. PLEASE DESCRIBE YOUR RECOMMENDATIONS REGARDING 

10 PROGRAM FUNDING. 

11 A. Funding for an electricity affordability program needs to be sufficient and reliable. 

Program funding should be sufficient to provide meaningful energy burden 

reduction and energy security for all electricity customers living below 60% of the 

state median income. In addition, program administration costs of 5% to 7% of 

program benefits to the total program cost estimate are required. 

A sustainable electricity affordability program with set benefit levels and 

participation rates also requires funding that is predictable and reliable. A 

uniform volumetric charge – approved prior to program implementation – is the 

optimal funding source for an effective program. 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 Q. PLEASE PROVIDE YOUR RECOMMENDATIONS REGARDING 

22 PROGRAM ADMINISTRATION AND IMPLEMENTATION. 

23 A. Electricity affordability program design should foster efficient, streamlined 

administrative procedures. With limited program resources available, funds 

26 

24 
1 should be devoted to participant benefits rather than administrative costs to the 

greatest extent feasible. Minimizing administrative costs while delivering an 

effective electricity affordability program requires that certain agencies, 

organizations and individuals work together cooperatively and efficiently. I 

recommend that whenever possible, administrative structures and procedures that 

apply to the state’s LIHEAP be “piggybacked” onto any new electricity

affordability program to create administrative efficiencies. 

2 

3 

4 

5 

6 

7 

8 

9 The state’s Community Action Agencies, with sufficient support from program 

administrative funds collected by the Company, are ideally suited to conduct 

program intake and outreach functions. The agencies that certify LIHEAP 

eligibility could then simultaneously certify low-income rate and arrearage 

management eligibility using the same procedures that currently apply to 

LIHEAP. 

10 

11 

12 

13 

14 

15 

16 The companies would be responsible for collecting program-related charges from

all customers, and assigning qualified customers to a tariffed, low-income rate. 

They would further be responsible for tracking arrearage write-down for each 

participating customer. The companies would also be responsible for regular 

reporting to PURA of program activities and financial transactions. All program 

costs, including bill credits or discounts, approved startup and ongoing 

administrative expenses, and approved arrearage retirement amounts should be 

recoverable through volumetric charges, as described above. 

27 

17 

18 

19 

20 

21 

22 

23 
1 Affordability rate applicants would provide documentation required for 

certification on an annual basis. In addition, program applicants should be 

referred to all appropriate energy efficiency services that may be available. 

2 

3 

4 

5 Q. WHAT ARE THE UTILITY SYSTEM COSTS OF IMPLEMENTING THE 

6 PROGRAM THAT YOU HAVE PROPOSED? 

7 A. Most prospective low-income assistance program costs may be readily identified 

and quantified. Projecting the cost of implementing the affordability program 

requires multiplying the projected number of program participants by the sum of 

the value of the monthly discount (or revenue loss) per customer and the average 

arrearage per customer that is retired. Program administration costs must then be 

added to the value of discounts and retired arrearages to obtain an estimate of total 

program costs. 

8 

9 

10 

11 

12 

13 

14 

15 Q. WHAT ARE SOME OF THE UTILITY SYSTEM BENEFITS 

16 ASSOCIATED WITH EFFECTIVE BILL PAYMENT ASSISTANCE? 

17 A. Quantifying the entire range of program benefits, including those associated with 

utility uncollectible accounts, presents a greater analytical challenge than 

quantifying costs. Nonetheless, quantification challenges do not appropriately 

lead to the conclusion that benefits simply do not exist. Rather, they suggest that 

decisions regarding adoption and implementation of low-income payment 

assistance programs should not hinge entirely on the results of overly simplified 

cost-benefit analysis. 

28 

18 

19 

20 

21 

22 

23 
1 That said, effective bill payment assistance programming may bring the benefit of 

reduced uncollectible account write-offs. Precise quantification of the bad debt 

mitigation impact of a low-income payment assistance program presents a 

considerable analytical challenge, particularly on a prospective basis. The extent 

to which this objective may be achieved is contingent on a number of existing 

conditions and key program design and implementation elements, including the 

following: 

2 

3 

4 

5 

6 

7 

8  A company’s existing bad debt profile and the extent to which uncollectible 

account write-offs are currently concentrated among low-income customers; 

 Income and expense circumstances of the program participants; 

 Program benefit levels and reduction of participants’ utility burden (i.e., 

reduction of the proportion of a participant’s income that is devoted to utility

bills); 

 Outreach and targeting of “payment troubled” customers and prospective 

program participants; 

 The extent to which the program comprehensively incorporates reduction of 

current bills with means of effectively managing pre-program arrears; and 

 Contact and follow-up with program participants. 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 Q. WHAT ARE THE PREDOMINANT LOW-INCOME BILL 

AFFORDABILIY PROGRAM DESIGN MODELS OPERATIVE IN THE 

U.S.? 

21 

22 

23 A. The predominant models are the straight discount, the percentage of income 

payment plan, and the tiered discount. The percentage of income payment plan 

29 

24 
 

1 and the tiered discount model differ from the straight percentage discount in that 

the programs are designed to bring all participants’ payments a predetermined 

target burden level, whereas the straight discount decreases all participants’ bills 

by the same percentage without regard to burden impact. 

2 

3 

4 

5 

6 Q. PLEASE BRIEFLY DESCRIBE THE STRAIGHT DISCOUNT PROGRAM 

7 DESIGN MODEL. 

8 A. A straight discount entails reducing the total utility bill by a specified percentage 

or dollar amount. Under this model, the discount may be achieved through a set 

customer charge reduction and/or a usage charge reduction. The states of 

California and Massachusetts have adopted straight discount rates that are 

available to utility customers who participate in LIHEAP. The straight discount 

model reduces the energy burden of participants at a relatively low administrative 

cost. However, this model does not differentiate the benefit level within the broad 

participant group. In other words, the benefit level is the same for a household 

living at 50% of the federal poverty level as it is for a household living at the 

upper limit of the income eligibility guideline. Households with the lowest income 

experience the least energy burden reductions under a straight discount. 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 The table below illustrates the electricity burden impacts of a 36% discount on 

various low-income household configurations, assuming an undiscounted nonheating annual electricity service expenditure of $1,525.23 For comparative 

21 

22 

30 

23 Eversource (CL&P) 2019 FERC Form 1, p. 304. 
1-person Household, 

50% FPL

2-person 

Household, 100% 

FPL

2-person 

Household, 

130% FPL

2-perso

Househol

150% FP

Annual Pretax Income $6,440 $17,420 $22,646 $26

Monthly Pretax Income $537 $1,452 $1,887 $2

Undiscounted Current Annual Electricity Expenditure $1,525 $1,525 $1,525 $1

Undiscounted Current Monthly Electricity Expenditure $127 $127 $127 $

Monthly Arrearage Payment $0 $0 $0 

Total Undiscounted Monthly Payment $127 $127 $127 $

Undiscounted Electricity Burden 23.7% 8.8% 6.7% 5

Discounted Electricity Expenditure $976 $976 $976 $

Discounted Electricity Burden 15.2% 5.6% 4.3% 3

Electricity Burden Impacts: Straight Discount - Eversourc

1 purposes, the table also reflects the home electricity burdens of higher-income, 

2 nonparticipating residential customers. 

3 Table 4 

4 

5 

6 Q. PLEASE BRIEFLY DESCRIBE THE PERCENTAGE OF INCOME 

7 PAYMENT PLAN MODEL. 

8 A. A percentage of income payment plan (“PIPP”) entails participant customers 

9 paying a predetermined, "affordable" percentage of income for natural gas or 

10 electric service. PIPPs therefore target benefit levels to a household’s particular

11 income circumstances based on a predetermined affordability goals. However, 

12 since separate billing and payment arrangements must be developed for each 

13 participating customer, PIPPs generally entail a somewhat higher level of 

14 administrative complexity than straight discount rates. The Colorado Public 

15 Utilities Commission recently approved a PIPP for Excel Energy customers. 

16 Illinois investor-owned utilities have also implemented a PIPP. In addition, the 

17 program model has been operative for many years in Ohio, Pennsylvania, New 

18 Jersey and Maine. 

19 

31 
 

1 Q. PLEASE BRIEFLY DESCRIBE THE TIERED DISCOUNT MODEL. 

2 A. A tiered discount represents a hybrid of design elements of straight discount and 

3 PIPP models. In a tiered discount, the level of the discount depends on the 

4 customer’s income or poverty level. Like a PIPP, the tiered discount is designed 

5 to reduce a customer’s bill to an affordable level, and households in the lower 

6 income or poverty tiers receive a steeper discount than those in higher tiers. Thus, 

7 benefits are targeted according to a household’s income circumstances, but the 

8 individual payment arrangements and billing typified by a PIPP are not required. 

9 

10 A tiered discount entails somewhat higher administrative cost than a straight 

11 discount, but considerably less than a PIPP. Tiered discount programs currently 

12 operate in New Hampshire24 and Indiana. The table below illustrates the 

13 electricity burden impacts of a tiered discount that sets the target electricity burden 

14 level at 5% of household income, assuming an undiscounted annual electricity 

15 service expenditure of $1,891. 

24 A report detailing the New Hampshire tiered discount program may be found at 

https://www.puc.nh.gov/electric/SBC%20Reports/Electric-2019-SBC-Report.pdf. 

32 
 

 

 

 

1 Table 5 

2 

1-person Household, 

50% FPL

2-person 

Household, 100% 

FPL

2-person 

Household, 130% 

FPL

2-person 

Household, 

150% FPL

2-person 

Household, 

200% FPL

2-Person 

Household 

60% Median 

Income

2-Person 

Median Income 

Household

Upper-income 

Household 

($100,000)

Annual Pretax Income $6,440 $17,420 $22,646 $26,130 $34,840 $49,228 $82,047 $100,000

Monthly Pretax Income $537 $1,452 $1,887 $2,178 $2,903 $4,102 $6,837 $8,333

Undiscounted Current Annual Electricity Expenditure $1,891 $1,891 $1,891 $1,891 $1,891 $1,891 $1,891 $1,891

Undiscounted Current Monthly Electricity Expenditure $158 $158 $158 $158 $158 $158 $158 $158

Monthly Arrearage Payment $0 $0 $0 $0 $0 $0 $0 $0

Total Undiscounted Monthly Payment $158 $158 $158 $158 $158 $158 $158 $158

Undiscounted Electricity Burden 29.4% 10.9% 8.4% 7.2% 5.4% 3.8% 2.3% 1.9%

Discounted Electricity Annual Expenditure $326.63 $766.48 $1,201.98 $1,201.98 $1,739.72 $1,739.72 $1,891 $1,891

Discounted Electricity Monthly Expenditure $27.22 $63.87 $100.17 $100.17 $144.98 $144.98 $157.58 $157.58

Discounted Electricity Burden 5.1% 4.4% 5.3% 4.6% 5.0% 3.5% 2.3% 1.9%

Electricity Burden Impacts: Tiered Discount - United Illuminating

3 Q. PLEASE PROVIDE A COMPARATIVE VIEW ILLUSTRATING THE 

4 BURDEN IMPACTS OF THE TIERED AND STRAIGHT DISCOUNT 

5 PROGRAM DESIGNS THAT YOU DESCRIBED ABOVE. 

6 A. The charts below were derived from current poverty guidelines and an estimate of 

7 Eversource residential customer expenditure levels.25 The charts are based on a 

8 tiered discount target burden level of 4% for non-heating customers and 6% for 

9 heating customers. The straight discount charts reflect the burden impacts of a 

10 36% discount26 for both electric heat and non-electric heat for all participating 

11 customers. 

