Statewide Monthly Low-Income Energy Assistance Program Design (Report to the Legislature, November 12, 2024)
Summary
Statewide Monthly Low-Income Energy Assistance Program Design, a Report to the Legislature dated November 12, 2024 from the Energy Policy Office, submitted pursuant to Chapter 475, Laws 2023. The executive summary states that more than 270,000 low-income households in Washington (about 25% of low-income households) spend more than 6% of their annual household incomes on home energy bills, and that the average amount they spend above 6% is $1,016 annually. It states that these expenditures annually exceed $275 million statewide. It describes a recommended program design that would deliver monthly bill discounts for home energy costs above 6% of household income, with enrollment online, over the phone, or in person at community organizations.
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“Statewide Monthly Low-Income Energy Assistance Program Design (Report to the Legislature, November 12, 2024).”
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Statewide Monthly Low-
Income Energy Assistance
Program Design
Submitted pursuant to Sect. 132(11) of Chapter 475, Laws 2023
November 12, 2024
Report to the Legislature
ENERGY POLICY OFFICE Director Mike Fong
Acknowledgments Dave Pringle
Legislative Director
Washington State Department of Commerce
This report would not have been possible without Marie Davis
the generous time, insight, and candor provided by Senior Policy Advisor
community members and Washington utilities who
participated in community meetings and follow-up Rebecca Ponzio
conversations to challenge and support the Senior Policy Advisor
Washington State Department of Commerce to
Julia Havens
design of a statewide monthly low-income energy
Community Engagement Manager
assistance program that provides efficient, quality
and equitable bill assistance to low-income
Amelia Fujikawa
households.
Research and Data Analyst
Thank you to the following third party contractors
Alice Zillah
who contributed mightily to the report:
Research and Development Services Managing
The National Consumer Law Center Director
Greater Good Studio
Artesia Systems James Vogl
Research Analyst
Commerce expresses thanks to its sister agencies
that contributed to the report: Amelia V. Lamb
Publications Manager and Editor
The Washington State Department of Social
and Human Services Scott Varga
Department of Children Youth and Families Visual Communications Manager
Washington Office of Superintendent of Public
Instruction Washington State Department of Commerce
Washington State Employment Security Michael Furze
Department Michael.Furze@commerce.wa.gov
Washington State Department of Labor and 360-529-9587
Industries
1011 Plum St. SE
Washington State Caseload Forecast Council
P.O. Box 42525
Washington State Office of Attorney General
Olympia, WA 98504-2525
The Washington Utilities and Transportation
Commission
www.commerce.wa.gov
Michael Furze
Assistant Director, Energy Division For people with disabilities, this report is available on
request in other formats. To submit a request, please
call 360-725-4000 (TTY 360-586-0772)
Glenn Blackmon
Director, Energy Policy Office
Austin Scharff
Senior Energy Policy Specialist
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 2
Table of contents
Highlights of recommended program design elements ................................................................................. 5
Key benefits of the recommended program design ....................................................................................... 6
Context........................................................................................................................................................ 7
Executive summary...................................................................................................................................... 8
Introduction ............................................................................................................................................... 12
Recommended program design.................................................................................................................. 17
Recommended program design process .................................................................................................... 32
Energy burden and assistance need in Washington..................................................................................... 51
The impacts of energy burden on households ............................................................................................ 57
Disproportionately impacted households.................................................................................................... 69
Gaps in energy affordability protections for low-income households .......................................................... 76
Washington’s patchwork of utility bill assistance programs ........................................................................ 82
Alternatives under a utility-by-utility approach ........................................................................................... 92
Conclusion ................................................................................................................................................ 98
Appendix A: Definitions.............................................................................................................................. 99
Appendix B: the Low-Income Energy Affordability Data (LEAD) Tool ......................................................... 100
Appendix C: The Residential Energy Consumption Survey ........................................................................ 102
Appendix D: RCW 19.405.120 (2019) ....................................................................................................... 103
Appendix E: RCW 19.405.120 (Sec. 120) Analysis .................................................................................... 105
Appendix F: Centering lived experiences .................................................................................................. 116
Appendix G: Household surveys ............................................................................................................... 118
Appendix H: Community Organization Listening Sessions Summary ......................................................... 126
Appendix I: Program design principles and the recommended program design summary .......................... 140
Appendix J: Survey of utility programs and webpages .............................................................................. 142
Appendix K: Bill discount mechanisms ..................................................................................................... 162
Appendix L: Data sharing to streamline enrollment ................................................................................... 164
Appendix M: Funding options ................................................................................................................... 167
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 3
Appendix N: Caseload Forecast Council ................................................................................................... 170
Appendix O: Benefit cliffs ........................................................................................................................ 171
Appendix P: Best practices in social service program design .................................................................... 175
Appendix Q: Categorical eligibility for a statewide low-income energy assistance program ....................... 182
Appendix R: Department of Commerce outreach and community engagement .......................................... 185
Appendix S: DSHS outreach and community engagement ......................................................................... 188
Appendix T: Opportunities for partnership and lessons learned from Department of Children, Youth, and
Families Outreach .................................................................................................................................... 191
Appendix U: Office of Superintendent of Public Instruction outreach and community engagement ............ 192
Appendix V: Employment Security Division outreach and community engagement case study................... 194
Appendix W: Acknowledgements ............................................................................................................. 196
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 4
Highlights of recommended program design elements
Establishes universal
access to monthly low-
income energy bill
assistance targeted to meet
each household's energy
assistance need.
Maintains income criteria under existing law and administrative rule, which defines "low income" as the
greater of 80% of area median income or 200% of the federal poverty level, adjusted for household size.
Allows for streamlined income eligibility determination, including verification of a household’s participation
in other state means-tested programs for which eligibility does not exceed the low-income definition for the
statewide monthly low-income energy bill assistance program.
Offers a monthly income-tiered bill discount where benefit amounts are targeted to address energy
assistance need.
Provides a graduated benefit level that decreases as household income rises. No sudden drop in benefit or
arbitrary income threshold.
Builds on existing relationships and forges new ones with households and community-based organizations
through consistent, co-created communications and community outreach plans that respect the unique
needs of households and communities.
Incorporates the desires of low-income households and national best practices in social service and
human-centered design within system constraints.
Supports education about the benefits of conservation and helps connect households to other social
services and energy programs.
Embeds ongoing program evaluations that include metrics to track equitable access, effective delivery, and
compassionate integrity of the program.
Includes a statewide advisory group to help oversee program implementation and evaluation.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 5
Key benefits of the recommended program design
Universal access to
low-income monthly
energy bill assistance
with uniform benefits
for similarly situated
households
Highly visible program available to all low-income households statewide.
Benefit levels targeted to meet household need and providing gradual reduction in benefits as household
income rises.
Consistent communication about program eligibility, enrollment, and benefits to facilitate sharing about the
program by word of mouth and direct referrals.
Streamlined, user-friendly applications and enrollment processes.
Households enrolled in another state low-income program need not submit additional income
documentation.
No wrong door for accessing assistance — households can enroll online, over the phone, or in person at
any community organization offering assistance to low-income households.
Ability to self-check enrollment status, track progress over time, and chat with a customer service
representative.
Program participation does not affect eligibility for other social service programs, because it does not
affect household income.
Leverages existing communications with low-income households and service providers to raise program
awareness.
Increased awareness about other low-income energy programs and the benefits of conservation through
program messaging.
Reduces the inefficiencies of administering more than 50 separate monthly bill assistance programs
across Washington's electric utilities.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 6
Context
Low-income
households in
Washington face
significant energy
assistance need.
More than 270,000 low-income households in Washington (25% of all low-income households) are energy
burdened—that is, they spend more than 6% of their household incomes on residential energy bills.
On average, these households spend $1,016 per year in excess of the 6% energy burden threshold. This
figure reflects the comparatively low electric rates of many Washington utilities.
The total statewide energy burden of low-income households is $275 million after taking the comparatively
low electric rates of many Washington utilities into account.
Nearly a fifth (about 17%) of low-income households in urban counties are energy burdened, and nearly two
fifths (38%) of low-income households are energy burdened in rural counties.
Energy assistance need is not a “standalone” issue, but rather impacts other major societal challenges
such as housing stability, financial stability, food insecurity, physical and mental health, and broader public
problems.
Rising outdoor temperatures and subsequent interior cooling demands will exacerbate household energy
burdens.
Washington’s 50+ electric utilities are responsible, under Washington law (RCW 19.405.120), for
implementing programs to address the energy assistance need of the low-income households.
Participation rates in utility assistance programs vary widely, but in all cases are low compared to
statewide programs with comparable eligibility requirements, such as the Supplemental Nutrition
Assistance Program.
The patchwork of benefit levels and eligibility standards across 50+ utility programs places an undue
burden on households and community organizations seeking information about assistance, as well as
community organizations trying to serve households.
A low-income household must navigate fragmented and vastly different enrollment processes depending
on their electric utility, and may not have access to monthly energy bill assistance.
Low-income households in one utility service area may receive significantly different benefits than a
similarly situated household in another utility service area.
Rural electric utilities with a disproportionate share of low-income households face significant challenges
meeting energy assistance need within the rates paid by other customers, some of whom are themselves
low-income households
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 7
Executive summary
Overview
More than 270,000 low-income households in Washington (about 25% of low-income households) spend more
than 6% of their annual household incomes on home energy bills. The average amount they spend above 6% of
their household incomes on home energy bills is $1,016 annually. These expenditures annually exceed $275
million statewide. These costs include residential electricity, natural gas, propane, and other home heating and
fuel costs, and they reflect the comparatively low electric rates charged by many Washington utilities. They do
not include transportation-related costs.
This is a significant energy and housing problem. Households that spend over 6% of their incomes on
residential energy bills are more likely to leave the temperature of their homes at unhealthy and unsafe levels,
forgo other basic necessities, like essential food and medicine, and are more likely to lose their housing and
remain in cycles of poverty.
Energy assistance programs reduce the likelihood of these harms, but Washington’s current energy assistance
system is a patchwork of utility energy assistance programs with many holes where crucial programs and
funding remain absent. These programs serve only a small percentage (roughly 25%) of low-income
households compared to individual statewide programs, such as the Supplemental Nutrition Assistance
Program (SNAP), that have similar eligibility requirements. 1 These programs are described below in
Washington's patchwork of low-income energy assistance programs.
Layered over this patchwork of utility programs is a federal block grant program, the Low-Income Home Energy
Assistance Program (LIHEAP), and a few relatively small state programs that offer limited assistance to low-
income households and often prove inaccessible to households due to limited funding, and restrictive eligibility
and program design requirements mandated by the federal government.
The Legislature, in a 2023 budget proviso (Sect. 132(11) of Chapter 475, Laws 2023), directed Commerce to
recommend a design for a statewide low-income energy assistance program to provide universal access to
home energy assistance and meet energy assistance need. The Legislature asked Commerce for this
recommendation because of the high level of energy assistance need, low participation rates in utility
programs compared to statewide programs with similar eligibility criteria, and fragmentation of programs and
communications across Washington's electric utilities, which have varying levels of resources.
The report and recommended program design are rooted in the perspective of serving low-income residents of
Washington and so are “people first.” The recommended program design is based on input received over the
past year from hundreds of individuals from community providers, utilities, state agencies, environmental
justice advocates, and households across Washington. It is informed by national best practices and the
expertise and lived experiences of low-income households and community organizations, and input of
statewide low-income advocates, utilities, and sister state agencies
1 2023 Energy Assistance Report
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 8
The recommended program design would…
Provide universal access to monthly low-income home energy assistance to meet energy assistance
need regardless of their utility or home fuel source
Have one name and brand to be universally recognizable to low-income households and community
organizations
Strengthen existing relationships and forge new ones with community partners who serve low-income
households
Allow households to enroll in person at community organizations that serve low-income households,
over the phone, or online
Reduce the inefficiencies of administering 50+ separate monthly bill assistance programs across
Washington's electric utilities
Rationalize and simplify the accumulated layers of policy and process, and bring in new technology and
user-friendly, human-centered design to provide increased awareness and accessibility to monthly bill
assistance for households
Recommended program design
Under the recommended program design, every low-income household would have access to a highly visible
monthly energy bill assistance program that would deliver monthly bill discounts to address excess home
energy costs, which are home energy costs above 6% of household income. Household size and cost of living
differences across Washington would be factored into determining the income eligibility of the household.
Households enrolled in other state low-income programs would not need to submit additional income
documentation.
Households would be able to enroll in minutes online, over the phone, or in-person at any community
organization offering assistance. The program would offer streamlined, user-friendly applications and
enrollment processes, and may provide households to self-certify their household income, while maintaining
program integrity. Services would be provided in multiple languages.
Households would receive consistent communications about program services through networks of
community-based organizations across the state and the state administrator. The recommended program
design would enable the state to reach out directly to households already enrolled in statewide low-income
programs to enroll them in the statewide program.
Households not enrolled in statewide programs would be connected to services through the state
administrator building on existing and forging new relationships with households and community-based
organizations through consistent, co-created communications and community outreach plans that respect the
unique needs of households and communities. Program communications would raise awareness about other
low-income social service and energy programs, and the benefits of conservation.
At the center of the recommended program design is the belief that households deserve efficient, quality, and
equitable energy bill assistance programs. Continuous program evaluation would be an integral part of a
statewide low-income monthly energy bill assistance program to ensure it is meeting the needs of low-income
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 9
households in a timely and equitable manner. The program would have a formal advisory group of a diverse
set of households, community organizations, utilities, and national experts to provide input on key decisions
standing up a program and overseeing program performance and recommendations. Regular check-ins would
occur with community organizations in different regions of the state to share best practices and provide
feedback on the program.
Most low-income households are not enrolled in utility energy bill assistance programs, despite significant
energy assistance need. A statewide approach would relieve electric utilities responsibility under current law to
address the total home energy burden of low-income households, and avoid the inefficiencies of administering
more than 50 unique monthly bill assistance programs across Washington's 50+ electric utilities to meet
energy assistance need, replacing a patchwork of utility bill assistance programs and fragmented
communication process with a universal monthly energy bill assistance program responsive to the unique
needs of low-income households.
Commerce evaluated other approaches that either layer additional policy requirements on utilities or push
more funding through existing programs. Commerce found considerable drawbacks to each of these
approaches that would undermine the ability of households to access monthly bill assistance programs. The
benefits and drawbacks of the alternative approaches is summarized in Table P: Policy layering and
supplementary funding approaches.
Conclusion
Low-income households are essential workers, single mothers, seniors, disabled persons, immigrants, tribal
members, and other members of our shared Washington community. Home energy costs have a
disproportionate impact on the household budgets of low-income households. Low-income households are
disproportionately energy burden and disproportionately suffer from energy insecurities, such as forgoing
essential necessities, such as food and medicine, to pay their home energy bills or keeping their home
temperatures at unhealthy levels. Climate change, rising temperatures, and subsequent cooling demands will
exacerbate household energy burdens and prove deadly for some.
Washington's current laws and utility programs are not equipped to address energy assistance need
systemically or equitably. Washington's current laws are discussed in the report section Gaps in energy
affordability protections for low-income households.
The Legislature first encouraged electric utilities to offer bill discounts nearly 50 years ago. 2 In 2019, the
Legislature enacted Sec. 120 to address the full home energy burden of low-income households. The law puts
the obligation of addressing energy assistance need directly on electric utilities. Two years later, the
Legislature required Washington's three investor-owned electric utilities to redesign their assistance programs.
Those redesigned bill assistance programs were launched in the latter half of 2023 with additional investor-
owned utility programs being launched in October 2024. 3
2 RCW 74.38.070: Reduced utility rates for low-income senior citizens and other low-income citizens. (wa.gov)
3 In 2023, the IOUs implemented Bill Discount Rate (BDR) programs that provide assistance to low-income customers on a tiered basis.
The means customers with lower incomes receive a higher percentage of assistance to help offset their energy burden. In 2024, the
IOUs plan to implement Arrearage Management Plans (AMP) that forgive an income qualified customer's arrearage if their account
remains in good standing and they pay off a percentage of the arrearage amount. In some instances, an IOU customer could see up to
90% of their arrearage amounts forgiven.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 10
Despite many of their long histories, utility bill assistance program participation rates continue to
underperform compared to statewide programs with similar eligibility criteria, leaving many low-income
households in significant energy assistance need in every community across the state. Some utility programs
have seen recent increases in their program participation due to their programmatic reforms, but there remains
a significant gap between their program participation rates and participation rates of individual statewide
programs with similar eligibility criteria, such as the Supplemental Nutrition Assistance Program (SNAP).
Approximately four times as many households participate in SNAP as participate in electric utility bill
assistance programs statewide.4
The program challenges are more profound for rural utilities, which often have fewer resources. The share of
low-income customers is often greater for these small utilities, which makes it harder to fund energy
assistance costs from the rates paid by their other customers. Fully addressing the low-income energy burden
through utility rates for these rural utilities could result in other households becoming energy burdened
themselves.
Commerce heard from low-income households and community organizations across the state that the
fragmentation of programs, broken communication processes, and lack of a highly visible programs produce a
significant challenge for low-income households in accessing needed assistance. The recommended program
design intentionally simplifies and rationalizes access to monthly low-income energy assistance, and
addresses program access challenges raised by households, community organizations, statewide advocates,
and utilities.
There is no simple answer to addressing the excessive energy burden of low-income households, which is why
the recommended program design takes a holistic, multifaceted approach to delivering efficient, quality, and
equitable monthly energy bill assistance to low-income households regardless of the utility or utilities that
happen to serve them.
4 2023 Low-Income Energy Assistance Legislative Report
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 11
Introduction
Background
Department of Commerce's Low-Income Energy Assistance 2023 Legislative Report found low-income
households across Washington have significant energy assistance need, and far too often do not have access
to programs and funding crucial to maintaining affordable home energy bills. RCW 19.405.120 (Sec. 120)
intends to address the total home energy burden of low-income households and puts the obligation to address
that burden directly on electric utilities.
Commerce's 2023 report found utility programs serve only a small percentage (roughly 25%) of low-income
households (116,911 households) in 2020 compared to individual statewide programs with similar eligibility
standards, such as the Supplemental Nutrition Assistance program (666,269 households).
Per RCW 19.405.120(6), Commerce in 2023 evaluated additional mechanisms to assist low-income
households, including mechanisms within the existing utility-by-utility approach to monthly energy bill
assistance and mechanisms under an statewide and hybrid approaches. Commerce found a number of
potential benefits to the state administering monthly low-income energy bill assistance, including universal
access to monthly bill assistance for low-income households, uniform benefit levels for similarly situated
households, and reduced administrative costs compared to administering 50+ utility programs.
The Legislature required Commerce in the Sect. 132(11) of Chapter 475, Laws 2023 (the 2023-2025 Operating
Budget) to recommend a design for a statewide energy assistance program to provide universal access to low-
income households and address excessive energy burden of low-income households.
Legislative mandate
Sect. 132(11) of Chapter 475, Laws of 2023, mandates the following:
A) $300,000 of the climate commitment account—state appropriation is provided solely for the department to
develop recommendations on a design for a statewide energy assistance program to address the energy
burden and provide access to energy assistance for low-income households. The department may contract
with a third-party entity to complete the work required in this subsection.
B) The recommendations must include considerations for data collection on the energy burden and
assistance need of households, universal intake coordination and data sharing across statewide programs
serving low-income households, program eligibility, enrollment, multilingual services, outreach and
community engagement, program administration, funding, and reporting.
C) By January 1, 2024, the department must submit a report with the recommendations to the appropriate
committees of the Legislature.
The Legislature required Commerce recommend a design of a statewide program. Commerce is not required
to recommend the Legislature establish a statewide program, and the agency makes no recommendations for
legislative action in this report. Furthermore, Commerce is not required to recommend a funding source, and
Commerce makes no recommendation on how the Legislature would fund a statewide monthly low-income
energy assistance program. Commerce did evaluate the tradeoffs of different funding sources, including the
Climate Commitment Account, state general fund, and a system benefits charge. The evaluation is included in
Appendix M: Funding options.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 12
How we are providing the required information
Programs to assist low-income households have a long history of being developed with little input from those
most affected—potential program participants. The result often has been flawed programs that do not achieve
their intent. Commerce intentionally made it a priority to elevate the expertise and lived experiences of low-
income households, and put their input front-and-centered in this report. After all, low-income energy
assistance programs are first and foremost meant to address the energy assistance needs of low-income
households.
Listening sessions with low-income households
Commerce worked closely with community-based organizations to host three listening sessions with low-
income households and hired the Greater Good Studio, to design and conduct three group listening sessions
with low-income households. The sessions took place in Seattle, Auburn, and Tacoma. Commerce conducted
337 surveys to provide additional insights from across the state that align with the findings of the listening
sessions. Commerce will also be conducting listening sessions in other parts of the state through 2024.
The listening sessions explore experiences managing household needs and expenses, and navigating different
types of assistance programs. Their stories provide important knowledge and wisdom to help us understand
their priorities and key insights.
Commerce and the Greater Good Studio heard many impactful stories, including those from experts, Mr.
Cornethan, Bryan, and Jah’Kharri. They provide important knowledge and wisdom and help us better
understand the lived experiences and expertise of low-income households, and ground this report in the lived
experiences of low-income households.
Household Story: Mr. Cornethan
Mr. Cornethan previously worked in energy, where "I was in a neighborhood where
he expressed his experience with companies doing all the service was cut off… No
the “bare minimum” to qualify people and connect lights, no electricity. What does
them to assistance programs. a person do when it's dark?”
He emphasized the harm caused by cutting power, — Mr. Cornethan
and how it increases challenges households and
communities face.
Household Story: Bryan "We are fighting these fights
Bryan shared how hard-working people are doing all
everyday… we don’t want to be
they can but sometimes it’s not enough. Describing on assistance for the rest of
hardship to maintain eligibility, just to receive our lives but it does help.”
sudden reductions in benefits.
— Bryan
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 13
He hopes listening to people’s experiences continues
as a “new art,” because they have a lot of important
insights to share.
Household Story: Jah’Kharri
Jah’Kharri spoke of the divide that exists between
"People who've been up there
people of different incomes. Often programs rely on
people who have little direct lived experience to
so long [in high tax brackets],
make decisions for others more directly impacted. they don't know what it feels
like to be down here.”
They advocate for more transparency and
— Jah’Kharri
accountability from programs to deliver what they
promise.
Key insights and lived expertise of households are discussed in further detail below in Recommended program
design process section of the report and Appendix G: Household surveys.
Low-income household surveys
Commerce partnered with community-based organizations across the state to conduct surveys of low-income
household preferences for monthly low-income energy bill assistance.
Survey locations included:
Yakima
Vancouver
Spokane Valley
Seattle
Republic
Kent
Everett
Bellevue
The survey was made available in nine languages to better reach a diverse sample of respondents.
337 individuals completed surveys. The surveys provide insights into household preferences for accessing
monthly low-income energy bill assistance and supplement the findings from Commerce's listening sessions
with the voices of low-income households outside King and Pierce County.
The findings of the household surveys are covered in Appendix G: Household surveys.
In-person listening sessions with community organizations
Commerce conducted seven listening sessions in community spaces across Washington and one virtual
listening session with community organizations. Each listening session was two hours long. In total, 128
people from over 95 distinct organizations participated.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 14
Roughly 50% of the meeting participants reported over 10 years of experience serving low-income
households, and roughly 25% reported over 20 years of experience serving low-income households. The in-
person listening sessions occurred in seven cities:
Colville
Kennewick
Port Angeles
Seattle
Spokane
Stevenson
Tacoma
Each listening session had participants from nearby communities. For example, participants in the Spokane
listening session included local service providers from Clarkston (107 miles away), and the listening session in
Kennewick had participants from Granger (56 miles away). This inter-regional diversity provided insights
beyond the locations of each listening session. Local service providers from every region of Washington
participated in Commerce's virtual listening session.
