RESIDENTIAL AND LOW-INCOME
ELECTRIC CUSTOMER PROTECTION

SUMMARY

Residential electric customers take simple aspects of utility service for granted. No one ever questions who their utility company will be or if the company will serve them. Customers expect to be treated fairly. Before the Legislature takes any steps to deregulate electric utilities it must preserve the benefits of today's system that would prevent residential customers from being thrown to the lions in an open, competitive market. Without universal service and customer protection small residential customers could be facing higher rates, lower quality service or no service.

The regulated electric utility system provides little benefit to low-income customers. Texas ranks far behind other states in providing low-income weatherization programs and low-income rates. Texas needs a standard for low-income programs and low-income rates which should be met by every utility in the state whether or not retail competition is approved. This report provides an overview of utility service in Texas and support for this conclusion.

I. INTRODUCTION

II. BACKGROUND INFORMATION

III. THE BENEFITS OF REGULATION TO RESIDENTIAL AND LOW-INCOME CUSTOMERS

IV. THE NEED FOR UNIVERSAL SERVICE AND ENERGY CONSERVATION PROGRAMS

This report was prepared by the Texas Ratepayers' Organization to Save Energy (Texas ROSE). The report provides pertinent data regarding residential and low-income electric utility customers and recommends consumer protection and low-income program standards for Texas electric utilities.

There is little information to support a conclusion that electric utility competition holds any benefits for small customers. Benefits accrue primarily to customers who use large volumes of energy. If, and before, Texas chooses a competitive course for the electric utility industry, elected officials and policy makers must be diligent in establishing residential and low-income customer protections that are fully developed and enforceable before the market is opened to competition. These protections include:

Universal Service and Energy Conservation

• Standard Billing Procedures and Collection Practices
• Standard Procedures for Obtaining Service and Establishing Credit
• Adequate Notice of Termination of Service
• Fair Pricing and Protection Against Slamming, Cramming and Unfair Marketing Practices
• Accessible Effective Dispute Resolution
• Customer Education
  

II. BACKGROUND INFORMATION

Residential and Low-Income Customers
There are almost 8 million⁽¹⁾ residential electric utility customers in Texas who spend $7.7 billion⁽²⁾ a year on electricity. (Total industry revenues in 1996 were close to $19.4 billion.⁽³⁾ ) Approximately 6 million homes are served by nine investor-owned utilities. A million homes are served by 70municipal systems and another million homes are served by 73 electric cooperatives.⁽⁴⁾

There are over 1.4 million⁽⁵⁾ low-income customers who spend more than a billion dollars a year on electricity. Today, low-income customers spend anywhere from 13 to 44 percent of their total household income on utilities while average income Texans spend a little over 4 percent.⁽⁶⁾   A competitive market should not increase the utility cost burden on residential customers, especially low-income families.

Energy Assistance Programs
The federally-funded Comprehensive Energy Assistance Program (CEAP) provides billing assistance, energy education, energy crisis assistance, and heating and cooling system repairs and replacement. The U.S. Department of Energy's Weatherization Assistance Program for Low-Income Persons (Weatherization Assistance) installs energy conservation measures in homes and apartments to increase energy efficiency, reduce energy use, and increase comfort levels. In FY97, Texas received $21.7 million for CEAP and $6.9 million for Weatherization Assistance.⁽⁷⁾

In Texas, customers are eligible for (but are not entitled to) CEAP and Weatherization Assistance if they have a total household income at or below 125 percent of the federal poverty guideline. For an individual living alone, 125 percent of the federal poverty guideline is $9,863 per year.⁽⁸⁾ Approximately $3,400 is added for each additional family member.⁽⁹⁾

CEAP and Weatherization funds are limited and priority is given to the elderly, disabled, families with young children and households with the highest energy costs and lowest incomes. The programs benefit utilities as well as low-income households by paying bills in arrears and helping customers with payment problems to control their electric bills. However, many elderly, disabled and minimum wage households still have trouble paying for electricity under regulation. CEAP and Weatherization benefits are provided to only about 5 percent of the eligible households and Texas has no standard for a utility funded affordability program.