25 Average expenditure levels of Eversource residential customers using electric heat and those not using 

electric heat were derived from Connecticut Light and Power 2019 FERC Form 1, p. 304. 

26 Eversource’s income-eligible customers in Massachusetts receive a 36% discount on electricity bills. 

33 
 

■ ■ 

35.0% Non-heat Straight Discount 

Undiscounted and Discounted Electricity Burdens 

by Selected Household Incomes - Eversource 30.0% 

25.0% 23.7% 

20.0% 

15.2% 

15.0% 

8.8% 

6.7% 

10.0% 

5.8% 

4.3% 

5.6% 

4.4% 5.0% 3.7% 3.1% 

2.0% 1.9%1.9% 2.8% 

1.5%1.5% 

0.0% 

1-person 2-person 2-person 2-person 2-person 2-Person 2-Person Upper-income 

Household, Household, Household, Household, Household, Household Median Household 

50% FPL 100% FPL 130% FPL 150% FPL 200% FPL 60% Median Income ($100,000) 

Income Household 

Undiscounted Electricity Burden Discounted Electricity Burden 

■ ■ 

23.7% 

8.8% 

6.7% 

5.8% 

4.4% 

3.1% 

1.9% 1.5% 

4.1% 3.5% 4.2% 3.7% 4.0% 

2.9% 

1.9% 1.5% 

0.0% 

5.0% 

10.0% 

15.0% 

20.0% 

25.0% 

30.0% 

35.0% Non-heat Tiered Discount 

Undiscounted and Discounted Electricity Burdens 

by Selected Household Incomes - Eversource 

1-person 2-person 2-person 2-person 2-person 2-Person 2-Person Upper-income 

Household, Household, Household, Household, Household, Household Median Household 

50% FPL 100% FPL 130% FPL 150% FPL 200% FPL 60% Median Income ($100,000) 

Income Household 

Undiscounted Electricity Burden Discounted Electricity Burden 

1 Figure 6 

2 

3 Figure 7 

4 

34 
1 Figure 8 

2 

3 Figure 9 

35.0% 

30.0% 

25.0% 

20.0% 

15.0% 

10.0% 

5.0% 

0.0% 

34.1% Electric Heat Straight Discount 

4.0% 

2.9% 2.7%2.7% 

5.4% 6.2% 

9.7% 

8.1% 

 

■ ■ 

Undiscounted and Discounted Electricity Burdens 

by Selected Household Incomes - Eversource 

21.8% 

12.6% 

8.4% 

6.3% 

4.5% 

1-person 

Household, 

50% FPL 

2-person 

Household, 

100% FPL 

2-person 

Household, 

130% FPL 

2-person 

Household, 

150% FPL 

2-person 

Household, 

200% FPL 

2-Person 

Household 

60% Median 

Income 

2-Person 

Median 

Income 

Household 

Undiscounted Electricity Burden Discounted Electricity Burden 

2.2%2.2% 

Upper-income 

Household 

($100,000) 

4 

34.1% 35.0% Electric Heat Tiered Discount 

Undiscounted and Discounted Electricity Burdens 

30.0% by Selected Household Incomes - Eversource 

25.0% 

20.0% 

15.0% 12.6% 

9.7% 

10.0% 8.4% 

5.0% 

0.0% 

6.1% 6.4% 5.5% 6.3%5.8% 5.3% 4.5%4.1% 

2.7%2.7% 2.2%2.2% 

1-person 2-person 2-person 2-person 2-person 2-Person 2-Person 

Household, Household, Household, Household, Household, Household Median 

50% FPL 100% FPL 130% FPL 150% FPL 200% FPL 60% Median Income 

Income Household 

Undiscounted Electricity Burden Undiscounted Electricity Burden 

Upper-income 

Household 

($100,000) 

■ ■ 

35 
1 These charts illustrate that under a tiered discount, steeper discounts are provided 

to households with the lowest incomes, resulting in burdens that are fairly 

consistent throughout the spectrum of participants’ incomes, and all participants’ 

bills are brought closer to an “affordable” level. The charts include selected nonparticipant electricity burdens for comparative purposes. 

2 

3 

4 

5 

6 

7 Q. WHICH OF THE DESCRIBED PROGRAM DESIGNS DO YOU 

8 RECOMMEND? 

9 A. Based on the foregoing, I recommend that Eversource and UI implement tiered 

discount programs to operate in conjunction with arrearage management 

programs. The tiered discount approach brings the electricity burdens of the 

lowest-income participants to a level that is more manageable than that which 

would be provided under the straight discount model. 

10 

11 

12 

13 

14 

15 V. Analysis of Prospective Tiered Discount Program Costs and Benefits 

16 Q. PLEASE PROVIDE ESTIMATES OF THE INITIAL COST OF THE 

17 PROGRAMS OUTLINED ABOVE. 

18 A. Calculating an estimate of tiered discount program cost requires (1) determining a 

target electricity burden level, (2) determining ratio of income to poverty brackets 

(income tiers), (3) estimating the number of participants per income bracket, (4) 

estimating the undiscounted annual electricity expenditure level, and (5) 

estimating program administrative cost. Below there are program cost and benefit 

worksheets for prospective Eversource and UI tiered discount programs. There 

36 

19 

20 

21 

22 

23 
Ratio of Income to Poverty Brackets 

Lower Upper 

Tier 1 0 0.75 

Tier 2 0.76 1 

Tier 3 1.01 1.25 

Tier 4 1.26 1.5 

Tier 5 1.51 60% State Median Income 

1 are separate worksheets for participating non-heat customers and electric heat 

customers for Eversource and a single worksheet for UI, which does not provide a 

separate rate for electric heating customers. The Eversource target burden level 

for non-heat customers is set at 4% of household income and at 6% for electric 

heat customers. The UI target burden is set at 5% for all participants. Income 

tiers for both companies are consistent with those used in the New Hampshire 

tiered discount program, and are set as follows: 

2 

3 

4 

5 

6 

7 

8 Table 6 

9 

10 For cost estimation purposes, I assumed that an Eversource program would 

include 80,000 non-heat participants and 10,000 electric heat customers, and that

participants would be distributed equally among the income tiers. For UI, I 

assumed that 22,000 of its income-eligible customers would participate in the 

program and also be distributed equally among the income tiers. To estimate 

undiscounted expenditure levels, I drew on Eversource’s 2019 FERC Form 1 

reporting of rate schedule-specific customer and revenue data, and for UI I 

estimated the undiscounted expenditure using data from EOE-UI-3. Finally, I 

assumed that program administrative costs would be equal to 5% of participant 

benefits. Program cost and benefit worksheets are on the following page. 

11 

12 

13 

14 

15 

16 

17 

18 

19 

37 
1 Q. ARE THE ASSUMPTIONS YOU USED TO DEVELOP PROGRAM 

2 COSTS AND BENEFITS SUBJECT TO CHANGE? 

3 A. Yes. The assumptions I used to develop these estimates are based on publicly 

available data and some discovery responses. If participation rates vary, 

undiscounted expenditure levels of prospective participants differ from those 

reflected in my estimates, or the costs to administer the programs varies from the 

assumed levels, total program costs will differ from those reflected in the 

estimates. Therefore, I recommend that PURA direct the companies to, in 

collaboration with EOE and other stakeholders, develop program implementation 

plans that reflect the best available information on customer expenditure levels 

and other relevant program cost inputs. Plans should also detail critical program 

design and implementation components, such as eligibility guidelines, income and 

discount tiers, program intake protocols, and means of coordination between the 

new tiered discounts and arrearage management programs. 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

38 
I I I 

1 Table 7 

2 

4.0% 80,000 $1,525

Program 

Administration (% 

of Arrearage Write- 5%

Lower Upper

Income at 

Category 

Midpoint (2-

person hh)

# HH

Average 

Annual 

Electricity 

Expenditure

Target 

Burden

Discounted 

Expenditure

$ Annual 

Discount

$ Monthly 

Discount

Percentage 

Discount

Average Total 

Benefits per 

participant

Total $ 

Discount

per Tier

Total $

Program 

Administration

per Tier

Total $

per Tier

0.00 0.75 $ 6,533 16,000 $ 1,525 4.0% $ 261 $ 1,264 $ 105 82.9% $ 1,264 $ 20,225,366 $ 1,011,268 $ 21,236,635

0.76 1.00 $ 15,330 16,000 $ 1,525 4.0% $ 613 $ 912 $ 76 59.8% $ 912 $ 14,595,222 $ 729,761 $ 15,324,984

1.01 1.25 $ 19,685 16,000 $ 1,525 4.0% $ 787 $ 738 $ 62 48.4% $ 738 $ 11,808,022 $ 590,401 $ 12,398,424

1.26 1.50 $ 24,040 16,000 $ 1,525 4.0% $ 962 $ 564 $ 47 37.0% $ 564 $ 9,020,822 $ 451,041 $ 9,471,864

1.51 60% SMI $ 37,679 16,000 $ 1,525 4.0% $ 1,403 $ 122 $ 10 8.0% $ 122 $ 1,952,493 $ 97,625 $ 2,050,118

47.2%

Total Program Cost $ 48,581,105 $ 2,429,055 $ 51,010,160

Weighted Average Discount

Non-heat Tiered Discount Worksheet - Eversource

Target Burden # of Participants

Annual Expenditure 

(2019 FERC Form 1)

Program Costs Ratio of Income to 

Poverty Brackets

8% Discount - (not target burden calc)

39 

3 
+-

I ~ 

1 Table 8 

2 

6.0% 10,000 $2,195

Program 

Administration (% 

of Arrearage Write- 5%

Lower Upper

Income at 

Category 

Midpoint (2-

person hh)

# HH

Undiscounted 

Annual 

Electricity 

Expenditure

Target 

Burden

Discounted 

Annual 

Expenditure

$ Annual 

Discount

$ Monthly 

Discount

Percentage 

Discount

Average Total 

Benefits per 

participant

Total $ 

Discount

per Tier

Total $

Program 

Administration

per Tier

Total $

per Tier

0.00 0.75 $ 6,533 2,000 $ 2,195 6.0% $ 392 $ 1,803 $ 150 82.1% $ 1,803 $ 3,606,316 $ 180,316 $ 3,786,632

0.76 1.00 $ 15,330 2,000 $ 2,195 6.0% $ 920 $ 1,275 $ 106 58.1% $ 1,275 $ 2,550,664 $ 127,533 $ 2,678,197

