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“Affordable” Utility Service: What Exactly Is Regulation’s Role? With all the nation’s economy stressed, politicians are pressuring regulators to make utility service “affordable.” This picture has three problems. Wealth Redistribution is Not Regulation’s Department Under embedded cost ratemaking, the regulator identifies prudent costs, computes a revenue requirement to cover those costs, then designs rates to create the revenue requirement. Rate design makes each customer category bear the expenses it causes. None of these cost that is steps—prudent, revenue requirement computation, cost allocation—involves affordability. Affordability becomes one factor only whenever we jigger the numbers—if we lower rates for the unfortunate by raising rates for other people. Achieving affordability through rate design means cost that is compromising to redistribute wealth. It resembles taxation of 1 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. Instead of shifting costs between customer classes, regulators might redistribute wealth in different ways: by “taxing” shareholders, i.e., reducing shareholder returns below the otherwise appropriate level. But taxing shareholders isn’t any more the regulator’s domain than is taxing some other clients. And it is likely unconstitutional: Having invested to serve the general public, shareholders expect “just compensation,” undiminished by a forced contribution for affordability. Moving money among citizens is vital to a fair society. Poverty is intolerable and charity that is private suffices, so government steps in. But helping the luckless ought to be done by political leaders, who must justify their actions to your electorate; not by professional regulators, whose focus should be industry performance. Affordability of any product—groceries, a Lexus, or utility service—depends on one’s wealth and income, and on the cost of other products. The poor could better afford utility service if we raised their income and increased their wealth. Or if perhaps we lowered their price of housing, health care, transportation, or education. However these initiatives are outside regulators’ authority. To make regulators accountable for affordability is illogical. Cheap Energy is Cheap Politics Politicians who argue for affordability make the easy road. To legislate economic development, greenness, reliability, energy independence, and technology leadership, all efforts that increase costs, while commanding the regulator 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 instead of encouraged to contribute. But no family, no congregation, no society that is civil thrives if its key verb is “take” in the place of “give.” And when lower rates now result in higher costs later, citizens become cynical. Self-doubting, also, while they question their capability to differentiate pander from policy. These are the results when politicians avoid their responsibility for affordability. “Affordability” Undermines Regulation’s Responsibility Mathematician Carson Chow says he’s found the cause of our obesity epidemic: low food prices. Studying 40 many years of data, he spotted both correlation and causation between girth growth and cost declines. He traced these trends to government farm policy shifts (from spending money on non-production to stimulating full production) and technology boosts (which lowered production costs). The low the price, the greater production; the greater amount of production, the greater (fast) food; the greater food, the greater amount of calories available; the more calories available, the greater calories consumed. See C. Dreifus, “A Mathematical Challenge to Obesity,” The New York Times (May 14, 2012). We have been 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 have to do with “affordable” utility service? A regulator’s job is always to regulate—to performance that is establish, then align compensation with compliance. In this equation, affordability is certainly not a variable. In order to make service affordable into 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 more than the advantages. Conversely, economic inefficiency exists when we forego some action that, if taken, will make someone better off without making anyone worse off. To over-consume, to waste, to act inefficiently, to go out of good results on the table, makes everyone worse off. Underpricing in the true name of affordability makes someone worse off, unnecessarily. How sensible is that? Actions for Affordability: The Right Roles for Regulators Unless essential services are affordable, government will never be credible. Regulators, being section of government, need to help. (A commission staff chief told me 25 years ago, “Sometimes you have to put aside your principles and do what’s right.”) Plus some regulatory statutes explicitly require the regulator to help make service “affordable.” (As is the scenario, I am told, in Vanuatu, an nation that is 83-island the South Pacific.) Listed below are 3 ways, in line with economic efficiency, for regulators to deal with affordability. Help the reduce usage that is unlucky. Regulators can advocate for affordability by pressing for policies that produce consumption less costly, like improved housing stock, “orbs” that signal high prices, and efficient lighting and appliances. Analogy: Doctors save lives not merely 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 the most reliable and measure that is effective prevent firearm-related injuries. “) Interpret “affordability” as long-term affordability. Getting prices right and preventing overconsumption, even though it increases prices into the short run, reduces total costs within the run that is long. Expose the dark side of under-pricing. Rather than follow politicians along the low-price, low-risk, cheap politics path, regulators, like Dr. Chow, can talk facts: concerning the real costs of utility service, the situation of overconsumption, the error of under-pricing. With regards to credibility rooted in expertise, regulators can pressure legislators to behave on affordability directly by enacting policies that are income-raising. Better education, housing, and health care—all these lead to higher incomes, in order for citizens are able utility service priced properly.

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

Wealth Redistribution is Not Regulation’s Department

Under embedded cost ratemaking, the regulator…

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