Cross-State Finding #5

Five states, three assistance models, and one unresolved question: what level of protection makes electrification possible?

The five benchmark states use fundamentally different approaches to LMI energy assistance — from New Hampshire's 86% rate discount to Vermont's 12.5% to Pennsylvania's percentage-of-income payment plan. The states with the strongest assistance (PA, NH) have the highest enrollment rates. The states mandating electrification (VT, MA) have the widest gap between policy ambition and customer protection.

LI electric bill assistance — percentage discount states
New HampshireTiered discount
86%
Up to 86% off first 750 kWh
MassachusettsTiered discount
64%
Composite effective discount (Eversource)
ConnecticutLIAP
50%
50% for <160% FPL
Vermont — GMPFlat discount
25%
Flat 25% off energy + customer charges
Vermont — BEDFlat discount
12.5%
Flat 12.5% — lowest in corpus
Alternative models — not comparable on a percentage scale
PennsylvaniaCAP (PIPP model)
% of income cap
Bill capped at percentage of household income — affordability guaranteed by design
PIPP model
MichiganEWR + MEAP
$5.80/mo surcharge
All-class surcharge funds efficiency programs — no direct bill discount for LI customers
Socialized model
Model A: Percentage discount
Flat or tiered bill reduction
Reduces the bill by a fixed percentage. Simple to administer. Does not guarantee affordability — a 25% discount on a $300 bill still leaves $225 due.
Used by: NH (tiered 5-86%), MA (tiered up to 64%), CT (50%), VT (flat 12.5-25%)
Model B: PIPP (% of income)
Bill capped at income share
Caps the bill at a percentage of household income regardless of usage. Guarantees affordability by design. Program absorbs the difference as a credit.
Used by: PA (CAP — $494.7M/yr), IL (6% of income cap). Not used by: VT, WI, MI
Model C: Burden guarantee
Energy burden ceiling
Guarantees total energy costs stay below a threshold (e.g., 6% of income). Combines rate design, efficiency, and subsidy as needed. Decouples electrification from bill impact.
Piloted by: NY (EAG — Energy Affordability Guarantee). Proposed by: VT DPS (6% threshold)
12.5%
Vermont BED's discount — the lowest in the five-state corpus. BED's disconnection notice rate (14%) is 3× its enrollment rate (4.3%). The discount level is not protecting customers from disconnection.
6%
Energy burden threshold proposed by VT DPS and piloted in NY's EAG. If the EAG model works — capping total energy costs at 6% of income — it would be the first mechanism in the corpus that makes electrification possible without increasing burden.
The five states reveal three models of assistance, each with structural limitations. Percentage discounts (Model A) don't guarantee affordability. PIPP programs (Model B) guarantee affordability but incentivize consumption, not efficiency. The burden guarantee (Model C) is the only model designed to make electrification compatible with affordability — but it exists only as a pilot in one state.
NH, MA, CT discount data — VT PUC Docket 25-0443-INV comparative analysis. PA CAP — BCS Universal Service Report 2022. MI surcharges — MPSC 2024 EWR Report + Annual Report. VT GMP/BED — pipeline data. NY EAG — DPS LMI webinars, Chris Cole testimony. VT 6% threshold — VT DPS proposal, Docket 25-0443-INV. IL 6% PIPP — IL statute, cited in VT investigation.
Sources: NH up to 86% — VT PUC comparative analysis (utility-specific filings report 5-85%; PUC summary states 86%). MA 64% — VT PUC investigation, Eversource composite. CT 50% — United Illuminating LIAP filing. MI $5.80/mo ($2.00 electric + $2.55 gas EWR + $1.25 MEAP) — MPSC 2024 EWR Report p.3 + Annual Report p.29. PA CAP (% of income) — BCS Universal Service Report 2022. VT GMP 25% — pipeline data. VT BED 12.5% — pipeline data, high-confidence item. NY EAG 6% — DPS LMI stakeholder webinars, Case 25-M-0249. VT DPS 6% — Docket 25-0443-INV. IL 6% PIPP — cited in VT investigation filings.