1.01 1.25 $ 19,685 2,000 $ 2,195 6.0% $ 1,181 $ 1,014 $ 85 46.2% $ 1,014 $ 2,028,064 $ 101,403 $ 2,129,467

1.26 1.50 $ 24,040 2,000 $ 2,195 6.0% $ 1,442 $ 753 $ 63 34.3% $ 753 $ 1,505,464 $ 75,273 $ 1,580,737

1.51 60% SMI $ 37,679 2,000 $ 2,195 6.0% $ 2,019 $ 175.61 $ 15 8.0% $ 176 $ 351,217 $ 17,561 $ 368,778

45.7%

$ 7,491,062 $ 374,553 $ 7,865,615

Weighted Average Discount

Total Program Cost

Heat Tiered Discount Worksheet - Eversource

Target Burden # of Participants

Annual Expenditure 

(2019 FERC Form 1)

Ratio of Income to 

Poverty Brackets Program Costs

8% Discount - (not target burden calc)

40 

3 
1 Table 9 

2 

5.0% 22,000 $1,891

Program 

Administration (% 

of Arrearage Write- 5%

Lower Upper

Income at 

Category 

Midpoint (2-

person hh)

# HH

Average 

Annual 

Electricity 

Expenditure

Target 

Burden

Discounted 

Expenditure

$ Annual 

Discount

$ Monthly 

Discount

Percentage 

Discount

Average 

Arrearage 

per 

Customer

Average Total 

Benefits per 

participant

Total $ 

Discount

per Tier

Total $

Program 

Administration

per Tier

Total $

per Tier

0.00 0.75 $ 6,533 4,400 $ 1,891 5.0% $ 327 $ 1,564 $ 130 82.7% $ - $ 1,564 $ 6,883,250 $ 344,163 $ 7,227,413

0.76 1.00 $ 15,330 4,400 $ 1,891 5.0% $ 766 $ 1,125 $ 94 59.5% $ - $ 1,125 $ 4,947,888 $ 247,394 $ 5,195,282

1.01 1.25 $ 19,685 4,400 $ 1,891 5.0% $ 984 $ 907 $ 76 48.0% $ - $ 907 $ 3,989,788 $ 199,489 $ 4,189,277

1.26 1.50 $ 24,040 4,400 $ 1,891 5.0% $ 1,202 $ 689 $ 57 36.4% $ - $ 689 $ 3,031,688 $ 151,584 $ 3,183,272

1.51 60% SMI $ 37,679 4,400 $ 1,891 5.0% $ 1,740 $ 151 $ 13 8.0% $ - $ 151 $ 665,632 $ 33,282 $ 698,914

46.9%

Total Program Cost $ 16,486,558 $ 824,328 $ 17,310,886

Weighted Average Discount

Tiered Discount Worksheet - United Illuminating

Target Burden # of Participants

Annual Expenditure (UIEOE-3)

Program Costs Ratio of Income to 

Poverty Brackets

8% Discount - (not target burden calc)

41 

3 
1 Under the assumptions incorporated into these estimates, the annual cost of the 

Eversource tiered discount program would be $58.9M. The annual cost of the UI 

program would be $17.3M. 

2 

3 

4 

5 Q. DID YOU ESTIMATE THE BILL IMPACTS OF THE PROGRAMS THAT 

6 YOU PROPOSED? 

7 A. Yes. Estimated bill impacts by rate schedule for Eversource customers are 

attached as Exhibit JH-3 and estimated bill impacts for UI customers are attached 

as Exhibit JH-4. I calculated rate-schedule-specific bill impact estimates using the 

customer, usage, and revenue information provided on page 304 of the 

companies’ 2019 FERC Form 1 filings by applying a uniform percentage of 

revenue adder to each listed rate schedule or tariff designation. The percentage of 

revenue adder was derived by dividing estimated program costs, as delineated in 

in Tables 7 – 9, above, by total revenues from sales, as reported in the FERC 

Form 1. 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 The estimated cost of implementing the tiered discount programs I have 

recommended, including administrative expenses, would represent 2.03% of 

Eversource’s 2019 revenues from sales to all customers, and 2.06% of UI’s 

revenues from sales. Tables reflecting these calculations are attached as Exhibit 

JH-3 and Exhibit JH-4. 

18 

19 

20 

21 

22 

23 

42 
1 VI. Conclusions 

2 Q. PLEASE SUMMARIZE YOUR FINDINGS. 

3 A. I have found the following: 

 Low-income households served by Eversource and UI carry heavy home 

electricity burdens, much higher than those households with more stable, 

higher income. 

 Eversource’s and UI’s low-income, “hardship” customers carry past due 

account balances in greater numbers and at higher levels than “general 

residential” customers who have not been identified as having income that 

would qualify them to participate in the Connecticut Energy Assistance 

Program or other available means-tested energy assistance programs. 

 UI and Eversource hardship customer arrearage rates are 2- to 3-times higher 

than those of general residential customers. 

 The average dollar values of arrearages is much higher for hardship 

customers and has increased over the past year since the onset of the 

COVID-19 pandemic. 

 Examination of Eversource zip code level disconnections reveals a strong 

correlation between race and disconnections. (UI was unable to provide zip 

code level disconnections data.) 

 For many families and households in Connecticut, income in excess of 300% 

of the federal poverty guidelines is required to pay for the most basic 

necessities. 

 Nearly 35% of Connecticut’s population lives at or below 300% of poverty.

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

43 
1  Elevated rates of low-income service disconnections and bill payment 

pressures pose a threat to the health and safety of customers. 

 Unaffordable home energy bills lead many low-income households to resort 

to unsafe and unhealthy means of heating their homes, or to forego other 

basic necessities to retain access to utility service. 

 Distinct from the straight discount program design, the tiered discount 

approach brings the electricity burdens of the lowest-income participants to a 

level that is more manageable than that which would be provided under the 

straight discount model. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 Q. PLEASE SUMMARIZE YOUR RECOMMENDATIONS 

12 A. Based on the findings above, I recommend the following: 

 PURA should direct Eversource and UI to implement low-income customer 

affordability programs that meet the following objectives: 

o Serves all residential electricity customers at or below 60% of the state 

median income eligible to participate in the Low Income Home Energy 

Assistance Program (“LIHEAP”);

o Lowers program participants’ electricity burdens to an affordable level;

o Promotes regular, timely payment of electric bills by program 

participants; 

o Comprehensively addresses payment problems associated with program 

participants’ current and past-due bills; 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

44 
1 o Is funded through a mechanism that is reliable while providing sufficient 

resources to meet policy objectives over an extended timeframe; and 

o Is administered efficiently and effectively. 

 PURA should direct Eversource and UI to expeditiously develop and file 

plans to implement tiered discount programs modeled after those currently 

operating in New Hampshire. Development of implementation plans should 

be in collaboration with EOE and other stakeholders. 

 Program benefits levels should be set to reduce participant payments to 

achieve target electricity burden levels of either 

o 5% for all participants, or 

o 4% for non-heating customers and 6% for electric heating customers. 

 Eversource and UI should continue to offer arrearage management programs 

operating in conjunction with tiered low-income rates. 

 Program funding should come from non-bypassable, uniform volumetric 

charges – approved prior to program implementation – on all UI and 

Eversource customers. 

 Administrative structures and procedures that apply to the state’s LIHEAP 

should be “piggybacked” onto any new electricity affordability program to 

create administrative efficiencies. 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 Q. DOES THIS CONCLUDE YOUR TESTIMONY? 

22 A. Yes. 

45 
i T T T T .l 

I 

I 

Exhibit JH-1 

Case Name/Docket Client Topic Jurisdiction Date

Rulemaking 18-07-005 NCLC's low-income clients Establishment of a Percentage of Income Payment Plan California Feb-21

Docket No. E-01345A-19-0236 Arizona Wildfire - AZ Community Action Association

Surrebuttal Testimony - Establishment of a tiered discount and 

arrearage management program Arizona Jan-21

Docket No. E-01345A-19-0236 Arizona Wildfire - AZ Community Action Association

Direct Testimony - Establishment of a tiered discount and arrearage 

management program Arizona Oct-20

Case No. PUR-2020-00117 Southern Environmental Law Center and Appalacian Voices Establishment of a PIPP rate - Appalician Power Company Virginia Sep-20

Case No. PUR-2020-00109 Southern Environmental Law Center and Appalacian Voices Establishment of a PIPP rate - Dominion Energy Virginia Sep-20

Docket No. E-7, Sub 1214 - Duke Energy 

Carolinas

North Carolina Justice Center, North Carolina Housing Coalition, Natural 

Resources Defense Council, Southern Alliance for Clean Energy, Southern 

Environmental Law Center Affordability of electric utility service North Carolina Feb-20

Docket No. 32953 - Alabama Power Company Energy Alabama and Gasp Direct Testimony - Affordability of residential electricity service Alabama Dec-19

Cause No. 45253 - Duke Energy Indiana

Indiana Citizens Action Coalition, Indiana Community Action Association, 

Environmental Working Group

Direct Testimony - Low-income affordability program, credit and 

collections data reporting Indiana Oct-19

D.P.U. 18-150 - National Grid Massachusetts Energy Directors Association Direct Testimony - Transportation Electrification, Rate Design Massachusetts Mar-19

Docket No. 2018-318-E - Duke Energy Progress

Southern Environmental Law Center, NAACP, South Carolina Coastal 

Conservation League

Direct Testimony - Rate design, low-income energy efficiency and 

affordability programs South Carolina Mar-19

Cause No. 45159 - Northern Indiana Public 

Service Company Citizens Action Coalition of Indiana

Direct Testimony - Rate design, low-income affordability program, 

credit and collections data reporting Indiana Feb-19

Docket No. 2018-319-E - Duke Energy Carolinas

Southern Environmental Law Center, NAACP, South Carolina Coastal 

Conservation League

Direct Testimony - Rate design, low-income energy efficiency and 

affordability programs South Carolina Feb-19

Docket No. 18-1008/1009 - Ameren Illinois 

Company Illinois Attorney General’s Office Rebuttal Testimony - Prepaid utility service Illinois Nov-18

Docket No. 18-1008/1009 - Ameren Illinois 

Company Illinois Attorney General’s Office Direct Testimony - Prepaid utility service Illinois Sep-18

D.P.U. 18-40 - The Berkshire Gas Company

Massachusetts Low-Income Weatherization and Fuel Assistance Program Network 

and the Massachusetts Energy Directors Association Direct Testimony - General rate case, low-income discount rate Massachusetts Sep-18

D.P.U. 18-45 - Bay State Gas Company d/b/a 

Columbia Gas of Massachusetts

Massachusetts Low-Income Weatherization and Fuel Assistance Program Network 

and the Massachusetts Energy Directors Association Direct Testimony - General rate case, low-income discount rate Massachusetts Aug-18