Many different types of local service providers participated in the workshops, including:
Multi-cultural service providers
General social service providers
Youth and family support organizations
Community Action Agencies
Housing authorities
Food banks
Faith-based organizations
Tribal service providers
The workshops with community organizations are discussed in detail in Appendix H: Community Organization
Listening Sessions Summary.
Public workshops and comment periods
Commerce held nine public workshops, which were primarily attended by utilities and statewide advocacy
organizations. A public comment period followed all but the first kickoff meeting.
The first five workshops focused on co-designing principles to guide the program design. The last four
workshops focused on draft report materials, including draft outlines and reports for public comment.
Consultations with other state agencies
Commerce assembled a team of programmatic staff within Commerce and across state agencies to inform
the program design. The agencies involved include:
Department of Children Youth and Family (DCYF)
Department of Health and Social Services (DSHS)
Department of Labor & Industries
Employment Security Department
Office of the Attorney General, Public Counsel
Office of the Superintendent of Public Instruction, Migrant Education Program
Utilities and Transportation Commission
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 15
Commerce held state agency meetings on each element of the program design and worked with staff at each
agency to better understand the opportunities and limitations for how a statewide monthly low-income energy
assistance program would fit into the fabric of existing statewide low-income programs.
Consultations with national experts and research into national best
practices
Commerce worked extensively with Greater Good Studio to conduct listening sessions with low-income
households, and the National Consumer Law Center conducted additional research into energy insecurity in
Washington and the impacts of energy burden on households more broadly. The agency consulted U.S. Digital
Response about the ability to leverage data from the Supplemental Nutrition Assistance Program to enroll
households in bill assistance, and hired Artesia Systems to conduct additional research into streamlining
enrollment into a statewide program, while ensuring household data security and privacy. In addition,
Commerce conducted extensive research into national best practices in social service design, including work
from Code for America and Urban Institute.
Conclusion
This report is based on the input received over the past year from hundreds of individuals from community
providers, utilities, state agencies, environmental justice advocates, and households. National best practices,
staff at fellow state agencies, and national experts in human-centered design, customer software solutions,
and low-income energy bill assistance programs helped identify programmatic opportunities, constraints, and
ways to avoid common program design pitfalls. Each of these learnings informs the recommended program
design.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 16
Recommended program design
Background
The recommended program design is designed to provide efficient, equitable, and quality monthly low-income
bill assistance programs to low-income households statewide. It begins with the recognition that people
should not have to think or work hard to identify and access assistance, and that Washington's residents are
diverse people that deserve a system that supports equal access to resources.
Highlights
• The program would have a single name and brand to be universally recognizable to low-income
households and community organizations
• The program would provide universal access to monthly low-income energy bill assistance to meet
energy assistance need, which is defined as home energy expenses above 6% of household income
• The program requires only what is necessary to determine income eligibility and deliver benefits to
households
• The program would build on existing and forge new relationships with households and community-
based organizations through consistent, co-created communications and community outreach plans
and enrollment campaigns that respect the unique needs of households and communities
• Program materials would help connect households to other social services and energy programs, and
promote conservation
• The program rationalizes and simplifies accumulated layers of policy and process, and brings in new
technology and human-centered design to provide increased accessibility to monthly energy bill
assistance for all low-income households irrespective of the utility that happens to provide energy
services to a household or the household's heating source.
• The program places minimal administrative requirements on Washington’s 50+ energy utilities
Eligibility requirements
Income eligibility criteria
A statewide monthly low-income energy bill assistance program would maintain the current definition of low-
income under statute (RCW 19.405.020) and administrative rule (WAC 190-40-030), which defines low-income
as incomes that do not exceed the higher of 80% of area median income (AMI) or 200% of the federal poverty
level (FPL), adjusted for household size. AMI accounts for cost of living differences across the state.
Non-income eligibility requirements
A statewide monthly low-income energy bill assistance program would only require what is necessary to certify
the household is low-income and deliver assistance to them. These things include:
• Household size
• Household income
• Utility name
• Customer account number
• Service address
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 17
Categorical eligibility
Households participating in other low-income assistance programs with comparable income eligibility
requirements would be able to enroll in a statewide monthly low-income energy bill assistance program
without additional documentation.
The process of determining whether a household can enroll in a program based on their enrollment in another
program is referred to as "categorical eligibility."
Categorical eligibility can relieve documentation-related burdens for households and program administrators.
Administrative staff do not have to spend time reviewing income documents and households do not have to
spend time collecting and submitting them, which reduces application wait and processing times.
Categorical eligibility for a statewide monthly low-income energy bill assistance program could include but
not be limited to recipients of:
• The Supplemental Nutrition Assistance Program (SNAP)
• Temporary Assistance for Needy Families
• Low-Income Home Energy Assistance Program
• Aged, Blind, or Disabled Cash Assistance Program
Income verification
A statewide low-income energy assistance program would streamline income verification, while maintaining
program integrity, through categorical eligibility and self-certification.
Verifying incomes for categorically eligible households
One way a statewide low-income energy assistance program could streamline income verification is through
categorical eligibility.
Households enrolled in existing statewide low-income programs noted above could opt to provide their Social
Security Number or DSHS Client ID number for verification purposes. With appropriate data sharing
agreements in place, and as allowable by federal and state laws, the state administrator could query household
provided information and verify the household is low-income.
Self-certification
The Legislature expressly provided investor-owned utilities the option to use categorical eligibility or self-
attestation with limited documentation, also known as self-certification. The Legislature should provide a
statewide low-income energy assistance program the same option.
Improving program integrity through categorical eligibility and self-certification
The integrity of self-certification could be enhanced by removing households who have already verified their
incomes with the state to be removed from the state verification pool. Their incomes have already been
verified by the state, and it would be a waste of resources to verify known low-income households, rather than
focus on households that have not verified their incomes with the state.
Monthly bill discount mechanism
The recommended monthly bill discount mechanism would be tiered based on income, and the discount
amount is tied to an approximate amount of assistance needed to meet energy assistance need for
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 18
households in each income tier. Program participants with less income would individually receive a greater
level of assistance than individual households with more income.
A majority of utilities and statewide low-income advocacy organizations supported a tiered percentage
approach, because it was the most equitable option that is administratively straightforward. Community
organizations and low-income households also overwhelmingly favored a tiered bill discount. 5,6
A tiered discount design entails establishing a target burden level and calculating the percentage discount
required for a household at the income tier midpoint to achieve the target burden level. Average usage levels
are assumed in the tiered discount approach. Ideally, tier-specific benefit levels should be adjusted annually to
ensure that the value of the percentage discounts does not deteriorate as utility rates increase.
A program administrator would need to determine benefit tiers and amounts during program implementation
based on a sampling of utility and household data statewide. Avista and Puget Sound Energy provide
examples of how to establish income tiers and discount levels.
Ensuring no significant decrease in assistance for households
receiving benefits today
Under a statewide program, households already enrolled in a bill assistance program should not receive less of
a benefit than they currently do.
A statewide program administrator could ensure that households receives no less than the most generous
benefit offered to households in each income tier today, or continue to provide households the discount they
were receiving previously.
Addressing benefits cliffs
It is important for a statewide low-income energy assistance program to avoid households experiencing a
sudden loss of benefits when they experience increases in earnings (a benefits cliff), which may leave them
worse off than they would be with a more gradual transition off social services. 7
A tiered bill discount helps address benefit cliffs by decreasing bill assistance levels gradually as household
incomes rise. Furthermore, income eligibility criteria set at the greater of 80% AMI or 200% FPL, adjusted for
household size, is in most cases higher than federal assistance programs, which means households would not
lose access to crucial energy bill assistance at the same time they lose access to other social services. If
these measures prove insufficient, a program could take additional steps to ensure that households don’t
suddenly lose benefits they had been counting on to help stabilize their household finances.
Addressing Utility Payments to Landlords
One challenge bill assistance programs often face is providing a monthly discount to renters that do not have
accounts with their utility, but rather pay their utility bills through their landlords. One way to address this gap
would be for a statewide program to provide a monthly upfront rebate to the household. The upfront rebate
5 See Appendix G: Household surveys
6 See Appendix H: Community organization listening sessions
7 See Appendix O: Benefit cliffs
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 19
could be sized based on household income to target energy assistance need. Additional documentation may
be needed to establish the household is paying their utility bills through their landlord.
Application requirements
The application of a statewide monthly low-income energy assistance program would only require what is
necessary to enroll households in a program.
Application requirements might include:
• Household size
• Household income
• Utility name
• Customer account number
• Service address
Optional enrollment information
There is likely information to streamline enrollment through crosschecking their information in a state system;
however, this information is unnecessary to enroll households in the program. The application would make
clear that providing this type of information may be beneficial, but is not required to enroll.
Examples of information that would improve a household's experience with the program include:
• Phone number (optional)
• Email address (optional)
• Social Security Number (optional)
• DSHS Client ID number (optional)
Phone numbers and emails will allow the state to contact households directly via phone or email. Some
households may have neither, and the program does not required they have either. Social security numbers
and DSHS Client ID numbers will allow the state to verify household incomes if the household is enrolled in
another state program with similar income eligibility requirements. Benefits of providing this information to the
administrator will be clearly communicated in line with best practices in social service program delivery.
Another set of optional prompts would include information to improve program performance. Example
prompts in this bucket include:
• Language (optional)
• Ethnicity (optional)
• Race (optional)
• Education (optional)
• Disability status (optional)
• Senior (60+) (optional)
Application design
A statewide monthly low-income energy assistance program would adhere to user-friendly, human-centered
design principles, such as those recommended by Code for America, a civic tech non-profit organization that
partners with governments to help deliver software services, particularly for low-income and marginalized
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 20
communities. The following user experience design recommendations were informed by Code for America
based off of best practices for other, similar programs.
Human-centered application design 8 recommendations include:
• Use an application flow that sets expectations for the process and highlights support by phone, while
preserving language toggle translation options
• Use familiar words, be concise, and use headlines to make it clear what each page or section is about
• Group similar questions together
• Adjust the questions you ask based on the answers you’ve already received (gating questions)
• Remove unnecessary questions and pages
• Minimize typing and maximize use of tapping functions
• Limit switching between tapping and typing as much as possible
• Include a progress bar that tracks where an applicant is in the application
• Use large tap targets, wide buttons, and large dropdown inputs to make it easy to share information
• Keep a conversational tone that feels warm and inviting, rather than opaque or judgmental
The application and any supporting materials will be translated into the most spoken language by Washington
residents with limited English proficiency. These languages include, but not be limited to:
• Spanish
• Russian
• Chinese
• Vietnamese
• Ukrainian
A statewide program would begin with these recommendations and then co-design an application with the
people most likely to use it — the low-income households and community organizations that help households
enroll in programs.
Enrollment
Low-income households and service organizations emphasized the importance of having multiple enrollment
options to ensure a program is accessible. While an online application may be increase access for many
clients, households with limited or no internet access or who prefer in-person or phone appointments would be
able to receive services in their communities or over the phone.
Online enrollment
A statewide monthly low-income energy assistance program would help households enroll online easily.
A human-centered, mobile-friendly webpage is an important aspect of program accessibility. As noted by Code
for America: 9
“A benefits website should have a welcoming and accessible front door, which includes the homepage,
navigation, and any pages that lead to an application. Intimidating pages with complex navigation and
8 The Benefits Enrollment Field Guide — Code for America
9 The Benefits Enrollment Field Guide — Code for America
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 21
required account registrations can discourage visitors from applying for benefits. This can mean the
difference between securing benefits or becoming another household that falls through the
participation gap.”
A statewide monthly low-income energy assistance webpage would include the following best practices: 10
• A guide bar to identify official state websites
• A clear button to begin applications
• Homepage that provides an explanation of the application process
• The ability to navigate by means other than keyboards
• Content that works with screen readers, including using alternate text on images
• Video captions
• Apps that work on virtually any contemporary web browser
• Clearly identified button toggles to switch between different language translations
• A font size adjuster
• Guidance to find in-person enrollment options, if desired
• The ability for households to use GPS to connect users to the nearest community organization
• Information and contacts for low-income energy efficiency, weatherization, and solar programs
• Crucial information is not buried under tabs or hyperlinks
As with the development of a program application, a statewide program would begin with these
recommendations and co-design webpages with low-income households and community organizations that
help households enroll in programs.
Additional support features available on online portal
As observed by Code for America, "a good program experience isn’t limited to the application. It’s also about
being able to easily find answers to questions, ask an expert about a case with minimal wait time, make and
reschedule interview appointments, see the status of an application, and renew benefits online." 11
The online portal for a statewide program would allow applicants to: 12
• Check their application or renewal status
• Read notices
• Upload documents
• Update their contact information
• View their benefits
• Access live chat in multiple languages
• Access digital client communication
• Find assistance at a nearby community organization
• Upload required forms by taking pictures of them
• Use GPS to connect users to the nearest community organization
• Access information and contacts for low-income energy efficiency, weatherization, and solar programs
10 Ibid
11 Ibid
12 The Benefits Enrollment Field Guide — Code for America
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 22
In-person enrollment
It is important for households to be able to enroll in a statewide monthly low-income energy assistance
program in person at a community organization of their choice.
A highly visible program with uniform eligibility, streamlined application requirements, and an enrollment
process open to all low-income households would allow any service provider the ability to enroll households in
a program.
Partner registration
Low-income service providers would be able to sign-up their organization available to assist households with
getting monthly low-income energy bill assistance, and identify other services, such as language services,
available at the organization.
Lead partners
While a statewide low-income energy assistance program cannot address funding shortages for community
service providers statewide, the Legislature could provide funds for the program administrator to support in-
person enrollment and more tailored outreach and enrollment campaigns. These partners could include
organizations that serve historically marginalized communities and administrators of other energy services,
such as the Low-Income Home Energy Assistance Program and energy efficiency and weatherization
programs.
Phone enrollment
A statewide low-income energy assistance program would provide a call center for households seeking to
enroll over phone. Phone services would be provided in the preferred language of the household either directly
through the state administrator or indirectly through contracted service providers.
Data sharing and auto-enrollment
Commerce has identified data sharing opportunities with other means-tested statewide programs, such as the
Working Families Tax Credit, the Supplemental Nutrition Assistance Program (SNAP), the Special
Supplemental Nutrition Program for Women, Infants, and Children (WIC), the Low Income Home Energy
Assistance Program (LIHEAP), the Low Income Household Water Assistance Program (LIHWAP) and
Weatherization. These programs reach relatively few low-income households to those that would be eligible
under a statewide monthly low-income energy assistance program.
Commerce evaluated opportunities with DSHS to identify whether households enrolled in Supplemental
Nutrition Assistance Program could be auto-enrolled in a statewide program. DSHS found that federal
statutory barriers prevent data sharing needed for auto-enrollment of households participating in SNAP.
However, DSHS is seeking a legal waiver from the federal government to share SNAP data.
Integrated enrollment and eligibility
The Legislature required Commerce to evaluate options for universal intake of household information to
facilitate co-enrollment in a statewide low-income program, at the time of enrollment in other state aid
programs. This potential redundancy led Commerce to evaluate the potential of incorporating a statewide
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 23
monthly low-income energy assistance program in the Integrated Eligibility and Enrollment Modernization
Program. 13
The Integrated Eligibility and Enrollment (IE&E) Modernization Program seeks to transform how people in
Washington access health and human services. This multi-year initiative aims to develop modern, integrated
eligibility that better supports households and program staff. The IE&E program is still being built. Discussions
about whether and how a statewide monthly low-income energy assistance program could be incorporated
into IE&E are premature until a statewide monthly low-income energy assistance program is established by the
Legislature. 14
In any case, a statewide monthly low-income energy assistance program would have its own streamlined
individual application process. The application would be shorter than the IE&E application, because IE&E
requires more information to meet the requirements of other federal and state programs.
Outreach and enrollment campaigns
Outreach and enrollment campaigns under a statewide program would provide consistent, accessible, and
inclusive information. The program would use multiple types of media and communicate information in plain
speak. Communication items would be available in multiple languages.
A statewide program administrator would develop outreach plans that account for the differences in
characteristics and values between communities, and tailor messages to be responsive to them. The plans
would be developed with households and service providers across the state.
Outreach and enrollment campaign materials would be designed using input from local service providers and
households, and would be informed by national best practices in human-centered design. These best practices
include strategies for avoiding and proactively addressing poverty stigmas.
Making it easier for households and community organizations
A singular program with one set of eligibility criteria, an easy enrollment processes, and consistent messaging
would allow community partners to incorporate the program into their existing messaging and outreach and
tailor the program messaging to their communities with consistent facts about a singular program.
Promoting conservation while providing bill assistance
Program materials and communications would raise awareness about the benefits of power conservation, and
include information about energy efficiency and weatherization opportunities.
Referring households to wrap-around services
A statewide monthly low-income energy assistance program would help households connect to other
resources and programs online and in their communities through links to programs and resources on the
webpage and enrollment portal.
13 Integrated Eligibility and Enrollment Modernization Roadmap Report (wahealthplanfinder.org)
14 Integrated Eligibility and Enrollment Modernization Program (IE&E) | Healthier Washington Collaboration Portal (waportal.org)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 24
Existing state community engagement and outreach opportunities
A statewide monthly low-income energy assistance program could capitalize on existing opportunities to reach
low-income households through programs already administered by the state. Below is a summary of those
opportunities.
Washington State Department of Commerce (Commerce)
Commerce’s mission is to strengthen Washington communities. The agency conducts outreach and
community engagement through a statewide outreach and community engagement team, which has staff in
communities across Washington. 15
The agency is one of seven agencies subject to the Healthy Environment for All Act, which requires the agency
adopt an environmentally just community engagement plan and a tribal consultation framework with methods
and tools for measuring outreach and community engagement outcomes. These outreach methods and tools
will inform energy assistance program outreach and enrollment campaigns.
Commerce's Communications team has extensive experience conducting outreach and enrollment campaigns
through billboard and internet advertisement, e-mailing campaigns, and other forms of mass communication,
which could be leveraged to raise awareness about a statewide program open to all low-income households.
In addition to Commerce’s dedicated Communications and Outreach teams, Commerce has several policy
offices and programs dedicated to helping communities and households furthest from equity. These programs
and offices include:
• Outreach for Historically Underserved Communities Grants Program: Funds community organizations
that serve historically disadvantaged populations to conduct outreach and assist community members
in applying for state and federal assistance programs
• Weatherization Plus Health Program: An Energy Division program that contracts with local service
providers in all 39 counties to provide weatherization assistance to eligible households
• Housing Division: A division that works with local housing agencies, non-profit community
organizations and community action agencies on critical housing issues
• Office of Tribal Relations: A standalone unit that coordinates formal government-to-government
consultations between Commerce and tribes within Washington
Washington State Department of Social and Health Services (DSHS)
DSHS is the principal social service agency in Washington. DSHS has social service offices across
Washington, and contacts low-income households through in-person interactions at these offices, as well as
online and over the phone.
DSHS contracts with two organizations to conduct outreach and community engagement for the Supplemental
Nutrition Assistance Program (SNAP): People for People and WithinReach. These contractors coordinate
several different services related to food assistance, including subcontracting with over 38 community
organizations across Washington. These organizations primarily interface with SNAP clients by providing
15 See Appendix R: Department of Commerce outreach and community engagement
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 25
application assistance through Washington Connection, an online portal that helps Washington residents and
businesses connect to services. 16
DSHS and its partner organizations would be able to distribute outreach materials, such as pamphlets, for a
statewide low-income energy assistance program. More involved outreach and enrollment activities would
require a separate contract and funding.
Washington State Department of Children, Youth, and Families (DCYF)
DCYF is the lead agency for state-funded services that support children and families to build resilience and
health, and to improve educational outcomes. It accomplishes its mission by partnering with state and local
agencies, tribes, and other organizations in communities across the state of Washington. 17
DCYF could share information about a statewide monthly low-income energy bill assistance program through
social media and other online channels, raising awareness of the program’s existence, as well as how
households could enroll or get more information.
Office of Superintendent of Public Instruction’s (OSPI) Migrant Education
Program (MEP)
OSPI’s MEP is a federally funded program created in 1965 that provides a variety of supplemental services for
migratory children and their families to ensure migratory children have the same opportunities to achieve
educational success as their peers. These supplemental services include educational programs, supports, and
services, as well assistance in connecting with available health and other social services. 18
Both MEP’s recruitment teams and local educational agency program staff could help spread information
about a statewide low-income energy assistance program. With the appropriate information about eligibility
criteria and the enrollment process, MEP staff could inform migrant students and families about the program
and direct interested households to the program application.
Outreach through community partners
Outreach and enrollment campaigns through community partners
Uniform programming and consistent communications would enhance knowledge about program services at
community service organizations, and permit service providers to easily share information about low-income
monthly energy bill assistance.
Streamlined application and enrollment procedures help service providers enroll households in the program in
a timely fashion, furthering their mission to serve low-income households in their communities, and boosting
their ability to compete for state and federal funding opportunities.
Extensive outreach and enrollment campaigns through community partners would likely require additional
funding.
16 See Appendix S: DSHS outreach and community engagement for the Supplemental Nutrition Assistance Program
17 See Appendix T: Opportunities for partnership and lessons learned from the Department of Children, Youth, and Families outreach
18 See Appendix U: Office of Superintendent of Public Instruction outreach and community engagement
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 26
Outreach through utilities
Utilities could help advertise a statewide energy assistance program, and post general information about the
program provided by the state on the utility’s webpage per guidelines established by the state administrator.
Targeted outreach to most impacted populations
A state administrator could strengthen existing relationships and build new ones with organizations in energy
burdened communities. The state has relationships with local service providers across Washington, and the
Legislature has continued to make investments in improving those relationships through grant programs to
increase connections between state and federal social services, and local communities.
Program evaluations and assessments of energy burden in communities using real-world data would guide a
statewide program’s outreach efforts to target households in greatest need.
There would be clear communications that program participation would not be considered for the purposes of
making public charge determinations, and would not impact the ability for participants to change their
immigration status.19
Language services
A statewide energy assistance program would translate and produce language materials reviewed and
approved by first-language speakers. These materials include outreach materials, such as flyers and social
media advertisements, as well as application materials and enrollment services. Program webpages would be
translated into multiple languages.
The statewide program administrator would provide interpretation, translation, and American Sign Language
services for Washington households upon request through phone, email, video call, or e-mail. In addition,
program webpages would include self-identified community organizations and the language services provided
by those organizations. Commerce would intentionally work with these organizations to familiarize them with
the program and its outreach and enrollment materials.
Program administration
Embedded program evaluations
Continuous program evaluation integral to ensure the statewide low-income energy assistance program is
effective in reaching low-income households.
Table A: Illustrative Evaluation Metrics provides a framework adapted from Code for America that captures
various types of program evaluation data, such as benchmarking and performance measurement.20
A statewide program could leverage data from other statewide programs to identify potential points for
intervention to improve outcomes for households in communities. The state would leverage geo-spatial tools
that utilize multiple energy burden and program data sets to measure the effectiveness of the program, as well
as strategies for generating short- and long-term assessments of the impact of programs on participants.
19 See Appendix U: Office of Superintendent of Public Instruction outreach and community engagement
20 How should we measure safety net delivery? — Code for America
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 27
Regular check-ins with local service providers and surveys and listening sessions with households would
provide additional data and insights. Together, this data would help the administrator make decisions about
the best way to tailor program implementation to improve performance on an ongoing basis.
Table A: Illustrative Evaluation Metrics
Indicator Definition Metrics Examples of measurements
Accessibility means removing
barriers so all people can
easily access services across
languages, racial and ethnic • Average number of minutes
identities, ages, and levels of • Online accessibility to complete an application
ability. It also means a • Mobile accessibility and renewal, via desktop
dignified, respectful, and • Call center accessibility and mobile
Equitable access
welcoming experience that • In-person accessibility • Average wait times by
makes it as easy as possible • Application burden language at local offices
to access benefits. An • Customer satisfaction • Average call wait times and
accessible program has many call abandonment rate
open doors that successfully
and equitably invite in all
eligible people.
