1 Forgiving Utility Debt, Waiving Penalties & Punitive Deposits – How to Make the Case H. Gil...

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Forgiving Utility Debt, Waiving Forgiving Utility Debt, Waiving Penalties & Punitive Deposits Penalties & Punitive Deposits

– How to Make the Case– How to Make the Case

H. Gil Peach, PhDH. Gil Peach, PhD

H. Gil Peach & Associates LLC/Scan America®H. Gil Peach & Associates LLC/Scan America®16232 NW Oakhills Drive16232 NW Oakhills DriveBeaverton, Oregon 97006Beaverton, Oregon 97006

(503) 645-0716(503) 645-0716

[email protected]@scanamerica.net

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SOME BACKGROUNDSOME BACKGROUND

30+ Years doing program evaluations, public services and 30+ Years doing program evaluations, public services and policy work.policy work.

Originally in NYC – Studies in Housing & Urban Renewal, Originally in NYC – Studies in Housing & Urban Renewal, Health, Transit System (Subways), Child Services, Hospital Health, Transit System (Subways), Child Services, Hospital Services (Pediatric Medical Care), Taxi Bureau, Employment Services (Pediatric Medical Care), Taxi Bureau, Employment Department, etc.Department, etc.

Since 1980 – Utility Load Research, Rates, DSM Evaluation, Since 1980 – Utility Load Research, Rates, DSM Evaluation,

Low-Income, Universal Services Program Evaluations, Policy Low-Income, Universal Services Program Evaluations, Policy Studies.Studies.

First Low-Income Evaluation – 1988.First Low-Income Evaluation – 1988.

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Why the Problem in Paying Gas, Why the Problem in Paying Gas, Electricity, and Water Bills?Electricity, and Water Bills?

Since about 1972, the force of poverty has Since about 1972, the force of poverty has been increasing. It is largely driven by been increasing. It is largely driven by what economists call “what economists call “globalizationglobalization” of ” of production, although there are other production, although there are other factors.factors.

Globalization is a Globalization is a new economic ordernew economic order (or the resurgence of an old problem for (or the resurgence of an old problem for working people). working people).

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Income inequality is dramatically Income inequality is dramatically

increasingincreasing.. We are about back to 1900 in terms We are about back to 1900 in terms of the pattern of incomes. The upper 1% now of the pattern of incomes. The upper 1% now take 20% of all household income. The upper 5% take 20% of all household income. The upper 5% own 50% of everything. The pattern is getting own 50% of everything. The pattern is getting stronger and as it does, “cost of service” rates stronger and as it does, “cost of service” rates cannot work.cannot work.

Federal poverty and income measures are mis-Federal poverty and income measures are mis-

calibrated. calibrated. Households up to 350% of poverty Households up to 350% of poverty need some assistance.need some assistance. Most households do Most households do not have sufficient income – money runs out not have sufficient income – money runs out before basic needs are met. But we don’t like to before basic needs are met. But we don’t like to admit it.admit it.

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The “Solution Space” is getting smaller The “Solution Space” is getting smaller

for most households, and for communities and for most households, and for communities and the country as a whole. There is a growing the country as a whole. There is a growing network of interconnecting problems, network of interconnecting problems, including global warming, failure of wheat including global warming, failure of wheat crops, dead zones off the West Coast, loss of crops, dead zones off the West Coast, loss of jobs, pressure to reduce pay, turning key jobs, pressure to reduce pay, turning key government agencies into raggedy government agencies into raggedy ramshackle outfits, increasing cost of living, ramshackle outfits, increasing cost of living, and more…and more…

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Some Positive ExamplesSome Positive Examples

(New Programs)…(New Programs)…

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Three Examples of New Three Examples of New ProgramsPrograms

(1) Nevada – If under 150% of Poverty, (1) Nevada – If under 150% of Poverty, and at a utility where they pay into and at a utility where they pay into the Universal Service Program: Total the Universal Service Program: Total cost of gas plus electricity is set at cost of gas plus electricity is set at the median energy burden for the the median energy burden for the state (about 3%).state (about 3%).

(2) New Jersey – set at 175% of (2) New Jersey – set at 175% of Poverty and 6%.Poverty and 6%.