Case No. 18-00043-UT - Public Service Company 

of New Mexico New Mexico Coalition for Clean Affordable Energy Direct Testimony - Rate design New Mexico Aug-18

Cause No. 45029 - Indianapolis Power & Light 

Company

Citizens Action Coalition of Indiana, Indiana Coalition for Human Services, Indiana 

Community Action Association, Sierra Club Direct Testimony - Rate design Indiana May-18

Docket No. 17-0837 - Commonwealth Edison 

Company Illinois Attorney General’s Office Direct Testimony - Prepaid utility service Illinois Mar-18

D.P.U. 17-170 - Boston Gas Company, Colonial 

Gas Company,

each d/b/a National Grid

Massachusetts Low-Income Weatherization and Fuel Assistance Program Network 

and the Massachusetts Energy Directors Association Direct Testimony - General rate case, low-income discount rate Massachusetts Mar-18

Docket No. E-7, Sub 1146 - Duke Energy 

Carolinas

Southern Environmental Law Center, North Carolina Justice Center, North 

Carolina Housing Coalition, Natural Resources Defense Council, and Southern 

Alliance for Clean Energy

Direct Testimony - General rate case, rate design, affordable payment 

program North Carolina Jan-18

Cause No. 44967 - Indiana Michigan Power 

Company

Citizens Action Coalition of Indiana, Indiana Coalition for Human Services, Indiana 

Community Action Association, Sierra Club Direct Testimony - Rate design, affordable payment program Indiana Nov-17

Docket No. E-2, Sub 1142 - Duke Energy 

Progress

Southern Environmental Law Center, North Carolina Justice Center, North 

Carolina Housing Coalition, Natural Resources Defense Council, and Southern 

Alliance for Clean Energy

Direct Testimony - General rate case, rate design, affordable payment 

program North Carolina Oct-17

John Howat Regulatory Commission Testimony and Comment Experience

1 
i T T T T .l 

Exhibit JH-1 

Case Name/Docket Client Topic Jurisdiction Date

Docket No. P-2016-2572033 - RECO Energy 

Company's plan for an advanced payments program 

and petition for waiver of a portion of the 

Commission's regulations Pennsylvania Office of Consumer Advocate Surrebuttal Testimony - Prepaid utility service Pennsylvania Aug-17

Docket No. P-2016-2572033 - RECO Energy 

Company's plan for an advanced payments program 

and petition for waiver of a portion of the 

Commission's regulations Pennsylvania Office of Consumer Advocate Rebuttal Testimony - Prepaid utility service Pennsylvania Jul-17

Docket No. P-2016-2572033 - RECO Energy 

Company's plan for an advanced payments program 

and petition for waiver of a portion of the 

Commission's regulations Pennsylvania Office of Consumer Advocate Direct Testimony - Prepaid utility service Pennsylvania Jun-17

D.P.U 15-155 - Massachusetts Electric Company, 

Nantucket Electric Company, each d/b/a National 

Grid Massachusetts Low-Income Weatherization and Fuel Assistance Program Network

Direct Testimony - low-income discount rate, rate design, net energy 

metering and solar renewable energy credits Massachusetts Mar-16

Cause No. 44688 - Northern Indiana Public 

Service Company Citizens Actions Coalition of Indiana and the Environmental Law & Policy Center

Direct Testimony - General rate case - rate design, affordability 

program, credit and collections data reporting Indiana Jan-16

Case No. 15-00261-UT - Public Service Company 

of New Mexico New Mexico Coalition for Clean Affordable Energy

Direct Testimony - Rate design, affordable payment program, credit 

and collections data collection and reporting New Mexico Jan-16

6690-UR-124 - Wisconsin Public Service

Corporation Wisconsin Community Action Program Association Comment - Rate design Wisconsin Oct-15

Cause No. 44576 - Indianapolis Power and Light 

Company

Citizens Actions Coalition of Indiana, Indiana Association for Community and 

Economic Development, Indiana Coalition of Human Services, Indiana Community 

Action Association, Indiana NAACP, and National Association of Social Workers 

Indiana Chapter Direct Testimony - energy affordability program, rate design Indiana Jul-15

05-UR-107 - Wisconsin Electric Power Company 

and Wisconsin Gas Company Wisconsin Community Action Program Association Comment - Rate design Wisconsin Oct-14

3270-UR-120 - Madison Gas and Electric 

Company Wisconsin Community Action Program Association Comment - Rate design Wisconsin Oct-14

6690-UR-123 - Wisconsin Public Service 

Corporation Wisconsin Community Action Program Association Comment - Rate design Wisconsin Sep-14

Docket 14-05004 - Nevada Energy Company Nevada Bureau of Consumer Protection Direct Testimony - Prepaid utility service Nevada Aug-14

D.P.U. 14-04 - Investigation into time-varying rates NCLC's low-income clients Comment - Rate design, regulatory consumer protections Massachusetts Mar-14

Docket No. 4450 - Rules and regulations governing 

the termination of residential electric and natural gas 

service George Wiley Center Comment - Regulatory consumer protections Rhode Island Dec-13

Application 11-10-002 - San Diego Gas and 

Electric Company For Authority To Update 

Marginal Costs, Cost Allocation, And Electric Rate 

Design

National Consumer Law Center's low-income clients, The Utility Reform Network, 

Center for Accessible Technology, Greenlining Institute Direct Testimony - Prepaid utility service California Jun-12

Rulemaking 09-11-014 - Rulemaking to Examine 

the Commission’s Post-2008 Energy Efficiency 

Policies, Programs, Evaluation,

Measurement, and Verification, and Related

Issues NCLC's low-income clients Comment - Energy efficiency financing California Feb-12

John Howat Regulatory Commission Testimony and Comment Experience

2 
i T T T T .I 

I 

Exhibit JH-1 

3 

Case Name/Docket Client Topic Jurisdiction Date

Rulemaking 09-11-014 - Rulemaking to Examine 

the Commission’s Post-2008 Energy Efficiency 

Policies, Programs, Evaluation,

Measurement, and Verification, and Related

Issues NCLC's low-income clients Reply Comment - Energy efficiency financing California Feb-12

Docket Nos. UE-111048 and UG-111049 - Puget 

Sound Energy The Opportunity Council Direct Testimony - Bill payment assistance, home energy affordability Washington Dec-11

R-10-02-005 - Rulemaking to address the issue of 

customers' electric and natural gas service 

disconnection NCLC's low-income clients Comments - Regulatory consumer protections California Sep-10

Docket No. 7535 - Petition of AARP for the 

establishment of reduced rates for low-income 

consumers of Green Mountain Power Corporation 

and Central Vermont Public Service Corporation; 

and as expanded to possibly include general 

applicability to all Vermont retail electric utilities AARP Vermont Rebuttal Testimony - Bill payment assistance Vermont Jun-10

Docket 10-02009 - Nevada Energy Washoe County Senior Law Project Direct Testimony - Advanced meter consumer protections Nevada Apr-10

R-10-02-005 - Rulemaking to address the issue of 

customers' electric and natural gas service 

disconnection NCLC's low-income clients Opening Comment - Regulatory consumer protections California Mar-10

Docket No. 06-0703 - Rulemaking IL Admin. 

Code - Part 280 South Austin Community Council and Community Action for Fair Utility Practice Direct Testimony - Regulatory consumer protections Illinois Jan-10

Project No. 35533 NCLC's low-income clients Comment - Prepaid utility service Texas Jan-10

Cause No. 43669 - Citizens Gas, Northern Indiana 

Public Service Company, and Vectren Energy 

Delivery AARP and Citizens Action Coalition Direct Testimony - Bill payment assistance, home energy affordability Indiana Sep-09

Docket No. 7535 - Petition of AARP for the 

establishment of reduced rates for low-income 

consumers of Green Mountain Power Corporation 

and Central Vermont Public Service Corporation; 

and as expanded to possibly include general 

applicability to all Vermont retail electric utilities AARP Vermont Direct Testimony - Bill payment assistance Vermont Sep-09

D.P.U. 09-34 - Western Massachusetts Electric 

Company Low Income Weatherization and Fuel Assistance Network Comment - Prepaid utility service Massachusetts Jun-09

Case No. ER-2008-0318 - Ameren UE AARP Surrebuttal Testimony - Hot weather safety program Missouri Nov-08

Case No. ER-2008-0318 - Ameren UE AARP Direct Testimony - Hot weather safety program Missouri Aug-08

D.T.E./D.P.U. 07-30 - Petition of the Attorney 

General for an Oversight Investigation of the 

Proposed Merger of National Grid and Keyspan

Low-Income Weatherization and Fuel Assistance Program Network and 

Massachusetts Energy Directors Association 

Supplemental Direct Testimony - Customer service and regulatory 

consumer protections Massachusetts Nov-07

D.T.E./D.P.U. 07-30 - Petition of the Attorney 

General for an Oversight Investigation of the 

Proposed Merger of National Grid and Keyspan

Low-Income Weatherization and Fuel Assistance Program Network and 

Massachusetts Energy Directors Association 

Direct Testimony - Customer service and regulatory consumer 

protections Massachusetts Nov-07

CASE NO. PAC- 07-5 - Rocky Mountain Power Community Action Partnership of Idaho Direct Testimony - Collection agency costs, credit and collection rules Idaho Sep-07

Docket No. P- 00062240 - Equitable Gas 

company for Approval to Increase the Level of 

Funding for its Customer Assistance Program and to 

Implement an Adjustable Rate Mechanism to 

Recover Associated Expenses Concerning 

Universal Service and Energy Conservation Plan 

Costs Pennsylvania Utility Law Project Surrebuttal Testimony - Low Income affordability programs Pennsylvania May-07

John Howat Regulatory Commission Testimony and Comment Experience
i T T T T .l 

Exhibit JH-1 

Case Name/Docket Client Topic Jurisdiction Date

Docket No. P- 00062240 - Equitable Gas 

company for Approval to Increase the Level of 

Funding for its Customer Assistance Program and to 

Implement an Adjustable Rate Mechanism to 

Recover Associated Expenses Concerning 

Universal Service and Energy Conservation Plan 

Costs Pennsylvania Utility Law Project Rebuttal Testimony - Low Income affordability programs Pennsylvania May-07

Docket No. P- 00062240 - Equitable Gas 

company for Approval to Increase the Level of 

Funding for its Customer Assistance Program and to 

Implement an Adjustable Rate Mechanism to 

Recover Associated Expenses Concerning 

Universal Service and Energy Conservation Plan 

Costs Pennsylvania Utility Law Project Direct Testimony - Low Income affordability programs Pennsylvania Apr-07

Project No. 33814 - Rulemaking concerning 

prepaid retail electric service AARP Reply Comment - Prepaid electric service Texas Mar-07

Docket No. D-06-13 - Petition of Narragansett 

Electric Company and Southern Union Gas 

Company for Purchase and Sale of Assets George Wiley Center Direct Testimony - Merger impact mitigation Rhode Island Jun-06

Docket No. 06-0202 - Petition to Initiate 

Rulemaking with Notice and Comment for Approval 

of Certain Amendments to Illinois Administrative 

Code Part 280 South Austin Community Council and Community Action for Fair Utility Practice Direct Testimony - Regulatory consumer protections Illinois Apr-06

Docket No. 3696 - New England Gas Company George Wiley Center

Direct Testimony - General rate case - mitigation of low-income rate 

and bill impacts Rhode Island Oct-05

Docket 05-0237 - Petition to Initiate Rulemaking 

with Notice and Comment for Approval of Certain 

Amendments to Illinois Administrative Code Part 

280 South Austin Community Council and Community Action for Fair Utility Practice Direct Testimony - Regulatory consumer protections Illinois Jun-05

Docket No. 04-5003 - Nevada Power Company Nevada Bureau of Consumer Protection Direct Testimony - Prepaid utility service Nevada Jun-04

Docket No. R-00049255 - PPL Universal Service 

Programs Commission on Economic Opportunity Direct Testimony - Universal service programs Pennsylvania Jun-04

Docket No. UD-97-5 - Entergy New Orleans' and 

Entergy Louisiana's Electric and Natural Gas 

Service Regulations, Policies and Standards

Alliance for Affordable Energy, Louisiana Environmental Action Network, League 

of Women Voters of New Orleans, Pax Christi, and Bread for the World Direct Testimony - Regulatory consumer protections

New Orleans City 

Council Jul-00

John Howat Regulatory Commission Testimony and Comment Experience

4 
f f f f f 

rd B rd rd rd B 

r 

r 

r 

r 

r 

.. 

r 

.. 

r 

.. 

r 

.. 

r 

.. 