• Percent of applicants
denied for reasons beyond
financial eligibility
Safety net programs should
• Average number of days
operate smoothly to serve • Application outcomes from application
everyone eligible. Programs
• Procedural denials submission date to
need to get things right the
• Timeliness determination
first time — like determining
Effective delivery • Notifications • Percent of households who
someone’s eligibility and
• Verifications opted in for e-mail
calculating the correct benefit
• Renewals notifications
amount — so the experience
• Churn • Percent of renewal cases
can be fast, easy, and positive
denied for not recertifying
for clients.
• Percent of new applicants
that received benefits per
month
• Number of program
participants compared with
the total number of
Benefits should be delivered estimated eligible people
correctly according to policy, • Participation rate • Number of program
Integrity and people should benefit to • Accuracy participants compared with
the fullest extent from • Appeals the total number of SNAP
available policy flexibilities. participants
• Accuracy of determinations
• Percent of appeals upheld
• Percent of appeals reversed
Advisory group
Low-income service providers and households said that they often do not have a say in the design and
implementation of programs meant to serve them. A statewide program would have a formal advisory group
comprised of a diverse set of service providers, households, utilities, and statewide low-income advocates,
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 28
including service providers and households from historically marginalized communities. The advisory group
would assist the state administrator by providing input on key decisions launching the program and supporting
ongoing program implementation and evaluation.
Funding considerations
The Legislature requires Commerce to consider funding in its program design. It did not ask Commerce to
make a recommendation on a funding source, and Commerce does not make one in this report.
Potential funding sources
Commerce considered three different funding sources:
• The state general fund
• Climate Commitment Act
• A system benefits charge
Commerce did not identify significant differences in these potential funding sources that would affect program
administration, with exception of potential fluctuations in Climate Commitment Act revenues.21 There are
benefits and drawbacks to using different funding sources that do not directly impact the administration of a
statewide monthly low-income energy assistance program. Those considerations are included in Appendix M:
Funding options.
Forecasting caseloads
Funding decisions for a statewide low-income monthly energy bill assistance program would be informed by
forecasts of caseloads through the Washington Caseload Forecast Council (Council).
The Council is an independent state agency governed by a bi-partisan council. The Council is charged with
forecasting the entitlement and other caseloads for Washington. The Council meets several times a year to
adopt official forecasts used as the basis of the governor’s budget and by the Legislature developing the
omnibus biennial appropriations act. 22
The Council forecasts cover programs and services broadly grouped under children’s services, public
assistance, education, long term care, medical assistance, education, and corrections.
In the public assistance category, the Council provides caseload forecasts for the following programs:
• Temporary Assistance for Needy Families
• Aged, Blind and Disabled Assistance Grant
• Working Connections Child Care
• Early Achievers Tiered Reimbursement Providers
• Working Families’ Tax Credit
21 There is uncertainty about future revenues from the Climate Commitment Act, which may make it insufficient as a standalone
funding source in the future. Voters may decide to repeal the Climate Commitment Act in the 2024 election, which would eliminate the
Climate Commitment Act as a funding source.
22 See Appendix N: Caseload Forecast Council
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 29
The Council's caseload forecasts would provide an open and transparent process for regular, consensus-
based estimates of future program demand, which would inform budget decisions.
Limited requirements on utilities
One of the primary goals of a statewide program is to reduce the inefficiencies of administering more than 120
programs across 50+ utilities per Sec. 120, while making access to monthly low-income bill assistance
available to low-income households statewide. Electric utilities would be subject to significantly fewer
responsibilities under a statewide program.
Table B: Illustrative summary of utility obligations under a statewide approach
What utilities would do What utilities would not do
• Apply a discount percentage to household upon • Design and administer their own monthly low-
notice from the state administrator income energy bill assistance programs
• Bill the state administrator for the discounted • Conduct programmatic assessments and
amount evaluations
• Remove the discount for an address upon change • Verify household incomes
in customer service or notice from the state • Develop program materials
administrator that the household is no longer • Conduct their own independent outreach and
eligible comprehensive enrollment campaigns, unless
• Post general information about the program, desired
provided by the state, on the utility’s webpage • Be individually responsible for the energy burdens
• Advertise the program at least twice a year using for home heat and power sources beyond the
state-provided materials utility’s book of business
• Notify customers who fall behind on their • Be responsible for program outcomes
payments that they may be eligible for assistance
Being careful not to overdesign a statewide program
Commerce intentionally kept many of its recommended design elements of a statewide energy assistance
program from straying into granular details. This recognizes the importance of not overdesigning a program,
which could constrain the program's ability to adapt to meet household or community needs.
Allowing some flexibility in program design and implementation avoids several potential pitfalls of overly rigid
enacting legislation. The risks of an overly prescriptive statutory approach to a statewide monthly low-
income energy assistance program include:
• Bureaucratic hurdles that slow the development and implementation of a statewide low-income energy
assistance program and increase administrative costs.
• Difficulties adapting the program to rapid changes in technology, demographics, and environmental
conditions necessitate agile responses from program developers and implementers.
• Undermine community engagement and ownership by limiting opportunities for local households,
community organizations, and utilities to participate in the design and implementation of a statewide
monthly bill assistance program.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 30
Alternative frameworks within a statewide program
Voluntary opt out
An alternative design would be to allow utilities to opt out of a statewide low-income energy assistance
program. Any discussion of an opt-out provision should consider the impact on that utility's low-income
customers. An opt-out provision could leave households with an energy assistance program that is less visible,
less accessible, and less effective in meeting energy assistance need. It could even result in those households
receiving no monthly energy bill assistance at all. An opt-out mechanism would not ensure universal access,
uniform benefits, or human-centered, user-friendly program options for low-income households.
An alternative statewide approach to universal access, uniform
benefits, and human-centered program design
An alternative approach that provides universal access, uniform benefits, and human-centered program design
would be for the Legislature to adopt a statewide program for low-income households served by small- and
medium-sized utilities. It would address the funding dilemmas faced by these utilities and provide universal
access to low-income monthly energy assistance programs for households.
Large utilities would need to meet other criteria to ensure consistent services to households. These
requirements include:
• Meeting existing statutory income eligibility requirements
• Providing an income tiered bill discount
• Tying benefits in each tier to an approximation of benefits needed to meet energy assistance need
• Ensuring benefit level under each tier complies with a standard methodology established by rule
• Completing a biennial low-income energy assistance needs assessment
• Offering streamlined eligibility, including categorical eligibility and self-attestation
• Conducting significant outreach and submit annual reports with results of outreach efforts
• Coordinating programs with community based organizations, including those specifically serving
historically marginalized communities
• Conducting reasonable and good faith efforts to attain approval for program design, outreach, and
enrollment campaign plans from low-income advisory groups, according to guidelines established by
Commerce for consumer-owned utilities or Utilities and Transportation Commission for investor-owned
utilities
• Reporting program participation rates along with information currently submitted under Sec. 120 on a
biennial basis
• For large utilities: Matching program participation rates of SNAP; if not, programs would be required by
the Legislature to be phased out and households served by these utilities would be covered by the
statewide monthly low-income energy assistance program
This alternative statewide approach would fragment services between large, medium, and small utilities;
however, fragmentation across utility programs would decrease significantly and ensure universal access to
monthly low-income energy bill assistance and uniform benefit levels for similarly situated households.
Conclusion
The recommended program design begins with the assumptions that identifying and accessing assistance
should not be complicated, and Washington's diverse people deserve a system that supports equal access to
resources. These assumptions and the recommended design follow input over the past year from hundreds of
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 31
individuals from community providers, utilities, state agencies, environmental justice advocates, and
households, and careful consideration of alternative approaches outlined in Alternatives under a utility-by-utility
approach and summarized in Table P: Policy layering and supplementary funding approaches. The remaining
sections of this report discuss the process and insights that inform the recommended program design.
Recommended program design process
Background
Commerce designed its recommended program design over the course of a year with the assistance of low-
income households, community organizations, statewide advocacy organizations, and utilities. This section of
the report summarizes these activities and findings.
Listening sessions and surveys of low-income households
Services intended for marginalized communities are often developed with little input by those most affected:
Program participants. Commerce worked closely with community-based organizations and hired Greater Good
Studio, a third party consultant with human-centered design expertise, to design and conduct three group
listening sessions with low-income households to further the agency’s understanding of low-income
household needs.
The listening sessions explored experiences managing household needs and expenses, and navigating
different types of assistance programs. The stories shared provide important knowledge and wisdom to help
us understand household priorities and key insights. An in-depth analysis of the listening sessions is provided
in the Recommended program design process.
Five individuals from different households participated in each session. The listening sessions took place in
Seattle, Auburn and Tacoma. To provide a broader statewide perspective, Commerce conducted surveys of
low-income households with community organizations across the state to get a sense of their experiences
accessing energy assistance programs, program design preferences, and recommendations on low-income
energy assistance program designs. The methodology for these listening sessions is covered in Appendix F:
Centering lived experiences.
The agency is also conducting listening sessions in rural parts of Washington through the fall of 2024. The
workshops are not specific to a statewide program design. Results of those listening sessions will be made
available to the Legislature before Jan. 1, 2025.
Listening sessions with community organizations
Commerce held listening sessions with social service providers and community organizations across the
state. In total, 128 people from almost 100 distinct organizations participated. Roughly half of the session
participants reported over 10 years of experience serving low-income households, and roughly 25% reported
over 20 years of experience serving low-income households. Detailed descriptions of the sessions and their
outcomes are discussed extensively in Appendix H: Community organization listening sessions summary.
Workshops with utilities and statewide low-income advocates
Commerce held nine public workshops, which were attended by utilities and statewide advocacy
organizations. A public comment period followed all but the first kickoff meeting.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 32
The first five workshops focused on co-designing principles to guide the program design. The last four
workshops focused on draft report materials, including draft outlines and reports for public comment.
Highlights
Fragmentation, inequitable distribution and access to resources, inconsistent communications, and
burdensome enrollment processes affect the ability of low-income households to know about and enroll in
programs, and the ability of community based organizations to help enroll low-income households in
programs.
Low-income households take initiative to get their needs met, but broken program communications slow
down the process.
Power often sits with those who administer programs, not those they are meant to serve, with program
administrators determining who gains access to resources and how they do so, and providing few
opportunities for households to be empowered in setting terms.
A statewide program should have ongoing relationships with program participants and community-based
organizations.
Assistance programs need to be designed with a gradual off ramp from assistance, rather than sudden
program exit for households.
Household listening session insights
The listening sessions explored experiences managing household needs and expenses, and navigating
different types of assistance programs. Their stories provide important knowledge and wisdom to help us
understand household priorities and key insights.
Household priorities
Facing difficult daily choices, households often decide which needs to prioritize and which must wait. Housing
and food were ranked #1 and #2, because they meet immediate basic needs. But heat and power were named
as a critical concern relating to almost every category.
Figure 1: Household priorities by level of importance averaged across all listening sessions
Rent/Mortgage Food/Grocery
Heat/Power Phone/Internet
Healthcare Transportation
Childcare/Education
2%
11%
23%
13%
13% 21%
17%
Source: Greater Good Studio
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 33
"I think [my ranking] was between "I put [energy] behind a couple
heat and the power and the food. of the main ones... but then
I chose the food but I know I you're not gonna have any of
gotta have the heat and power to that if you don't have power.”
make the food.”
— Bryan
— Manuel (pseudonym used)
Household insights into programs
Insights from household experiences from interacting with low-income programs can support developing
design principles that amplify positive program effects and mitigate negative ones.
People take initiative to get their needs met, but broken program
communications slow down the process
The fragmented programmatic landscape causes undue burden of program participants seeking out
information about assistance and their benefit status.
“It all comes back to being
"When do we have funds? resourceful to yourself. If you
When do they get the grant? call enough people, if you go
We don't know. We don't know out, if you put the word out,
how to go at the right time to and know something’s gonna
figure it out.” come back to you… you’ll be
able to get that break”
— Annie
— Jah’Kharri
When resources are available, they don’t always get to where they are meant
to go
It isn’t enough to merely have funds to distribute or services to provide. Programs need to be set up to
provide equitable and culturally sensitive support.
“We’re being taken advantage "How do you go in one door,
of by [programs] the state has know the person that went
given money to. We’ve seen into the same door…. they did
[them] saying, Okay, give it to 1, [get assistance] and you
2, 3, 4, 5 [skip 6-9]… Come on, didn't. And the only difference
man, we all coming in for the between you is skin color, or
same thing” nationality. That's not right.”
— Bennie — Mr. Cornethan
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 34
Power often sits with those who administer programs, not those they are
meant to serve
Programs determine who gains access to resources and how they do so, with few opportunities for
households to be empowered in setting terms.
"When I see those [program requirement] papers it "Meet us where we at instead
makes me sick. But I need to eat. I need to do what of trying to push me into doing
they want to get my EBT.” what you want me to do.”
— Catherine — Jah’Kharri
You can’t build effective programs that support people you don’t know
Without direct information or ongoing relationship with program participants, it is difficult to determine what
assistance would be or is most impactful.
"Sometimes, [you] don't want
"I got an advocate and she helped me out with anything, just need somebody
everything… helped me with my application, all that to talk to. They don't have to
stuff. Everything went through.” give you no money, just be
there.”
— Kandee
— Annie
Assistance programs tend to penalize instead of support people experiencing
transitions
Assistance programs are often not designed for transition support, which can trap people in a cycle of
needing assistance instead of helping advance their lives.
I started in a transitional home. I've been there like two and a half years. And it's time to kind
of graduate, get a little independence, move forward. In doing that, I'll be taking on a lot of
these other bills…When I was talking to my housing unit, I was kind of trying to figure out the
basic expenses of things...”
— Lee
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 35
Program design insights from low-income household discussions
From the value-based insights that reference the general experiences of households accessing and navigating
assistance programs, Greater Good Studio developed feature-based insights to look at service offerings a
statewide program may incorporate. They reflect highlights and challenges households experience across
three phases:
Table C: Phases of program experiences
Awareness Enrollment Experience
How people find out about and first get How people find out they are eligible and How people navigate the program and
connected to programs. apply to programs. receive services.
Source: Greater Good
Feature-based insights from listening sessions
A wide range of communication
methods meets people where they "Well, one thing [that helped] was the bill credit. I applied
for it. I heard about it through my mail.”
are, increases visibility, and
— Tammy
expands program reach.
Features might include:
Awareness
Print and digital media; going to the office/site
"Being able to talk to somebody that was
Enrollment able to stay on track, and give me a nice
Interpersonal methods: Word of mouth, direct email… and get things back to them. Or
referrals to answer the questions. How do I learn
about the program with my friends and
Experience family. And also word of mouth.”
Case manager, navigator
— Bryan
Source: Greater Good Studio
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 36
Embrace accessibility and "[There are] people that are illiterate...
transparency to shift power when you in that, you don't want nobody
to know. You're ashamed. You can't read,
imbalances between households you can’t understand the small print.”
and the program.
— Annie
Features might include:
Enrollment
Ability to self-check enrollment status and track "The staff was very on hand step by step,
progress over time explain[ing] and help with the computer
and paperwork, bus passes, housing
Experience
network…”
Regular check-ins with program staff to address
needs and share feedback
Source: Greater Good Studio — Kwania
Invest in meaningful relationships
to understand needs and offer
appropriate assistance in real time. "My job developer continue[s] to help
me... with gas cards... getting me steel
Features might include: toed boots for work. They help you get
back on your feet and it's really a
Awareness
blessing."
Work with community organizations as trusted
liaisons for referrals
Experience — Manuel (pseudonym used)
Provide a program navigator or advocate that is
dedicated over time
Source: Greater Good Studio
"People are trying to count my utility
help as being monthly income... that
goes straight to my bills, I don't see
any of it.”
— Lula (pseudonym used)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 37
Close assistance gaps by reducing
unreasonable criteria and
administrative barriers
"You have to do a lot of work and
Features might include: efforts [to receive assistance] to
not even make enough to pay bills
Enrollment or keep a roof over your head.”
Tap into existing social service networks for
coordinated eligibility check
— Bryan
Experience
Align income requirements with area living wage
standards rather than federal poverty line
Source: Greater Good Studio
Be clear about what is being offered
and follow through on providing
what was promised.
"But I've never got anything from them nor didn't even get a
Features might include: response from my application and that's for energy... I just
left it alone.”
Enrollment
Sharing relevant personal information only;
accessible, responsive an easy enrollment
— Tammy
Experience
Follow through, customer service oriented
adequate provision of assistance
Source: Greater Good Studio
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 38
Provide flexible and sustained
assistance that responds to "When you're brought to tears, about your
emergent needs and eliminates need, all you trying to accomplish is what
sudden benefit decreases. they allowed you to do for a month. May
it be paying for your electrical bill, or may
you need a new roof or you're buying
Features might include:
enough oil. Once you get that assistance
Experience they're saying ‘thank you.’ But what am I
Budget for low-barrier discretionary funds that can gonna do next month?”
be applied on an as-needed or emergency basis
Different assistance pathways that provide gradual — Mr. Cornethan
rather than sudden program exit
Source: Greater Good Studio
Reflecting household insights in the recommended program design
The recommended program design incorporates the potential program design features from listening sessions
with low-income households. Below is a summary table that highlights how the recommended program
responds to the identified household insights.
Table D: Summary of ways a recommended program design provides a wide range of
communication methods that meet people where they are, increases visibility, and
expands program reach
Illustrative summary of
Phase Potential program design feature
recommended program design
State administrator publishes and
disseminates print and digital media
in multiple languages; program
Print and digital media; going to the
Awareness webpage allows organizations to
office or site
register their willingness to serve low-
income households in-person, so low-
income households can find them
Statewide program is highly visible
with a singular program name and
Interpersonal methods; word of mouth,
Enrollment brand, allowing households and
direct referrals
service providers to easily recognize
the program and make referrals
Statewide program and program staff
help households manage benefits
directly through an online portal or
Experience Case manager, navigator over through call center; statewide
program administrator works with
community organizations that provide
wrap-around services to help
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 39
Illustrative summary of
Phase Potential program design feature
recommended program design
households get connected to other
programs
Table E: Summary of how a program would embrace accessibility and transparency to
shift power imbalances between households and the program
Phase Potential program design feature Recommended program design
Households can self-check their
Ability to self-check enrollment status enrollment status and track progress
Enrollment
and track progress over time through the program’s online portal or
over the phone.
The statewide program administrator
would provide regular check-ins with
households via online messages or
Regular check-ins with program staff to email correspondence, including
Experience
address needs and share feedback customer service surveys.
Program correspondence would
include information for in-person
appointments
Table F: Summary of how a program would invest in meaningful relationships to
understand needs and offer appropriate assistance in real time
Phase Potential program design feature Recommended program design
The statewide program administrator
would strengthen existing and forge
new relationships with community
Work with community organizations as organizations across the state family;
Awareness
trusted liaisons for referrals provide regular regional check-ins; and
could conduct coordinated enrollment
campaigns with community
organizations
The statewide program administrator
Provide a program navigator or advocate would have dedicated staff to help
Experience
that is dedicated over time households navigate program
requirements
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 40
Table G: Summary of how a program would close assistance gaps by reducing
unreasonable criteria and administrative barriers
Close assistance gaps by reducing unreasonable criteria and administrative barriers
Phase Potential program design feature Recommended program design
The statewide program would plug
into existing social service networks
Tap into existing social service networks
Enrollment and provide categorical eligibility for
for coordinated eligibility check
households to verify their household
incomes
The statewide program adopts area
Align income requirements with area
median income standards where they
Experience living wage standards rather than federal
are higher than the federal poverty
poverty line
level
Table H: Summary of how a program would be clear about what the program would
offer and follow through on providing what was promised
Phase Potential program design feature Recommended program design
The statewide program requires only the
information needed to determine
Sharing relevant personal information income eligibility and deliver benefits to
Enrollment only; accessible, responsive, and easy a household’s utility account; program is
enrollment accessible online, in-person, or phone
with responsive communications with
staff through the online portal or phone
Follow through, customer service
Assistance is targeted to address
Experience oriented, adequate provision of
household energy assistance need
assistance
Table I: Provide flexible and sustained assistance that responds to emergent needs
and eliminates sudden benefit decreases
Phase Potential program design feature Recommended program design
The recommended program design does
Budget for low-barrier discretionary not have an as-needed or emergency
Experience funds that can be applied on an as- assistance funding mechanism, which
needed or emergency basis could be added if desired by the
Legislature
The monthly bill assistance mechanism
is tiered to provide gradual reduction in
Different assistance pathways that benefits as household incomes rise;
Experience provide gradual rather than sudden income eligibility requirements take into
program exit account area median income, which is
often higher than income criteria of
federal assistance programs, thereby
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 41
Phase Potential program design feature Recommended program design
avoiding a sudden drop in household
assistance overall
Household survey insights
Commerce partnered with community-based organizations in Clark, Ferry, King, Snohomish, Spokane, and
Yakima counties.
The survey was made available in nine languages to better reach a diverse sample of respondents. The survey
was provided digitally and physically in Arabic, Chinese (simplified and traditional), Spanish, Vietnamese,
Somali, Russian, Ukrainian, and Tagalog.
337 individuals completed surveys. Open-ended questions were translated and standardized by Commerce.
The survey did not ask for demographic information such as age, race, income, or household size. Survey
results are not statistically significant, but provide insights into how low-income households currently access
energy assistance programs and their thoughts around certain program design elements.
Additional survey details are provided in Appendix G: Household surveys.
Key survey findings
Surveyed households overwhelmingly favored universal access to monthly bill
assistance
Almost all (95%) of the survey participants said low-income households should have the same ability to access
bill assistance regardless of where they live.
A majority of survey households favored income tiered monthly bill assistance
Most survey participants (63%) believe low-income households with lower incomes should receive a higher bill
discount, and those with more income should receive less of a discount.
Surveyed households supported categorical eligibility
Most survey participants (78%) agree that the enrollment process for assistance should be minimal if a
household is already enrolled in another statewide low-income program.
Surveyed households overwhelmingly favored multiple ways to enroll in
programs
Almost all survey participants (96%) agree that enrollment should be available online, over the phone, or at any
local community service center serving low-income households.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 42
Online and phone enrollment options were the most chosen responses for how
households would like to enroll with in-person options also chosen lots
When asked where they would most want to be able to sign-up for statewide or local energy assistance
programs, participants overwhelmingly said online. 119 participants selected more than one answer.
61% of survey participants selected online
44% of survey participants selected phone
22% of survey participants selected local DSHS office
18% of survey participants selected community action agency
16% of survey participants selected multicultural service center
When asked they primary reasons why survey participants wanted to enroll in an energy assistance program,
survey participants said:
47% of survey participants included wanting to save money for me and my family
41% of survey participants included wanting to save money to help afford other housing costs
27% of survey participants included wanting to avoid being disconnected from power
35% of survey participants included wanting to save money for food
Only 7% of survey participants included the statement that their home is not comfortable because it is
either too hot or cold.
Most survey participants were not enrolled in utility bill assistance programs or
LIHEAP
Most survey participants said they were not enrolled in LIHEAP or a utility program (72%). 9% of survey
participants said they were not sure if they were enrolled in LIHEAP utility program, and 10% said they were not
sure if they were enrolled in a utility bill assistance program.
