We request that our comments be placed in the following docket and made available on the Commission’s website: 2020-106-A Actions in Response to COVID-19.
January __, 2021
Hon. Justin T. Williams
The Public Service Commission of SC
101 Executive Center Dr, Suite 100
Columbia, South Carolina 29210
contact@PSC.SC.gov, 803-896-5100
Dear Chairman Williams,
Thank you for this opportunity to comment. We are ratepayers of South Carolina utilities providing public comments on your decisions around disconnections and arrearage management, near-term and long-term solutions for those suffering from energy poverty. We appreciate the Commission’s swift suspension of utility shut offs at the beginning of the pandemic. However, we wish to express concern about the reinstatement of those shut offs and the ongoing concern about high energy burdens in South Carolina.
Uncertainty around utility disconnections has an extremely disproportionate impact on communities that are already suffering from high energy burdens. The energy burden refers to the percent of income a household pays for its utilities - experts consider costs above 6% of a household’s income to be unaffordable. The term energy insecurity can be used to describe when household hardships are so enormous that unhealthy decisions must be made or the fear of losing energy access appears unavoidable. And the term energy poverty is a loss of energy access - putting households in extremely difficult and dangerous situations.
South Carolinians pay some of the highest bills in the nation and families in the lowest income group pay 37% of their income towards energy costs. Compare this to the median national energy burden of just 3.1% of income. This struggle pre-dates the COVID crisis - a 2015 analysis revealed 31% of all Americans regularly face energy insecurity, with the figure jumping to 45% for Latinx respondents and 52% for Black respondents. But COVID-19 has undoubtedly exacerbated the suffering, with reports showing that 67% of low-income households in America face a high energy burden and that the energy burden is disproportionate across racial lines.
A recent poll commissioned by the Conservation Voters of South Carolina reveals a disturbing picture of the economic toll that the pandemic has had on South Carolina families – particularly among those who already face disproportionate economic challenges. More than seven in 10 (72%) of those who reported already having difficulty meeting ends meet said the pandemic has made paying their utility bills even more difficult than before. The percentage of voters who struggled to pay their utility bills was observed to be especially high among the following groups when compared to other groups:
- Multi-generational (66%) compared to single generation (24%) households
- Single-parent households (51%) compared to multi-parent (30%) households
- Black (45%) households compared to white households (26%)
- Low income (41%) households compared to middle income (25%) or high income (23%) households
We believe shutoffs and late payments should remain suspended until utilities and the Commission more fully understand the economic impacts of COVID-19 on utility customers, especially those suffering from energy poverty, and potential means to address them. Rather than allowing utilities to determine deferred payment plan options or debt forgiveness, we request that the Commission prohibit disconnections at this time and pursue additional tracking and reporting of data, while still respecting ratepayer privacy, to ensure that mid- and post-pandemic actions from utilities are in the best interest of ratepayers of South Carolina. Gathering clear, specific monthly data for both general residential customers and identified low-income residential customers is key to understanding affordability and home energy security challenges in South Carolina’s communities.
Additionally, we request that the Commission pursue short and long term clean energy solutions to address ratepayers’ high energy burdens, like expanding solar access and comprehensive energy efficiency programs. While energy efficiency is the most cost-effective way to lower energy bills for low-income households, expanding programs like community solar gives homeowners, renters, and businesses equal access to the economic and environmental benefits of solar energy and increases grid resiliency.
Thank you for this opportunity to comment and for your consideration of our concerns.
This letter is signed by the following individuals:
