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“Affordable” Utility Service: What Exactly Is Regulation’s Role? Aided by the nation’s economy stressed, politicians are pressuring regulators to help make utility service “affordable.” This picture has three problems. Wealth Redistribution just isn’t Regulation’s Department Under embedded cost ratemaking, the regulator identifies prudent costs, computes a revenue requirement to pay for those costs, then designs rates to make the revenue requirement. Rate design makes each customer category bear the expenses it causes. None among these steps—prudent cost identification, revenue requirement computation, cost allocation—involves affordability. Affordability becomes an issue only we lower rates for the unfortunate by raising rates for others if we jigger the numbers—if. Achieving affordability through rate design means compromising cost causation to redistribute wealth. It resembles taxation of one class to benefit another, using this exception: With taxation, citizens can retire representatives whose votes offend; however with utility service, captive customers are stuck with all the rates regulators set. As opposed to shifting costs between customer classes, regulators might redistribute wealth in a different way: by “taxing” shareholders, for example., reducing shareholder returns below the otherwise level that is appropriate. But taxing shareholders isn’t any more the regulator’s domain than is taxing other customers. And it is likely unconstitutional: Having invested to serve the public, shareholders expect “just compensation,” undiminished by a forced contribution for affordability. Moving money among citizens is essential to a fair society. Poverty is intolerable and charity that is private suffices, so government steps in. But helping the luckless should be done by political leaders, who must justify their actions towards the electorate; not by professional regulators, whose focus must certanly be industry performance. Affordability of any product—groceries, a Lexus, or utility service—depends on one’s income and wealth, and on the expense of other products. The poor could better afford utility service when we raised their income and increased their wealth. Or if we lowered their price of housing, health care, transportation, or education. However these initiatives are outside regulators’ authority. To help make regulators in charge of affordability is illogical. Cheap Energy is politics that are cheap Politicians who argue for affordability use the road that is easy. To legislate economic development, greenness, reliability, energy independence, and technology leadership, all efforts that increase costs, while commanding the regulator in order to make service “affordable,” is low-risk politics, responsibility-avoidance politics, cheap politics. When politicians call for “lower rates,” the electorate feels entitled to get rather than encouraged to contribute. But no family, no congregation, no civil society, thrives if its key verb is “take” in place of “give.” So when lower rates now result in higher costs later, citizens become cynical. Self-doubting, also, because they question their ability to distinguish pander from policy. They are the results when politicians avoid their responsibility for affordability. “Affordability” Undermines Regulation’s Responsibility Mathematician Carson Chow says he is found the reason for our obesity epidemic: low food prices. Studying 40 several years of data, he spotted both correlation and causation between girth growth and value declines. He traced these trends to government farm policy shifts (from spending money on non-production to stimulating production that is full and technology boosts (which lowered production costs). The reduced the price, the greater production; the more production, the more (fast) food; the greater food, the greater amount of calories available; the greater amount of calories available, the more calories consumed. See C. Dreifus, “A Mathematical Challenge to Obesity,” The New York Times (May 14, 2012). We are both over-consuming and under-appreciating: Dr. Chow discovered that “Americans are wasting food at a progressively increasing rate.” (Fairness point: Chow has his doubters. See Michael Moyer, “The Mathematician’s Obesity Fallacy,” Scientific American (May 15, 2012). What does food need to do with “affordable” utility service? A regulator’s job is to regulate—to establish performance standards, then align compensation with compliance. In this equation, affordability just isn’t a variable. To make service affordable towards the unlucky, the commission will have to lower the purchase price below cost. That leads to overconsumption, to Dr. Chow’s “waste.” This inefficiency hurts everyone. Economic efficiency exists when no further action can create benefits without increasing costs by a lot more than the huge benefits. Conversely, economic inefficiency exists as soon as we forego some action that, if taken, can make someone best off without making anyone worse off. To over-consume, to waste, to act inefficiently, to go out of a benefit up for grabs, makes everyone worse off. Underpricing when you look at the true name of affordability makes someone worse off, unnecessarily. How sensible is that? Actions for Affordability: The Proper Roles for Regulators Unless essential services are affordable, government will never be credible. Regulators, being section of government, have to help. (A commission staff chief told me 25 years back, “Sometimes you must put away your principles and do what’s right.”) Plus some statutes that are regulatory require the regulator which will make service “affordable.” (as it is the outcome, I am told, in Vanuatu, an nation that is 83-island the South Pacific.) Here are three straight ways, in keeping with economic efficiency, for regulators to address affordability. Help the unlucky reduce usage. Regulators can advocate for affordability by pressing for policies which make consumption less costly, like improved housing stock, “orbs” that signal high prices, and lighting that is efficient appliances. Analogy: Doctors save lives not just by treating gunshot wounds, but by advocating for gun safety. (American Academy of Pediatrics: “The lack of guns from children’s homes and communities is considered the most reliable and measure that is effective prevent firearm-related injuries. “) Interpret “affordability” as long-term affordability. Getting prices right and preventing overconsumption, just because it raises prices within the short run, reduces total costs within the long term. Expose the side that is dark of. Rather than follow politicians down the low-price, low-risk, cheap politics path, regulators, like Dr. Chow, can talk facts: about the real costs of utility service, the difficulty of overconsumption, the error of under-pricing. With their credibility rooted in expertise, regulators can pressure legislators to act on affordability directly by enacting income-raising policies. Better education, housing, and health care—all these lead to higher incomes, so that citizens are able utility service priced properly.

“Affordable” Utility Service: What Exactly Is Regulation’s Role? Aided by the nation’s economy stressed, politicians are pressuring regulators to help make utility service “affordable.” This picture has three problems. Wealth...

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