.. .. r r 

.. .. r r 

.. .. r r 

.. .. r r 

.. .. r r 

.. .. r r 

.. .. 

.. .. r r 

.. .. r r 

.. .. r r 

.. .. 

Exhibit JH-2 

Zip

Total 

Accounts

Total 

Disconnections for 

Non-payment - 

January 2019 - 

Disconnections to 

Accounts Ratio

Disconntions to 

Accounts Ratio Rank

Non-white 

Percent of 

Population

NonWhite 

Population 

Rank

White Population City County

06710 4091 1097 0.2681 1 41% 17 59% WATERBURY NEW HAVEN

06120 4529 1166 0.2575 2 80% 2 20% HARTFORD HARTFORD

06112 8644 2168 0.2508 3 87% 1 13% HARTFORD HARTFORD

06702 1070 263 0.2458 4 46% 11 54% WATERBURY NEW HAVEN

06114 10970 2560 0.2334 5 71% 3 29% HARTFORD HARTFORD

06105 9617 2207 0.2295 6 63% 5 37% HARTFORD HARTFORD

06106 15415 3431 0.2226 7 57% 6 43% HARTFORD HARTFORD

06051 13423 2962 0.2207 8 36% 23 64% NEW BRITAIN HARTFORD

06704 10594 2332 0.2201 9 47% 9 53% WATERBURY NEW HAVEN

06708 12878 2479 0.1925 10 26% 36 74% WATERBURY NEW HAVEN

06706 5758 1080 0.1876 11 46% 12 54% WATERBURY NEW HAVEN

06705 10807 2018 0.1867 12 41% 18 59% WATERBURY NEW HAVEN

06108 9535 1711 0.1794 13 47% 10 53% EAST HARTFORD HARTFORD

06372 42 7 0.1676 14 237

06052 3437 530 0.1542 15 25% 38 75% NEW BRITAIN HARTFORD

06451 9932 1513 0.1523 16 23% 40 77% MERIDEN NEW HAVEN

06855 287 40 0.1395 17 25% 39 75% NORWALK FAIRFIELD

06053 14456 1958 0.1354 18 26% 37 74% NEW BRITAIN HARTFORD

06450 14990 1980 0.1321 19 21% 43 79% MERIDEN NEW HAVEN

06320 11865 1541 0.1299 20 43% 15 57% NEW LONDON NEW LONDON

06118 11162 1430 0.1281 21 43% 16 57% EAST HARTFORD HARTFORD

06810 20785 2553 0.1228 22 45% 13 55% DANBURY FAIRFIELD

06263 225 27 0.1199 23 3% 195 97% ROGERS WINDHAM

06103 1397 167 0.1196 24 41% 19 59% HARTFORD HARTFORD

06854 5769 676 0.1172 25 36% 24 64% NORWALK FAIRFIELD

06002 9043 1024 0.1132 26 64% 4 36% BLOOMFIELD HARTFORD

06226 6650 751 0.1129 27 32% 26 68% WILLIMANTIC WINDHAM

06387 410 46 0.1123 28 19% 53 81% WAUREGAN WINDHAM

06010 27161 2880 0.106 29 16% 64 84% BRISTOL HARTFORD

06040 16061 1701 0.1059 30 39% 22 61% MANCHESTER HARTFORD

06110 5469 551 0.1007 31 35% 25 65% WEST HARTFORD HARTFORD

06353 112 11 0.098 32 53% 7 47% MONTVILLE NEW LONDON

06018 1397 133 0.0952 33 6% 152 94% CANAAN LITCHFIELD

06770 13252 1236 0.0933 34 21% 44 79% NAUGATUCK NEW HAVEN

06095 12165 1133 0.0931 35 49% 8 51% WINDSOR HARTFORD

06061 108 10 0.0927 36 0% 224 100% PINE MEADOW LITCHFIELD

06902 27817 2571 0.0924 37 44% 14 56% STAMFORD FAIRFIELD

06373 124 11 0.0887 38 0% 225 100% ONECO WINDHAM

06383 23 2 0.0883 39 238

06790 16513 1441 0.0873 40 11% 97 89% TORRINGTON LITCHFIELD

06457 20654 1746 0.0845 41 27% 32 73% MIDDLETOWN MIDDLESEX

06098 5241 430 0.082 42 7% 135 93% WINSTED LITCHFIELD

06081 690 56 0.0812 43 15% 73 85% TARIFFVILLE HARTFORD

06850 9117 740 0.0812 44 28% 30 72% NORWALK FAIRFIELD

06786 3797 308 0.0811 45 7% 136 93% TERRYVILLE LITCHFIELD

06779 3388 263 0.0776 46 6% 153 94% OAKVILLE LITCHFIELD

06851 11490 892 0.0776 47 22% 41 78% NORWALK FAIRFIELD

06042 10000 771 0.0771 48 40% 20 60% MANCHESTER HARTFORD

Involuntary Residential Service Disconnections by Zip Code and Race:

January 2019 - February 2021 - Eversource Service Territory

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Zip

Total 

Accounts

Total 

Disconnections for 

Non-payment - 

January 2019 - 

Disconnections to 

Accounts Ratio

Disconntions to 

Accounts Ratio Rank

Non-white 

Percent of 

Population

NonWhite 

Population 

Rank

County City White Population

HARTFORD MILLDALE 93% 137 7% 49 0.0766 13 170 06467

HARTFORD WEST HARTFORD 81% 54 19% 50 0.0765 532 6956 06119

HARTFORD PLAINVILLE 86% 75 14% 51 0.0762 623 8173 06062

WINDHAM NORTH WINDHAM 84% 65 16% 52 0.076 72 948 06256

FAIRFIELD DANBURY 70% 27 30% 53 0.0758 894 11794 06811

FAIRFIELD BETHEL 84% 66 16% 54 0.0745 585 7852 06801

239 55 0.074 12 162 06246

WINDHAM CENTRAL VILLAGE 100% 226 0% 56 0.0729 38 522 06332

WINDHAM PUTNAM 95% 164 5% 57 0.072 308 4275 06260

FAIRFIELD STAMFORD 71% 28 29% 58 0.0717 284 3962 06906

WINDHAM MOOSUP 95% 165 5% 59 0.0716 163 2275 06354

WINDHAM DANIELSON 89% 98 11% 60 0.0713 355 4976 06239

FAIRFIELD STAMFORD 78% 42 22% 61 0.0697 270 3874 06907

LITCHFIELD SOUTH KENT 88% 79 13% 62 0.067 24 358 06785

HARTFORD ENFIELD 82% 57 18% 63 0.0664 1166 17550 06082

LITCHFIELD NEW MILFORD 89% 99 11% 64 0.0659 765 11606 06776

NEW LONDON BALTIC 88% 87 12% 65 0.0656 76 1159 06330

FAIRFIELD SANDY HOOK 93% 138 7% 66 0.0652 261 4000 06482

LITCHFIELD NORFOLK 95% 166 5% 67 0.0647 63 973 06058

NEW HAVEN SEYMOUR 87% 80 13% 68 0.0642 446 6951 06483

LITCHFIELD THOMASTON 98% 209 2% 69 0.0621 210 3379 06787

WINDHAM DAYVILLE 94% 154 6% 70 0.0593 125 2107 06241

HARTFORD PLANTSVILLE 96% 183 4% 71 0.0589 230 3907 06479

WINDHAM QUINEBAUG 100% 227 0% 72 0.0586 15 256 06262

HARTFORD WINDSOR LOCKS 84% 67 16% 73 0.0585 329 5627 06096

NEW HAVEN BRANFORD 90% 107 10% 74 0.0584 832 14257 06405

NEW LONDON UNCASVILLE 72% 31 28% 75 0.0577 259 4490 06382

MIDDLESEX MIDDLE HADDAM 100% 228 0% 76 0.0576 10 174 06456

LITCHFIELD EAST CANAAN 100% 229 0% 77 0.057 10 175 06024

TOLLAND VERNON ROCKVILLE 79% 45 21% 78 0.0564 836 14819 06066

FAIRFIELD STAMFORD 60% 21 40% 79 0.0559 327 5846 06901

MIDDLESEX CROMWELL 87% 81 13% 80 0.0557 349 6261 06416

TOLLAND STORRS MANSFIELD 82% 58 18% 81 0.0552 231 4188 06268

HARTFORD EAST WINDSOR 81% 55 19% 82 0.0547 139 2540 06088

240 83 0.0547 6 110 06781

NEW LONDON QUAKER HILL 92% 124 8% 84 0.0533 81 1520 06375

NEW HAVEN BEACON FALLS 95% 167 5% 85 0.053 137 2587 06403

HARTFORD BROAD BROOK 80% 48 20% 86 0.0527 150 2848 06016

LITCHFIELD BARKHAMSTED 95% 168 5% 87 0.0525 74 1411 06063

HARTFORD SOUTHINGTON 92% 125 8% 88 0.0519 715 13767 06489

LITCHFIELD WATERTOWN 92% 126 8% 89 0.0516 289 5604 06795

HARTFORD NEWINGTON 81% 56 19% 90 0.0515 681 13211 06111

FAIRFIELD STAMFORD 73% 33 27% 91 0.0514 445 8655 06905

WINDHAM STERLING 96% 184 4% 92 0.0512 72 1405 06377

WINDHAM NORTH GROSVENORDALE 97% 196 3% 93 0.0509 83 1631 06255

241 94 0.0506 6 06233 119

PLAINFIELD WINDHAM 9% 115 91% 95 0.0504 06374 3154 159

WOLCOTT NEW HAVEN 7% 139 93% 96 0.05 06716 6320 316

0% 230 100% EAST KILLINGLY WINDHAM 97 0.0499 06243 521 26

BROOKFIELD FAIRFIELD 12% 88 88% 98 0.0495 06804 7191 356

WEATOGUE HARTFORD 5% 169 95% 99 0.0491 06089 1364 67

WATERFORD NEW LONDON 13% 82 87% 100 0.0485 06385 7224 350

CANTON HARTFORD 10% 108 90% 101 0.0475 06019 4382 208

Involuntary Residential Service Disconnections by Zip Code and Race:

January 2019 - February 2021 - Eversource Service Territory

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Zip

Total 

Accounts

Total 

Disconnections for 

Non-payment - 

January 2019 - 

Disconnections to 

Accounts Ratio

Disconntions to 

Accounts Ratio Rank

Non-white 

Percent of 

Population

NonWhite 

Population 

Rank

County City White Population

14% 76 86% WETHERSFIELD HARTFORD 102 0.0472 06109 11565 546

COLCHESTER NEW LONDON 7% 140 93% 103 0.0472 06415 6595 311

6% 155 94% SOUTH WINDHAM WINDHAM 104 0.0466 06266 279 13

NEWTOWN FAIRFIELD 9% 116 91% 105 0.0466 06470 6229 290

COBALT MIDDLESEX 0% 231 100% 106 0.0464 7 06414 151

CLINTON MIDDLESEX 5% 170 95% 107 0.0463 06413 6225 288

WINDHAM WINDHAM 20% 49 80% 108 0.0461 06280 1432 66

ROCKY HILL HARTFORD 27% 34 73% 109 0.046 06067 8956 412

20% 50 80% SOUTH WINDSOR HARTFORD 110 0.046 06074 10585 487

WOODBURY LITCHFIELD 5% 171 95% 111 0.0454 06798 4555 207

PAWCATUCK NEW LONDON 9% 117 91% 112 0.0451 06379 4127 186

7% 141 93% EAST HAMPTON MIDDLESEX 113 0.0447 06424 5565 249

LEDYARD NEW LONDON 17% 61 83% 114 0.0446 06339 3382 151

BANTAM LITCHFIELD 4% 185 96% 115 0.0446 06750 717 32

WILLINGTON TOLLAND 13% 83 87% 116 0.0444 06279 2633 117

11% 100 89% NORTH STONINGTON NEW LONDON 117 0.0443 06359 2305 102

MONROE FAIRFIELD 10% 109 90% 118 0.0443 06468 6947 308

MORRIS LITCHFIELD 2% 210 98% 119 0.0441 06763 1157 51

SHARON LITCHFIELD 7% 142 93% 120 0.0436 06069 1859 81

CHAPLIN WINDHAM 11% 101 89% 121 0.0436 06235 1010 44

LAKESIDE LITCHFIELD 0% 232 100% 122 0.043 5 06758 116

5% 172 95% STAFFORD SPRINGS TOLLAND 123 0.0426 06076 5893 251

BROOKLYN WINDHAM 8% 127 92% 124 0.0425 06234 3154 134

21% 46 79% WEST HARTFORD HARTFORD 125 0.0415 06117 5539 230

PROSPECT NEW HAVEN 10% 110 90% 126 0.0409 06712 3741 153

DEEP RIVER MIDDLESEX 7% 143 93% 127 0.0403 06417 2136 86

COLUMBIA TOLLAND 4% 186 96% 128 0.0401 06237 2318 93

1% 221 99% NEW HARTFORD LITCHFIELD 129 0.0397 06057 2923 116

MIDDLEFIELD MIDDLESEX 3% 197 97% 130 0.0396 06455 1718 68

WESTPORT FAIRFIELD 10% 111 90% 131 0.0395 06880 10750 425

PLYMOUTH LITCHFIELD 1% 222 99% 132 0.0393 06782 1348 53

RIVERTON LITCHFIELD 10% 112 90% 133 0.0389 06065 283 11

PORTLAND MIDDLESEX 3% 198 97% 134 0.0389 06480 4111 160

OXFORD NEW HAVEN 7% 144 93% 135 0.0388 06478 5030 195

LITCHFIELD KENT 6% 156 94% 136 0.0386 06757 1374 53

THOMPSON WINDHAM 5% 173 95% 137 0.0384 06277 2212 85

12% 89 88% MANSFIELD CENTER TOLLAND 138 0.0381 06250 2414 92

LAKEVILLE LITCHFIELD 2% 211 98% 139 0.0379 06039 1294 49

OAKDALE NEW LONDON 12% 90 88% 140 0.0377 06370 2651 100

AMSTON TOLLAND 4% 187 96% 141 0.0374 06231 803 30

SOUTHBURY NEW HAVEN 7% 145 93% 142 0.0374 06488 8563 320

EAST LYME NEW LONDON 17% 62 83% 143 0.0372 06333 2982 111

242 144 0.0372 06753 296 11

13% 84 87% WASHINGTON DEPOT LITCHFIELD 145 0.0371 06794 592 22

MOODUS MIDDLESEX 5% 174 95% 146 0.0365 06469 1478 54

MIDDLESEX HADDAM 1% 223 99% 147 0.0361 06438 1192 43

8% 128 92% NEW FAIRFIELD FAIRFIELD 148 0.0361 06812 5671 205

CHESTER MIDDLESEX 3% 199 97% 149 0.036 06412 1723 62

BETHANY NEW HAVEN 12% 91 88% 150 0.0359 06524 2089 75

9% 118 91% NEW CANAAN FAIRFIELD 151 0.0359 06840 7597 273

6% 157 94% CORNWALL BRIDGE LITCHFIELD 152 0.0353 06754 850 30

CHESHIRE NEW HAVEN 16% 68 84% 153 0.0351 06410 10197 358

0% 233 100% WOODSTOCK VALLEY WINDHAM 154 0.035 06282 515 18

Involuntary Residential Service Disconnections by Zip Code and Race:

January 2019 - February 2021 - Eversource Service Territory

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Zip

Total 

Accounts

Total 

Disconnections for 

Non-payment - 

January 2019 - 

Disconnections to 

Accounts Ratio

Disconntions to 

Accounts Ratio Rank

Non-white 

Percent of 

Population

NonWhite 

Population 

Rank

County City White Population

WINDHAM SCOTLAND 71% 29 29% 155 0.0348 22 633 06264

TOLLAND BOLTON 94% 158 6% 156 0.0346 71 2051 06043

FAIRFIELD NORWALK 94% 159 6% 157 0.0346 53 1532 06853

LITCHFIELD SALISBURY 89% 102 11% 158 0.0345 44 1277 06068

HARTFORD GLASTONBURY 84% 69 16% 159 0.0344 429 12455 06033

TOLLAND COVENTRY 95% 175 5% 160 0.0344 183 5318 06238

LITCHFIELD GAYLORDSVILLE 97% 200 3% 161 0.0339 15 443 06755

HARTFORD EAST GRANBY 89% 103 11% 162 0.0334 73 2182 06026

243 163 0.0333 4 120 06094

MIDDLESEX WESTBROOK 93% 146 7% 164 0.0333 135 4060 06498

FAIRFIELD RIDGEFIELD 92% 129 8% 165 0.0333 320 9623 06877

LITCHFIELD LITCHFIELD 96% 188 4% 166 0.0329 90 2738 06759

MIDDLESEX HIGGANUM 90% 113 10% 167 0.0327 73 2233 06441

HARTFORD WEST HARTFORD 91% 119 9% 168 0.0325 259 7961 06107

NEW LONDON GALES FERRY 89% 104 11% 169 0.0324 87 2683 06335

FAIRFIELD WESTON 88% 92 12% 170 0.0324 120 3698 06883

244 171 0.032 4 125 06439

NEW LONDON NIANTIC 84% 70 16% 172 0.0319 196 6151 06357

TOLLAND TOLLAND 93% 147 7% 173 0.0317 178 5617 06084

LITCHFIELD BETHLEHEM 93% 148 7% 174 0.0316 54 1707 06751

NEW LONDON OLD LYME 96% 189 4% 175 0.0315 190 6031 06371

FAIRFIELD GREENWICH 80% 51 20% 176 0.0315 339 10772 06830

NEW HAVEN GUILFORD 92% 130 8% 177 0.0313 304 9706 06437

TOLLAND SOMERS 88% 93 12% 178 0.0311 115 3700 06071

LITCHFIELD WASHINGTON 97% 201 3% 179 0.0307 25 813 06793

HARTFORD SIMSBURY 90% 114 10% 180 0.0305 202 6613 06070

HARTFORD BERLIN 93% 149 7% 181 0.0304 243 7987 06037

TOLLAND ELLINGTON 87% 85 13% 182 0.0303 216 7129 06029

LITCHFIELD NEW PRESTON MARBLE DALE 92% 131 8% 183 0.0302 32 1058 06777

GREENWICH FAIRFIELD 12% 94 88% 184 0.0299 06831 5928 177

ASHFORD WINDHAM 5% 176 95% 185 0.0298 06278 1977 59

WILTON FAIRFIELD 12% 95 88% 186 0.0298 06897 6581 196

HARWINTON LITCHFIELD 3% 202 97% 187 0.0296 06791 2364 70

EASTFORD WINDHAM 2% 212 98% 188 0.0294 06242 816 24

UNIONVILLE HARTFORD 16% 71 84% 189 0.0293 06085 2658 78

MYSTIC NEW LONDON 8% 132 92% 190 0.0293 06355 6045 177

GOSHEN LITCHFIELD 5% 177 95% 191 0.0292 06756 1749 51

3% 203 97% MARLBOROUGH HARTFORD 192 0.029 06447 2417 70

ROCKFALL MIDDLESEX 2% 213 98% 193 0.029 6 06481 207

PRESTON NEW LONDON 13% 86 87% 194 0.0289 06365 2039 59

MADISON NEW HAVEN 6% 160 94% 195 0.0288 06443 8049 232

8% 133 92% BRIDGEWATER LITCHFIELD 196 0.0288 06752 903 26

STAMFORD FAIRFIELD 14% 77 86% 197 0.0287 06903 5235 150

6% 161 94% FALLS VILLAGE LITCHFIELD 198 0.0284 06031 670 19

LEBANON NEW LONDON 3% 204 97% 199 0.0284 06249 2041 58

245 200 0.0283 06258 600 17

MARION HARTFORD 0% 234 100% 201 0.0283 6 06444 212

NORTHFIELD LITCHFIELD 7% 150 93% 202 0.0283 06778 529 15

VOLUNTOWN NEW LONDON 11% 105 89% 203 0.0279 06384 1218 34

SALEM NEW LONDON 11% 106 89% 204 0.0279 06420 1830 51

9% 120 91% EAST HARTLAND HARTFORD 205 0.0277 06027 578 16

WOODSTOCK WINDHAM 2% 214 98% 206 0.0276 06281 3301 91

HARTFORD AVON 18% 59 82% 207 0.027 06001 7673 207

20% 52 80% FARMINGTON HARTFORD 208 0.027 06032 8607 232

Involuntary Residential Service Disconnections by Zip Code and Race:

January 2019 - February 2021 - Eversource Service Territory

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Zip

Total 

Accounts

Total 

Disconnections for 

Non-payment - 

January 2019 - 

Disconnections to 

Accounts Ratio

Disconntions to 

Accounts Ratio Rank

Non-white 

Percent of 

Population

NonWhite 

Population 

Rank

County City White Population

2% 215 98% EAST HADDAM MIDDLESEX 209 0.0267 06423 3033 81

2% 216 98% WEST CORNWALL LITCHFIELD 210 0.0267 06796 449 12

DURHAM MIDDLESEX 2% 217 98% 211 0.0262 06422 2753 72

ROXBURY LITCHFIELD 3% 205 97% 212 0.0262 06783 1258 33

REDDING FAIRFIELD 4% 190 96% 213 0.0262 06896 3397 89

ANDOVER TOLLAND 5% 178 95% 214 0.0261 06232 1340 35

SHERMAN FAIRFIELD 5% 179 95% 215 0.0257 06784 1870 48

SUFFIELD HARTFORD 21% 47 79% 216 0.0256 06078 4337 111

GRANBY HARTFORD 6% 162 94% 217 0.0251 06035 3193 80

17% 63 83% CENTERBROOK MIDDLESEX 218 0.0244 8 06409 328

COLEBROOK LITCHFIELD 4% 191 96% 219 0.0243 06021 740 18

IVORYTON MIDDLESEX 2% 218 98% 220 0.0237 06442 1139 27

3% 206 97% KILLINGWORTH MIDDLESEX 221 0.0236 06419 2674 63

MIDDLEBURY NEW HAVEN 9% 121 91% 222 0.0233 06762 3049 71

HEBRON TOLLAND 3% 207 97% 223 0.0232 06248 2888 67

CANTERBURY WINDHAM 3% 208 97% 224 0.0228 06331 2105 48

5% 180 95% OLD SAYBROOK MIDDLESEX 225 0.0228 06475 5882 134

2% 219 98% WEST GRANBY HARTFORD 226 0.0225 06090 444 10

JEWETT CITY NEW LONDON 9% 122 91% 227 0.0221 06351 4882 108

HAMPTON WINDHAM 4% 192 96% 228 0.022 06247 819 18

STONINGTON NEW LONDON 5% 181 95% 229 0.0219 06378 3148 69

4% 193 96% POMFRET CENTER WINDHAM 230 0.0217 06259 1013 22

BURLINGTON HARTFORD 6% 163 94% 231 0.0213 06013 3658 78

8% 134 92% SOUTH GLASTONBURY HARTFORD 232 0.0212 06073 1979 42

246 233 0.0204 1 06230 49

GROTON NEW LONDON 27% 35 73% 234 0.0204 06340 1031 21

DARIEN FAIRFIELD 9% 123 91% 235 0.0202 06820 7185 145

EAST BERLIN HARTFORD 14% 78 86% 236 0.0196 06023 509 10

COS COB FAIRFIELD 16% 72 84% 237 0.0194 06807 2883 56

ESSEX MIDDLESEX 15% 74 85% 238 0.0176 06426 1700 30

12% 96 88% OLD GREENWICH FAIRFIELD 239 0.0173 06870 2778 48

5% 182 95% WEST SUFFIELD HARTFORD 240 0.017 06093 1468 25

HANOVER NEW LONDON 0% 235 100% 241 0.0163 2 06350 123

7% 151 93% WEST SIMSBURY HARTFORD 242 0.0156 06092 1406 22

4% 194 96% NORTH FRANKLIN NEW LONDON 243 0.0152 06254 789 12

RIVERSIDE FAIRFIELD 18% 60 82% 244 0.0152 06878 2767 42

2% 220 98% NORTH GRANBY HARTFORD 245 0.0134 06060 892 12

0% 236 100% WEST HARTLAND HARTFORD 246 0.0119 2 06091 168

247 247 0.0077 1 06829 131

248 248 0 0 06251 11

Involuntary Residential Service Disconnections by Zip Code and Race:

January 2019 - February 2021 - Eversource Service Territory

5 
Exhibit JH-3 

sched_num_ttl

MWH Sales Revenue

Average # 

Customers

kWh Sales per 

Customer Revenue per kWh

Annual 

Residential 

Expenditure

Monthly 

Residential 

Expenditure

Monthly Bill 

Impact: Tiered 

Discount

Monthly Bill 

Impact: Straight 

Discount

Annual Revenue From 

Program Assessment: 

Tiered Discount

Annual Revenue From 

Program Assessment: 

Straight Discount

Residential (Account 440)

1 Residential 7,990,244 $1,532,850,270 1,004,740 7,953 $0.1918 $1,525 $127 $2.58 $2.39 $31,134,063 $28,780,538

5 Res. Electric Heating 1,680,962 $299,002,707 136,237 12,339 $0.1779 $2,195 $183 $3.72 $3.44 $6,075,101 $5,615,864

7 Time of Day 5,758 $1,024,805 480 11,996 $0.1780 $2,135 $178 $3.61 $3.34 $20,821 $19,247

18 Controlled Water Heating 24 $5,283 10 2,400 $0.2201 $528 $44 $0.89 $0.83 $107 $99

30 Small Gen Service 11,499 $1,322,118 230 49,996 $0.1150 $5,750 $479 $9.73 $9.00 $26,864 $24,833

35 Intermediate Gen Service 2,051 $158,685 6 341,833 $0.0774 $26,458 $2,205 $44.79 $41.40 $3,225 $2,981

37 Intermediate T-O-D 5,607 $384,240 7 801,000 $0.0685 $54,869 $4,572 $92.88 $85.86 $7,802 $7,213

56 Intermediate T-O-D 2,570 $170,796 2 1,285,000 $0.0665 $85,453 $7,121 $144.66 $133.72 $3,472 $3,209

115 Unmetered 28 $5,355 22 1,273 $0.1913 $244 $20 $0.41 $0.38 $109 $101

116 Street Lighting and Security 4,101 $1,523,479 2,707 1,515 $0.3715 $563 $47 $0.95 $0.88 $30,950 $28,610

Unbilled Revenue 3,466 $627,771 $0.1811

Less: Duplicate Customers col d -2,718

Total 9,706,310 $1,837,075,509 1,141,723 8,501 $0.1893 $1,609 $134 $2.72 $2.52 $37,323,633 $34,502,218

Eversource 2019 FF1 p. 304

1 
Exhibit JH-3 

sched_num_ttl

MWH Sales Revenue

Average # 

Customers

kWh Sales per 

Customer Revenue per kWh

Annual 

Residential 

Expenditure

Monthly 

Residential 

Expenditure

Monthly Bill 

Impact: Tiered 

Discount

Monthly Bill 

Impact: Straight 

Discount

Annual Revenue From 

Program Assessment: 

Tiered Discount

Annual Revenue From 

Program Assessment: 

Straight Discount

Commercial (Account 442)

1 Residential 18,943 $3,130,553 987 19,193 $0.1653 $3,173 $264 $5.37 $4.96 $63,611 $58,803

5 Com. Electric Heating 8 $1,081 1 8,000 $0.1351 $1,081 $90 $1.83 $1.69 $22 $20

7 Time of Day 461 $58,053 8 57,625 $0.1259 $7,255 $605 $12.28 $11.35 $1,179 $1,090

18 Water Heating 640 $105,152 142 4,507 $0.1643 $741 $62 $1.25 $1.16 $2,136 $1,975

21 Interruptible

27 Time of Day 138,253 $14,700,348 277 499,108 $0.1063 $53,055 $4,421 $89.82 $83.03 $298,545 $275,977

29 Outdoor Recreational 2,637 $602,759 211 12,498 $0.2286 $2,857 $238 $4.84 $4.47 $12,246 $11,320

30 Small Gen. Service 3,448,900 $479,037,502 98,387 35,054 $0.1389 $4,869 $406 $8.24 $7.62 $9,731,506 $8,995,870

35 Intermediate Gen. Service 424,373 $38,949,986 1,088 390,049 $0.0918 $35,806 $2,984 $60.62 $56.03 $791,395 $731,571

37 Intermediate T-O-D Electric 1,028,325 $86,009,657 1,147 896,534 $0.0836

39 Large Interruptible Service

40 Church & School 91,868 $11,762,199 1,876 48,970 $0.1280 $6,268 $522 $10.61 $9.81 $238,878 $220,820

41 Large Church & School 14,187 $1,368,545 12 1,182,250 $0.0965 $114,087 $9,507 $193.13 $178.53 $27,811 $25,709

55 Intermediate T-O-D Manuf. 255,097 $17,236,557 108 2,362,009 $0.0676 $159,672 $13,306 $270.30 $249.87 $350,312 $323,830

56 Intermediate TOD Non-Man. 1,860,324 $132,920,974 666 2,793,279 $0.0715 $199,719 $16,643 $338.10 $312.54 $2,702,073 $2,497,815

57 Large T-O-D Manufacturers 103,403 $7,306,872 13 7,954,077 $0.0707 $562,353 $46,863 $951.99 $880.02 $148,510 $137,283

58 Large T-O-D Non-Man. 1,326,349 $91,684,769 91 14,575,264 $0.0691 $1,007,151 $83,929 $1,704.97 $1,576.08 $1,861,823 $1,721,082

115 Unmetered 45,794 $4,312,180 1,602 28,586 $0.0942 $2,693 $224 $4.56 $4.21 $87,633 $81,009

116 Street & Security Lighting 21,248 $4,454,862 8,572 2,479 $0.2097 $520 $43 $0.88 $0.81 $90,523 $83,680

119 Standby & Auxillary Power 256 $16,754 $0.0654

Unbilled Revenue 11,150 -$1,104,107 -$0.0990

Less: Duplicate Customers col d -8,713

Total 8,792,216 $892,554,696 106,475 82,575 $0.1015 $8,381 $698 $14.19 $13.12 $18,128,622 $16,758,221

Eversource 2019 FF1 p. 304

2 
Exhibit JH-3 

sched_num_ttl

MWH Sales Revenue

Average # 

Customers

kWh Sales per 

Customer Revenue per kWh

Annual 

Residential 

Expenditure

Monthly 

Residential 

Expenditure

Monthly Bill 

Impact: Tiered 

Discount

Monthly Bill 

Impact: Straight 

Discount

Annual Revenue From 

Program Assessment: 

Tiered Discount

Annual Revenue From 

Program Assessment: 

Straight Discount

Industrial (Account 442)