Program data reported by the Texas Department of Housing and Community Affairs (TDHCA) show that 64,269⁽¹⁰⁾ energy assistance payments were processed in FY97 (September 1, 1996 through August 31,1997). In FY97, 2,692⁽¹¹⁾ low-income households received weatherization services. Over half of the assistance was provided to critically impoverished households with incomes under $7,999.⁽¹²⁾ And most of the recipients have at least one family member who is over 60 years old or disabled.⁽¹³⁾

The CEAP program assigns case managers to households in danger of losing electric utility service. The objective of the program is to teach the household to better manage energy use so bills are affordable in the long term. The low-income weatherization program is key to helping low-income customers control utility costs because it permanently reduces electricity use.

In addition to the CEAP and Weatherization Assistance programs there are privately funded billing assistance programs. Most are funded by utilities and operated by local non-profit agencies. The number of these programs and their funding levels are not currently known. More information about these programs is being gathered for a Public Utility Commission (PUC) report on low-income programs.

How Utility Low-Income Programs in Texas Compare to Programs in Other States
On a national basis, Texas ranks far behind other states in making utility weatherization programs and special rate programs available to low-income customers. A 1997 study published by Oak Ridge National Laboratory shows utility funding for low-income programs by state. The report estimates national utility expenditures of $335.7 million. The study shows no funding from utilities in Texas.⁽¹⁴⁾ Likewise, summaries published by the National Consumer Law Center and the LIHEAP (Low-Income Home Energy Assistance Program) Clearinghouse show no activity for utilities in Texas providing special low-income rates or weatherization services to their customers.⁽¹⁵⁾

Low-Income DSM Program Development in Texas
The 1995 Amendments to the Public Utility Regulatory Act and the Integrated Resource Planning (IRP) Rule adopted by the PUC on July 10, 1996 requires utilities to provide equitable demand-side management (DSM) or energy conservation programs to low-income customers and tenants. The rule does not, however, set a standard for what the minimum investment in low-income programs should be. Rather, the questions of how much is equitable is deferred to the public participation phase of the IRP process.

Low-income DSM programs require special program design. First, the programs must be no-cost or very-low-cost to succeed. Low-income customers have no or very little disposable income and cannot invest in energy conservation improvements. And most low-income households are renters. The problem with lack of income is compounded by renters who hesitate to spend money to improve property owned by someone else that they will live in for only a short time.

The Weatherization Assistance Program
The Weatherization Assistance program was created in 1976 to reduce heating and cooling costs for low-income families -- particularly the elderly, persons with disabilities and young children -- by improving the energy efficiency of their homes and ensuring their health and safety. Weatherization Assistance services are delivered to low-income customers in the 254 Texas counties by a network of 41 subgrantees of TDHCA which include municipalities, counties and multi-county community action agencies. Over the last ten years this network has weatherized over 54,000 homes.

A national study conducted by Oak Ridge National Laboratory shows that low-income weatherization recipients reduce their overall energy use by 10.9 percent to 23.7 percent.⁽¹⁶⁾   The dollar value of nonenergy benefits resulting from the weatherization of a single home is estimated at $976.⁽¹⁷⁾ Nonenergy benefits are produced from improved property values, improved health for the residents, growth in local employment, reduced arrearages, and environmental externalities.

There are many low-income individuals in need of basic weatherization services which cannot be provided by local agencies due to a lack of resources. Waiting lists for services are common. The typical waiting period for Weatherization Assistance is one to two years and in some communities it is even longer. Weatherization Assistance is never publicized because funding permits less than a half of a percent of eligible households to be served every year. The 1995 community needs survey conducted by Texas Department of Housing and Community Affairs (TDHCA) shows 71 percent of all respondents stating a critical major need for weatherization to increase energy efficiency.⁽¹⁸⁾

The Piggy-Back Program
Working through the IRP process and other (PUC) proceedings, Texas ROSE and Texas Legal Services Center have worked with utilities to secure commitments to implement piggy-back programs. Piggy-back programs are utility-funded programs coordinated with weatherization and other government funded energy assistance programs. The piggy-back programs supervised by TDHCA provide comprehensive weatherization for homeowners and renters, refrigerator replacement, water aerators, energy education and installation of compact fluorescent lighting in place of incandescent lighting. TDHCA apportions the funds among the local weatherization providers in the utility's service area based on local poverty rates and local agency performance.