Most survey participants are unaware of utility programs, which may or may be
available to them
When asked why they weren't enrolled in utility bill assistance programs, 43% said they weren't aware of the
programs, 30% said they didn't know if they were eligible, 15% responded they were unsure, and 14% said they
didn't know how to sign up. 23
23 See Appendix G: Household surveys
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 43
Figure 2: Why survey participants are not enrolled in utility bill assistance programs
I don’t know about the programs 43%
I don’t know if I am eligible 30%
Not sure 15%
I don’t know how to sign up 14%
I don’t want assistance 12%
I am already enrolled in a program 8%
It is too much paperwork and personal information 5%
It wouldn’t help enough to be worth my time 1%
0% 10% 20% 30% 40% 50%
Suggestions for improving outreach and enrollment from survey participants
Survey participants said participation could be increased by expanding eligibility requirements, increased
guidance on how to sign up, and bundling program communications and enrollment processes with other low-
income assistance programs.
Methods to increase awareness included traditional methods such as flyers, TV and news ads, texts, social
media posts, radio, and bill inserts.
Some participants recommended specific public places that could help spread awareness, such as the local
PUD, community centers, parks schools, food banks, grocery stores, and libraries.
A few survey participants noted the importance of disseminating information in culturally relevant ways, such
as in alternative languages and through trained and unbiased facilitators. Other participants noted that sites
that already offer low-income assistance would be good places to provide the information, such as refugee
centers, non-profits, senior centers, and DSHS offices.
Reflecting survey results in the recommended program design
The preferences of households with the recommended program design are reflected in the statewide monthly
low-income energy assistance program design.
Table J: Comparison of household survey results and recommended program design
Survey results Recommended program design
Almost all (95%) of the survey participants said low- Low-income households could access monthly low-income
income households should have the same ability to energy assistance regardless of their utility or home fuel
access bill assistance regardless of where they live source
Most survey participants (63%) believe low-income
Low-income households with less income would receive a
households with lower incomes should receive a higher
larger discount than low-income households with higher
bill discount, and those with more income should receive
incomes
less of a discount
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 44
Survey results Recommended program design
Most survey participants (78%) agree that the enrollment Enrollment is streamlined and does not require households
process for assistance should be minimal if a household submit additional income document if they are already
is already enrolled in another statewide low-income enrolled in a statewide low-income program and provide
program their SSI or DSHS account number
Almost all survey participants (96%) agree that
enrollment should be available online, over the phone, or Low-income households can enroll online, over the phone,
at any local community service center serving low- or in-person at any community service center
income households
Community based organization insights
There were many insights from listening sessions with local service providers for low-income households
yielded, what challenges they encounter, and what they need to connect households to services. 24
Below are summary findings from the six in-person listening sessions and virtual workshop with service
providers. Commerce identified common themes, which are highlighted below, along with responses from the
sessions that underline statewide themes.
A full description of these sessions and detailed summary is included in Appendix H: Community organization
listening sessions summary.
Low-income households are resilient, care for and contribute to their families
and communities
"Their resiliency, determination, and "How hard [low-income households]
hopefulness” work to make ends meet."
— Community based organization, Port Angeles — Community based organization, Spokane
"They are persistent and clearly know
"Their ability to change and grow for the
what they need to help improve their
better."
quality of life”
— Community based organization, Stevenson
— Community based organization, Seattle
24 See Appendix H: Community Organization Listening Sessions Summary
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 45
Additional insights from local service provider about what is most inspirational about the clients you serve?
• Their resiliency
• How resilient and enduring they are with what little they have
• Many of them go through a lot of challenges but still keep going
• They think outside the box
• How hard they work to make ends meet
• They are persistent and clearly know what they need to help improve their quality of life
• Desire to provide for their families
• Their ability to change and grow for the better
See Appendix H: Community organization listening sessions summary
Low-income and working class households and local service providers
encounter many obstacles to accessing social services
"Inequitable distribution of resources “Gaps in eligibility leave households in
and access to resources” need”
— Community-based organization, Seattle — Community-based organization, Stevenson
"Documentation stress and "No access to be able to apply”
complicated requirements”
— Community-based organization serving
— Community-based organization, Kennewick Southeast Washington, Spokane
Additional insights from service provider about what challenges do service providers encounter most when
serving clients?
• Lack of clarity on how to access programs
• Complexity of requirements to access programs
• Too many steps to access resources
• Funder restrictions
• Strict guidelines that are not flexible
• Digital and technological navigation, particularly for older clients
• Being underserved, marginalized, and racial discrimination
• Getting people to come to resource events, despite many methods of advertising
• Explicit and implicit biases
• Language barriers
• Poverty stigmas
See Appendix H: Community organization listening sessions summary
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 46
Low-income and households need highly visible, easily accessible programs
“Greater programmatic visibility. It “Minimizing documentation and [using]
sometimes seems like services and self-attestation would help reduce
resources are hidden” documentation and barriers. Clients can
get discouraged when they see all the
documentation required”
— Community-based organization, Stevenson
— Community-based organization, Port Angeles
“Multiple entities enrolling customers “Both outreach and enrollment should
and categorical eligibility should be be conducted with trusted community
provided based on participation in partners—would add interested parties
other programs all with the mindset to that because often those trusted
that no door is the wrong door when it community partners have no bandwidth
comes to applying for and receiving to do new work, so it would be
assistance” important to consider how to bring new
partners into this work”
— Community-based organization, Virtual
— Community-based organization, Colville
Insights from service provider workshop responses to the question: What do clients need to successfully
access resources? 25
• Structure, predictability, and certainty
• Clear, simple processes to access resources—not having to jump through hoops to access what they
need
• Give what is needed and get out of the way
• For resources to be there now and in the future
• Systems that reflect who they are
• Culturally appropriate services and accommodations
• Help from people who look like them
• Culturally-specific resources for providers
25 See Appendix H: Community organization listening sessions summary
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 47
Overlap between household service provider insights
Table K summarizes common themes from community based organizations and low-income households, and
opportunities to address the identified program issues through program design.
Table K: Design opportunities
CBOs* shared… Households shared… Opportunity
A wide range of communication
Greater program visibility is Utilize a variety of trusted sources
methods meets people where they
desirable, with multiple access to help households learn about the
are, increases visibility, and expands
points program.
program reach.
Programs are challenging to
Embrace accessibility and
access and navigate. Design intentional opportunities for
transparency to shift power
participants to influence program
imbalances between households and
Multicultural services should be terms and service offerings.
programs.
provided.
Eliminate unnecessary Close assistance gaps by reducing Develop flexible criteria that
application barriers or adversarial unreasonable criteria and promotes adequate financial living
program requirements. administrative barriers. standards.
Center building and maintaining
Follow-ups are important and Build relationships to understand
meaningful relationships in the
should provide ongoing support. and meet needs in real time.
program.
Be clear about what is being offered Develop guidelines and processes
Programs should provide and follow through on providing what that result in clear and reliable
structure, predictability, and was promised. assistance.
certainty.
Provide flexible and sustained
Provide adequate assistance and
Households need to be assistance that responds to
gradual program exit that
treated with dignity and respect. emergent needs and eliminates
promotes long-term stability.
sudden benefit decreases.
*community based organizations
Co-created program design principles
Commerce collected input from these groups to inform a statewide program design. Potential program
participant experiences were centered throughout the conversations, and the resulting principles reflect areas
of general consensus across the groups.
Program principles developed with utility and statewide low-income
advocates
Commerce held four workshops through the fall of 2023 to gather input from utilities and statewide low-
income advocates to co-develop program design principles. Commerce then workshopped the principles with
local service providers across the state through the fall and winter of 2023.
The co-designed principles include:
• The program should minimize documentation required to enroll
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 48
• The program should have multiple application and enrollment methods, including methods that do not
require internet access or travel to a physical location
• Categorical eligibility should be provided based on participation in other low-income assistance
programs
• The program administrator should be able to cross-enroll customers in other low-income assistance
programs
• Multiple entities should be able to enroll customers in a statewide program
• There should be a quick turnaround time from submission of application to receiving the benefit
• Self-attestation with limited documentation with a small set of random income verification could
balance program accessibility and integrity goals
• Immigration status should not affect eligibility
• Both outreach and engagement should be conducted with trusted community partners
• Utilities could post or distribute outreach materials with consistent messaging
• Program materials and communications should use plain language, be trauma informed, and be
available in multiple languages
• Communications and services should be available in multiple languages with translation services
available on request.
• Outreach efforts should precede program launch
Additional principles from local service providers
The program design principles developed through workshops with utilities and statewide advocacy
organizations. Through discussions with community organizations that specialize in serving low-income
households, additional principles were identified to help guide the design of a statewide program. These
principles include:
• No systems that are long and complicated
• The program should have a quick turnaround time from submission of the application to receiving the
benefit
• Multilingual communications should be vetted by first-language speakers
• The program should acknowledge low-income seniors tend to live on fixed incomes, and reduce
frequency of application renewals for these households
• The program should avoid benefits cliffs
• Program materials and communications should raise awareness about the benefits of conservation
• A statewide monthly low-income energy bill assistance program should include Black, Indigenous, and
People of Color and other historically marginalized communities in the development and
implementation of energy assistance program if the Legislature chooses to create a program
Co-designed principles guiding program development
The principles developed through workshops with community organizations and utilities and statewide low-
income advocates were used to develop the statewide low-income energy assistance program alongside the
insights of low-income households and system constraints.
Conclusion
Low-income households are resilient and take initiative to meet their needs, but fragmented program
landscapes and an inequitable distribution of resources and program access mean many don’t receive help.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 49
When programs are available, they often have lengthy and unnecessary enrollment requirements. Households
that manage to enroll only receive one-time assistance, which does not provide sustained, stable support that
gradually reduce benefits as households move up the economic ladder.
Visible programs, clear and simply enrollment requirements, multiple ways to enroll, and culturally responsive
programs were among the most cited elements for successfully reaching low-income households. Proactively
addressing racism and poverty stigmas through program design were also frequently mentioned. These
insights help guide Commerce’s review of Washington laws and the utility monthly energy bill assistance
programs, and Commerce’s recommended program design.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 50
Energy burden and assistance need in Washington
Background
The expertise and lived experiences of low-income households listened to and surveyed as part of this study
are echoed in the data on household energy burden, assistance need, and energy insecurity. The next two
sections of this report focus on the data.
Definitions
A household is considered energy burdened when its residential energy bills exceed 6% of its gross income.
Energy assistance need is the amount of funding needed to reduce home energy bills of a low-income
household to 6% of its gross income. Total energy burden refers to the sum of every household’s energy
burden in the state.
Highlights
• More than 270,000 low-income households in Washington state (25% of low-income households) are
energy burdened—that is, they spend more than 6% of their household incomes on residential energy
bills
• On average, these households spend $1,016 in excess of their home energy bills annually after taking
the comparatively low electric rates of many Washington utilities into account
• The total statewide energy burden of low-income households is $275 million after taking the
comparatively low electric rates of many Washington utilities into account
• Nearly a fifth (about 17%) of low-income households in urban counties are energy burdened, and nearly
two fifths (38%) of low-income households are energy burdened in rural counties
Low-Income Energy Affordability Data (LEAD) Tool
The federal Department of Energy (DOE) and the National Renewable Energy Lab (NREL) provide national,
state, and local energy burden data through the Low-Income Energy Affordability Data (LEAD) Tool. It is the
only statewide resource for understanding energy burden and assistance need in Washington. A full
description of the DOE LEAD Tool and a summary of its strengths and weaknesses is provided in Appendix B:
The Low-Income Energy Affordability (LEAD) Tool. The DOE LEAD Tool was last updated in 2024 with
American Community Survey 5-year estimates for 2018-2022.
Energy burden and assistance need
The DOE LEAD Tool estimates that 25% of low-income households — which represents more than 270,000
households statewide — spend more than 6% of their household income on energy bills and are therefore
energy burdened. The average annual household energy burden in excess of 6% of a household income is
$1,016. This amounts to $1,016 million in energy assistance need statewide. These costs include residential,
electricity, natural gas, propane, and other home heating and fuel costs, and they reflect the comparatively low
electric rates charged by many Washington utilities. They do not include transportation-related costs.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 51
The number of energy burdened households and total energy burden
are greatest in urban counties
Figure 3: Number of low-income households that are energy burden in rural and urban
counties
Rural counties 92,528
Urban counties 178,388
Statewide 270,916
- 50,000 100,000 150,000 200,000 250,000 300,000
Source: Commerce calculations using U.S. Department of Energy Low-income Energy Assistance Data WA DOE LEAD Tool Data | Powered by Box
Figure 4: Total energy burden in urban and rural counties
Rural counties $95,310,856
Urban counties $179,956,755
Statewide $275,267,611
$0 $50,000,000 $100,000,000 $150,000,000 $200,000,000 $250,000,000 $300,000,000
Source: Commerce calculations using U.S. Department of Energy Low-income Energy Assistance Data WA DOE LEAD Tool Data | Powered by Box
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 52
Figure 4 shows rural counties have a greater percentage energy burdened low-income households than urban
counties. These same rural counties tend to have average per household energy burdens equal to or greater
than urban counties. The mid-Columbia counties (Chelan, Douglas, and Grant) fall outside this pattern.
Rural counties are disproportionately energy burdened
Figure 4: Percent of low-income households that are energy burdened
Rural counties 38%
Urban counties 17%
Statewide 25%
0% 5% 10% 15% 20% 25% 30% 35% 40%
Source: Commerce calculations using U.S. Department of Energy Low-income Energy Assistance Data WA DOE LEAD Tool Data | Powered by Box
Figure 5: Percent of energy burdened low-income households out of the total
population
Rural counties 15%
Urban counties 6%
Statewide 9%
0% 2% 4% 6% 8% 10% 12% 14% 16%
Source: Commerce calculations using U.S. Department of Energy Low-income Energy Assistance Data WA DOE LEAD Tool Data | Powered by Box
While rural counties are disproportionately energy burdened (see Figure 5), their total excess burden is often
far less than their urban counterparts. For example, 81% of low-income households in Ferry County have an
average annual energy burden per household of $1,354. The excess burden for all low-income households in
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 53
Ferry County totals just over $1.6 million annually. That compares to 17% of low-income households being
energy burdened in King County. Low-income households in King County average an annual household burden
of $1,188. The total annual excess burden for all low-income households in King County is about $63 million.
The rural electric utility dilemma
Many of the rural counties with disproportionately burdened populations are served by relatively small electric
utilities. For instance, Ferry County is served by Ferry County PUD No 1 — one of the state's smallest utilities. It
has 0.8% of the residential customers and 1.7% of the revenues of Seattle City Light. 26 Its service territory is
one of the most low-income and energy burdened parts of the state yet it illustrates the difficulties that rural
utilities with a disproportionate share of low-income households face.
It may be difficult for Ferry County PUD No 1 to provide ratepayer-funded energy assistance sufficient to
address the energy burden of its low-income households without rate hikes, because of its high proportion of
low-income, energy-burdened customers compared to larger utilities, such as Seattle City Light. Fully
addressing the energy burden of low-income customers for utilities with a disproportionate share of low-
income customers could result in other customers becoming energy burdened themselves.
Table L: Household energy burden by county
Percent of Average energy
Number of Percent of low- Total excess
energy burden for
energy income burden of
burdened low- energy
County burdened low- households that energy low-
income burdened low-
income are energy income
households of income
households burdened households
total population household
Adams 896 33% 14% $998 $893,607
Asotin 1,581 40% 17% $963 $1,522,072
Benton 5,609 22% 7% $866 $4,854,892
Chelan 1,069 10% 4% $415 $443,673
Clallam 5,422 41% 16% $989 $5,359,706
Clark 12,903 18% 7% $741 $9,562,209
Columbia 405 60% 22% $1,195 $484,052
Cowlitz 4,139 25% 10% $811 $3,357,312
Douglas 579 12% 4% $562 $325,358
Ferry 1,243 81% 41% $1,354 $1,683,084
Franklin 2,433 23% 9% $880 $2,140,430
Garfield 271 60% 27% $1,559 $422,967
26 Annual Electric Power Industry Report, Form EIA-861 detailed data files
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 54
Percent of Average energy
Number of Percent of low- Total excess
energy burden for
energy income burden of
burdened low- energy
County burdened low- households that energy low-
income burdened low-
income are energy income
households of income
households burdened households
total population household
Grant 2,955 21% 9% $705 $2,083,758
Grays Harbor 5,837 46% 20% $1,064 $6,211,221
Island 4,729 40% 13% $1,075 $5,081,798
Jefferson 3,323 53% 21% $1,251 $4,157,131
King 53,220 17% 6% $1,188 $63,225,460
Kitsap 10,124 27% 10% $1,264 $12,791,480
Kittitas 3,286 40% 17% $1,079 $3,545,054
Klickitat 2,058 56% 21% $1,049 $2,159,310
Lewis 5,474 44% 17% $853 $4,668,437
Lincoln 838 49% 18% $1,184 $991,923
Mason 4,056 47% 16% $1,189 $4,822,050
Okanogan 5,609 73% 33% $1,171 $6,566,812
Pacific 1,569 34% 15% $1,122 $1,760,451
Pend Oreille 1,231 51% 21% $1,211 $1,490,330
Pierce 26,769 22% 8% $985 $26,361,306
San Juan 2,008 64% 23% $1,561 $3,133,877
Skagit 6,726 38% 13% $1,032 $6,941,844
Skamania 1,449 70% 30% $1,332 $1,930,498
Snohomish 20,241 18% 7% $873 $17,663,347
Spokane 27,502 33% 13% $807 $22,189,622
Stevens 4,123 54% 22% $1,276 $5,261,346
Thurston 11,587 27% 10% $999 $11,572,296
Wahkiakum 490 56% 25% $1,433 $702,541
Walla Walla 3,001 33% 13% $1,034 $3,103,309
Whatcom 10,432 30% 11% $1,125 $11,736,144
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 55
Percent of Average energy
Number of Percent of low- Total excess
energy burden for
energy income burden of
burdened low- energy
County burdened low- households that energy low-
income burdened low-
income are energy income
households of income
households burdened households
total population household
Whitman 3,926 43% 22% $551 $2,162,197
Yakima 11,804 32% 14% $1,009 $11,904,709
Source: Commerce calculations using U.S. Department of Energy Low-income Energy Assistance Data WA
DOE LEAD Tool Data | Powered by Box
Other considerations
When examining energy burden and energy assistance need data, it is important to remember that just
because a household energy bill is not greater than 6% of its income, it does not mean the household does not
struggle to pay its home energy bills. Higher costs of living can reduce disposable household income and
make it more difficult to pay home energy bills.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 56
The impacts of energy burden on households
Background
This energy insecurity profile is based on data from the U.S. Department of Energy, Energy Information
Administration, 2020 Residential Energy Consumption Survey (RECS). RECS results include information
regarding housing type and structure, appliances and end uses, home energy consumption and expenditures,
“energy insecurity,” and household demographics. State-level RECS microdata was tabulated by National
Consumer Law Center (NCLC) to generate the findings outlined below. Some variables, including those
depicting ratio of income to poverty and home energy burdens, were calculated by NCLC using RECS
microdata. 27
Highlights
• More than one in five (22%) Washington households reported some form of energy insecurity in 2020;
only 3.4% reported having ever participated in energy assistance
• About 11% of all Washington households showed chronic insecurity, in that they needed to forego
necessities during some months or almost every month of the year; an additional 4% of all Washington
households went without food, medicine or other necessities one or two months during the past 12
months
• Over 5% of all Washington households reported maintaining an unhealthy indoor temperature some
months or almost every month, and an additional 4% reported unhealthy indoor temperature one or two
months during the previous year
Energy insecurity
There is growing evidence demonstrating the links between high energy burdens, 28 energy insecurity, 29 and
challenges related to housing, health, financial stability and debt.
According to results the 2020 RECS, about 13% of Washington households were energy burdened. National
data and literature show that energy burdened households are about three times more likely than non-
burdened households to receive an electric utility disconnection notice.
27 https://www.eia.gov/consumption/residential/data/2020/index.php?view=microdata
28 “Energy burden” is defined as the proportion of household income devoted to paying for home energy service. Households with
burdens of 6% or more are considered to be “energy burdened.”
29 “Energy insecurity” is defined broadly as the inability to adequately meet household energy needs. The U.S. Department of
Energy/Energy Information Administration measures the prevalence of energy insecurity through the Residential Energy Consumption
Survey (RECS) by querying respondents about frequency of forgoing other necessities to pay for home energy, maintaining unhealthy
indoor temperatures, receipt of disconnection notices, and involuntary disconnection of home energy services or fuels.
Columbia University researcher and professor Diana Hernandez noted that “(t)hose impacted by energy insecurity allocate a
disproportionate share of their income to utilities-related expenses and encounter inefficiencies in the home such as older, and less
efficient appliances and drafts that induce heat-loss. Concomitants of energy insecurity include extreme home temperatures,
hazardous heating alternatives, and the constant threat of utility shut-offs or mounting arrearages in utility bills because of
nonpayment. This problem is especially acute for low-income residents such as single parents, the elderly, the disabled, and others with
low or fixed incomes.” (Hernandez, “Energy Insecurity: A framework for Understanding Energy, The Built Environment, and Health
Among Vulnerable Populations in the Context of Climate Change,” American Journal of Public Health, April 2013).
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 57
Figure 5: U.S. households that received disconnection notices by burden (2020)
Burdened 20%
Not Burdened 7%
0% 5% 10% 15% 20% 25%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
Burdened households are about four times more likely than non-burdened households to experience
involuntary loss of electric service and inability to operate indoor heating or cooling equipment.
Figure 6: U.S. households unable to use heating or cooling equipment in the past year
because they could not afford electricity and it was disconnected (2020)
Burdened 4%
Not Burdened 1%
.0% .5% 1.0% 1.5% 2.0% 2.5% 3.0% 3.5% 4.0% 4.5% 5.0%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
Loss of service, particularly as extreme temperatures and weather become more common, can bring grave
consequences, particularly for households that include elders, infants, or those with illness or disability.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 58
Energy insecurity variables
As indicated above, RECS results include variables related to energy insecurity. These variables include the
frequency of:
• Forgoing necessities such as food or medicine The presence of energy insecurity
to pay a home energy bill
provides strong evidence of lack of
• Maintaining unhealthy indoor temperatures to
afford home energy service affordability of essential home energy
• Receipt of disconnection notices service for households experiencing
• Loss of service due to home energy bills or such insecurity
equipment repair expenses.
-- National Consumer Law Center
These measures are commonly viewed as key indicators home energy affordability challenges.
Households are energy insecure, but not receiving assistance
Following is a chart illustrating the percentage of Washington households that experienced any form of energy
insecurity in 2020, along with the percentage of households that have ever participated in an energy assistance
program such as LIHEAP or ratepayer-funded bill assistance.
Figure 7: Home energy insecurity and energy assistance program participation in
Washington (2020)
Any Home Energy Insecurity 22%
Ever participated in home energy assistance program 4%
0% 5% 10% 15% 20% 25%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 59
Figure 7 shows that, while over one in five Washington households reported some form of energy insecurity in
2020 alone, only 3.4% reported having ever participated in energy assistance. The overall portrait is of high
need for programs and policies that enhance affordability.
Households are forgoing basic necessities and keeping their homes at
unhealthy temperatures because of unaffordable home energy bills
The next charts illustrate the frequency of households forgoing basic necessities because of unaffordable
home energy bills and frequency of maintaining unhealthy indoor temperatures.
Figure 8: Frequency of Washington households reducing or forgoing basic
necessities due to home energy bills (2020)
1 or 2 Months 4%
Some Months 6%
Almost Every Month 5%
Total 15%
0% 5% 10% 15% 20%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 60
Figure 9: Frequency of Washington households keeping their homes at unhealthy
temperatures (2020)
Almost Every Month 0%
1 or 2 Months 4%
Some Months 5%
Total 9%
0% 2% 4% 6% 8% 10%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
Chronic insecurity and other concerning cases
In 2020, about 11% of households showed chronic insecurity, in that they needed to forego necessities
during some months or almost every month. An additional 4% of households went without food, medicine of
other necessities 1 or 2 months during the past 12 months. More than 5% of Washington households reported
maintaining an unhealthy indoor temperature some months or almost every month, while an additional 4%
reported unhealthy indoor temperature one or two months during the previous year.