27 Time of Day 22,820 $2,464,752 69 330,725 $0.1080 $35,718 $2,977 $60.47 $55.90 $50,066 $46,281

30 Small Gen. Service 128,273 $18,805,885 2,212 57,990 $0.1466 $8,501 $708 $14.39 $13.30 $382,010 $353,133

35 Intermediate Gen. Serv 48,130 $5,623,603 129 373,101 $0.1168 $43,578 $3,632 $73.77 $68.20 $114,199 $105,566

37 Intermediate T-O-D 171,832 $15,538,422 237 725,030 $0.0904 $65,543 $5,462 $110.95 $102.57 $315,555 $291,701

39 Interruptible Service 159,426 $4,469,249 4 39,856,500 $0.0280 $1,115,982 $92,999 $1,889.20 $1,746.39 $90,682 $83,827

55 Inter. T-O-D Man. 450,392 $30,066,621 193 2,333,637 $0.0668 $155,887 $12,991 $263.89 $243.95 $611,181 $564,980

56 Inter. T-O-D Non-Man. 118,826 $10,022,132 53 2,242,000 $0.0843 $189,001 $15,750 $319.95 $295.77 $203,489 $188,107

57 Large TOD Manufacturer 841,925 $44,678,831 75 11,225,667 $0.0531 $596,083 $49,674 $1,009.09 $932.81 $908,177 $839,525

58 Large T-O-D Non-Manu. 42,715 $5,751,533 9 4,746,111 $0.1346 $638,827 $53,236 $1,081.44 $999.69 $116,796 $107,967

115 Unmetered -$123 1

116 Street & Security Light 784 $142,882 290 2,703 $0.1822

119 Standby & Auxillary Pwr 3,825 $676,391 2 1,912,500 $0.1768 $338,130 $28,178 $572.41 $529.14 $13,738 $12,699

Unbilled Revenue 9,185 -$6,436 -$0.0007

Less: Duplicate Customers col d -290

Total 1,998,133 $138,233,742 2,984 669,616 $0.0692 $46,337 $3,861 $78.44 $72.51 $2,808,881 $2,596,548

Eversource 2019 FF1 p. 304

3 
Exhibit JH-3 

sched_num_ttl

MWH Sales Revenue

Average # 

Customers

kWh Sales per 

Customer Revenue per kWh

Annual 

Residential 

Expenditure

Monthly 

Residential 

Expenditure

Monthly Bill 

Impact: Tiered 

Discount

Monthly Bill 

Impact: Straight 

Discount

Annual Revenue From 

Program Assessment: 

Tiered Discount

Annual Revenue From 

Program Assessment: 

Straight Discount

Street Lighting (Account 444)

115 Unmetered 8,515 $886,891 $0.1042

116 Street & Security Lighting 24,116 $7,965,172 1,703 14,161 $0.3303 $4,677 $390 $7.92 $7.32 $161,815 $149,583

117 Partial Street Lighting 27,729 $2,376,607 2,465 11,249 $0.0857 $964 $80 $1.63 $1.51 $48,274 $44,625

Unbilled Revenue -229 -$2,676 798 -287 $0.0117 -$3 $ 0 -$0.01 -$0.01 -$54 -$50

Total 60,131 $11,225,994 4,966 12,109 $0.1867 $2,261 $188 $3.83 $3.54 $228,067 $210,826

Railroads and Railways

(Account 446)

58 Large T-O-D Non-Mfg 163,782 $19,169,747 2 81,891,000 $0.1170 $9,581,247 $798,437 $16,219.72 $14,993.62 $389,273 $359,847

Unbilled Revenue -884 -$21,286 $0.0241

Total 162,898 $19,148,461 2 81,449,000 $0.1175 $9,570,258 $797,521 $16,201.12 $14,976.42 $388,827 $359,434

Total Sales (MWH) and Revenue 

From Sales ($) 20,719,688 $2,898,238,402 58,878,029 54,427,247

Tiered Discount Program Cost as 

Percent of Revenues From Sales 2.03%

Eversource 2019 FF1 p. 304

4 
Exhibit JH-4 

sched_num_ttl

MWH Sales 

(Delivery + 

Generation)

Revenue

Revenue 

(Delivery + 

Generation)*

Average # 

Customers 

(Delivery + 

Generation)

kWh Sales per 

Customer (Weighted 

Average: Delivery & 

Generation)

Revenue per kWh

Annual 

Residential 

Expenditure

Monthly 

Residential 

Expenditure

Monthly Bill 

Impact: Tiered 

Discount

Monthly Bill 

Impact: Straight 

Discount

Annual Revenue From 

Program Assessment: 

Tiered Discount

Annual Revenue From 

Program Assessment: 

Straight Discount

Residential - Delivery

(R) Residential 2,086,127 $210,360,654 $356,936,330 395,980 5,268 $0.1711 $912 $76 $1.56 $1.29 $4,325,837 $3,572,434

(RT) Optional 1,274,704 $106,176,869 $173,359,744 119,434 10,673 $0.1360 $1,478 $123 $2.53 $2.09 $2,183,831 $1,803,487

(GS) General Service 31,259 $2,766,077 $4,404,393 3,175 9,845 $0.1409 $1,512 $126 $2.59 $2.14 $56,869 $46,964

(GST) TOD Commercial 36,489 $2,598,899 $3,189,139 423 86,262 $0.0874 $9,549 $796 $16.36 $13.51 $53,404 $44,103

(LPT) Large Power Session 13,238 $664,056 $749,271 18 735,444 $0.0566 $47,447 $3,954 $81.29 $67.14 $13,657 $11,279

(M) Street and Security Lighting 1,526 $279,853 $407,137 $0.2668

(MH) Metal Halide 1,760 $318,870 $469,216 $0.2666

(LED) Outdoor 269 $64,045 $71,796 $0.2669

TOTAL RESIDENTIAL 3,445,372 $323,229,323 $536,788,958 519,030 6,638 $0.1558 $1,061 $88 $1.82 $1.50 $6,644,229 $5,487,046

United Illuminating 2019 FF1 p. 304

sched_num_ttl

MWH Sales 

(Delivery + 

Generation)

Revenue

Revenue 

(Delivery + 

Generation)*

Average # 

Customers 

(Delivery + 

Generation)

kWh Sales per 

Customer (Weighted 

Average: Delivery & 

Generation)

Revenue per kWh

Annual 

Residential 

Expenditure

Monthly 

Residential 

Expenditure

Monthly Bill 

Impact: Tiered 

Discount

Monthly Bill 

Impact: Straight 

Discount

Annual Revenue From 

Program Assessment: 

Tiered Discount

Annual Revenue From 

Program Assessment: 

Straight Discount

Commercial - Delivery

(R) Residential 1,128 $122,145 $225,826 485 2,326 $0.2002 $477 $40 $0.82 $0.68 $2,511 $2,074

(RT) Optional 2,868 $229,981 $375,134 200 14,340 $0.1308 $2,035 $170 $3.49 $2.88 $4,728 $3,904

(GS) General Service 632,061 $54,269,280 $80,082,129 34,164 18,501 $0.1267 $2,453 $204 $4.20 $3.47 $1,115,681 $921,370

(GST) TOD Commercial 1,412,653 $102,924,876 $122,900,811 10,848 130,222 $0.0870 $12,435 $1,036 $21.31 $17.59 $2,116,377 $1,747,781

(LPT) Large Power Session 849,037 $53,065,423 $55,866,635 363 2,338,945 $0.0658 $168,038 $14,003 $287.91 $237.76 $1,091,746 $901,603

(M) Street and Security Lighting 6,094 $1,175,258 $1,583,221 $0.2598

(MH) Metal Halide 13,122 $2,242,643 $3,409,096 $0.2598

(LED) Outdoor 822 $190,327 $213,720 $0.2600

TOTAL COMMERCIAL 2,917,785 $214,219,933 $256,765,080 46,060 63,347 $0.0880 $6,893 $574 $11.81 $9.75 $4,405,103 $3,637,895

United Illuminating 2019 FF1 p. 304

1 
Exhibit JH-4 

sched_num_ttl

MWH Sales 

(Delivery + 

Generation)

Revenue

Revenue 

(Delivery + 

Generation)*

Average # 

Customers 

(Delivery + 

Generation)

kWh Sales per 

Customer (Weighted 

Average: Delivery & 

Generation)

Revenue per kWh

Annual 

Residential 

Expenditure

Monthly 

Residential 

Expenditure

Monthly Bill 

Impact: Tiered 

Discount

Monthly Bill 

Impact: Straight 

Discount

Annual Revenue From 

Program Assessment: 

Tiered Discount

Annual Revenue From 

Program Assessment: 

Straight Discount

Industrial - Delivery

(R) Residential

(GS) General Service 19,347 $2,023,996 $2,652,474 606 31,926 $0.1371 $4,509 $376 $7.73 $6.38 $41,628 $34,378

(GST) TOD Commercial 281,314 $22,674,119 $25,683,968 526 534,817 $0.0913 $50,866 $4,239 $87.15 $71.97 $466,436 $385,199

(LPT) Large Power Session 160,095 $9,422,750 $9,541,662 42 3,811,786 $0.0596 $235,696 $19,641 $403.83 $333.50 $193,838 $160,079

(M) Street and Security Lighting 147 $29,507 $34,427 $0.2342

(MH) Metal Halide 180 $33,014 $42,444 $0.2358

(LED) Outdoor 4 $776 $1,035 $0.2587

TOTAL INDUSTRIAL 461,087 $34,184,162 $37,394,156 1,174 392,749 $0.0811 $36,578 $3,048 $62.67 $51.76 $703,162 $580,697

Street Lighting - Delivery

(GS) General Service 3,052 $782,676 $845,404 973 3,137 $0.2770 $845 $70 $1.45 $1.20 $16,097 $13,293

(GST) TOD Commercial 5,925 $693,149 $694,410 187 31,684 $0.1172 $3,809 $317 $6.53 $5.39 $14,253 $11,771

(R) Residential $9,679 $0.2305 $1,614 $134 $2.76 $2.28 $199 $164

(M) Street and Security Lighting 4,193 $1,269,214 $1,603,403 162 25,883 $0.3824 $50,767 $4,231 $86.98 $71.83 $26,095 $21,550

(MH) Metal Halide $637,781 $0.3824 $91,121 $7,593 $156.12 $128.93 $13,114 $10,830

(LED) Outdoor 16,525 $5,236,016 $6,319,160 60 275,417 $0.3824 $113,814 $9,484 $195.00 $161.04 $107,642 $88,894

(U) Unmetered Municipal 4,264 $707,600 $711,235 5 852,800 $0.1668 $176,891 $14,741 $303.08 $250.29 $14,548 $12,014

TOTAL STREET LIGHTING 37,391 $9,336,115 $11,011,650 1,409 26,537 $0.2945 $7,800 $650 $13.36 $11.04 $191,958 $158,526

Total Sales (MWH) and Bills ($) 6,861,635 $841,959,843

Tiered Discount Program Cost as 

Percent of Bills 2.06%

Straight Discount Program Cost as 

Percent of Bills 1.70%

United Illuminating 2019 FF1 p. 304

* Assumes power supply charges paid by generation and delivery customers are equal.

2