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Three ExamplesThree Examples

(Example 3) PECO Energy (Example 3) PECO Energy (Philadelphia) – (Philadelphia) –

Token rate with no penalties and no Token rate with no penalties and no fees for customers from 0-25% of fees for customers from 0-25% of povertypoverty

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PECO Rate “CAP A”PECO Rate “CAP A”

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Examples of New ProgramsExamples of New Programs

It can be shown mathematically that It can be shown mathematically that the optimum approach is the the optimum approach is the Percentage of Income Payment Plan – Percentage of Income Payment Plan – PIPP. PIPP.

A PIPP rate is the best one to go for if A PIPP rate is the best one to go for if you can get it. Some utilities are you can get it. Some utilities are afraid of PIPP programs.afraid of PIPP programs.

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Why Would a Utility want a PIPP Why Would a Utility want a PIPP Rate?Rate?

Develop the Develop the business casebusiness case for for showing the Limits to Cost-of-Service showing the Limits to Cost-of-Service based rate designs.based rate designs.

Show the Need for Percentage of Show the Need for Percentage of Income or Closely Related Design Income or Closely Related Design ApproachesApproaches

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The Benefits to the UtilityThe Benefits to the Utility

Use the Sector Map tool to look at Use the Sector Map tool to look at what what households can payhouseholds can pay..

Optimize from a utility collections Optimize from a utility collections perspective (to get households to perspective (to get households to pay pay what they canwhat they can of the cost-based bill) of the cost-based bill)

Structure rates to recover the rest Structure rates to recover the rest up up frontfront – ask only for what is reasonable – ask only for what is reasonable and possible – but optimize that amount.and possible – but optimize that amount.

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Utilities have other Collections Tools – Utilities have other Collections Tools – Expect them to continue in useExpect them to continue in use

Adherence to planAdherence to plan Adherence to regulatory requirements Adherence to regulatory requirements Payment agreementsPayment agreements Credit scoring/data mining/segment Credit scoring/data mining/segment

customerscustomers Use of trade allies (Collection Agencies)Use of trade allies (Collection Agencies) New technologies (AMR, Remote New technologies (AMR, Remote

Disconnect, Pre Pay)Disconnect, Pre Pay) Etc.Etc.

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What to Focus OnWhat to Focus On

First – Focus on Write OffsFirst – Focus on Write Offs

Second – Interest on Debt (Cost of Second – Interest on Debt (Cost of Working Capital)Working Capital)

Third – Cost of Collections (by activity Third – Cost of Collections (by activity and step)and step)

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Utility Collections Tools that need to Structured for Utility Collections Tools that need to Structured for Low-Income HouseholdsLow-Income Households

Rate Design (PIPP)Rate Design (PIPP)

Arrearage ManagementArrearage Management

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Arrearage Management Can Arrearage Management Can Lower CostLower Cost

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Bottom LineBottom Line

Utility loses least money with a well Utility loses least money with a well structured low-income rate that is structured low-income rate that is actually affordable to customers.actually affordable to customers.

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Things You Need to KnowThings You Need to Know

All Utilities have an account for All Utilities have an account for uncollectibles (write-offs)uncollectibles (write-offs)

This account is one of many items that This account is one of many items that determine revenue requirements.determine revenue requirements.

Revenue requirements are reflected in Revenue requirements are reflected in the the currentcurrent utility rate. utility rate.

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If the amount for uncollectibles is not If the amount for uncollectibles is not correct it is “trued up” in the next correct it is “trued up” in the next rate case.rate case.

Bottom line: Bottom line: Customers are already Customers are already covering all the costs of both the covering all the costs of both the collections activities and the write collections activities and the write offs.offs.

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To Repeat: Customers are already To Repeat: Customers are already covering the costs of uncollectibles covering the costs of uncollectibles (bad debt or write-offs) plus the cost (bad debt or write-offs) plus the cost of running the utility’s collection of running the utility’s collection function in function in currentcurrent rates.rates.

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Most arrearages are temporary and are Most arrearages are temporary and are from missed payments. Most are made up from missed payments. Most are made up within one billing cycle.within one billing cycle.

Usually, low-income customers are not Usually, low-income customers are not responsible for the bulk of arrearage.responsible for the bulk of arrearage.

However, if an account goes three cycles However, if an account goes three cycles without payment, it usually becomes a without payment, it usually becomes a write off.write off.

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Arrearages on the books Arrearages on the books costcost utilities utilities money. The part of arrearage that is money. The part of arrearage that is going towards write-off costs more the going towards write-off costs more the longer it is held on the books.longer it is held on the books.

Utilities typically do not help Utilities typically do not help collections staff understand these collections staff understand these realities. However the Rates Manager realities. However the Rates Manager and the Treasurer or Budget Director and the Treasurer or Budget Director will know. will know.