Unaffordable energy costs are not a standalone issue
The above findings suggest that that energy assistance need in Washington is not a “standalone” issue, but
rather that it impacts other major challenges such as food insecurity and public health. At the same time, the
data highlights very low participation in existing energy assistance programs, due perhaps to problems with
program availability and funding, enrollment barriers, or a combination of challenges.
High energy burden and inability to meet financial obligations affect not only financial well-being, but also
physical and psychological health. Because of high energy costs, low-income families often sacrifice spending
on other important needs, such as groceries and medication, and reduce their energy usage in ways that harm
their physical health
Energy burdens and housing instability
Energy insecurity and housing insecurity are inextricably linked. When monthly utility bills are unaffordable, the
threat of disconnection lurks as a destabilizing force. Utility disconnections threaten housing stability for
many, especially extremely low-income tenants.
Utility affordability challenges and energy insecurity are related to housing affordability. High rental or
mortgage payments can strain household budgets and lead to late utility payments, past due account
balances, disconnection notices and disconnection for non-payment. Similarly, in households lacking sufficient
income to pay for basic necessities, unmanageable home energy costs put pressure on the ability to meet
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 61
rental or mortgage payment obligations. Effective bill assistance programming frees up household cash to pay
for other necessities, such as housing costs.
As illustrated below, data from the 2020 RECS indicates that renters are 28% more likely than homeowners to
carry energy burdens of 6% or more.
Figure 10: Frequency that U.S. renters or home owners are energy burdened
Rented 72% 28%
Owned 82% 18%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Not Burdened Burdened
Source: 2020 RECS microdata tabulated by National Consumer Law Center
The data further show that, nationally, high energy burdens are most prevalent among residents of mobile
home and small apartment buildings.
Figure 11: U.S. Energy Burden by Household Type
Apartment in a building with 5 or more units 80% 20%
Apartment in a building with 2 to 4 units 66% 34%
Single-family house attached to one or more other houses (for
81% 19%
example: duplex, row house, or townhome)
Single-family house detached from any other house 82% 18%
Mobile home 51% 49%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Not Burdened Burdened
Source: 2020 RECS microdata tabulated by National Consumer Law Center
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 62
How energy burdens affect financially struggling customers first, before housing costs become a problem. For
example, the U.S. Housing and Urban Development (HUD) Housing Choice Voucher (HCV) Program (Section 8)
provides that building owners “may consider a family’s history with respect to factors such as: payment of rent
and utilities …” 30 Also, in many private-market leases, tenants are responsible for utilities and failure to
maintain utility service can be considered a breach of the lease and grounds for terminating the tenancy and
filing an eviction action in court.
Energy burden and its impact on the ability to afford other basic
necessities
RECS data clearly illustrates that energy-burdened households are far more likely to forgo necessities such as
food or medicine to pay home energy bills. The 2020 RECS included the following query: “In the past year, how
many months did your household reduce or forego expenses for basic household necessities, such as
medicine or food, in order to pay an energy bill?” Figure 12, based on calculations using the 2020 RECS
microdata, indicates that 40% of households with home energy burdens of 6% or greater reported forgoing
necessities such as food or medicine to stay connected to pay a home energy bill, in contrast to only about
14% of households with burdens below 6%.
Figure 12: Likelihood of low-income energy burdened households in the U.S. reducing
or forgoing basic necessities due to home energy bill
Burdened 40%
Not Burdened 14%
0% 5% 10% 15% 20% 25% 30% 35% 40% 45%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
Clearly, going without food or medicine raises serious household and public health concerns. Over 30% of
burdened households experience this “heat or eat” insecurity on a chronic basis (almost every month or some
months).
30 Seattle Housing Authority, HCV Program, Administrative Plan available at:
https://www.seattlehousing.org/sites/default/files/HCV%20Administrative%20Plan%204.17.24.pdf
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 63
Figure 13: Frequency of reducing or forgoing basic necessities due to home energy
bill by energy burdened low-income households in the U.S. by month
1 or 2 months 9%
Some months 18%
Almost every month 14%
0% 5% 10% 15% 20%
Effective bill assistance programming that lowers home energy bills to a more affordable level is necessary to
mitigate these threats to health.
Energy burden negatively impacts physical and mental health.
There is growing evidence documenting the links between high energy burdens and negative health effects.
For example, there is evidence in peer-reviewed studies of heightened respiratory illness and weight gain
deficiencies in infants, as well as adult and adolescent mental health effects. 31 In a 2016 study, Columbia
University’s Diana Hernandez found that households facing various forms of energy insecurity correlate to high
levels of asthma, chronic stress, and mental health triggers. 32
The sacrifices families make to avoid disconnection from power also pose direct risks to their physical health.
For example, families may reduce their energy usage by setting their thermostat at extreme temperatures,
resulting in unhealthy home temperatures.
31 Christine Liddell, Chris Morris, “Fuel poverty and human health: A review of recent evidence,” Energy Policy, Volume 38, Issue 6, 2010,
Pages 2987-2997,
32 Diana Hernández, “Understanding ‘energy insecurity’ and why it matters to health,” Social Science & Medicine,
Volume 167, 2016, Pages 1-10.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 64
Maintaining unhealthy temperatures in the home to avoid disconnection places families at risk of hypothermia
and heat stress. 33 Among older adults and chronically-ill
individuals, such extreme hot or cold temperatures in the home,
may result in preventable deaths. 34 And skipping medications to
pay utility bills exacerbates the health problems of individuals
Most debts in collections are for
with chronic conditions, such as hypertension or diabetes, which
low-balance, non-financial
disproportionately affect marginalized groups. 35
accounts, such as utility bills. In
Loss of utility service can also result in displacement from the fact, past-due utility bills are one
home, and raise the risk of investigation by child protection of the most frequent sources of
agencies, creating significant psychological stress for families. collections items in consumer
Carrying debt of any sort also causes psychological distress, credit reports.
due to the fear of never being able to pay the debt or dealing
with aggressive debt collectors. 36 Most debts in collections are Sources: Consumer Financial Protection
for low-balance, non-financial accounts, such as utility bills; 37 in Bureau and the Urban Institute.
fact, past-due utility bills are one of the most frequent sources of
collections items in consumer credit reports. 38
Contact with a debt collector is a common experience for
Americans, and it is one of the most common reasons for complaints to the Federal Trade Commission. 39
Consumers report debt collectors contacting them too often and even threatening them. 40 This stress
increases an individual’s risk of anxiety, depression, substance use disorders, and other mental health
disorders. 41
33 Hernández, D. and J. Laird, Surviving a Utility Shutoff: U.S. Households at Greatest Risk of Utility Disconnections and How They Cope
(American Behavioral Scientist, May 2021), DOI:10.1177/00027642211013401; see also Klinenberg, E., Dying alone: The social
production of urban isolation, Ethnography, 2(4), 501-531. https://doi.org/10.1177%2F14661380122231019.
34 Hernández, D. and J. Laird, Surviving a Utility Shutoff: U.S. Households at Greatest Risk of Utility Disconnections and How They Cope
(American Behavioral Scientist, May 2021), DOI:10.1177/00027642211013401; see also Klinenberg, E., Dying alone: The social
production of urban isolation, Ethnography, 2(4), 501-531. https://doi.org/10.1177%2F14661380122231019.
35 Hernández, D. and J. Laird, Surviving a Utility Shutoff: U.S. Households at Greatest Risk of Utility Disconnections and How They Cope
(American Behavioral Scientist, May 2021), DOI:10.1177/00027642211013401; see also Haynes, Berneta, The Racial Health and Wealth
Gap: Impact of Medical Debt on Black Families (National Consumer Law Center, March 2022) (also discussing the connection between
chronic conditions and burdensome medical debt), available at https://www.nclc.org/wp-content/uploads/2022/09/RacialHealth-Rpt-
2022.pdf.
36 Body, Dyvonne, The Burden of Debt on Mental and Physical Health (The Aspen Institute, Aug. 2, 2018)
37 Market Snapshot: Trends in Third-Party Debt Collections Tradelines Reporting (Consumer Financial Protection Bureau, Feb. 2023),
available at https://files.consumerfinance.gov/f/documents/cfpb_market-snapshot-third-party-debt-collections-tradelines-
reporting_2023-02.pdf.
38 Thompson, Kelly et. al, Overview: Access to Utility Data for Underwriting Credit (Urban Institute, 2021), available at
https://www.urban.org/sites/default/files/2022-03/access-to-utility-data-for-underwriting-credit.pdf (also noting “but only about 3
percent of consumers with utility accounts are estimated to have tradelines reflecting routine payment history in their credit files with
Equifax, Experian, or TransUnion”).
39 Consumer Sentinel Network: Data Book 2021 (Federal Trade Commission, Feb. 2022), available at
https://www.ftc.gov/reports/consumer-sentinel-network-data-book-2021.
40 Consumer Experiences with Debt Collection: Findings from the CFPB’s Survey of Consumer Views on Debt (Consumer Financial
Protection Bureau, Jan. 2017).
41 R. Jenkins et al., Debt, Income, and Mental Disorder in the General Population, 38 Psychol. Med. 1485, 1490 (2008) (“The more debts
people had, the more likely they were to have . . . alcohol dependency and drug dependency.”); see also Elizabeth Sweet, Arijit Nandi,
Emma K. Adam, & Thomas W. McDade, The High Price of Debt: Household Financial Debt and its Impact on Mental and Physical Health,
91 Soc. Sci. & Med. 94, 95 (2013) (“several empirical studies have found that financial strains such as personal debt and home
foreclosures are strong predictors of depression, general psychological distress, mental disorders, suicidal ideation and behavior”); see
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 65
The psychological burden of carrying debt leads to feelings of
hopelessness, shame, and despair. 42 Moreover, studies show a
relationship between carrying debt and risk of suicidal
ideation. 43 Suicidal ideation is common enough that debt The psychological burden of
collectors frequently report encountering suicidal customers. A carrying debt leads to feelings of
2017 survey of debt collection organizations found that one in hopelessness, shame, and
four frontline staff reported having spoken to at least one despair. Some studies have even
customer in the past year who seemed serious about shown a correlation between
committing suicide. 44 carrying debt and increased risk
of suicide.
Reliable utility service is a life necessity, meaning utility bill
assistance represents a lifeline for many struggling families. Sources: H. Meltzer et al., Personal Debt
and Suicidal Ideation, 41 Psychol. Med. 771
Loss of utility service results in dangerous and potential lethal (2011); Chris Fitch et al., Vulnerability: A
living conditions for vulnerable groups, including children, Guide for Debt Collection (Personal Finance
Research Center, Mar. 2017).
chronically-ill people, and older adults. Disconnections and the
fear of disconnections place undue stress on families as well,
contributing to significant mental health harms. Bill assistance
reduces these harms by helping families keep the lights and
heat on.
Unfortunately, quantifying the impacts of bill assistance presents an analytical challenge. For example, little
public data exists about accounts in arrears and disconnections of utility service. 45 However, quantification
challenges should not lead to the conclusion that bill assistance has no impacts on mental and physical
health. Rather, these challenges suggest that decisions regarding the adoption and implementation of low-
income bill assistance programs should not hinge entirely on the results of overly simplified impact
assessments.
Excessive energy burdens lead to borrowing through credit cards,
payday loans, and other financial products that push low-income
households further into poverty
Energy burden and poverty are intertwined, and some researchers argue that high energy burdens and
unaffordability of energy utility services push consumers into poverty. 46
also Thomas Richardson, Peter Elliott, & Ronald Roberts, The Relationship Between Personal Unsecured Debt and Mental and Physical
Health: A Systematic Review and Meta-Analysis, 33 Clinical Psychol. Rev. 1148, 1154 (2013) (“Odds ratios demonstrate more than a
three-fold risk of a mental disorder in those with debt, or alternatively a three-fold risk of debt in those with a mental disorder.”).
42 H. Meltzer et al., Personal Debt and Suicidal Ideation, 41 Psychol. Med. 771 (2011) (“Feelings of hopelessness partially mediated the
relationship between debt and suicidal ideation.”).
43 H. Meltzer et al., Personal Debt and Suicidal Ideation, 41 Psychol. Med. 771 (2011).
44 Chris Fitch et al., Vulnerability: A Guide for Debt Collection (Personal Finance Research Center, Mar. 2017), p. 54, available at
https://www.bristol.ac.uk/media-library/sites/geography/pfrc/pfrc1701-21-steps-vulnerability-and-debt-collection-(web).pdf.
45 What States Can Do to Help Consumers Energy Insecurity (National Consumer Law Center, January 2020), available at
https://www.nclc.org/wp-content/uploads/2022/08/energy-insecurity-one-pager-1.pdf. Energy Burdens and Debt
46 J. Bohr, A. McCreery, Do Energy Burdens Contribute to Economic Poverty in the United States? A Panel Analysis, Oxford University
Press on behalf of the University of North Carolina at Chapel Hill, 2019, p. 4;
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 66
To pay for household necessities including utility service, low-income families may resort to borrowing through
credit cards, payday lending, and other financial products such as paycheck advance apps. 47 Borrowing leads
to additional financial pressures. The average annual percentage rate (APR) for credit cards reached 22.8% in
2023, 48 and interest costs put further financial burdens on families. 49 For years, utilities were one of the most
common reasons consumers resort to payday loans. 50 Climate change and extreme weather may exacerbate
this problem. 51
Measures to reduce household energy burdens, such as monthly bill assistance, can have a beneficial impact
on the financial health of low-income families, enabling them to repay borrowed funds and avoid debt
collection actions. 52
Arrearages
There is a great deal of evidence demonstrating that low-income households are more likely to experience a
broad range of energy insecurities, including carrying seriously past due balances on their utility accounts. For
example, a recent comprehensive electric utility affordability report from North Carolina concluded that
households with income below 200% of the federal poverty level were far more likely to struggle with arrears. 53
Bill assistance programs, making payments more affordable for utility customers with low incomes, are
required to reduce the likelihood that customers will accumulate seriously past accrued accounts and face
disconnection for nonpayment.
Conclusion
Commerce heard from low-income households and community organizations that home energy is an essential
need that underpins other basic needs. The Washington-specific, regional, and national data and case studies
support these observations and point to harmful coping mechanisms to pay their home energy bill.
https://jeremiahbohr.github.io/pages/publications/Bohr%20McCreery_2020_SF.pdf, citing B.K. Sovacool, R.V. Sidortsov, & B.R. Jones,
Energy Security, Equality and Justice (1st ed.), Routledge (2013), https://doi.org/10.4324/9780203066348.
47 Nyanya Browne, Ph.D., , “Lured into Debt: How Payday Loans and Paycheck Apps Exacerbate Financial Struggles in Underserved
Communities,” Howard Univ. Research Centers (2023), https://coascenters.howard.edu/lured-debt-how-payday-loans-and-paycheck-
apps-exacerbate-financial-struggles-underserved
48Dan Martinez and Margaret Seikel, “Credit Card Interest Rate Margins at All-Time High,” Consumer Financial
Protection Bureau (CFPB blog), February 22, 2024, https://www.consumerfinance.gov/about-us/blog/credit-
card-interest-rate-margins-at-all-time-high/.
49 Marjin A.Bolhuis, Judd N. L. Cramer, Karl Oskar Schulz, and Lawrence H. Summers, “The Cost of Money is Part of the Cost of Living:
New Evidence on the Consumer Sentiment Anomaly.” Working paper 32163.
Cambridge, MA: National Bureau of Economic Research (2024).
50 Pew Charitable Trust, “Payday Lending in America: Who Borrows, Where They Borrow, and Why,” July 19, 2012,
https://www.pewtrusts.org/en/research-and-analysis/reports/2012/07/19/who-borrows-where-they-borrow-and-why; Pew Charitable
Trust, “What Does the Research Say About Payday Loans? Pew expert looks back at 30 years of developments in the field,” June 21,
2023, https://www.pewtrusts.org/en/research-and-analysis/articles/2023/06/07/what-does-the-research-say-about-payday-loans.
51 S. Xie, V. Wenxin Xie, X. Zhang, Extreme Weather and Low Income Household Finance: Evidence from Payday Loans, January 8, 2024;
https://www.bankofcanada.ca/2024/01/staff-working-paper-2024-1/ (having more extreme temperature days in a month increases
payday loan demand, and more extreme heat days in a month leads to deteriorating performances of existing payday loans).
52Jennifer Andre, Breno Braga, Kassandra Martinchek, & Signe-Mary McKernan, The Effects of the State Utility Shutoff Moratoria on
Credit Delinquencies during the Covid-19 Pandemic (January 22, 2024),
https://www.sciencedirect.com/science/article/abs/pii/S0148619524000122?dgcid=rss_sd_all#:~:text=We%20find%20that%20reside
nts%20of,debt%20sent%20to%20a%20collector or https://ssrn.com/abstract=4702669 or
https://doi.org/10.1016/j.jeconbus.2024.106170.
53 Final Report of the Low Income Affordability Collaborative, Appendix C, pp. 13 – 14, Docket E-2 Sub 1219, North Carolina Utilities
Commission, August 2022.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 67
Furthermore, the data shows that many households have never participated in home energy assistance
programs. The next section of this report looks at the households that are disproportionately impacted.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 68
Disproportionately impacted households
Background
The National Consumer Law Center (NCLC) reviewed a sampling of results from the 2020 Residential Energy
Consumption Survey regarding energy insecurity in the West Census Region. NCLC reviewed West Census
Region data rather than Washington state data because the state-level data sampling was insufficient to
produce statistically reliable results in cross-tabulations.
The energy insecurity variables we reviewed included the following:
Frequency of forgoing necessities to due to home energy bills
Frequency of keeping home at an unhealthy temperature due to home energy bills
Frequency of receiving a disconnection notice
NCLC cross-tabulated the variables cited above the following household characteristics:
Gross household income
Race of householder
Housing tenure
Highlights
Low-income households in the West Census Region are disproportionately likely to suffer from energy
security, such as forgoing basic necessities or receiving a disconnection request
Black, Indigenous, and people of color experience energy insecurity more frequently than other households
in the Western Census Region
Renters experience energy insecurity more frequently than homeowners in the Western Census Region
Findings
Results of this inquiry, as reflected in Figures 14-21, provide evidence of disparate energy insecurity experience
by household income, race and housing tenure. For example, households with income between $12,500 and
$14,999 were about four times more likely to receive a disconnection notice and about three times more likely
to maintain an unhealthy indoor temperature almost every month or some months than households with
income between $60,000 and $74,999.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 69
Figure 14: Frequency of receiving disconnection notice by household income in the
West Census Region
All Households 7%
Less than $5,000 17%
$5,000 - $7,499 18%
$7,500 - $9,999 16%
$10,000 - $12,499 13%
$12,500 - $14,999 21%
$15,000 - $19,999 12%
$20,000 - $24,999 11%
$25,000 - $29,999 10%
$30,000 - $34,999 7%
$35,000 - $39,999 11%
$40,000 - $49,999 11%
$50,000 - $59,999 11%
$60,000 - $74,999 6%
$75,000 - $99,999 4%
$100,000 - $149,999 4%
$150,000 or more 1%
0% 5% 10% 15% 20% 25%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 70
Figure 15: Frequency of maintaining unhealthy indoor temperature due to home
energy bills by household income in the West Census Region
All Households 11%
Less than $5,000 27%
$5,000 - $7,499 28%
$7,500 - $9,999 25%
$10,000 - $12,499 32%
$12,500 - $14,999 27%
$15,000 - $19,999 17%
$20,000 - $24,999 24%
$25,000 - $29,999 19%
$30,000 - $34,999 19%
$35,000 - $39,999 12%
$40,000 - $49,999 10%
$50,000 - $59,999 9%
$60,000 - $74,999 7%
$75,000 - $99,999 6%
$100,000 - $149,999 5%
$150,000 or more 5%
0% 5% 10% 15% 20% 25% 30% 35%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
American Indian or Alaskan Native-headed households were about three times more likely to forego
necessities almost every month due to home energy bills than white-headed households. Black-headed
households were more than twice as likely to receive a disconnection notice as white-headed households.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 71
Figure 16: Frequency of reducing or forgoing basic necessities due to home energy
bill by race in West Census Region
All Households 19%
Native Hawaiian or Other Pacific Islander Alone 43%
American Indian or Alaska Native Alone 40%
Black or African/American Alone 37%
2 or More Races Selected 30%
Asian Alone 18%
White Alone 17%
0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
Figure 17: Frequency of receiving a disconnection notice by race in West Census
Region
All Households 7%
2 or More Races Selected 20%
Black or African/American Alone 17%
American Indian or Alaska Native Alone 15%
Native Hawaiian or Other Pacific Islander Alone 9%
White Alone 6%
Asian Alone 3%
0% 5% 10% 15% 20% 25%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
Results from the 2020 RECS Western Census Region data show that households headed by an American
Indian or Alaskan Native person were particularly likely to report maintaining an unhealthy indoor temperature
due to high energy bills. Households headed by a respondent of two or more races also reported elevated
levels of this key energy insecurity indicator.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 72
Figure 18: Frequency of keeping home at an unhealthy temperature by race in the
West Census Region
All Households 11%
American Indian or Alaska Native Alone 19%
2 or More Races Selected 17%
Black or African/American Alone 15%
Asian Alone 14%
Native Hawaiian or Other Pacific Islander Alone 11%
White Alone 11%
0% 2% 4% 6% 8% 10% 12% 14% 16% 18% 20%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
Renter households were more than twice as likely to forego necessities due to home energy bills as
homeowner households. Similarly, renters were about twice as likely to maintain unhealthy indoor
temperatures as homeowner households.
Figure 19: Frequency of reducing or forgoing basic necessities due to home energy
bill by housing tenure in West Census Region
All Households 19%
Rented 29%
Occupied without payment of rent 24%
Owned 13%
0% 5% 10% 15% 20% 25% 30% 35%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 73
National and regional data demonstrate that one of the coping mechanisms used by some households in
response to unaffordable energy bills is to maintain unhealthy indoor temperatures. This coping mechanism
has been linked to serious health consequences. 54
Examination of the data on housing tenure reveals that respondents living in rental housing or in housing
occupied without payment of rent are about twice as likely as owner-occupants to report high bills leading to
maintenance of unhealthy indoor temperatures.
Figure 20: Frequency of keeping home at an unhealthy temperature by housing tenure
in the West Census Region
All Households 11%
Occupied without payment of rent 16%
Rented 16%
Owned 9%
0% 2% 4% 6% 8% 10% 12% 14% 16% 18%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
54 See, Hernandez, D., "Understanding Energy Insecurity and Why it Matters to Health," Social Science and Medicine, Vol. 167. 2016, pp.
1 - 10.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 74
Figure 21: Frequency of receiving disconnection notice by housing tenure in the West
Census Region
All Households 7%
Rented 12%
Occupied without payment of rent 11%
Owned 4%
0% 2% 4% 6% 8% 10% 12% 14%
Source: 2020 RECS microdata tabulated by National Consumer Law Center
Conclusion
Data from the West Census Region suggests that households comprised of low-income, BIPOC and renters are
more likely to experience energy insecurity. While this section looks only at quantitative data about energy
insecurity, these numbers point to real human suffering that lands hardest on low-income households, BIPOC
communities, and renters. The next section of this report looks at the laws intended to mitigate this suffering,
and the gaps in those laws.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 75
Gaps in energy affordability protections for low-income
households
Background
RCW 19.405.120 (Sec. 120) addresses the total home energy burden of low-income households and puts the
obligation of addressing that burden directly on electric utilities.
There are two main types of electric utilities:
Investor-owned utilities (IOUs), which include Avista Corp, PacifiCorp and Puget Sound Energy (PSE). Investor-
owned utilities serve about 44% of residential electric utility customers.