To date, six investor-owned utility companies have a piggy-back program in various stages of development. Four utilities have committed 0.12 percent of 1996 revenue to the programs which are summarized below.

Summary of Electric Utility Funding for Piggy-Back Programs

*Program budget represents 0.12% of total revenue.

A survey conducted by Oak Ridge National Laboratory in 1994 documents 132 utility low-income energy efficiency programs in the United States, 79 of which are provided through local Weatherization Assistance providers.⁽¹⁹⁾

Piggy-back programs are effective in reducing low-income household energy use and are more cost effective than independent utility program efforts because marketing costs are eliminated and duplication of effort is minimized. Piggy-back programs allow community action agencies to serve more weatherization clients and reduce the one to two year waiting period for program services. Piggy-back programs also help utility companies meet their energy conservation program goals and improve individual customers' ability to pay their utility bills.

When a low-income customer qualifies for Weatherization Assistance the first step in the process is an energy audit of the residence. All the weatherization providers in Texas provide a computerized audit (called Easy Audit for Texas) and a blower door test for the dwelling unit. For piggy-back programs, Easy Audit calculates savings-to-investment ratios for individual energy conservation measures using both the utility's avoided cost and the residential rate. The audit identifies a package of cost-effective energy conservation measures for each customer separating those that are cost effective using the utility's marginal costs and those that are cost effective using the customer's cost. Utility funds are used to pay for the measures that are cost effective to the utility. State and federal funds are used to pay the balance. Utility funds generally cover $400 to $600⁽²⁰⁾ of the total costs. The average cost of weatherizing a unit ranges from $1,600 to $1,800.⁽²¹⁾   The program cap is $2,002 per unit.⁽²²⁾ Thus, for every 3 to 4 units supplemented with utility funds an additional unit can be weatherized.

After the audit is conducted the energy conservation measures are installed by local, specially trained workers. All work is inspected and verified by the local agency. Ten percent of all installations are inspected by TDHCA after the local agency completes its inspection.

The high efficiency refrigerator and compact fluorescent lighting portions of the program can be used to assist households who do not qualify for weatherization. This frequently occurs because the condition of the structure is poor and it requires rehabilitation before weatherization can be effective.

All funds are spent and accounted for under procedures established by the state and federal government. All programs are continually monitored and audited annually by both state and federal agencies. The funds are carefully monitored because the state can qualify for additional federal funds when utilities contribute to the program.

Development of Low-Income Rates in Texas
A key component of a low-income affordability program is rates. Studies conducted by the National Consumer Law Center and individual utility companies show that even the current system is not always fair to low-income customers. Low-income customers have fewer appliances than upper- and middle-income customers and rarely have central air conditioning. Most low-income families use fans for cooling. When there is air conditioning there is usually one window unit. Residential rate increases are driven primarily by summer peak demand caused by air conditioning use. Rates for low-income customers are probably too high in most service areas and some utilities offer special rate programs to compensate for the inequity. For example, the City of Austin prices the first 500 kWh (kilowatthours) of a residential bill at a lower rate to encourage energy conservation. In addition, the City of Austin waives the monthly customer service charge for customers living in poverty.

There is a limited amount of effort by utilities in Texas to offer special rates to their low-income customers. The following table briefly describes known low-income and low-usage rates in Texas.

SPECIAL LOW-INCOME RATES

Utility Description of Rate
Central Power & Light Company economy rate with reduced or waived customer
Texas Utilities service charge for low-usage customers
Entergy Gulf States proposed rate filed at the PUC waives customer service charge for low-income customers and encourages energy conservation
El Paso Electric Company customer service charge waiver for low-income
City of Austin customers
Many states including Alabama, Alaska, Arizona, California, Maine, Maryland, Michigan, Massachusetts, Minnesota, Montana, New Jersey, New York, Ohio, Pennsylvania, Rhode Island offer special rates for low-income customers.⁽²³⁾
These rates, offered under regulation, are being preserved in competitive systems as they are created.


III. THE BENEFITS OF REGULATION TO RESIDENTIAL AND LOW-INCOME CUSTOMERS

Our regulated system benefits small consumers by: (1) obligating utilities to serve customers within their franchised service area, (2) setting an established rate for all residential customers, and (3) enforcing billing, collection, and disconnection standards.