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What did it Take to get PECO What did it Take to get PECO CAP A?CAP A?

Commission ordered a special study.Commission ordered a special study.

In the rate study we showed every In the rate study we showed every possible combination under different possible combination under different rate approaches.rate approaches.

It became clear that households from It became clear that households from 0-25% of poverty and in special 0-25% of poverty and in special circumstances needed a token rate.circumstances needed a token rate.

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Why is a Special Rate Why is a Special Rate Necessary?Necessary?

The US is a poor country for most The US is a poor country for most households. We don’t like to admit households. We don’t like to admit this, but we are transitioning from a this, but we are transitioning from a manufacturing economy to a service manufacturing economy to a service economy and our productive assets economy and our productive assets are going into foreign ownership.are going into foreign ownership.

There is more…There is more…

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Pattern of Income ChangesPattern of Income Changes

CBPP data, adjusted. – John Mitchell

Trends in Real Income: Total U.S. With Children

70.90%

100.00%

78.17%

80.39%

89.17%

92.51%

95.72%

96.52%100.37%

116.68%

107.43%

60%

70%

80%

90%

100%

110%

120%

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78

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79

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80

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81

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82

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95

Year

Per

cen

t o

f 1

97

8-19

80 A

ver

age

Lowest Fifth withChildren

Second Lowest Fifthwith Children

Middle Fifth withChildren

Second Highest Fifthwith Children

Highest Fifth withChildren

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Implications of Income shifts for Implications of Income shifts for Programs & Program EvaluationsPrograms & Program Evaluations

……an increasingly impoverished an increasingly impoverished underclass is falling out of the new underclass is falling out of the new “globalized” economic system.“globalized” economic system.

……so, this contextual or “background so, this contextual or “background factor” is a major force affecting all factor” is a major force affecting all programs, including utility collections programs, including utility collections and low-income programs.and low-income programs.

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Roger Colton, The Home Energy Affordability Gap in Pennsylvania, April 2003

Implications of Income Shifts for Implications of Income Shifts for Program EvaluationsProgram Evaluations

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Representations of InequalityRepresentations of Inequality

Example - The Example - The “Income Donut”“Income Donut”

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Poverty & DonutsPoverty & Donuts

This donut is typical This donut is typical of of the US: the of of the US: the bottom 20% of bottom 20% of families receives 3% families receives 3% of community income.of community income.

If this were a If this were a mechanical system, mechanical system, an engineer would an engineer would never put equal never put equal stress on each sector.stress on each sector.

Community Income by HouseholdCensus 2000

(Each Slice represents 20% of Households)

3%10%

16%

30%

41%

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Poverty & DonutsPoverty & Donuts

If this were a real donut If this were a real donut shared by five children, shared by five children, we would expect more we would expect more equality.equality.

The top 5% receives The top 5% receives 18% of community 18% of community income.income.

The top 1.5% receives The top 1.5% receives 8% of community 8% of community income.income.

Community Income by HouseholdCensus 2000

(Each Slice represents 20% of Households)

3%10%

16%

30%

41%

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Where Does Income Come Where Does Income Come From?From?

Market Derived – For Utility Customers, market Market Derived – For Utility Customers, market income comes mainly from the Job Structure – but income comes mainly from the Job Structure – but the Job Structure has been weakened by the Job Structure has been weakened by GlobalizationGlobalization

In the absence of substantial income transfers, In the absence of substantial income transfers, traditionally, in the US, we have relied more on traditionally, in the US, we have relied more on economic activity and economic growth to economic activity and economic growth to increase demand for labor and employment. increase demand for labor and employment.

But, this mechanism no longer works.But, this mechanism no longer works.

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JOB STRUCTUREJOB STRUCTURE

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Job StructureJob Structure

The “The “income donut”income donut” that we just that we just reviewed reflects the underlyingreviewed reflects the underlying

““job structure”job structure” of a community of a community..

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Poverty isPoverty is produced produced by by economic economic arrangementsarrangements, reflected in the “, reflected in the “job job structurestructure.”.”

Poverty may be influenced by Poverty may be influenced by individual individual actionaction, but only if a , but only if a structure of structure of opportunityopportunity opens up. opens up.

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At any one time, a community, city, At any one time, a community, city, state, or service territory has a “state, or service territory has a “job job structurestructure..””