Consumer-owned utilities (COUs), including roughly 24 public utility districts, 17 municipal utilities and 17
cooperatives providing electricity to retail customers. Consumer-owned utilities serve about 56% of residential
electric utility customers.
The Utilities and Transportation Commission (UTC or Commission) regulates investor-owned utilities within
the state and has broad jurisdiction over its utilities as the economic regulator. The Commission’s jurisdiction
and authority are enumerated under RCW Title 80.
Consumer-owned utilities have their own locally elected governing boards and are primarily self-regulated
under their respective statutory frameworks.
The Legislature has passed a handful of laws governing utility low-income energy assistance that result in a
patchwork of programs. Some of the more precise statues only pertain to investor-owned utilities and are
enforced by the UTC. These laws and their gaps are detailed below.
Highlights
The Legislature has enacted energy assistance requirements for all electric utilities under RCW 19.405.120
(Sec. 120) and placed additional requirements on investor-owned utilities under RCW 80.28.068.
Washington’s current laws do not ensure universal access to monthly energy bill assistance programs or
comparable benefits to similarly situated households served by different utilities.
Sec. 120 allows utilities to comply with the law even if they serve few low-income households and make
little progress in reducing energy assistance need.
Sec. 120 allows inadequately designed, insufficiently funded, inaccessible energy assistance programs
unable or unlikely to serve all types of low-income households.
RCW 80.28.068(1) allows the UTC to approve rates, charges, services, and/or physical facilities at a
discount, or through grants, for low-income seniors and low-income customers. The statute requires
utilities to use reasonable and good faith efforts to seek approval on program design, eligibility, operation,
outreach, and funding proposals from its low-income and equity advisory groups. The statute requires
consultation with community-based organization to help develop and expedite the programs. It does not
set metrics for success, which the UTC sets on an ad-hoc basis. RCW 80.28.068 does not apply to
consumer-owned utilities.
RCW 80.28.068(2) allows for approved low-income programs to use means tested public benefits to enroll
customers in a low-income discount rate or grant so long as the eligibility criteria for the other program
does not exceed the low-income definition set forth by RCW 19.405.020. RCW 80.28.068 does not apply to
consumer-owned utilities.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 76
RCW 80.28.425 requires investor-owned energy utilities to submit multi-year rate plans to the Commission.
Under the multi-year rate plan statute, the Commission must (at minimum) approve low-income assistance
programs at double the percentage of the underlying rate increase for each year of the rate plan. When
approving a multi-year rate plan, the Commission must approve performance measures that track and
assess the utilities’ operations in many areas including but not limited to: affordability, rate stability, cost of
service, and customer satisfaction and engagement. RCW 80.28.425 does not apply to consumer-owned
utilities.
Summary of prevailing statutes
RCW 80.28.068
RCW 80.28.068 was first enacted in 1999 to allow the Utilities and Transportation Commission to approve rate
discounts for low-income customers of electric and gas companies. It was subsequently revised in 2009 and
most recently in 2021. The law only applies to investor-owned utilities.
RCW 80.28.068 requires investor-owned utilities propose low-income discount rates to the Commission, as
well as grants and other low-income assistance programs. Investor-owned utilities must make reasonable and
good faith efforts to seek approval of these programs from low-income energy assistance and equity advisory
groups. The programs must be delivered in coordination with community action agencies or other community-
based organizations, and with streamlined eligibility rules and “substantial outreach and community
engagement.”
The Utilities and Transportation Commission is key to implementation of RCW 80.28.068. The Utilities and
Transportation Commission has extensive powers to convene low-income advocates and utilities to design
programs and drive reforms across the three investor-owned utilities.
The law does not apply to consumer-owned utilities, and the reforms at the Utilities and Transportation
Commission do not impact low-income households served by consumer-owned utilities.
Relationship with RCW 80.28.425
RCW 80.28.425 requires investor-owned energy utilities to submit multi-year rate plans to the Commission.
Under the statute, the Commission must (at minimum) approve low-income assistance programs at double the
percentage of the underlying rate increase for each year of the rate plan. Additionally, when approving a multi-
year rate plan, the Commission must approve performance measures that track and assess the utilities’
operations.
The Commission has created a set of metrics that measure and evaluate IOU assistance programs. Although
the metrics are subject to change or revision in the future, the UTC requires IOUs to report the following
metrics on a census tract level:
• Arrearages by month
• Percentage of customers in arrears with an AMP
• Average Energy Burden
• Percentage of customer funded assistance funds disbursed
• Number of customers that participate in one or more bill assistance program
RCW 80.28.425 does not apply to consumer-owned utilities.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 77
Gaps in RCW 80.28.068
RCW 80.28.068 includes more specific provisions around bill assistance mechanisms than RCW 19.405.120,
but also relies on UTC interpretation and negotiations between low-income advocates and utilities.
Gaps in RCW 80.28.068 include:
• Absence of statutory goals to evaluate program success related to household outcomes, such as
program participation rates and reductions in energy burden
• Requirements to conduct regular low-income energy assistance need assessments
• Requirement to offer assistance to households when they sign up for electric or natural gas service
• Requirement that programs meet best practices in human-centered design
RCW 19.405.120 (Sec. 120)
The Legislature in 2019 required electric utilities make programs and funding available by July 31, 2021, and
places the obligation of addressing energy assistance need directly on electric utilities. Sec. 120 requires
electric utilities provide assistance to low-income households, and to the extent practicable prioritize
assistance to low-income households who spend more than 6% of their household income on home heat and
power. 55
Low-income is defined under state law (RCW 19.405.020) and administrative rule (WAC 194-40-030) as
household incomes that do not exceed the higher of 80% of area median income or 200% of federal poverty
level, adjusted for household size.
Utilities must submit assessments and reports on a biennial basis to Commerce. Utilities decide the methods
and metrics used for the assessments. Commerce is then required to aggregate utility reports and provide a
summary of utility programs, energy burden, and energy assistance need to the Legislature on a biennial basis.
The Legislature recognized that Sec. 120’s requirements may be inadequate and not the right approach, and
required Commerce to evaluate a number of additional mechanisms and alternative approaches for assisting
household in Sec. 120(6).
Gaps in Sec. 120
While Sec. 120 provides a clear statement of the legislative intent that electric utilities are responsible for
making progress in reducing energy burden, the statute does not ensure utility energy assistance programs are
well-designed, sufficiently funded, or readily accessible. It does not require continuous data-driven evaluations
or assessments, or the co-creation of bill assistance programs with households and local service providers.
Perhaps most important, Sec. 120 does not:
• Ensure universal access to low-income energy monthly bill assistance
• Ensure uniform benefit levels for similarly situated low-income households statewide
• Ensure programs are sufficiently funded to meet energy assistance need
• Require utilities work with tribes and community partners who specialize in serving low-income
households
• Require utilities improve the process for households to enroll in monthly bill assistance programs and
allow any community partner the ability to assist households
55 RCW 19.405.120
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 78
• Require utilities perform ongoing outreach and enrollment campaigns tailored to historically
marginalized groups, or ensure outreach and enrollment campaigns deliberately avoid and proactively
address poverty stigmas
• Ensure utilities develop data-driven, evidence-based plans and assessments that align with national
best practices and account for local household needs
• Systematically interrogate how the unequal distribution of household experiences might be structured
by a household’s position within the intersecting fields of race, income, gender, age, disability, and
geographical location.
• Measure progress based on meaningful outcomes for low-income households, such as program
participation rates and reductions in energy burden
These gaps in policy directly impact low-income households:
• Low-income households do not have universal access to monthly energy bill assistance no matter
where they happen to live
• Low-income households do not have access to bill assistance programs with uniform benefit levels
• Low-income households do not have a uniform way to easily enroll in assistance programs
• Low-income households cannot go to any community organization and receive assistance
These gaps may also have impacts on households if utilities are not proactively addressing these areas
under other statutes or the direction of their regulator:
• Outreach and enrollment campaigns may not be tailored to historically marginalized groups
• Low-income households may not benefit from programs informed by data-driven plans and
assessments, such as low-income needs assessments, that align with national best practices
• Low-income households may not benefit from systematic evaluations of unequal distribution of
household experiences might be structured by a household’s position within the intersecting fields of
race, income, gender, age, disability, and geographical location, or any corresponding programmatic
reforms to address identified disparities
RCW 74.38.070
Low-income energy bill assistance first appeared in statute in 1979. The law grants permissive authority for
public utility districts and municipalities to provide reduced rates for low-income seniors. Low-income disabled
citizens were added to the statute in 1988. The statute received its last significant revision in 1998, when it
was broadened to include all low-income citizens.
RCW 74.38. 070 requires any reduction in rates granted in any manner to low-income senior citizens or other
low-income citizens be uniformly extended to low-income senior citizens or other low-income citizens in the
service area.
Gaps in RCW 74.38.070
RCW 74.38.070 does not require utilities offer discounts to low-income households, and it says nothing about
the design, administration, or evaluation of program beyond non-discrimination.
Conclusion
The Legislature has granted utilities explicit authority to pursue low-income energy assistance programs to
low-income households for 45 years, and six years ago the Legislature mandated utilities offer programs and
funding to low-income households. Investor-owned utilities have the most specific requirements, and benefit
from a supportive regulator in the Utilities and Transportation Commission.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 79
Built into each of these laws is the fragmentation of home energy assistance by utility service provider. The
utility-by-utility approach to energy bill assistance does not address the fundamental challenges households
and service providers highlighted in Commerce’s listening sessions, surveys, and local service provider
workshops. Indeed, while the laws have grown increasingly specific, the statutes still have significant gaps.
None of the statutes provide universal access, uniform benefit levels, or human-centered, user-friendly monthly
bill discounts for low-income households statewide, and none set statutory goals or mandates for program
participation.
Table M: Summary of Washington’s Principal Low-Income Energy Bill Assistance
Laws
RCW The law says The law does not require utilities
Make programs and funding available and
74.38.070 Public utility districts and municipalities may
accessible for low-income households
(1979, 1980, provide assistance to low-income seniors and
1988, 1990, other low-income households on a non-
Limit utility programs to seniors or customers
1998, 2002) discriminatory basis
with disabilities
Ensure low-income households have universal
access to monthly bill assistance
Ensure low-income households at one utility
receive a comparable level of assistance to
households of another utility
Prioritize funding to households with greater
The law addresses the full energy burden of assistance need
low-income households and puts the obligation
of addressing energy assistance need directly Track progress based on program participation
on electric utilities rates and reductions in energy burden
Electric utilities must make energy assistance Conduct third-party low-income needs
19.405.120 programs and funding available to households assessments that examine disproportionate
(2019) outcomes on historically marginalized groups
Electric utilities must submit data and
assessments of their programs to Commerce Establish statutory goals related to household
on a biennial basis outcomes, such as program participation rates
and reductions in energy burden
Commerce submits a summary report to
Legislature on a biennial basis Ensure rural utilities with a disproportionate
share of low-income households can meet
energy assistance need without rate hikes
Provide assistance in the preferred languages
of households beyond written translation
Extend assistance to households when they
sign up for electric or natural gas service
Apply to consumer-owned utilities
Requires investor-owned utilities propose low-
80.28.068 income discount rates to the UTC, after seeking
Achieve statutory goals specific to household
(2021) input from advisory groups.
outcomes, such as program participation rates
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 80
RCW The law says The law does not require utilities
Programs must delivered with community Conduct third party low-income energy
action agencies or other community assistance need assessments
organizations, and with streamlined eligibility
rules Extend assistance to households when they
sign up for electric or natural gas service
Provide service in the preferred languages of
households
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 81
Washington’s patchwork of utility bill assistance
programs
Background
Electric utility energy assistance programs, and their low program participation rates, reflect the current utility-
by-utility approach under Washington law.
Electric utility monthly energy bill assistance programs represent a patchwork of utility energy assistance
programs with many holes where crucial programs and funding are absent. This patchwork has remained
relatively the same since utility reported programs and expected programmatic changes in Commerce's 2023
Legislative Report.
Layered over the patchwork of utility programs is a federal block grant program, the Low-Income Housing
Energy Assistance Program (LIHEAP), and a few relatively small state programs that offer limited assistance
to low-income households. Additional one-time funding from the federal government and Legislature has
helped reduce outstanding arrearages for low-income households in the wake of the COVID-19 pandemic.
Somewhat related, the Legislature in 2024 provided a one-time allocation of $150 million from the Climate
Commitment Account to help low-income and moderate-income households with the clean energy transition.
Funds will be distributed as one-time $200 payments to households by September 15, 2024. 56 Notably, the
funds were appropriated to “help with the costs of the clean energy transition,” including transportation costs,
and could be distributed to middle income households (150% of AMI). The funds were not allocated for the
expressed purpose of addressing the home energy burden of low-income households.
Highlights
• Many low-income households do not have monthly low-income bill assistance programs available to
them, because consumer-owned utilities often adopt income eligibility requirements below state law
and administrative rule; require households meet additional eligibility criteria; or choose to offer no
monthly bill assistance program at all
• The inconsistences across the patchwork of utility energy assistance programs include varied
application requirements and often limited enrollment processes, incomplete information about
eligibility and application requirements, and other barriers to understanding and enrolling in utility low-
income energy bill assistance programs
• Many consumer-owned utility bill assistance programs depend on unreliable funding sources that are
insufficient to serve low-income households and meet energy assistance need
• Investor-owned utilities have reformed their programs yet program participation rates continue to lag
significantly behind statewide programs with similar eligibility criteria, such as the Supplemental
Nutrition Assistance Program, which may reflect the inherent difficulties of having utilities administer
assistance programs at scale
56 Engrossed Substitute Senate Bill 5950, Sec. 130 (2024)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 82
Survey of utility programs in March 2024
In March 2024, Commerce surveyed utility webpages to assess the availability and accessibility of utility low-
income energy bill assistance programs, and to better understand the availability and accessibility of programs
from an individual household perspective. 57
Methodology
Commerce surveyed the webpages of Washington's roughly 50 electric utilities for low-income energy bill
assistance program information and followed relevant hyperlinks posted on utility webpages to view all readily
available program information.
Great care was taken to thoroughly document this information to minimize potential data collection errors.
Commerce collected data from utility webpages in an Excel workbook and preserved the webpages and
program information in PDFs. 58 Any information that was not readily available was labeled as "unknown."
This survey includes important information, such as future utility plans or program participation rates, which
will be available in Commerce's Biennial Low-Income Energy Assistance Legislative Report (Sec. 120(6)),
expected before January 1, 2025.
Key findings of 2024 survey of utility webpages
• Nearly all utility low-income energy bill assistance programs do not match state law (RCW 19.405.020)
and administrative rule (WAC 194-40-030).
• Most programs funded through utility operations have non-income eligibility criteria that deny many
low-income households access to monthly bill assistance.
• Low-income households in one utility service area may receive significantly different benefits if they
were located in another utility service area.
• Many of the programs have unreliable funding sources insufficient to meet all energy assistance need.
• Income eligibility criteria listed on utility webpages was found to be in some cases inaccurate and
outdated.
• Low-income households must navigate fragmented and vastly different enrollment processes
depending on their electric utility.
• Low-income households interested in applying for assistance may not find information on their utility's
website about how long it may take from application to receive of benefits.
57 RCW 19.405.120 (Sec.120) requires utilities submit data on their programs on a biennial basis. Commerce last published data on
utility assistance programs in 2023. Utilities were required to submit data for the reporting years 2022 and 2023 by April 1, 2024. That
data will be aggregated, cleaned, and published before Jan. 1, 2025. It will be made available on Commerce's Clean Energy
Transformation (CETA) Energy Assistance webpage at that time.
58 RCW 19.405.120: Energy assistance for low-income households. (wa.gov)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 83
Inconsistent low-income energy affordability protections
Income eligibility requirements that do not match state law and
administrative rule
Many utilities use eligibility criteria that fall below the higher of 80% of the Area Median Income (AMI) or 200%
of the Federal Poverty Level (FPL). 59
By setting income requirements below state law (RCW 19.405.020) and administrative rule (WAC 194-40-030),
low-income households that should be eligible for energy assistance under state law and administrative rule
are denied access to utility assistance programs.
Washington's investor-owned electric utilities, under the direction of the Utilities and Transportation
Commission, have deliberately matched the eligibility requirements set in state law (RCW 19.405.020) and
administrative rule (WAC 194-40-030).
Commerce observed in its survey of utility webpages that Mason County PUD No 3 was the only consumer-
owned utility with a program funded through utility operations that has eligibility criteria that matches state law
and administrative rules in March 2024. 60 Okanogan Electric Cooperative and Benton PUD No. 1 offer donation
programs that match state law and administrative rule.
Not matching state law and administrative rule is not simply a small
utility issue
Washington’s large consumer-owned utilities do not match state law (RCW 19.405.020) and administrative rule
(WAC 194-40-030) requirements for income eligibility.
Use of income eligibility criteria that do not match state law or administrative rule may make a considerable
number of low-income households ineligible for assistance.
Tacoma Power’s Bill Credit Assistance program uses 300% FPL for determining income eligibility. For a one
person household, 300% FPL would be $45,165. Tacoma’s other bill assistance program is available to seniors
who fall below 225% FPL, which is $33,885 for a one person household. In comparison, 80% AMI for a one-
person household in Pierce County is $60,200. That’s a difference of $15,035 and $26,315, respectively.
Snohomish Public Utility District No 1 only uses 200% FPL, although AMI is significantly higher in Snohomish
County. Clark Public Utility District offers no monthly bill discount program at all. 61
Seattle City Light uses 70% of state-median income (SMI). 62 Table N: Seattle Median Income versus State
Median Income Comparisons shows the comparison between AMI and SMI income limits in Washington and
the city of Seattle.
59 88% of programs use more restrictive eligibility criteria than the state law (See Appendix J: Survey of utility programs and webpages)
60 See Appendix J: Survey of utility programs and webpages
61 Roughly 9% (5 out of 58) of Washington utilities do not offer bill assistance programs
62 State Median Income does not match the income eligibility metrics in the state law (RCW 19.405.020)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 84
Table N: Seattle Area Median Income versus State Median Income Comparisons
Household/Family Size 80% AMI (2023) 70% SMI (2023) Difference
1 $70,650 $44,268 $26,382
2 $80,750 $57,900 $22,850
3 $90,850 $71,520 $19,330
4 $100,900 $85,140 $15,760
5 $109,000 $98,760 $10,240
6 $117,050 $112,392 $4,658
The difference in AMI and SMI reflects the fact that the cost of living in Seattle is significantly higher than the
rest of the state.
Using statewide median income does not account for this difference in the cost of living, which deems low-
income households that would be eligible under state law (RCW 19.405.020) and administrative rule (WAC
194-40-030) as ineligible under Seattle City Light’s income eligibility requirements.
Low-income households may not be able to access programs because
consumer-owned utilities have adopted additional eligibility
requirements that rule out many low-income households from
accessing monthly low-income energy assistance
Another way of restricting access to assistance is to require eligibility criteria unrelated to income. Many
utilities limit their bill assistance programs to senior citizens or individuals with disabilities. 63 One program
includes veterans64 and another program includes veterans, widows and widowers. 65
Limiting low-income energy assistance programs to a few households based on non-income criteria excludes
other households. For instance, if a single mother and a child happens to be served by a utility with restricted
programs, she would not be able to receive month-to-month energy bill assistance for her and her child, even if
their household’s energy assistance need is greater than that of someone deemed eligible for the program.
Restricting access to a subset of low-income household does not comply with the requirement in Sec. 120,
which requires that utilities make programs and funding available to low-income households, and to the extent
practicable prioritize funds to households who spend more than 6% of their household income on home energy
bills. There is no language in the statute that allows utilities to limit access to the programs to only certain
groups of low-income households and meet Sec. 120 requirements for programs and funding to be available
to low-income households.
63 Over half (59%) of utility-funded bill assistance programs exclusively serve certain low-income groups such as seniors or individuals
with disabilities
64 Cowlitz County PUD No 1 and Benton County PUD No 1
65 Benton County PUD No 1
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 85
Investor-owned utilities have programs open to all low-income households.
Low-income households likely encounter many challenging
application and enrollment requirements to utility energy bill
assistance programs
Low-income households experience vastly different enrollment processes across utilities, 66 and low-income
households and community organizations face significant uncertainty about whether low-income bill
assistance programs exist and how to access them. 67 The exception is community action agencies, which
administer other energy-related social services.
An example of limited enrollment may be best illustrated by City of Chewelah. The Chewelah Electric
Department only offers a residents five possible days to apply for its utility bill assistance program. Online
applications can be submitted at 11 a.m. on Oct. 2, Feb. 1, and June 3. Applications can be taken over the
phone at 11 a.m. on Dec. 1 and April 1. The city webpage notes that after submitting an application, a
household may wait up to 90 days for an appointment at the local community action agency. 68
Low-income households may have very different utility bill assistance
programs offered to them with very different benefit amounts
Utility funded programs have the following bill design makeup:
• 51% of programs provide a monthly discount rate
• 18% of programs provide a lump sum bill credit monthly
• 12% of programs provide a lump sum bill credit yearly
• 12% of programs did not provide publicly available information on the bill assistance mechanism or
assistance amount
• Investor-owned utilities are required to offer bill discounts and have adopted tiered bill discounts based
on the recommendation of their low-income advisory groups and at the direction of the Utilities and
Transportation Commission.
It is generally unclear how donation-based provide assistance:
• 77% of donation-based programs did not provide publicly available information on the bill assistance
mechanism or assistance amount
• 22% of donation-based programs provide a lump sum bill credit yearly
Programs can offer significantly different assistance levels across utilities
Commerce’s survey of utility webpages found flat monthly discount rates range from 20 to 60%. Monthly lump-
sum bill credits range from $9.55 to $55.51. Yearly lump-sum bill credits range from $75 to $1,320.69
66 See Appendix J: Survey of utility programs and webpages
67 See Appendix G: Household surveys and Appendix H: Community organization listening sessions summary
68 See Appendix for Webpage analysis
69 See Appendix J: Survey of utility programs and webpages
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 86
Low-income households in some parts of the state may only receive
assistance during certain times of the year
Less prominent ways of limiting assistance to low-income households occurs through placing seasonal
restrictions on assistance. 70
Households may struggle to pay their energy bills at any time during the year, and increased cooling needs
during hotter and hotter summers raise significant questions about the merits of limiting bill assistance to
winter months.
Low-income households may only be able to get one-time assistance
insufficient to meet energy assistance need
Low-income households served by consumer-owned utilities may only have donation programs, which have
been shown to be unreliable, insufficient, and do not provide a source of sustained energy burden reduction for
low-income households. 71
Pierce County case study
Pierce County provides a microcosm of the state when it comes to monthly low-income energy assistance
programs. As shown in Table O: Pierce County Overview. The county has 12 utilities. Only one of the utilities,
Puget Sound Energy, Inc., offers a monthly low-income energy bill assistance open to all low-income
households as defined under state law and administrative rule. The other utilities tend to run limited donation
programs, assistance programs that restrict eligibility to only certain persons, such as seniors and disabled, or
programs with income eligibility criteria that fall below state law and administrative rule. Low-income
households in Pierce County may have vastly different experiences accessing energy bill assistance based
solely on where they happen to live in Pierce County. Many have access to no monthly bill assistance
programs at all.
