The PUC Takes Us Back to 1922

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Power to the People is a column by D. Maurice Kreis, New Hampshire’s Consumer Advocate. Kreis and his staff of four represent the interests of residential utility customers before the NH Public Utilities Commission and elsewhere.

By Donald M. Kreis, Power to the People

Sometimes, in my exasperation, I have been known to complain that New Hampshire’s public utilities are mired in the year 1955.  But it turns out that maybe I should be grateful these companies are as evolved as they are.

This week we learned that the Public Utilities Commission (PUC) is partying like it’s 1922.

On May 3, the PUC approved a modest increase in the distribution rates paid by electric customers of Unitil.  So far, so good.  These rates are just and reasonable.

But what has the local energy mavens abuzz, including me as the state’s advocate for residential ratepayers, is a couple of additional rulings the PUC made in the Unitil rate case.  Specifically, the PUC made clear that two things it doesn’t like are (1) building infrastructure for electric vehicles at ratepayer expense, and (2) helping poor people.

Let’s take those up in reverse order.

The PUC rejected Unitil’s proposed “arrearage management” program.  The PUC approved a similar program for Eversource in late 2020, but those commissioners are gone.

Now the Commission has ruled that, because Unitil already has an Electric Assistance Program (discounts for poor people) and already negotiates payment plans with at least some customers who fall behind on their payments, the proposed arrearage management program is “unnecessary.”

“The Company failed to present any evidence that additional arrearage support is needed, or that such a program is likely to be effective,” ruled Chairman Daniel Goldner and Commissioner F. Anne Ross.

Here’s the evidence the PUC ignored, or at least misinterpreted.  According to Unitil’s manager of credit and collections, Carole Beaulieu, the utility would end up forgiving about $375,000 a year in unpaid bills. Additionally, Unitil would need to spend $65,000 on an employee to manage the program.  The Commission described these as “incremental costs.”

Well, not really.  According to Beaulieu – whose testimony was unchallenged at the hearing – the arrearage management program would cover $1.5 million in unpaid bills a year – money the utility would recover from customers who do pay their bills – into a source of at least some revenue.

In other words, there are benefits here for all customers the PUC has now rejected.  Plus, as Beaulieu explained, the goal of an arrearage management program is to provide customers with “the opportunity to successfully manage and pay for their energy usage.  Successfully accomplishing this goal will stop the pattern of building arrears, being disconnected, and carrying additional debt.”

In other words, it helps poor people.

As for electric vehicles, the PUC rejected $2.8 million in planned spending on EV infrastructure, marketing time-of-use rates for customers with electric vehicles, and rebates to make those rates attractive.  Most of the money would have gone toward so-called “make-ready EV infrastructure,” which just means upgrading facilities on the utility’s side of meters associated with public charging stations.

The PUC reasoned that this would be a bad use of ratepayer money because EVs are more expensive than gas-fueled vehicles, EV users are “likely to be among the most affluent group of Unitil customers,” free fast-charging stations are popping up around the state, and EVs can be charged at home.

Let’s rattle off the list of realities the PUC had to ignore to get to that result.  First, the world’s automakers are phasing out gas-powered vehicles whether we like it or not.  Second, time-of-use rates for EV customers are designed to save everyone money, by nudging demand into hours when supply is abundant.  But people won’t embrace rates like that without promotion and education.

Finally, if we essentially tell people to charge their EVs at home, or hope their employers will let them charge for free at work, we are taking steps that will be especially harmful to poor people.  They’ll drive EVs alongside the affluent, but only the affluent will be able to travel freely.  Plus we’ll be encouraging tourists from neighboring states to stay out of New Hampshire.

One person who might be rolling in his grave over the PUC’s decision is C. Julian Tuthill.

In 1922, what was then known as the New Hampshire Public Service Commission rejected Tuthill’s petition to bring electric service to Maple Avenue in Atkinson.  A century later, the Public Service Commission’s decision in Tuthill v. Plaistow Electric Light and Power Company was one of the precedents the PUC cited in rejecting the EV infrastructure proposal.

The Public Service Commission opined that Atkinson is “beautifully situated, with a healthful climate, which makes it an attractive residential setting.”  But the Commission noted a century ago that the population in Atkinson actually fell during the previous decade and Maple Avenue, by virtue of its “large number of beautiful maple shade trees,” was “an undesirable location for an electric pole line.”

“In these progressive times,” the Commission continued, “electric lights and power are recognized as not only desirable but almost a necessity, and the residents of Maple Avenue, knowing that electricity is so near them, feel they should have the benefit of it.” 

But – and here’s the rub – the proposal to build a line to serve 13 customers on Maple Avenue was not deemed worthy of approval as presented to the regulators in 1922.  According to the century old wisdom of the Public Service Commission, “[s]uch extensions are not in the public interest because they must be carried by increasing the rates upon other consumers.”

Spoiler alert:  Maple Avenue in Atkinson is still gloriously tree-lined and shady in summer. The Plaistow Electric Light & Power Company is long gone.  But the residents of Maple Avenue now have electricity.

Have we learned anything in 100 years?  Well, we’re still arguing about who’s subsidizing whom even though, as utility customers, we’re all subsidizing each other.  (To make it otherwise, the utility would have to calculate a unique rate for each home based on the costs it imposes on the system.)

We’re still freaked out by the evolution of technology.  A century ago, it was electrification.  Now, it’s transportation electrification.

Finally, as to the question of whether to take affirmative steps to reduce the extent to which poor people are behind on their utility bills at a time of soaring energy costs that impose disproportionate burdens on those with few resources:  The Roaring ‘20s – hailed by the utility regulators of that era as “these progressive times” but now remembered as a time of excess and indifference – were swiftly followed by the Great Depression.

Let’s not go there again.  We need energy policy calculated to produce a better tomorrow – as opposed to a reprise of 1922.

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