Consumers today are guaranteed that someone is there to supply power to their homes. One rate is charged to all residential customers. Consumers expect their meters to be read regularly and to receive their bills every month. Bills are easy to understand, and customer information is confidential. Customers also receive one electric bill.

The regulated system also protects the vast majority of customers from unfair and life threatening treatment. The PUC sets rates, enforces standards for fair billing and collection, notice of termination of service and safeguards to prevent service from being disconnected when it endangers the health of the customer.

Making sure that all Texans have affordable electricity to meet their basic needs must be a guarantee of any restructuring legislation passed in Texas. Making sure that consumers are treated fairly by the companies soliciting their business must be the foundation of any restructuring legislation passed in Texas. Making sure that customers understand their new choices will help prevent customer confusion and help keep competitors seeking their business honest.

IV. THE NEED FOR UNIVERSAL SERVICE AND ENERGY CONSERVATION PROGRAMS

One of the problems with electric utility competition is that it works well for large industrial customers who individually pay millions of dollars a year for electricity. They have bargaining power. Small customers have little to gain. Low-income families and the elderly living on fixed incomes could end up paying higher prices for lower quality, less reliable services.

Today, most utilities have the authority to operate exclusively in a geographic service area. Every home has a utility that must supply them with electricity. If customers can choose an electric supplier we must be careful that electric suppliers cannot refuse to serve a customer because they live in a high cost rural area or a low-income neighborhood.

If electric utilities are deregulated, consumers will lose the benefit of rates that are reviewed for fairness. Today, customers who choose to live in rural areas cannot be charged more than other customers who live in the city. Customers who live in minority and low-income neighborhoods are charged the same price as all other customers. The elderly on fixed incomes pay the same rates as all other residential customers.

To make sure low-income, and fixed income customers are not harmed by competition we need to make sure power is available and affordable to everyone by offering low-income customers special rates and energy conservation programs. The utility industry should make a concerted effort to conduct load research to identify the electricity usage characteristics of low-income households. If the anecdotal assumptions that low-income customers have lower demand for electricity and lower overall use is correct, low-income customers should be treated as a separate rate class in Texas as they are in many other states.

Affordability Programs for Low-Income Customers
Electricity is essential to life. Every Texan needs electricity for refrigeration, lighting, fans, cooling and, in some instances, heating. Low-income neighborhoods typically have high priced, low quality food, checking accounts with high service charges, and small loan companies with the highest interest rates. The same conditions -- lower quality service and higher prices -- will be the legacy of electric utility competition for fixed and low-income customers unless they are protected from the competitive market's discriminatory treatment of people perceived as having poor credit.

From the time the California restructuring debate was opened in April 1994, utility commissions and legislatures recognized that fixed and low-income households face unique market barriers to obtaining low-cost services in an open market. Residential customers could be refused service because of the neighborhood they live in, because they have no credit rating, or because they use small amounts of electricity. For the same reasons, they could also be charged higher rates than other residential customers. An essential part of deregulation in the states which have passed laws to allow retail competition (California, Pennsylvania, Massachusetts, New Hampshire, Rhode Island, Minnesota, Montana, Oklahoma, Nevada and Illinois) is affordability programs for low-income customers. Much of the legislation defines affordability programs as low-income rate relief, billing assistance and weatherization programs.⁽²⁴⁾ Texas must follow suit because small consumers, especially low-income consumers, could be the first victims of discrimination in a competitive market.

Cost of Universal Service and Energy Conservation Programs
Using 1996 data, Texas ROSE recommends a total expenditure level of approximately $200 million or about 1 percent of total 1996 electric utility industry revenue ($19.4 billion). Weatherization and related energy conservation programs would account for 0.2 percent of total revenue while a 15% rate discount for low-income customers (as provided in California⁽²⁵⁾) would account for 0.8 percent. This standard should be in effect today. Low-income programs are needed even in a regulated market and should be developed before any transition to competition begins.

Other states (California, Pennsylvania, Massachusetts, Hew Hampshire, Rhode Island, Minnesota, Vermont, Montana, Oklahoma, Nevada, and Illinois) which have passed restructuring legislation have made provisions for universal service and low-income customers.⁽²⁶⁾

Some legislation sets a specific standard for funding low-income programs. Many states already have affordability programs under regulation and the restructuring legislation continues programs that low-income customers can benefit from today. Others defer the decisions to an administrative process.