Table O: Pierce County Overview
Number of
Number of low-
Number of
low-income income
Number of Number of low-income
energy bill monthly
Approximat Approximat low-income low-income energy bill
assistance energy bill
e service e number bill bill assistance
Energy programs assistance
Utilities territory (in of assistance assistance programs
services that match programs
Pierce residential programs, programs w/o non-
state law that match
County) customers including w/o income
and state law
donations donations eligibility
administrat and
restrictions
ive rule administrat
ive rule
Tacoma
Electricity Tacoma 183,000 2 2 1 0 0
Power
70 Lewis County PUD 1
71 Low-Income Energy Assistance 2023 Legislative Report
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 87
Number of
Number of low-
Number of
low-income income
Number of Number of low-income
energy bill monthly
Approximat Approximat low-income low-income energy bill
assistance energy bill
e service e number bill bill assistance
Energy programs assistance
Utilities territory (in of assistance assistance programs
services that match programs
Pierce residential programs, programs w/o non-
state law that match
County) customers including w/o income
and state law
donations donations eligibility
administrat and
restrictions
ive rule administrat
ive rule
Western
Pierce
Peninsula
County,
Light Electricity 30,000 3 2 0 0 0
including
Company
University
Place
Northweste 118,162
rn parts of electric
Puget Tacoma, customers
Electricity,
Sound including 3 2 2 1 1
natural gas
Energy, Inc. Puyallup 159,428
and gas
Tacoma customers
Greater
Lakewood
area,
Lakeview
including
Light and Electricity 2,824 1 0 0 0 0
south
Power
Tacoma
and city of
Lakewood
Ohop Rural parts
Mutual Electricity of Pierce 4,808 2 1 0 0 0
Light Co. County
Town of
Electricity Eatonville 1,274* 0 0 0 0 0
Eatonville
Parkland
Light & Electricity Parkland 4,604* 1 0 0 0 0
Water Co
Greater
areas
Elmhurst around
Mutual central
Electricity 15,043* 1 0 0 0 0
Power & Pierce
Light Co County,
including
Spanaway
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 88
Number of
Number of low-
Number of
low-income income
Number of Number of low-income
energy bill monthly
Approximat Approximat low-income low-income energy bill
assistance energy bill
e service e number bill bill assistance
Energy programs assistance
Utilities territory (in of assistance assistance programs
services that match programs
Pierce residential programs, programs w/o non-
state law that match
County) customers including w/o income
and state law
donations donations eligibility
administrat and
restrictions
ive rule administrat
ive rule
Steilacoom
City of
Public Electricity 2,904* 1 1 0 0 0
Steilacoom
Works
Town of
Town of
Ruston Electricity 631* 0 0 0 0 0
Ruston
Utility Dept.
City of City of
Electricity 3,550* 1 1 0 0 0
Milton Milton
Tanner
Electric Anderson
Electricity 835* 1 0 0 0 0
Cooperativ Island
e
Challenges utilities encounter implementing energy assistance laws
Utilities and utility staff face a number of challenges when implementing bill assistance programs. Some of
these challenges can be mitigated or addressed, but many are inherent in the utility-by-utility approach to low-
income energy assistance. Both these individual utility and structural challenges within the utility-by-utility
approach contribute to program outcomes for low-income households. Indeed, while investor-owned utilities
have adopted more extensive programs and seen boosts in program participation, they continue to struggle
with relatively low-program participation rates.
The rural utility dilemma
Many of the rural counties with disproportionately burdened populations are served by relatively small electric
utilities. 72 For example, Ferry County is served by Ferry County PUD No 1 — one of the state's smallest utilities.
It has 0.8% of the residential customers and 1.7% of the revenues of Seattle City Light. Ferry County PUD No
1’s service territory is one of the most low-income and energy burdened parts of the state.73
It may be difficult for Ferry County PUD No 1 to provide ratepayer-funded energy assistance sufficient to
address the energy burden of its low-income households without rate hikes, because of its high proportion of
low-income, energy-burdened customers compared to larger utilities, such as Seattle City Light. Fully
addressing the energy burden of low-income customers for utilities with a disproportionate share of low-
income customers could result in other customers becoming energy burdened.
72 Low-Income Energy Assistance 2023 Legislative Report
73 Form EIA-860 detailed data with previous form data (EIA-860A/860B)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 89
It is important to note that the rural utility dilemma extends beyond simply funding needs of households but
also the costs to stand up and deliver efficient, equitable, and quality services for low-income households.
These costs may be significant, and it may be highly inefficient from a statewide perspective to require these
utilities perform the necessary elements for efficient, equitable, and quality programs for households.
Addressing energy burden from fuel sources other than what is
provided by the utility
Sec. 120 intends to address the total household energy burden and puts the obligation of addressing that
energy burden directly on electric utilities. 74 Electric utilities may struggle to cover the costs and deliver
immediate assistance for households using non-electric power sources, such as natural gas, propane, and
wood.
Utilities often struggle to gather and track household demographic,
energy burden, and assistance need data in their service territory
Utilities have traditionally tracked their physical infrastructure and revenues — not household demographics,
energy burden, or energy assistance need. Their lack of tracking important information for administering low-
income programs may be because many of their service territories overlap, making it difficult to track this
information.
There are ways to gather and track demographic information, energy burden, and assistance need. Only a
handful of utilities have invested in this information. 75 Commerce is unaware of any utility using information
from statewide low-income energy assistance programs to help inform their programs and program
development.
Utilities generally do not conduct income verification procedures
Many utilities do not want to conduct income verification for eligible households, because they do not want to
retain personal demographic information on their customers. Instead of doing income verification in-house,
most utilities send households to community action agencies.
Investor-owned electric utilities recently started conducting income verification in-house alongside community
action agencies.
Policy slippage
An immense number of staff and local decision-makers are needed to implement low-income monthly bill
assistance programs for over 50 utilities. Most utilities have not implemented Sec. 120 requirements to offer
two energy assistance programs open to low-income households as defined in state law and administrative
rule, with exception of the investor-owned utilities, which are required to do so by the Utilities and
Transportation Commission.
The slippage in implementation means state law and administrative rules that are specific are not being
implemented, or may not be being implemented effectively, at the local level. Any effort to reform utility
programs from the state level will require extensive coordination by more than 50 administrators and local
74 RCW 19.405.020; RCW 19.405.120
75 Low-Income Energy Assistance 2023 Legislative Report
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 90
decision makers, no matter the policy; even then, it is not guaranteed that statutes and administrative rules will
be uniformly implemented.
Conclusion
Washington’s patchwork of programs reflects the inconsistencies and broken communications that arise when
fragmenting the design and administration of essential social services across more than fifty different entities
that often have overlapping service territories. This outcome matches the challenges identified by households
and local social services providers of getting resources to households in need.
Even investor-owned utilities with their relatively more robust programs continue to struggle with getting their
program participation rates near that of statewide programs, which may be the result of the fragmentation of
programs and breakdown of communications about what assistance is available to low-income households
across utility providers overall.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 91
Alternatives under a utility-by-utility approach
Background
Utilities asked Commerce to evaluate several alternative options to a statewide approach as part of this
proviso. While these alternative options do not align with the legislative requirement to recommend a design of
a statewide energy program to address the energy burden and provide access to energy assistance for all low-
income households through a universally accessible statewide program, Commerce is providing an analysis of
these options for the Legislature to be able to compare a statewide program to alternative policy approaches.
Each of the alternative approaches tries to fix a discrete and individual problem by adding more layers or
functionality to Washington’s patchwork of programs or pushing more funding through existing programs. In
reality, the reasons why utility programs have low program participation rates are more nuanced, complex, and
sometimes structural than these options suggest.
Perhaps more importantly, additional policy layers and funding approaches under a utility-by-utility approach
ignore structural inequalities that influence outcomes for low-income households in ways that are sometimes
hard to see: Who has access to access human-centered, user-friendly assistance and who does not.
A statewide data clearinghouse
A “statewide data clearinghouse” is the idea that utilities simply need the state to identify low-income
households for utilities. Proponents of this approach suggest the state could provide lists of households
enrolled in state programs, such as the Supplemental Nutrition Assistance Program (SNAP), or federal income
information, such as through information submitted to the IRS or disclosed to Medicaid.
There are many federal and state laws and administrative statutes that limit access to household income
information and prohibit sharing lists of households enrolled in many state and federal programs unless the
data is being shared to a program directly related to administration of the specific program or, in some cases,
for implementation of programs that directly relate to purposes and goals of the programs. 76 For instance, lists
of SNAP participants can be shared under certain circumstance for implementation of local food assistance
programs.
There is a long history of Washington agencies, companies, and local governments seeking access to state
and federal low-income information from DSHS. Commerce, DSHS, and Commerce’s IT consultants spent
many months exploring potential opportunities of sharing lists of households with utilities.
DSHS found that federal statutory barriers prevent data sharing. DSHS is seeking a legal waiver from the
federal government to share SNAP data with Commerce. It remains unclear whether that data could be then
passed to investor-owned or consumer-owned utilities.
Providing lists of households to utilities would not provide universal access or uniform benefit levels to low-
income households. It would not provide a uniform way to enroll in utility programs, fix fragmented broken
communications, or provide comprehensive multilingual services and enrollment campaigns. It would not
address funding issues for utilities with a disproportionate share of low-income households, and may
exacerbate them. A data clearinghouse would not help households not enrolled in statewide programs.
76 Appendix L: Data sharing to streamline enrollment
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 92
Additional funding for utility low-income energy assistance programs
Another option was for the Legislature to pump more funding through the existing patchwork of utility
programs. Unfortunately, simply pushing more funding through existing system of energy assistance programs
would not address current bottlenecks of having roughly 50 utilities offering programs with varying and often
limited program eligibility criteria, enrollment processes, multilingual services, comprehensive enrollment
campaigns, and programmatic evaluations and other quality controls.
The state could choose to condition funding based on programmatic reforms and deliver funding only to
utilities unable to meet energy assistance targets with customer revenues.
This idea comes from Chapter 188, Laws of 2021, which the Washington Legislature passed in 2021. It permits
the UTC to approve, disapprove, or approve with modifications energy assistance proposals of the following
types:
Any proposal to recover from ratepayers up to five percent of the total revenue requirement for each year
of a multiyear rate plan for tariffs that reduce the energy burden of low-income residential customers
including, but not limited to: (a) bill assistance programs; or (b) one or more special rates. For any
multiyear rate plan approved under this section resulting in a rate increase, the commission must approve
an increase in the amount of low-income bill assistance to take effect in each year of the rate plan where
there is a rate increase. At a minimum, the amount of such low-income assistance increase must be equal
to double the percentage increase, if any, in the residential base rates approved for each year of the rate
plan. The commission may approve a larger increase to low-income bill assistance based on an
appropriate record.
The Legislature could build on this law and provide state funding only if a utility's energy assistance
expenditures exceed the 5% threshold. Amounts over the threshold could be returned to utilities as a credit
against the public utility tax. Like the system benefits charge, it could be an effective mechanism to help
utilities in areas of the state with high energy burden provide the necessary assistance to their customers.
The 5% threshold appears to be substantially higher than current low-income assistance funding levels, so
significant increases in utility spending could occur without triggering the tax credit provision. As noted
elsewhere, low-income customers who do not participate in the program and non-low-income households
could see rate changes. Streamlined enrollment and improved outreach and community engagement could
increase program participation and reduce the overall number of non-participating low-income households.
Additional funding for the Low-Income Home Energy Assistance
Program (LIHEAP)
The Legislature could choose to provide more funding to LIHEAP, but that would not address the restrictive
eligibility requirements of the program set by the federal government. The most notable restriction is the
income eligibility criteria of 150% FPL, which is $30,660 for a household of two. LIHEAP also includes
citizenship requirements, which further restricts availability.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 93
Providing additional funding for LIHEAP would not address ongoing energy burden, because LIHEAP is an
annual grant program. Once the grant is spent, energy bill assistance is no longer available through the
program until the household navigates LIHEAP’s enrollment process the following year. 77
Additional funding for the Heat and Eat Program
The Heat and Eat program is a special energy assistance program provides up to twenty dollars and one cent
in federal low income home energy assistance program (LIHEAP) benefits to households receiving both SNAP
and LIHEAP. It may be possible for the amount of assistance through the Heat and Eat program to be
increased; however, LIHEAP serves relatively few households in the state and therefore this mechanism would
not reach many low-income households.
Additional funding for the Public Utility Tax Credit for Home Energy
Assistance
Electric and gas utilities can request a public utility tax credit for energy assistance they give to low-income
customers. The statute caps the total credit at $2.5 million per year. The tax credit is set to incentivize electric
and gas utility companies to provide additional energy assistance to low-income customers. Although tax
preference utilities report increasing amounts of energy assistance, the credit is likely of limited influence
relative to statutory requirements under Sec. 120 and RCW 80.28.068. Based on these observations, increasing
the public utility tax credit is likely to have negligible effects on program participation rates and reductions in
energy assistance need.
Continuing Washington Families Clean Energy Credits Program
In the 2023-2025 supplemental operating budget, Commerce was instructed to start up the Washington
Families Clean Energy Credits Grant Program, funded by the climate commitment account.
The Washington Families Clean Energy Credits Grant Program dedicates $150 million to assist low- and
moderate-income households with the clean energy transition. This initiative will offer bill credits of $200 per
household to eligible residential customers through their electric utility provider. The Department of Commerce
will distribute grants to all utility companies in Washington, enabling them to pass on $200 bill credits to
customer accounts by September 15, 2024.
Utilities must first prioritize bill credits for customers at or below 80 percent area median income (AMI) and if
funds remain, may expand bill credits for customers up to 150 percent of area median income (AMI).
Customers residing in overburdened communities and vulnerable populations as defined under RCW
70A.02.010 will receive additional prioritization. This includes individuals who have participated in programs
like the Low-Income Housing Energy Assistance Program (LIHEAP), utility payment plans, or other ratepayer-
funded assistance programs. Utilities may also qualify customers through self-attestation.
The Washington Families Clean Energy Credits Program does not offer monthly low-income energy bill
assistance to households, and the $200 is not sufficient to address the energy assistance needs of most
energy burdened low-income households nor is it targeted to households in greatest need. The program has
income eligibility criteria that include households that are not low-income and the credit is intended for
transportation and other energy costs, and the assistance is a one-time flat amount.
77 Washington State Low Income Home Energy Assistance Program (LIHEAP)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 94
Implementation of the Washington Families Clean Energy Credits Program will provide insights for how a
statewide monthly program may identify and deliver benefits to low-income households. However, the program
is fundamentally not designed to provide universal access to low-income monthly energy bill assistance or
address energy assistance need.
Additional statutory requirements
Another option is to tighten and expand the requirements on utility programs.
A comprehensive approach may include requiring utilities to:
• Offer monthly bill assistance programs for low-income households funded through utility operations
• Offer streamlined eligibility requirements, including self-attestation with limited documentation
• Perform biennial energy assistance needs assessments conducted through a third-party contractor
with expertise in equity and environmental justice
• Conduct ongoing data-driven, evidence-based programmatic evaluations
• Track program participation rates in their bill assistance programs and disparities in program
performance across demographic groups on an ongoing basis
• Partner with rural organizations in their service territory to expand program enrollment for historically
marginalized communities
• Partner with directly Black, indigenous, and people of color organizations in their service territory to
expand program enrollment for these historically marginalized communities
• Provide in-person translation services and multilingual materials for all languages reasonably believed
to be in the service territory
• Provide an online portal and in-person options for enrolling in bill assistance programs
• Provide low-income households with information about federal, state, and local energy efficiency
services and where they can apply for them
• Provide information to low-income households about where they can find additional low-income
services beyond energy assistance
• Co-develop and seek approval for monthly low-income bill assistance program designs, eligibility,
operation, outreach and funding from low-income households and community organizations that
specialize in serving low-income households, including households and organizations from Black,
indigenous, and people of color communities.
There would need to be program standards, reporting methodologies and requirements established to ensure
consistent program implementation across utilities.
This policy approach would retain the utility-by-utility approach to energy assistance. If history holds, it would
not avoid policy slippage absent significant investment in legislative and programmatic oversight from the
state. It would not address funding issues in areas of the state with a disproportionate share of low-income
households and also be highly inefficient compared to a statewide energy assistance program. It also would
not address broken communication processes across overlapping utility service territories.
Commerce conducting outreach on behalf of utilities
Some utilities suggested Commerce conduct outreach and enrollment campaigns on behalf of utilities. The
variety of utility programs, eligibility requirements, processes for applications and enrollment, benefit levels
and amounts, ad-hoc utility programmatic changes, and other utility-by-utility considerations mean it would be
implausible to create consistent messaging for low-income households. Moreover, Commerce does not have
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 95
staff to track and implement robust outreach and enrollment campaigns for multiple low-income energy
assistance programs, and it would be extremely inefficient to do so.
Conclusion
The alternative approaches to patch gaps and address issues that stem from administering low-income
monthly energy bill assistance programs across 50+ utilities do not address the fragmentation and
fundamental inconsistencies and inefficiencies of administering 50+ monthly low-income energy bill
assistance programs.
Table P: Policy layering and supplementary funding approaches
Augmented utility-
by-utility Idea The approach does not address
approaches
Federal prohibitions on sharing data from statewide programs with
significant household participation, such as SNAP
Universal access to monthly bill assistance for low-income
households
Disparate benefit amounts for low-income households served by
different utilities
The state provides utilities
with information on
Data sharing with Fragmented, restrictive eligibility requirements and enrollment
households enrolled in
state agencies processes for low-income households
statewide low-income
programs
Fragmented, broken communication processes between utilities,
community service organizations, and households
Slippage in implementation of statutes, limiting household access
to critical assistance and potentially affecting life outcomes
Ability of rural utilities with disproportionate share of low-income
customers to develop and fund programs without rate hikes
Same as above
Commerce conduct Commerce conducts
Complexity of communicating details of 50+ disparate utility
outreach for each of outreach and community
programs, and sending households and service providers to look for
Washington’s 50+ engagement for electric
resources that may not exist
utilities utilities
Funding to support outreach on behalf of utilities
Gaps depend on comprehensiveness and specificity of the law
The Legislature addresses
Inefficiency, slippage, and communication challenges with
Additional statutory policy gaps on a utility-by-
implementing 50+ monthly energy bill assistance programs
requirements utility basis through
legislation
Ability of rural utilities with disproportionate share of low-income to
develop and fund programs without rate hikes
Supplementary Universal access to monthly bill assistance for low-income
The Legislature funds utility
funding for utility households
assistance programs
programs
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 96
Augmented utility-
by-utility Idea The approach does not address
approaches
Inefficiency, slippage, and communication challenges with
implementing 50+ assistance programs
Disparate benefit amounts for low-income households served by
different utilities
Reduces money available for other state programs
Supplementary Restrictive eligibility requirements set in federal statute
funding for the Low-
The Legislature provides
Income Home Meeting home energy costs after the awarded grant is exhausted
more funding for LIHEAP
Energy Assistance
Program Limited enrollment opportunities
Households who are not enrolled in LIHEAP
Universal access to monthly energy bill assistance
Supplementary
The Legislature provides
Funding for the Targeting benefits to meet home energy assistance need
more funding for the Heat
Heat and Eat
and Eat Program
Program Variations in household energy consumption
Ability of rural utilities with disproportionate share of low-income
customers to develop and fund programs without rate hikes
Federal prohibitions on sharing data from statewide programs with
significant household participation, such as SNAP
Continuing The Legislature continues Universal access to monthly energy bill assistance
Washington to provide $200 to
Families Clean households annually for Targeting benefits to meet home energy assistance need
Energy Credits transportation and home
Program energy expenses Variations in household energy consumption
Ability of rural utilities with disproportionate share of low-income
customers to develop and fund programs without rate hikes
Federal prohibitions on sharing data from statewide programs with
significant household participation, such as SNAP
Variations in household energy consumption
The Legislature provides
rebates for home energy Targeting benefits to meet home energy assistance need
Energy Rebates
costs on an annual or
monthly basis If rebates are provided on an annual basis, the program would not
provide universal access to monthly bill assistance
If rebates are provided on an annual basis, administrative costs
could be exceptionally high to process payments on a monthly basis
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 97
Conclusion
The Legislature first requested Commerce examine a statewide approach under RCW 19.405.120 (Sec. 120),
and subsequently asked Commerce under Chapter 475, Laws 2023 to recommend a design for a statewide
program.
The recommended program design satisfies the Legislature's request for the agency to make
recommendations on a design for a statewide energy assistance program to address the energy burden and
provide access to energy assistance for low-income households. It also addresses key considerations the
Legislature asked Commerce consider in its recommended design. 78 It is based on the input received over the
past year from hundreds of individuals from community providers, utilities, state agencies, environmental
justice advocates, national experts, and households.
At its core, the recommended program design removes barriers households confront under a fragmented
utility-by-utility approach to bill assistance, and expands opportunities for low-income households to access
low-income energy assistance no matter where they happen to live and in a manner responsive to their unique
needs and preferences. The program also reduces the inefficiencies of administering 50+ separate monthly bill
assistance programs across Washington's electric utilities.
785187-S.sl.pdf (wa.gov)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 98
Appendix A: Definitions
Consumer-owned utility (COU) means a municipal electric utility formed under Title 35 RCW, a public utility
district formed under Title 54 RCW, an irrigation district formed under Chapter 87.03 RCW, a cooperative
formed under Chapter 23.86 RCW, or a mutual corporation or association formed under Chapter 24.06 RCW,
that is engaged in the business of distributing electricity to more than one retail electric customer in the
state. 79
Energy assistance need means the amount of assistance necessary to achieve an energy burden at or below
6% for utility customers. 80
Energy burden means the share of annual household income used to pay annual home energy bills. 81 It is
limited to residential expenses, and includes any fuel source for energy, such as electricity, natural gas,
propane, heating oil, and wood. It does not include transportation-related energy expenses, such as gasoline or
electric vehicle charging.
A household is energy burdened by their home energy bills when their bills exceed 6% of their gross income.
This calculation reflects that shelter costs should not exceed 30% of income, and utility costs should not
exceed 20% of shelter costs. Therefore, an affordable energy burden should be at or below 6% of household
income (30% x 20% = 6%).
Investor-owned utility (IOU) means a company owned by investors that meets the definition of "corporation" in
RCW 80.04.010 and is engaged in distributing electricity to more than one retail electric customer in the
state. 82
Low-income means household incomes that do not exceed the higher of 80% of area median income (AMI) or
200% of federal poverty level (FPL) adjusted for household size.83
79 RCW 19.405.020: Definitions. (wa.gov)
80 WAC 194-40-030:
81 RCW 19.405.020: Definitions. (wa.gov)
82 Ibid.
83 WAC 194-40-030:
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 99
Appendix B: the Low-Income Energy Affordability Data
(LEAD) Tool
The LEAD Tool was developed by the U.S. Department of Energy (DOE) and National Renewable Energy Lab
(NREL) as part of the Clean Energy for Low-Income Communities Accelerator (CELICA), a U.S. Department of
Energy Better Buildings Initiative Accelerator, aimed to lower energy bills for low-income communities through
a two-year voluntary partnership between DOE and state and local governments.
The LEAD Tool uses the U.S. Census Bureau’s 2020 American Community Service data (ACS) data with
microdata samples from the survey (2016-2020).
Like all U.S. Census Bureau data, the data in the LEAD Tool is self-reported by households. This includes the
energy cost data, which is collected for the month the survey was conducted. Household energy costs are then
extrapolated over the course of a year. DOE calibrates the energy cost data using electric utility and natural gas
utility survey data submitted by utilities to U.S. Energy Information Administration. This fixes averages across
geographic areas to match roughly utility reported data. For instance, electricity expenditures by households
across Census tracts in a utility service area would be roughly equal to the average utility revenue by customer.
The tool contains energy burden data at the national, state, county, tribal, and city levels. The ACS is household
reported data. However, as a survey, not all households are sampled. Household types are grouped together
and energy expenditures are assumed to be the same within a group.
Income information is provided as a percentage of the area median income (AMI), state median income (SMI),
and federal poverty level (FPL). The tool provides the number of occupied housing units and energy
expenditures by:
Tenure (renter or owner)
Year of first construction
Number of units in the building
Housing unit primary heat type
Strengths and limitations
The DOE LEAD Tool provides the only publicly available resource on household energy burden. It is the only
comprehensive resource to look at energy burden by Census tracts and the above dimensions.
The primary limitation of the DOE LEAD Tool is that it relies on self-reported data. Self-reported data is subject
to error. A household may incorrectly identify the primary heat type of their building, for instance reporting
utility gas instead of bottled gas.