You can picture it as like an You can picture it as like an organization chart for a corporation…organization chart for a corporation…

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Globalization & Centralization Effects on Local & Globalization & Centralization Effects on Local & RegionalRegional

Job StructuresJob Structures

MOVED

MOVED DELETED MOVED

DELETED RETAINED

MOVED MOVED

DELETED

RETAINED RETAINED DELETED

RETAINEDRETAINED

RETAINEDOUTSOURCED

OTHER LEVELS

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So long as the job structure of a So long as the job structure of a Service Territory does not provide Service Territory does not provide enough jobs that supply a family enough jobs that supply a family wage, a significant portion of the wage, a significant portion of the families in the community will be families in the community will be payment troubled and in poverty.payment troubled and in poverty.

- H. Gil Peach- H. Gil Peach

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Job Structure - Market Income inJob Structure - Market Income inGlobalized MarketsGlobalized Markets

On the positive side, prices of goods On the positive side, prices of goods decrease, reflecting lower cost of labor. decrease, reflecting lower cost of labor.

On the negative side, locally produced On the negative side, locally produced goods are replaced by goods produced goods are replaced by goods produced overseas. As jobs disappear, so do many overseas. As jobs disappear, so do many local businesses as, for example, big box local businesses as, for example, big box stores replace local entrepreneurs.stores replace local entrepreneurs.

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• The long term trend is to continually The long term trend is to continually drop “job slots” from the job structure.drop “job slots” from the job structure.

• This both eliminates jobs and restrains This both eliminates jobs and restrains wages and benefits. wages and benefits.

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• It is now commonplace for young It is now commonplace for young persons to feel that they cannot persons to feel that they cannot achieve the level of living of their achieve the level of living of their parents.parents.

• Structurally, that perception is correct. Structurally, that perception is correct.

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With globalization, the local market may clear at point G, With globalization, the local market may clear at point G,

the intersection of line D2-D2’ (reduced local demand for labor)the intersection of line D2-D2’ (reduced local demand for labor)

and line S3-S3’ (labor supply augmented by global labor supply).and line S3-S3’ (labor supply augmented by global labor supply).

D2

S1’

D1

D1’

D2’

S2’ S3’

S1 S2

S3

(+)

P R I C E

(-)

(-) QUANTITY (+)

P

G

Market Determination of (Market) Income Market Determination of (Market) Income with and without Globalization.with and without Globalization.

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ImplicationsImplications

As real income declines funding of As real income declines funding of quality of life must take place outside quality of life must take place outside market mechanics.market mechanics.

Markets have their place but when Markets have their place but when the job structure is broke the market the job structure is broke the market can’t fix it.can’t fix it.

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Energy BurdenEnergy Burden

Reichmuth Sector MapsReichmuth Sector Maps

0

25

50

0.4

0.4

0.7

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0.9

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Income, %FPL

Us

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Fra

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Us

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Electric Energy Burden - CAP

50%-60%

40%-50%

30%-40%

20%-30%

10%-20%

0%-10%

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MISLEADING MISLEADING FEDERAL FEDERAL

STATISTICSSTATISTICS

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Statistics on Unemployment - Statistics on Unemployment - 11

The Bureau of Labor Statistics (BLS) The Bureau of Labor Statistics (BLS) puts out the unemployment numbers puts out the unemployment numbers you hear on the radio or TV. As a you hear on the radio or TV. As a rule of thumb, economists know to rule of thumb, economists know to double whatever they say. If the double whatever they say. If the government says 6%, it is actually government says 6%, it is actually about 12%.about 12%.

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Unemployment - 2Unemployment - 2

Unemployment is a good example of how Unemployment is a good example of how government statistics are defined in ways government statistics are defined in ways that diverge substantially from useful that diverge substantially from useful information.information.

They just don’t count people who are beaten They just don’t count people who are beaten down and give up. down and give up.

They don’t count people who want full time They don’t count people who want full time work, but don’t have the energy to keep work, but don’t have the energy to keep pushing while still working less than full time. pushing while still working less than full time.

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Unemployment - 3Unemployment - 3

Bottom Line – Unemployment numbers are Bottom Line – Unemployment numbers are not true in an ordinary sense. In this case, not true in an ordinary sense. In this case, you know the true number is always about you know the true number is always about double what the government says, so the double what the government says, so the true number is not hidden very well.true number is not hidden very well.

