Air conditioning systems are now prevalent in most residential structures. It is safe to say that the vast majority of compressors are driven by electric motors, and in the unusual cases where natural gas is used in the cooling process, the systems still require electricity to operate the fans that distribute air in the conditioned space within the dwelling. Providers of electric utility services are sensitive to the fact that our customers have become accustomed to the use of air conditioning systems during hot weather. Additionally, it is important to note that home and apartment construction design has changed to anticipate the availability and use of air conditioning equipment and do not necessarily facilitate an acceptable environment during hot weather absent cooling equipment.

Electric utilities are subject to regulation by State and Federal agencies, with consumer rulemaking generally residing at the State or local level. In many jurisdictions, rules are in place that mandate suspension of collection activity (primarily focused on interruptions of service due to non-payment of bills) under certain weather conditions. In cases where no such rules exist, most utilities have self imposed guidelines as a means to minimize exposure to litigation and liability claims resulting from the effect on health when service is interrupted during hot weather events. More importantly, these self-imposed guidelines are in place because the utilities have a sincere desire to avoid contributing to a further decline in health for our at risk customers. It is also important to note that no utility can know with certainty who all of their at risk customers are.

Understanding the relationship between hot weather events and the effects on individual health is not within the core competencies of most electric utilities or utility regulatory bodies. It is critically important that we rely on a qualified and independent third party to assess the situation and provide information on the weather to support our decision making processes. Heat/health warning systems that are based on research into the correlation between specific weather systems and the impact on health in specific geographic areas are key to supporting our operations for these reasons:

a) While the objective is to take steps to ensure that health is not affected, traditional thresholds based merely on heat index do not consider the effect of individuals being less conditioned to higher temperatures at the start of the summer season.

b) Significant resources are affected when collection activity is suspended. Decision thresholds based on heat index alone are arbitrary and may at times overstate the potential threat to health. Suspending collection activity extends an unintended benefit to a large number of delinquent accounts that are not at risk even when conditions are severe.