The undersigned groups sent the following letter to the Wisconsin Public Service Commission.
April 2, 2021
Chairperson Valcq, and Commissioners Nowak and Huebner,
A significant PSC role is to ensure reliable and affordable energy to utility customers. Our winter utility shutoff moratoriums reflect the necessity of electricity and heating as essential for people’s safety and lives. We also have systems in place to provide assistance and support when difficulties arise in paying for power.
The extension of the utility shutoff moratoriums through 2020 due to COVID-19 is an acknowledgement that there are risks beyond seasonal temperature variations. It has also highlighted the considerable variabilities and disparities that exist within our population and communities regarding health and financial situations, and who is at risk.
The rationale for ending the shutoff moratoriums was assumptions of significantly lessened risks and adequate support systems to provide safety. However, much of those assumptions are also based on overall numbers and presumptions of functionality in our systems. If this past year has shown us anything, it is that we have many flaws in our systems that result in significant impacts on, and harms to, people.
While COVID numbers have reduced, considerable variability still exists among communities. Statistics show that COVID has disproportionately impacted people of color, who not only have suffered the most illnesses and deaths, but remain at higher risk due to greater health risks and living situations, lower vaccination rates, and less access to health care. These are situations that will not be easily or quickly resolved, and remain significant in some locations.
Part of the basis for ending the shutoff moratoriums is that significant amounts of financial support are becoming available from both the state and federal government. However, this is predicated on distribution and support systems that work well. Unfortunately, that is not the experience of many people in communities of color in Milwaukee. Some people are not aware of programs that exist to serve them. Even when they are, a chronic problem is people reaching out to agencies but unable to contact anyone to provide help. Even staff with non-profits or religious organizations who work to connect people are unable to reach people in agencies and obtain assistance.
In many cases, the need for support has overwhelmed these agencies. Many also do not have enough staff to deal with the extreme overloads on the system that the pandemic has resulted in. Some systems have also been disrupted due to COVID and financial problems. Further, our systems often have complexities that are difficult if not impossible to navigate, with some people getting lost in the system, and others turning away out of frustration.
We have seen the disparities with vaccinations between having them produced and getting them in people’s arms. We also have seen huge unemployment backlogs where people have been unable to make contact, and some who have yet to receive a single check after a year of being unemployed. In addition, some people, especially in poorer communities, have never received one stimulus check, and don’t know why. Any flood of money to deal with utility debts is only as good as a system that can distribute it effectively - and who it works for.
In addition, especially now in communities of color, many have very limited financial options as compared to others who can rely on savings, family, assets or obtaining loans to pay off debts. Not being able to pay their utility bills means they may lose lighting, heating or cooling, home medical equipment, refrigeration, cooking capabilities, hot water, and phone and internet connections, causing them to be at higher risk during the continuing pandemic whether they stay or have to move. Even if they stay, their means to communicate with others, contact health care providers, support systems, employers or family, or for children to have remote access to school will be severely diminished. For too many, there is no plan B - troubling in the best of times, much worse during a pandemic.
We regard cold winters as the season where power is needed for heat as a life-saving measure. But heat has become the #1 greatest cause of weather-related deaths in our country. While a higher risk in southern states, our urban heat islands contribute to this and are worse in many neighborhoods with less tree cover, and we can get high humidity for many days in addition to worsening heat waves. This particularly impacts elderly and those already at risk.
Many currently impacted people already have a very high energy burden – the percentage of income that goes to pay for utility bills. Census data from 2013 - 2018 show that many Black and Latinx census tracts in Milwaukee have as high as 7 - 10% energy burdens, as compared to a 3% statewide average, and many census tracts where resident’s energy burden is well under 1%. Some individual households pay well in excess of 10%. Some of this energy burden is linked to the increase in fixed fees granted since 2015 that raised rates for many low income customers.
It is not by chance that the census tracts where residents have a high energy burden are the same ones that were historically redlined. The same ones where there are high rates of asthma, heart disease, diabetes, and other health care problems, and hence were heavily impacted by COVID. The same ones where income and wealth are far lower than average, and unemployment much higher, especially with COVID – and those who do work often have high risk service jobs. The impacts in their communities are not just cumulative harms, they are multiplicative.
These are also the same areas that have historically felt both the sting and impacts of racism. This last year has been especially harsh with so many Black murders, often by the people in communities that are supposed to keep people safe. After so many years of the system failing them badly, the pandemic has confirmed to them that it does not serve them and they cannot trust it.
Energy burden and differential pandemic problems however are not limited to Milwaukee. While no census tracts exist in Milwaukee that are majority Native/Indigenous, this is not true statewide where the median energy burden for this group is also significantly impacted with an average of 5.6% - nearly double the statewide average. This is another group that has traditionally experienced low income and inadequate housing along with significant health issues, and has also suffered disproportionate impacts prior to and during the pandemic.
