These utility sponsored programs, some run with charitable funds and some approved by the PSC to use ratepayer funds, do not come close to addressing the affordability issue that has resulted in more than 300,000 New York utility customers per year being shut off as part of bill collection efforts. The utility programs typically are small, and most have restrictive eligibility conditions. For example, Niagara Mohawk dba National Grid's "Care and Share" program, funded with combination of tax-deductible contributions from the utility and from customers who respond to appeals, does not assist any working families suffering hardship due to low wages or unemployment, unless the household contains an elderly or disabled member:
Managed by the American Red Cross, Care & Share meets the needs of individuals and households in the Niagara Mohawk service area who are facing difficult financial situations with nowhere else to turn for emergency energy assistance. The program serves households in which a member is 60 or older, or is disabled and receiving Supplemental Security Income or Social Security Disability, or is experiencing a medical emergency.The eligibility of households with medical emergencies for the charitable assistance is curious. Under the Home Energy Fair Practices Act, (HEFPA), the utility generally cannot shut off service for nonpayment to any household "experiencing a medical emergency," or one which has a member with a serious medical condition that a doctor certifies would be worsened by a lack of utility service. See PULP's Help Center Page on Medical Emergencies. Could it be that some of the charitable Care and Share dollars, probably an income deduction on the utility's federal income tax returns, cycle through the Red Cross and come back to pay Niagara Mohawk dba National Grid for its charges to customers with medical emergencies who, under the law, generally cannot be shut off to collect the "emergency energy assistance" paid by Care and Share?
Some utility programs involve participation in arrangements designed to increase utility collections from customers, and steer the customer's HEAP benefits to reduce arrears that built up in prior years, sweetened with some "arrears forgiveness" incentives for participants who pay their current bills in full. These "assistance" programs are designed explicitly to cost-effectively glean more revenue from the customer than the company would otherwise receive. See PULP Comments on Niagara Mohawk's "Low-Income Affordability Program," where we noted the diversion of HEAP funds intended to address current energy needs to reduce old arrears balances of program participants:
PULP is extremely concerned that in order to participate, customers must agree to provide the full amount of every Home Energy Assistance Program ("HEAP") dollar they receive to National Grid during their time in the Program and for these payments to be used exclusively to pay down arrears. PULP believes that the intent of the HEAP program is primarily to assist qualifying energy users in meeting current household energy needs, not to retire a portion of arrears that may have accrued from past years. [n fact, the stated purpose of the federal Low Income Home Energy Assistance Act is to assist eligible low income households "primarily in meeting their immediate home energy needs." As proposed under the Program, National Grid will receive money owed a few months earlier than it would have been without applying the HEAP payments to arrears; an action taken at the expense of the low income customer and his or her ability to pay current bills. Should a HEAP qualified customer agree to participate in the Program, they will receive absolutely no benefit from HEAP for the current heating season.A summary of the private utility programs for low income customers, prepared by the New York PSC, is posted at the PULP website. It contains a brief description of the programs and provides contact information for those seeking more information about applying.