Cross-State Finding #4

Program generosity does not drive enrollment. Outreach infrastructure does.

Pennsylvania's PECO enrolls 83.7% of eligible low-income customers through 30 community-based enrollment sites. PPL enrolls 34.6% through customer-initiated processes. Vermont expanded its program AND increased the discount — enrollment fell 26%. The difference between 83% and 4% enrollment isn't the program. It's the pipeline.

CAP enrollment rate by utility — sorted by enrollment method
The Vermont paradox: more generous program → fewer participants
GMP before expansion
10,560 enrolled
150% FPL eligibility, 20% discount, ~30% of eligible
→
GMP after expansion
7,770 enrolled
185% FPL eligibility, 25% discount, ~25% of eligible. Wider eligibility + higher discount = fewer participants.
83.7%
PECO's enrollment rate — highest in the five-state corpus. Mechanism: 30 community-based organization enrollment sites, proactive outreach, community partnerships. Not customer-initiated.
4.3%
Burlington Electric's enrollment rate — lowest in the corpus. Disconnection notice rate is 14% — more than 3× the enrollment rate. The gap between need and reach is a factor of three.
−26%
GMP's enrollment change after expanding eligibility and increasing the discount. The program became more generous. Fewer people enrolled. Privacy restrictions block auto-enrollment from income-verification databases.
The five-state evidence shows that enrollment is an infrastructure problem, not a generosity problem. States can design the most generous assistance program in the country — if eligible households don't know about it, can't navigate the application, or can't be identified by the utility, the program serves a fraction of its intended population. The only enrollment rate above 75% in the entire corpus used community-based enrollment partnerships.
PECO 30 CBO sites — PA pipeline data, Docket R-2022-3037368. Privacy restriction on auto-enrollment — Stowe Electric filing, VT Docket 25-0443-INV. All enrollment rates from validated state-specific charts.
Sources: PA enrollment rates by utility — BCS Universal Service Report 2022, CAP Participation tables: PECO 83.7% (121,487/145,073), Duquesne 74.5% (38,092/51,118), Penn Power 41.9%, Penelec 39.8%, West Penn 39.8%, Met-Ed 36.7%, PPL 34.6% (68,949/199,360). PECO 30 CBO sites — PA pipeline data. VT GMP before (10,560, 150% FPL, 20%) and after (7,770, 185% FPL, 25%) — VT pipeline data, Docket 25-0443-INV. BED 4.3% enrollment / 14% disconnection — VT pipeline, high-confidence item. Privacy restriction — Stowe Electric filing.