1. Common Problems with Universal Service Programs Roger D. Colton Fisher, Sheehan & Colton Belmont, MA 02478 May 2002

2. Our participation is too low. b Eliminate barriers to participation b Enlist full range of partners b Consider “express lane eligibility”

3. We don’t have enough money b Additional sources of funding Rate refundsRate refunds New partnersNew partners Cost offsetsCost offsets b Programs with limited scope EITC outreachEITC outreach Non-energy outreach (circuit breakers)Non-energy outreach (circuit breakers) Cash deposit alternativesCash deposit alternatives

4. We only have crisis funding b New partnerships for funding b Partnership with NFFN b Rationalize your payment plan processes b Maximize revenue potential Utility customer contributionsUtility customer contributions External fundraisingExternal fundraising

5. Our primary heating is non-utility b State UDAP regulations for fuel oil and propane b Use of PUC regulations for non-regulated utilities b Fuel buying co-ops work

6. We have no data on payment problems b Use LIHEAP’s vendor contract process to require periodic reporting b Initiate state PUC rulemaking requiring reporting b Intervene in a regulatory proceeding with settlement potential

7. Our PUC says USF is “discriminatory” b Become conversant with special contracts b Look for “reverse subsidies” b Look for “public good” arguments

8. For more information, contact: roger@fsconline.com