After the Joint Proposal (“JP”) regarding Niagara Mohawk’s Interim Gas Energy Efficiency Program was submitted on August 1st by several parties, all parties were permitted to submit comments on the JP. PULP, along with several parties, filed comments on August 8th, expressing concern that basing the low income portion of the program on last winter’s costs would be woefully inadequate in light of the anticipated increase in the cost of natural gas for the coming winter. See PULP Opposes Niagara Mohawk’s Interim Gas Efficiency Program PULP’s submission, and that of NYSERDA (which identified several inadequacies with the implementation and operation of the programs), prompted Commission Staff to request permission of file reply comments. The judge presiding over the case granted the request and all parties were given until today to file replies.
In today’s reply, PULP reiterated its support for energy efficiency programs which would benefit low income consumers, but demonstrated that funding these programs at a static level, essentially the same as last year — when the cost of the natural gas itself was 32 cents less per therm than what it is anticipated to be in January 2009 — does not comport with Niagara Mohawk and Staff’s claim that impact of the JP will be “meaningful.” PULP emphasized that the JP is not in the public interest:
Rather, it is a public relations disservice, which will draw attention from the need to address soaring spikes in arrears, disconnections for non-payment, and thousands of families being left in the cold. Terminations are already higher this year. Weatherization efforts designed to reach as many people as possible would be one credible way to defend against the worst that winter 2008 – 2009 has to bring. Since the JP lacks this basic benefit, and merely continues existing efforts, it must be rejected for not being in the public interest. In this case, the status quo equals more fuel poverty, more hardship, and a potentially deadly winter for low income households.
PULP asked that at a minimum, the program be expanded to $8 million, with $5 million of that reserved for low income customers whose homes need weatherization.
The Public Service Commission may act on the JP at its September 17, 2008 meeting.