Wisconsin, and in particular Milwaukee as well as Madison, is known to have some of the worst racial disparities in the country. We are increasingly recognizing that our racism problem is not just particular incidents, or around certain issues, but is systemic and engrained in so many of our interrelated systems. We have declared that we need to do something about it, to fix the inequities that exist. We cannot continue to act in ways that exacerbate it.
The decision to end the utility shutoff moratorium is predicated on a system that works, that the support we say is there will be available, and that people will not incur significant harms or deaths as a result of eliminating shutoffs. It’s not true. The system has not worked and will not work for too many who are already disenfranchised, and are already hurt and suffering. The past year has not only taken a huge financial toll on those who had little in the first place, it has added significantly to suffering and mental anguish - to which we are now willing to subject people to added insults, aggravation and uncertainty in trying to deal with a system that has, and is continuing to, fail them.
If Communities of Color need any further evidence of systemic racism after what they endured the past year, they will now additionally be at risk for having their power shut off and homes perhaps made uninhabitable. Meanwhile, CEOs of companies continue to earn million-dollar plus compensations, and
shareholders with money to invest reap profits, while impacted customers are without means for them to conduct their lives well and safely. They could further be faced with needing to move or paying high reconnection fees, children who may be homeless or cannot attend school virtually, the loss of possessions and added difficulty retaining jobs, and experience even worse risk for obtaining future housing.
How can we legitimately make decisions to put people’s lives and futures at risk without fully understanding the situation especially impacted minorities are in, and ensuring that the system we say is there to serve them actually can and will? Can we afford another failure for those who have been most discriminated against, who have suffered the greatest harms this past year, and to whom we have said, we will do better? That cannot be acceptable at this time, and in this state. These are people, even under the best of circumstances, who will continue to be at a disadvantage in our society. Adding further burdens will have increased ripple effects for added years and decades.
We ask the Commission to ensure that the intended outcomes for everyone are realistic based on how our systems actually function, especially for those we have continually harmed and who have borne the brunt of our systemic disparities, particularly this past year.
To meet the desired outcomes regarding discontinuing the shutoff moratoriums, the optimal solution that provides the strongest safeguards would be to continue the shutoff moratorium until we can ensure the problems are resolved and systems are truly in place and functional, and will avoid the continued impacts to
those already harmed.
If the Commission cannot see its way to taking the most proactive measure to ensure the well-being of our residents, we suggest the following measures, or some version of them be seriously considered to avoid harming those in need of our support, and not cast them aside again.
- If feasible, work with Governor Evers to have state and federal funds allotted to paying off utility debts disbursed directly to the utilities for them to work with customers to forgive or limit any debts. This would be far more efficient and cost effective, and require far less bureaucracy and processing than working to get funds to customers to give back to the utilities anyhow.
- If direct distribution of funds to utilities cannot be accomplished, utilities should be prohibited from shutting off power to any residences until state and federal funds have actually been made available to those individuals beyond their own programs. Utilities should provide customers assistance in accessing those funds. If utilities cannot provide the needed assistance, then the Commission must ensure that a fully functional support network is in place to distribute funds in a timely and equitable manner.
- Utilities shall work with the Commission to determine processes as to who shall have debts forgiven and how to work towards partial debt forgiveness for others.
- No household under 200% (or perhaps even higher) of the poverty level can have their power shut off. This would be $53,000 for a family of 4, or $26,760 for an individual, for example.
- Waivers of all interest, late payment and reconnection fees by utilities.
- Deferred utility payments for at least 18 months and a payment plan for those unable to pay otherwise.
- Households in arrears of payments and under 300% of the poverty level shall receive a free energy consult to assist with reducing energy bills, along with directed Focus on Energy funding to fix problems.
- Consider allowing utilities to recover a portion of lost payments through other means such as increasing charges or a higher allowed rate of return.
Respectfully submitted and supported by:
Elizabeth Ward
Chapter Director, Wisconsin Chapter Sierra Club
Dana Kelley
Health Equity Organizer, North Side Rising
Dr. Robert Kraig
Executive Director, Citizen Action Wisconsin
Huda Alkaff
Founder and Director, Wisconsin Green Muslims
Tim Cordon
Social Justice Coordinator, First Unitarian Society-Madison Justice Ministry
Matt Rothschild
Executive Director, Wisconsin Democracy Campaign
Rabbi Bonnie Margulis
Executive Director, Wisconsin Faith Voices for Justice
Jennifer Giegerich
Government Affairs Director, Wisconsin Conservation Voters
Mike McCabe
Executive Director, Our Wisconsin Revolution
Elaine Kinch and Sonali Knotek
Co-chairs, Racine Coalition for Peace and Justice
Peter Bakken
Justice and Witness Coordinator, Wisconsin Council of Churches
Abby Lois
Executive Director, Wisconsin Health Professionals for Climate Action
Jeff Wild
Board President, Wisconsin Interfaith Power and Light
Julie Enslow
Lead Organizer, 350 Milwaukee
Barbara Leigh
Project Consultant, Quasimondo Physical Theatre
Jess Haven
Organizer, Clean Power Coalition of Southeast Wisconsin