Texas should begin to set up affordability programs prior to any decision to restructure to assure that funding levels are adequate and that programs operate efficiently and effectively. The piggy-back programs and low-income rates in effect today are still developing and more attention should be given to implementing the programs to gain experience and refine them before the need for them becomes more critical.

Paying for Universal Service and Energy Conservation Programs
All restructuring legislation passed in other jurisdictions provides for a competitively neutral funding mechanism for low-income programs which should be assessed fairly on all energy suppliers.⁽²⁷⁾

Large industrial customers should not benefit from lower electricity costs at the expense of low-income customers who struggle daily to make ends meet. Universal service costs should be charged to all customers on a kWh basis. In 1996, Texas residential customers paid an average of 7.77¢ per kWh while industrial customers paid 4.03¢ per kWh.⁽²⁸⁾ Residential and industrial customers use roughly the same number of kWh but industrial revenues are about half of residential revenues.⁽²⁹⁾ These data are similar to 1995 data provided by the PUC in its 1997 report on competition.⁽³⁰⁾

V. RESIDENTIAL CUSTOMER PROTECTIONS ARE NEEDED IN A COMPETITIVE MARKET

Customers are not always treated fairly whether a business is regulated or not. According to the PUC Office of Customer Protection 5,340 customers filed complaints in 1997 -- a 50 percent increase in one year. The majority of the complaints were filed against telephone companies, in particular long-distance companies that operate in a competitive market.

Consumer Complaints Received at PUC

Percentage-wise, complaints against electric utilities increased more than complaints against telephone companies. The increase in complaints can be explained by a number of factors -- resolution of a backlog of complaints, damage from ice storms caused in part by utilities cutting back on tree trimming and maintenance, and increased activity by the PUC Office of Customer Protection.

There is no way of tracking the number of complaints settled in the customer's favor versus the utility's favor. The only measure that is available for 1996 and 1997 is the amount of refunds paid to customers who file complaints. In resolving complaints against telephone companies in 1996 customers recovered $11,128.  Funds recovered increased to $136,295 in 1997. In 1996, electric utility customers recovered $49,360 and funds recovered increased to $74,507 in 1997. Clearly there is a need for an effective and expedient complaint process now. Under electric utility competition, complaints are likely to increase in number and in dollar value as they have in the telephone industry.

In the competitive electricity market, residential customers at-large and low-income customers, in particular, must be treated honestly and fairly by businesses who sell electricity. Consumers also need an efficient, user-friendly, dispute resolution process that provides for impartial review of complaints.

The Greatest Low-Income Customer Concerns
During two conferences held in 1997 for low-income energy assistance providers Texas ROSE and Texas Legal Services Center conducted a survey of the top customer protection concerns for customers with low-incomes. The survey is not scientific but it polled 35 professionals who operate energy assistance programs. The top three concerns were as follows:

• regulation of deposits and a procedure for qualifying customers without credit ratings for electric service
• forbidding disconnection of a customer's service during extreme weather conditions
• forbidding basic service disconnections for a failure to pay charges for services other than basic service
  
  These top three concerns were followed by:

• a statement of a customer's right to reconnection and a limit on reconnection fees
• when late a fee may be assessed and a limit how much can be charged for late fees

Many of the individuals who ranked the customer protections said the survey wasn't fair because everything listed on the survey form was important. In particular, many of the service providers noted the importance of establishing ways to quote prices and contract terms and conditions so that customers can easily compare offers from alternative suppliers.

In addition, the participants expressed a concern for businesses that may take advantage of a consumer's lack of knowledge and sell a product or service that is substandard or one that the customer doesn't need and can't afford.

Equal Standards and Statewide Jurisdiction for Enforcement
In FY97, at least 4 percent of all complaints received at the PUC were from municipal utility and other customers where the PUC had no jurisdiction. Approximately 6 million of the 8 million residential electric utility customers are served by investor-owned utilities that are fully regulated by the PUC. Close to 2 million customers of municipal and cooperative systems are not always provided with service which meets standards which are comparable to PUC standards.