Still, everyone is repeatedly told on the Still, everyone is repeatedly told on the radio, TV, and in the papers and radio, TV, and in the papers and government speeches a number that is government speeches a number that is about half the number that makes sense about half the number that makes sense from the perspective of workers and from the perspective of workers and families.families.

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Employment Statistics - 1Employment Statistics - 1

Government numbers on employment Government numbers on employment are also misleading in an ordinary are also misleading in an ordinary sense.sense.

Employment is defined in a way that Employment is defined in a way that does not make sense from a worker’s does not make sense from a worker’s perspective or from a family perspective or from a family perspective.perspective.

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Employment - 2Employment - 2

Let’s say the US loses 20,000 Let’s say the US loses 20,000 manufacturing jobs in auto plants this year. manufacturing jobs in auto plants this year.

Suppose over the same year, Wal Mart plus Suppose over the same year, Wal Mart plus Wendy’s hire 22,000 people. Wendy’s hire 22,000 people.

According to the government, that is a net According to the government, that is a net

gain of 2,000 jobs.gain of 2,000 jobs.

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The government does not keep the The government does not keep the numbers in terms of jobs that offer a numbers in terms of jobs that offer a living wage, along with the prospect living wage, along with the prospect of job security, some kind of “career of job security, some kind of “career ladder,” a defined-benefit pension, ladder,” a defined-benefit pension, and a decent medical and dental and a decent medical and dental plan.plan.

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The government will barrage us with talk The government will barrage us with talk about how the job situation is improving about how the job situation is improving because it does not care to report about because it does not care to report about what is really happening to the quality of what is really happening to the quality of jobs.jobs.

If it reported accurately, it would be If it reported accurately, it would be reporting a national emergency – the reporting a national emergency – the deterioration of the job structure over the deterioration of the job structure over the last 40 years. Generally, the federal last 40 years. Generally, the federal government is silent on this sea change.government is silent on this sea change.

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Consumer Price Index -1Consumer Price Index -1

The CPI is an index that is supposed to The CPI is an index that is supposed to indicate overall changes in prices indicate overall changes in prices experienced by people in their role as experienced by people in their role as consumers.consumers.

It is used to adjust Social Security It is used to adjust Social Security payments, other Cost of Living payments, other Cost of Living adjustments, and figures into the major adjustments, and figures into the major numbers used to describe the national numbers used to describe the national economy.economy.

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Consumer Price Index - 2Consumer Price Index - 2

At about the end of the 1960’s the At about the end of the 1960’s the method of calculation was changed method of calculation was changed to permit “hedonic” adjustments and to permit “hedonic” adjustments and substitutions.substitutions.

“ “Hedonic” adjustment example… Hedonic” adjustment example…

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Hedonic Adjustment –Hedonic Adjustment –

Lets say a family had a large black and white TV in Lets say a family had a large black and white TV in 1968. In 2008 a similar family is looking to buy a 1968. In 2008 a similar family is looking to buy a TV. The kind of unit from 1968 is no longer on the TV. The kind of unit from 1968 is no longer on the market. So the family has to buy a color TV set up market. So the family has to buy a color TV set up to receive high definition pictures over cable. to receive high definition pictures over cable.

The low end TV is no longer in the market, and the The low end TV is no longer in the market, and the new TV costs twice as much. new TV costs twice as much.

The CPI calculation is adjusted to say the new TV The CPI calculation is adjusted to say the new TV costs less than the old one due to the increase in costs less than the old one due to the increase in pleasure.pleasure.

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Leave out Actual Costs Families Have to PayLeave out Actual Costs Families Have to Pay

Another questionable practice – they ask that Another questionable practice – they ask that people focus on the CPI with the energy items people focus on the CPI with the energy items removed (“core CPI”). When energy prices are removed (“core CPI”). When energy prices are increasing, how useful is that?increasing, how useful is that?

Example: if natural gas price runs up suddenly, Example: if natural gas price runs up suddenly, leave it out because it fluctuates. In this case the leave it out because it fluctuates. In this case the government reports results with and without, but government reports results with and without, but asks that the “core CPI” be the one that everyone asks that the “core CPI” be the one that everyone focuses on.focuses on.

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Treatment of Housing CostTreatment of Housing Cost Another questionable practice – Another questionable practice –

Instead of putting the costs of buying Instead of putting the costs of buying a house into the CPI, they use the a house into the CPI, they use the cost of equivalent rental housing. cost of equivalent rental housing.

That might work sometimes but not That might work sometimes but not

in the context of the run up in in the context of the run up in housing prices over the last 15 years.housing prices over the last 15 years.

