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7.30.21 - No household should be disconnected from essential services based on the inability to pay.

No household should be disconnected from essential services based on the inability to pay.


The above is a sentiment we would all endorse and is one of the key tenets of “A Roadmap to Utility Service as a Human Right” developed by the National Consumer Law Center (NCLC) and co-signed by 13 other consumer, environmental, and social justice advocacy organizations1 and published in March of this year. In April, NCLC and its partners released a four page companion brief highlighting the specific policies required to fulfill the Roadmap (Brief: Implementing a Roadmap to Utility Service as a Human Right, April 2021).


This week, the Energy Efficiency Institute released a memo wholeheartedly endorsing the epigram of this email and other the principles expressed in the Roadmap, and explaining how “PAYS® is not only compatible with the Roadmap, but can help make those goals more attainable... “by making efficiency upgrades accessible with no credit check or upfront payment, providing immediate improvement in their cash flow, and imposing no new debt obligations.”

Pointing to the Pay As You Save track record, EEI noted that “the result over the past 20 years has been no reports of Pay As You Save program participants, including many customers in low-income communities, being disconnected for non-payment of their utility bills.”



In the past, some consumer advocates have opposed Pay As You Save program proposals based on its perceived reliance on disconnection for non-payment. The EEI memo underscores that Pay As You Save is not in fact reliant on disconnection for non-payment, rather: “In its delivery of an essential utility service, PAYS simply applies the terms of the existing regulated utility system and the cost recovery mechanisms that the system employs. If the regulated utility system were to use a different mechanism to ensure cost recovery for the utility, PAYS would use that system to ensure cost recovery for the utility’s efficiency and clean energy investments through the PAYS system.” EEI highlights that it “supports efforts to enhance services and protections for low-income customers that help to ensure that they can maintain essential utility services.”


Hopefully, this memo along with the earlier Southern Environmental Law Center’s Review of National Consumer Law Center’s Tariff On-Bill Recommendations in the Context of the Pay As You Save® System’s Built-In Consumer Protections released earlier this year will allow PAYS and consumer advocates to work together to advance policies that fulfill their common goal to relieve energy burdens, improve equity, and provide restorative justice, health, and income preservation to low-income and historically marginalized BIPOC households.


We encourage all PAYS Pals to read all four documents (the Roadmap, its companion brief, EEI’s memo, and SELC’s review) since the Roadmap and its implementation plan are likely to shape much of the utility advocacy policy agenda in the coming years. EEI’s memo and SELC’s review together equip readers to effectively explain how Pay As You Save protects consumers from genuine risks of abuse posed by tariff on bill investment that lack the strong Pay As You Save consumer protections.


1 Citizens Action Coalition, Community Organizing and Family Issues, Energy efficiency for All, Grene Power Alliance, Network for Energy, Water, and Health in Affordable Buildings, North Carolina Justice Center, Natural Resources Defense Council, Ohio Partners for Affordable Energy, Public Utility Law Project of New York, Inc., Pennsylvania Utility Law Project, The Utility Reform Network, and Wildfire

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