Under regulation, policy makers can state with certainty that 75% of all customers are protected by PUC regulations. If the market is open to retail competition the number of customers served by suppliers outside of PUC jurisdiction should not increase. If any changes occur in jurisdictional oversight the change should be made in the direction of expanding the PUC's jurisdiction and enforcement authority for customer protection and low-income programs to any business that sells electricity in Texas.

Minimum Consumer and Low-Income Customer Provisions
Prior to making any decisions to allow retail access in Texas, the state should establish universal service standards which include low-income affordability programs. The affordability programs should include a special rate that provides an affordable block of service priced at a reduced rate and low-income weatherization programs. These programs should be funded at a level of $200 million per year or approximately 1 percent of total industry revenues for 1996. The PUC should be given the authority to increase funding levels based on need.

In a deregulated industry the State should license every business selling electricity. The PUC should be given the authority to qualify businesses for licenses to sell electricity and to impose fines or revoke licenses for violations of the licensing standards or customer protections. Suppliers licensed to sell electricity in Texas should agree to comply with all standards set by the Legislature and the PUC. The consumer and low-income provisions needed in a competitive electricity market which all retail suppliers should be required to follow are outlined below.

Universal Service and Energy Conservation Programs

• an affordable basic electricity package with a discounted rate for low-income consumers, a default provider for customers not exercising choice, and levelized payment plans
• a prohibition on redlining (discrimination against certain customers based on income or neighborhood)
• targeted energy conservation and weatherization programs for low-income customers
• funding for universal service and low-income weatherization programs assessed as a standard operating cost of producing or selling electricity in Texas paid for by all energy suppliers
• coordinate universal service programs with existing community-based organizations administering state and federally funded energy efficiency and billing assistance programs

Standard Billing Procedures and Collection Practices

• a single bill that is easily understood for all services (generation, transmission and distribution)
• optional equal monthly payment plans (to allow people on fixed- or low-incomes to budget)
• standard procedures for issuing and collecting bills (regular reading of meters, predictable timing of bills and payment due dates)
• well-defined late fees (when they may be charged and how much)
• itemized bills clearly showing the amount owed for electricity and the amount owed for other charges and services
• credit partial payments to pay electricity charges before any other charges are paid
• disregard jointly incurred prior debts to the utility when a victim of domestic violence (referred by a state-funded domestic violence project or the county attorneys' office) seeks new service in the sole name of the victim;
• protect customer usage, billing and payment history from disclosure unless the disclosure is required by law, or has been approved by the customer in writing
• provide understandable disclosures of financial stability, fuel sources, emissions profile, customer complaints, stranded costs and other services offered
• allow a customer to change retail electric suppliers at any time upon three business days notice with no fee or penalty

Standard Procedures for Obtaining Service and Establishing Credit

• fair and easy to understand application and credit evaluation procedures
• access to a retail supplier without having to obtain a special meter
• procedures for establishing credit and qualifying customers without credit ratings or customers with bad credit ratings for electric service
• flexible deposit plans (payment plans, waivers for special circumstances), prompt refund of deposits (and interest) in established time limits
  

Adequate Notice of Termination of Service

• advanced notices of disconnection and the right to arrange payment to prevent disconnection
• no basic service disconnections for a failure to pay charges other than basic service charges, no disconnection when weather conditions are extreme, and no disconnection of a tenant's service when the landlord fails to pay
• a clear and understandable explanation of reconnection rights and a limit on reconnection fees
  
  Fair Pricing and Protection Against Slamming, Cramming and Unfair Marketing Practices

• standard disclosures for comparing the price and service terms of different suppliers (like nutrition labeling and truth in lending statements)
• advance notice of changes in prices (sufficient to allow the customer to change suppliers before any price change goes into effect)
• suppliers prevent slamming (the unauthorized change of a customer's supplier) by verifying the customer's consent to a change in service (using methods similar to those established in Senator Barrientos' telephone slamming bill)
• suppliers honor a three day cooling off period before a confirmed agreement to purchase electricity goes into effect
• suppliers provide clear and accurate information about the commitment a customer makes in exchange for gifts and other inducements to change suppliers

