We have 3 concerns about the amendments proposed to the Public Utilities Act in Bill 212.
The first is that there is no direct relief to low-income customers
The second concern is that the 1.8% limit will undermine the transition to zero carbon energy society wide.
The third concern is that this Bill undermines the independent review process by UARB.
Solutions We will propose solutions to the 1st 2 concerns. But first we would like to make clear that we support 2 elements of the legislation:
We support the exemption of Demand Side Management from the 1.8% cap on expenses, in clause 3 of Bill 212. The contract for Efficiency Services approved in September for the next 3 years includes dramatic increases in low income programming and it supports the transition to a zero carbon economy.
We also support the proposed restrictions on profit to no more than 9.25% on no more than 40% equity thickness (in clause 4 of Bill 212) and no sharing of profit above the 9.25% cap (in clause 5 of Bill 212) and recommend these provisions be strengthened. Our Opening Statement to the UARB regarding the Rate increase proposed stricter restrictions, including lowering the profit rate cap to 8%. The Consumer Advocate also supported a rejection of NSPI’s proposed profit increases, backed up by expert testimony far more substantial than ours. We believe these measures will make a difference on affordability while making a small dent in the inequality that arises from excessive profits and rising rates. RECOMMENDED CHANGES: We believe the best answer to the affordability crisis is to create a systematic program targetting low and modest income households with on bill energy credits to reduce energy poverty. We believe this is much wiser than deferring the transition to zero carbon energy as this Bill does, in part, by eliminating financing for the transition, except for the very important exemption of Demand Side Management
To read the full document, please see the PDF attached below:
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