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Substitutions –Substitutions –

Remember that the purpose of the CPI was Remember that the purpose of the CPI was to hold a “basket of goods” constant so to hold a “basket of goods” constant so that comparisons of prices could be made that comparisons of prices could be made across years.across years.

Since the early 1990’s substitutions have Since the early 1990’s substitutions have been allowed in the CPI calculations. been allowed in the CPI calculations. Williams notes that this changes the index Williams notes that this changes the index from a “cost of living” to a “cost of from a “cost of living” to a “cost of survival” index. survival” index.

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One of these adjustments might not One of these adjustments might not cause much of a problem, but over the cause much of a problem, but over the years since 1968 there have been years since 1968 there have been many. many.

So the official CPI is not a real number So the official CPI is not a real number

anymore. And, everything it adjusts is anymore. And, everything it adjusts is therefore out of calibration.therefore out of calibration.

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See Paulos, Alternative Inflation Index (1968-2004). Source: George J Paulos, www.gold-eagle.com

Bottom Line -- What has really happened to pay since 1968.

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Bottom Line – What has happened to Social Security since 1968.Bottom Line – What has happened to Social Security since 1968.

The cumulative distortions in the CPI result in The cumulative distortions in the CPI result in current Social Security payments that are current Social Security payments that are somewhere between 40% to 70% too low. If a somewhere between 40% to 70% too low. If a Social Security payment is $20,000 per year, it Social Security payment is $20,000 per year, it should be – by law – and if the CPI system had not should be – by law – and if the CPI system had not been distorted, about $33,000. (See Williams been distorted, about $33,000. (See Williams study)study)

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Poverty Statistics - 1Poverty Statistics - 1

The official statistics on poverty in The official statistics on poverty in the US were created in the 1960s.the US were created in the 1960s.

The system was defective from the The system was defective from the start because it was based on a start because it was based on a basket of subsistence goods and did basket of subsistence goods and did not take income inequality into not take income inequality into account.account.

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The basket of goods would have The basket of goods would have been hard to find even then.been hard to find even then.

The method assumes someone at The method assumes someone at home full time and does not take home full time and does not take child care expense when everyone child care expense when everyone must work into account.must work into account.

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The New Massachusetts Health The New Massachusetts Health Insurance proposal puts the poverty Insurance proposal puts the poverty cut off at 300% of poverty (April cut off at 300% of poverty (April 2006). Why?2006). Why?

Because if you have a consensus Because if you have a consensus across the political spectrum and are across the political spectrum and are trying to do something real, you have trying to do something real, you have to use real numbers.to use real numbers.

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All of the state income self-sufficiency All of the state income self-sufficiency studies come out with self-sufficiency studies come out with self-sufficiency income for a family at over 200% of official income for a family at over 200% of official poverty and, in some cases to 323% of poverty and, in some cases to 323% of FPL. FPL.

The self-sufficiency studies are based on The self-sufficiency studies are based on family budgets, but do not include family budgets, but do not include provision for severe illness, retirement provision for severe illness, retirement income, or (sometimes) a car.income, or (sometimes) a car.

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In our work, we come up with at least In our work, we come up with at least 250% of official poverty as the 250% of official poverty as the breakpoint.breakpoint.

Massachusetts and California use the Massachusetts and California use the equivalent of 250% and use 300% for equivalent of 250% and use 300% for some (limited) programs.some (limited) programs.

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Bottom Line on Poverty –Bottom Line on Poverty –

Conservatively, 100% of poverty in Conservatively, 100% of poverty in 1965 is 250% of poverty in 2006. 1965 is 250% of poverty in 2006. Using the income insufficiency Using the income insufficiency methodology and in more methodology and in more progressive perspective, program progressive perspective, program eligibility should be at 350%.eligibility should be at 350%.

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SECTOR MAP TOOLSECTOR MAP TOOL

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Sector Map ToolSector Map Tool

The basic idea is just a graph:The basic idea is just a graph:

Usage or a proxy for usage on the Usage or a proxy for usage on the side.side.

Income or a proxy for income on the Income or a proxy for income on the bottom.bottom.

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Reichmuth Sector Maps – For energy Reichmuth Sector Maps – For energy burden.burden.

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Electric Energy Burden - CAP

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Energy BurdenEnergy Burden

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Reichmuth Sector Map – for Affordability.Reichmuth Sector Map – for Affordability.

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Electric Affordability Conformance Map - CAP

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