Accessible Effective Dispute Resolution

• a simple, well advertised, toll-free, expedited resolution of complaints where oral or written complaints are resolved quickly by holding hearings on the telephone
• an opportunity to appeal a telephone hearing where the commission investigates, mediates if possible, holds hearings, and resolves any complaint submitted by a customer
• prohibit disconnection of a customer's service when a decision is pending on the customer's complaint
• reimbursement of a customer's legal expenses when the appeals process rules in the customer's favor
  

Customer Education

• comprehensive programs to educate consumers, low-income energy assistance agencies and low-income customers, including non-English speaking customers, about changes in the industry and how they can exercise choice

I. ENDNOTES

1. Residential Customers in Texas, John McElroy, Office of Public Utility Counsel, December 1988.

2. Electric Sales and Revenue 1996, Energy Information Administration, Table 7. Revenue From Sales to Ultimate Consumers by Sector, Census Division and State, 1996.

3. Electric Utility Revenue, 1996 Texas Jurisdictional, compiled by John McElroy, Office of Public Utility Counsel.

4. Residential Customers in Texas, John McElroy, Office of Public Utility Counsel, December 1988.

5. 18% of 7,890,536 of total residential customers.

6. National Consumer Law Center, Energy and the Poor: The Crisis Continues, National Consumer Law Center, Boston, MA 1994.

7. Texas Department of Housing and Community Affairs, Draft 1998 State of Texas Low-Income Housing Plan and Annual Report.

8. Texas Department of Housing and Community Affairs, General Memorandum #97-3.1, Mach 21, 1997.

9. bid.

10. Texas Department of Housing and Community Affairs, Draft 1998 State of Texas Low-Income Housing Plan and Annual Report.

Note: Individuals households may have received more than one assistance payment.

11. Ibid.

12. Ibid.

13.  Ibid.

14. LOW-INCOME ENERGY POLICY IN A RESTRUCTURING ELECTRIC INDUSTRY: AN ASSESSMENT OF FEDERAL OPTIONS, Lester W. Baxter, Oak Ridge National Laboratory, Oak Ridge, TN, July 1977, p. 72

15. Universal Service Rates (Table), National Consumer Law Center, Boston, MA, September 1997. State-By-State Summary of Supplements to Energy Assistance and Weatherization Compiled by the LIHEAP Clearinghouse, National Center for Appropriate Technology, Butte, MT, October 1996.

16. Weatherization Works: An Interim Report of the National Weatherization Evaluation, Oak Ridge National Laboratory, ORNL/CON-395, September 1994.

17. Ibid.

18. Texas Department of Housing and Community Affairs, 1997 State of Texas Low-Income Housing Plan and Annual Report, p. 19.

19. UTILITY INVESTMENTS IN LOW-INCOME ENERGY EFFICIENCY PROGRAMS, Marilyn A. Brown et.al., Oak Ridge National Laboratory, Oak Ridge, Tennessee, ORNL/CON-379, September 1994, p. xii-xiii.

20. Texas Department of Housing and Community Affairs, Energy Assistance Division, January 1988.

21. Ibid.

22. Ibid.

23. Universal Service Rates (Table), National Consumer Law Center, Boston, MA, September 1997. State-By-State Summary of Supplements to Energy Assistance and Weatherization Compiled by the LIHEAP Clearinghouse, National Center for Appropriate Technology, Butte, MT, October 1996.

24. Summary of State Electric Restructuring Legislation: Universal Service Provisions, Barbara R. Alexander, Consumer Affairs Consultant, 15 Wedgewood Dr., Winthrop, ME, January 1, 1998.

25. State Universal Service Rates (Table), National Consumer Law Center, Boston, MA, September 1997.

26. Ibid.

27. Ibid.

28. Energy Information Administration/Electric Sales and Revenue 1996, Table 12. Average Revenue per Kilowatthour by Sector, Census Division, and State, 1996.

29. Energy information Administration/Electric Sales and Revenue 1996, Table 7 and Table 12.

30. Calculated from PUC Report to 75th Legislature Volume II, The Scope of Competition in the Electric Industry in Texas: A Detailed Analysis, Tables ES-1 and Table ES-2, January 1997.

Texas Ratepayers' Organization to Save Energy Carol Biedrzycki, Executive Director 815 Brazos Street, Suite 1100 Austin, Texas 78701-2509 512-472-5233 Send email to Texas ROSE

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last updated March13, 1998
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