Self-reported data may also overestimate or underestimate true energy costs. Extrapolating one month of
energy costs over a year introduces additional uncertainty into the dataset. Households tend to use more
energy in winter and summer months to heat and cool their homes, than in spring and fall. Extrapolating
household energy data collected in winter and summer months may overestimate household costs, while data
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 100
collected in spring and fall may underestimate a household’s annual energy costs. Bias from non-responsive
households are addressed through the U.S. Census Bureau's methodology. 84
DOE calibrates the energy price data to align it with energy price data collected through surveys of electric
utilities (Survey Form 861) and natural gas utilities (Survey Form 176) to mitigate against potential errors in the
ACS data. Non-responsive households are likely corrected by the Census Bureau as part of their methodology.
Perhaps importantly, some households do not pay energy costs directly – like an apartment building with a
shared boiler. The actual per unit costs may differ from a similar household that pays energy costs directly.
Many utilities reported difficulties working with the LEAD Tool data because Census tracts do not align with
utility service area boundaries. A utility serving the same Census tract served by other utilities cannot
determine the energy burden associated with its customers from the customers of the other utilities. They
must estimate it.
Utilities know the actual bills of their customers. They know arrearages, late payments and disconnection
notices, conservation potential, energy assistance expenditures and other program data. Customer
demographic data is available through third parties. County assessors have information on buildings and the
state has customer information about households served through state programs, such as the Low-Income
Heat Assistance Program (LIHEAP). 85
This information has been used by some utilities to build household-level data dashboards for their service
territories. These efforts have been limited to the three IOUs and a half-dozen COUs.
84 An Overview of Addressing Nonresponse Bias in the American Community Survey During the COVID-19 Pandemic Using
Administrative Data (census.gov)
85 Energy Equity · Empower Dataworks
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 101
Appendix C: The Residential Energy Consumption
Survey
Survey Background
The Residential Energy Consumption Survey (RECS) is the only nationwide source of energy related
characteristics, consumption, and expenditures for U.S. homes.
EIA administers the Residential Energy Consumption Survey (RECS) to a nationally representative sample of
housing units. Traditionally, specially trained interviewers collect energy characteristics on the housing unit,
usage patterns, and household demographics. For the 2020 survey cycle, EIA used Web and mail forms to
collect detailed information on household energy characteristics. This information is combined with data from
energy suppliers to these homes to estimate energy costs and usage for heating, cooling, appliances and other
end uses — information critical to meeting future energy demand and improving efficiency and building design.
First conducted in 1978, the fifteenth RECS collected data from nearly 18,500 households in housing units
statistically selected to represent the 123.5 million housing units that are occupied as a primary residence.
Data from the 2020 RECS are tabulated by geography and for particularly characteristics, such as housing unit
type and income, that are of particular interest to energy analysis.
The results of each RECS include data tables, a microdata file, and a series of reports. Data tables are generally
organized across two headings; "Household Characteristics" and "Consumption & Expenditures." See RECS
data tables.
The RECS and many of the EIA supplier surveys are integral ingredients for some of EIA's more comprehensive
data products and reports, such as the Annual Energy Outlook (AEO) and Monthly Energy Review (MER). These
products allow for broader comparisons across sectors, as well as projections of future consumption trends.
RECS began in 1978 as an annual survey. The 2020 RECS is the fifteenth iteration of the survey. 86
86
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 102
Appendix D: RCW 19.405.120 (2019)
Energy assistance for low-income households.
1) It is the intent of the legislature to demonstrate progress toward making energy assistance funds available
to low-income households consistent with the policies identified in this section.
2) An electric utility must make programs and funding available for energy assistance to low-income
households by July 31, 2021. Each utility must demonstrate progress in providing energy assistance
pursuant to the assessment and plans in subsection (4) of this section. To the extent practicable, priority
must be given to low-income households with a higher energy burden.
3) Beginning July 31, 2020, the department must collect and aggregate data estimating the energy burden
and energy assistance need and reported energy assistance for each electric utility, in order to improve
agency and utility efforts to serve low-income households with energy assistance. The department must
update the aggregated data on a biennial basis, make it publicly accessible on its internet website and, to
the extent practicable, include geographic attributes.
a) The aggregated data published by the department must include, but is not limited to:
i) The estimated number and demographic characteristics of households served by energy
assistance for each utility and the dollar value of the assistance;
ii) The estimated level of energy burden and energy assistance need among customers served,
accounting for household income and other drivers of energy burden;
iii) Housing characteristics including housing type, home vintage, and fuel types; and
iv) Energy efficiency potential.
b) Each utility must disclose information to the department for use under this subsection, including:
i) The amount and type of energy assistance and the number and type of households, if applicable,
served for programs administered by the utility;
ii) The amount of money passed through to third parties that administer energy assistance programs;
and
iii) Subject to availability, any other information related to the utility's low-income assistance programs
that is requested by the department.
c) The information required by (b) of this subsection must be from the electric utility's most recent
completed budget period and in a form, timeline, and manner as prescribed by the department.
4)
a) In addition to the requirements under subsection (3) of this section, each electric utility must submit
biennially to the department an assessment of:
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 103
i) The programs and mechanisms used by the utility to reduce energy burden and the effectiveness of
those programs and mechanisms in both short-term and sustained energy burden reductions;
ii) The outreach strategies used to encourage participation of eligible households, including
consultation with community-based organizations and Indian tribes as appropriate, and
comprehensive enrollment campaigns that are linguistically and culturally appropriate to the
customers they serve in vulnerable populations; and
iii) A cumulative assessment of previous funding levels for energy assistance compared to the funding
levels needed to meet: (A) Sixty percent of the current energy assistance need, or increasing energy
assistance by fifteen percent over the amount provided in 2018, whichever is greater, by 2030; and
b) ninety percent of the current energy assistance need by 2050.
(a) The assessment required in (a) of this subsection must include a plan to improve the
effectiveness of the assessed mechanisms and strategies toward meeting the energy
assistance need.
5) A consumer-owned utility may enter into an agreement with a public university, community-based
organization, or joint operating agency organized under chapter 43.52 RCW to aggregate the disclosures
required in this section and submit the assessment required in subsections (3) and (4) of this section.
6)
a) The department must submit a biennial report to the legislature that:
i) Aggregates information into a statewide summary of energy assistance programs, energy burden,
and energy assistance need;
ii) Identifies and quantifies current expenditures on low-income energy assistance; and
iii) Evaluates the effectiveness of additional optimal mechanisms for energy assistance including, but
not limited to, customer rates, a low-income specific discount, system benefits charges, and public
and private funds.
b) The department must also assess mechanisms to prioritize energy assistance towards low-income
households with a higher energy burden.
7) Nothing in this section may be construed to restrict the rate-making authority of the commission or the
governing body of a consumer-owned utility as otherwise provided by law.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 104
Appendix E: RCW 19.405.120 (Sec. 120) Analysis
Background
The Legislature made each of Washington’s roughly 50 electric utilities responsible for addressing the
household energy burden of its customers under Sec. 120, while recognizing that additional mechanisms may
be necessary to address household energy burden.
This appendix underscores the gaps in Sec. 120, and how these gaps have direct impacts on low-income
households. This section focuses exclusively on Sec. 120 and does not comment on RCW 80.28.068, which
applies additional requirements to investor-owned utilities. A discussion of RCW 80.28.068 is included in the
body of this report.
Key findings
Sec. 120 does not do the following:
• Ensure universal access to low-income energy monthly bill assistance
• Ensure uniform benefit levels for similarly situated low-income households statewide
• Ensure programs are sufficiently funded to meet energy assistance need
• Require utilities work with tribes and community partners who specialize in serving low-income
households
• Require utilities improve the process for households to enroll in monthly bill assistance programs and
allow any community partner the ability to assist households
• Require utilities perform ongoing outreach and enrollment campaigns tailored to historically
marginalized groups, or ensure outreach and enrollment campaigns deliberately avoid and proactively
address poverty stigmas
• Ensure utilities develop data-driven, evidence-based plans and assessments that align with national
best practices and account for local household needs
• Systematically interrogate how the unequal distribution of household experiences might be structured
by a household’s position within the intersecting fields of race, income, gender, age, disability, and
geographical location.
• Measure progress based on meaningful outcomes for low-income households, such as program
participation rates and reductions in energy burden
Findings
While Sec. 120 provides a clear statement of the legislative intent for electric utilities to make progress in
reducing energy burden, the statute does not ensure utility energy assistance programs are well-designed,
sufficiently funded, or readily accessible by low-income householders across the state. Moreover, the statute
does not require data-driven, evidence-based assessments, continuous program evaluations, or the co-creation
of bill assistance programs with households and communities with the intention of serving all low-income
households and meeting energy assistance need.
There are policy flaws in low-income household protections under Sec. 120, and there are inherent
inefficiencies in energy assistance programs when they are administered by over 50 different entities. While
some aspects of program design can be fixed through state law, others, such as slippage in utility
implementation of state law, will likely persist under a utility-by-utility approach.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 105
Both programmatic and structural failures could be more uniformly addressed under a statewide approach to
the benefit of low-income households statewide.
Analysis
RCW 19.405.120(2)
An electric utility must make programs and funding available for energy assistance to low-income households
by July 31, 2021.
Summary of the statute
Each of Washington’s nearly 50 utilities subject to Sec. 120 must make two or more programs available for
energy assistance to low-income households as defined in RCW 19.405.020(25) and WAC 194-40-030. Utilities
were required to make programs available by July 31, 2021.
Noteworthy gaps in the statute
Sec. 120 allows utilities to comply with the law using programs incapable of meeting energy assistance need.
This lack of specificity differs from the Legislature’s directive under RCW 80.28.068, which requires investor-
owned utilities offer at least one bill assistance program funded through utility operations.
Sec. 120 neither enables low-income households the ability to enroll themselves in utility bill assistance
programs nor provides the opportunity for households to receive in-person help with bill assistance program
enrollment from any local community organization of their choosing.
Sec. 120 does not specify that households be able to enroll in a program year round or that program benefits
be available year round.
Policy impacts on low-income households
Low-income households may not have realistic energy assistance options to meet their energy assistance
need. Below are a handful of examples of programs that meet the requirements of Sec. 120, but are incapable
of addressing the total energy burden of households.
• Donation-based programs rely on donations, which have been shown to be unreliable and insufficient to
meet energy assistance need.
• One-time waivers of customer account fees by design do not address a household’s ongoing energy
assistance needs.
• Energy efficiency programs do not address the total energy burden of low-income households. Energy
efficiency programs often require significant investments upfront, which may be too expensive for low-
income households to participate in them. Renters may also not have access to energy efficiency
programs, because changes to rental units require the consent of a landlord and renters often do not
want to invest in properties they do not own.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 106
RCW 19.405.120(2) continued
Each utility must demonstrate progress in providing energy assistance pursuant to the assessment and plans
in subsection (4) of this section.
Summary of the statute
Each of Washington’s roughly 50 utilities must make progress in making funds available to low-income
households based on their own assessments and plans.
Noteworthy gaps in the statute
Currently, each utility defines progress based on their own written assessments and plans—with the notable
exception of the cumulative funding assessments in subsection 4(a)(iii). There are no assessment or planning
criteria to ensure increases program participation or reductions in energy burden, and no requirement that
plans and assessments be developed with low-income households or community partners that specialize in
serving low-income households—in line with national best practices for public participation and program
design.
Utility plans and assessments under Sec. 120(2) and the data collection that occurs under Sec. 120(3)
separates many crucial aspects of data collection on energy assistance need from program implementation
unless utilities decide to develop data resources in-house.
Policy impacts on low-income households
Data-driven plans and assessments of programs are crucial for monitoring program performance and closing
gaps between policy intentions and real-world outcomes for low-income households is vague on what is
required in utility assessments and plans, and there is no requirement for programs to be informed by the
expertise and lived experiences of low-income households and community organizations in a manner
consistent with national best practices. The result are suboptimal policy evaluations and missed opportunities
for program improvements, which have downstream effects on programmatic outcomes for low-income
households, whether it be low participation rates or unaddressed energy burden.
The bifurcated data collection process between Commerce and utilities further impedes efforts to translate
data on low-income energy assistance need and program outcomes into programmatic changes that improve
program participation and reductions in energy burden for low-income households.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 107
RCW 19.405.120(2) continued
To the extent practicable, priority must be given to low-income households with a higher energy burden
Summary of the statute
Programs available to low-income households under Sec.120 must prioritize assistance to households with
higher energy burden to the extent practicable.
Noteworthy gaps in the statute
Sec. 120 does not explicitly require programs be designed to help households in greatest energy assistance
need even though there are plenty of practicable program designs utilities could adopt to target funds to low-
income households in greatest need. For instance, a utility could use a tiered bill assistance program based on
income. The amount of benefits may be calculated for each income tier based on an approximate amount of
funding needed to bring household energy expenses to 6% of household income. Avista, Puget Sound Energy,
and PacifiCorp utilize this approach for their customers per regulatory requirements set by the Utilities and
Transportation Commission.
Policy impacts on low-income households
The ambiguity in program design in Sec. 120 means low-income households in most need may not receive
sufficient funding to meet their need, while other low-income households may receive more assistance than
needed to eliminate their energy burden. Some households may have no monthly utility bill assistance
programs available to them at all.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 108
RCW 19.405.120(3)
Beginning July 31, 2020, the department must collect and aggregate data estimating the energy burden and
energy assistance need and reported energy assistance for each electric utility, in order to improve agency and
utility efforts to serve low-income households with energy assistance. The department must update the
aggregated data on a biennial basis, make it publicly accessible on its internet website and, to the extent
practicable, include geographic attributes.
a) The aggregated data published by the department must include, but is not limited to:
i) The estimated number and demographic characteristics of households served by energy
assistance for each utility and the dollar value of the assistance;
ii) The estimated level of energy burden and energy assistance need among customers
served, accounting for household income and other drivers of energy burden;
iii) Housing characteristics including housing type, home vintage, and fuel types; and
iv) Energy efficiency potential.
Summary of the statute
Commerce must collect and aggregate data and post it on its webpage on a biennial basis. To the extent
practicable, the data must include geographic attributes.
Noteworthy gaps in the statute
Sec. 120 does not require real-time, data-driven analysis to inform ongoing program performance to improve
programs and outcomes for low-income households.
While there are many practicable ways for utilities to use geospatial data to improve their programs, most do
not use geospatial data. When they do, they often use unreliable third party data, rather than comparisons of
their programs with actual data on low-income household participation in state programs with similar eligibility
criteria.
There is no standardization or integration of data tools across utilities to ensure household need from multiple
fuel sources are being addressed when households are served by multiple fuels and have different service
providers.
Policy impacts on low-income households
Low-income households may not be served or may be insufficiently served by utility assistance programs,
because programmatic evaluations and quality controls are absent or not sufficiently embedded in utility
programs. Rigorous program evaluations and quality controls help programs meet the energy assistance
needs of households.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 109
RCW 19.405.120(3)(b) and (c)
Each utility must disclose information to the department for use under this subsection, including:
v) The amount and type of energy assistance and the number and type of households, if
applicable, served for programs administered by the utility;
vi) The amount of money passed through to third parties that administer energy assistance
programs; and
vii) Subject to availability, any other information related to the utility's low-income assistance
programs that is requested by the department.
b) Refer to (c).
c) The information required by (b) of this subsection must be from the electric utility's most
recent completed budget period and in a form, timeline, and manner as prescribed by the
department.
Summary of the statute
Utilities are required to disclose information on a biennial basis about the amount and type of assistance
provided to households. They must also provide how much money is provided to third parties that administer
energy assistance programs, and any other available information requested by Commerce related to a utility’s
low-income energy assistance programs.
Noteworthy gaps in the statute
The law does not require utilities conduct their own ongoing data-driven, evidence based programmatic
evaluations between biennial reporting periods.
Policy impacts on low-income households
Ongoing reviews of program performance are often infrequent and result in significant slippage in program
performance and ensuring compliance with affordability protections for low-income households.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 110
RCW 19.405.120(4)(a)(i)
In addition to the requirements under subsection (3) of this section, each electric utility must submit biennially
to the department an assessment of:
i) The programs and mechanisms used by the utility to reduce energy burden and the
effectiveness of those programs and mechanisms in both short-term and sustained energy
burden reductions
Summary of the statute
Utilities must assess their programs and mechanisms for how effective they are in both addressing “short-
term” and “sustained energy burden reductions.”
Noteworthy gaps in the statute
Sec. 120 leaves it up to utilities to define what is meant by programs and mechanisms, and for utilities to
determine methods for evaluating whether programs and mechanisms are addressing “short-term” and
“sustained” energy burden reductions, leading many utilities to use rules of thumb in the evaluation of the
effectiveness of their programs for short-term and sustained reductions in energy burden.
Policy impacts on low-income households
The vagueness of Sec. 120 and lack of requirements for utilities to conduct data-driven, evidence-based
evaluations of whether their programs are successfully meeting short-term and sustained energy burden
needs of low-income households means low-income households are not benefitting from potential program
improvements that could be revealed through more qualitatively and quantitatively rigorous assessments of
whether certain bill assistance designs are more tailored to addressing short-term or sustained energy burden
reductions.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 111
RCW 19.405.120(4)(a)(ii)
Each electric utility must submit biennially to the department an assessment of:
ii) The outreach strategies used to encourage participation of eligible households, including
consultation with community-based organizations and Indian tribes as appropriate, and
comprehensive enrollment campaigns that are linguistically and culturally appropriate to
the customers they serve in vulnerable populations
Summary of the statute
This requirement says utilities must look at their past outreach strategies and submit an assessment of their
outreach and enrollment strategies.
Noteworthy gaps in the statute
The statute alludes to, but does not specifically require utilities consult with community-based organizations or
tribes. Similarly, it does not require utilities conduct comprehensive enrollment campaigns that are
linguistically and culturally appropriate to the customers they serve in vulnerable populations.
There are no assessment methodologies or metrics in statute.
There is nothing in Sec. 120 that ensures programs, plans, or assessments are developed with low-income
households and community organizations that specialize in serving low-income households.
Policy impacts on low-income households
Low-income households may not be aware of utility programs, because utilities are not working with all of the
community partners in their service territory to increase awareness and accessibility of their programs.
Multilingual households and those with little or no English proficiency may not be able to access services or
find someone who can walk them through the program in the language the household is most comfortable
speaking. They may also be missed in any utility outreach efforts that are not linguistically or culturally
appropriate for them.
A lack of data on outreach and enrollment campaigns means there is no way to assess what is going well and
what is not with each program’s outreach and enrollment strategies.
Low-income households and the community organizations that serve them do not have a way of providing
input into program designs to ensure outreach and enrollment campaigns suit low-income households.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 112
RCW 19.405.120(4)(a)(iii)
Each electric utility must submit biennially to the department an assessment of:
A cumulative assessment of previous funding levels for energy assistance compared to the funding levels
needed to meet: (A) Sixty percent of the current energy assistance need, or increasing energy assistance by
fifteen percent over the amount provided in 2018, whichever is greater, by 2030; and (B) ninety percent of the
current energy assistance need by 2050
Summary of the statute
Utilities must look at their year-to-year spending since 2018 and compare that spending to what is needed to
meet 60% of current energy assistance need by 2030 or increase spending by 15% over the amount provided in
2018, whichever is greater. They must also look at the funding levels needed to meet 90% of current energy
assistance need by 2050.
Noteworthy gaps in the statute
Utilities are not required to reach the funding assessment levels in Sec. 120.
The statute is vague on whether or how quickly it expects utilities to reach the 2030 and 2050 funding levels
expected to meet energy assistance need.
The statute allows uneven progress across the state on increasing low-income program funding.
The statute measures an input, funding, and does not measure outcomes for households, such as program
participation rates or annual reductions in energy assistance need.
There is nothing in the statute that ensures programs, plans, or assessments are developed with low-income
households and community organizations that provide low-income services.
Policy impacts on low-income households
Program funding and programmatic funding assessments do not make a difference to low-income households
if programs are not realistically available to low-income households or program participation rates are
drastically low.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 113
RCW 19.405.120(4)(b)
The assessment required in (a) of this subsection must include a plan to improve the effectiveness of the
assessed mechanisms and strategies toward meeting the energy assistance need.
Summary of the statute
Utilities must make a plan for improving their low-income energy assistance programs and outreach strategies
and enrollment campaigns toward meeting energy assistance need.
Noteworthy gaps in the statute
The requirement to “improve the effectiveness” is vague and lacks specificity.
It is unclear at what pace utilities need to act in reducing energy assistance need.
The statute does not specify a uniform methodology for developing a plan that accounts for the desires of low-
income households and system constraints.
The plans for improving mechanisms and strategies do not need to align with national best practices.
The plans for improving mechanisms and strategies do not need to be comprehensive in their approach to
addressing the needs of Washington households.
There is nothing in the statute that ensures programs, plans, or assessments are developed with low-income
households and community organizations that provide low-income services.
Policy impacts on low-income households
Utility plans can lack quantitative and qualitative rigor and not meet the needs of their communities, setting up
another two years of small or no changes in program improvements.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 114
RCW 19.405.120(5)
A consumer-owned utility may enter into an agreement with a public university, community-based organization,
or joint operating agency organized under chapter 43.52 RCW to aggregate the disclosures required in this
section and submit the assessment required in subsections (3) and (4) of this section.
Summary of the statute
The Legislature provides explicit authority to consumer-owned utilities may find other entities specified in
statute to assist them in performing the data gathering, assessments, and plans required under the law.
Noteworthy gaps in the statute
There is nothing in the statute that requires utilities or other entities prepare assessments and plans that align
with national best practices and are conducted in a uniform manner with a consistent methodology.
Policy impacts on low-income households
Uneven and inconsistent data collection and varying quality in assessments and plans can lead to substantially
different outcomes for low-income households.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 115
Appendix F: Centering lived experiences
Background
This appendix provides a summary of the methodology used by Commerce and the Greater Good Studio to
center lived experiences. This methodological summary is adapted from a presentation originally produced by
the Greater Good Studio and that has been formatted into the Washington State Department of Commerce
branded template. The presentation is available on Commerce’s webpage.
Through this study, we aimed to learn directly from households about the importance of energy access and
home energy costs, and understand their experiences navigating other low-income programs and bill
assistance. Household listening sessions prioritized human-centered design methods such as deep listening,
storytelling prompts, and hands-on activities to further explore barriers and opportunities directly with
households.
Project scope and limitations
This project was scoped to be one component of a larger body of work exploring the potential for an energy
assistance program. A summary of meeting participants is provided below:
• 15 households
• Seattle-Tacoma metro area
• Identified as low-income
• Racially diverse
• English speaking
• Experience with different assistance programs
While we learned a lot from these households, future work should include rural regions and linguistically
diverse households. Commerce conducted surveys in rural regions and among linguistically diverse
households
Centering lived experience
People closest to challenges are experts in their own needs and experiences.
Services meant to provide assistance to underserved members of our communities are often developed with
little input by those most affected - program participants. By centering lived experience, we shift that dynamic
and design interventions that are more inclusive and effective in making a meaningful difference.
Listening sessions
We engaged in three group listening sessions with low-income households. We explored experiences
managing household needs and expenses, and navigating different assistance programs. Reflective activities
prompted storytelling and better understanding of household perspectives.
First, we asked households to rank budget priorities by level of importance. Then, we mapped supportive and
unsupportive features of assistance programs to examine what worked and what didn’t.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 116
How we process data and honor experiences
During research, we collaborate with people who have lived expertise to understand their stories in their own
words.
We engage intentionally with people closest to the focus area to learn directly from them. We code each quote,
story, or observation shared as its own data point, in the participant’s words. Our process carefully considers
and preserves each individual’s lived experience to find themes across the group and develop key insights.
Sorting and combining data themes
We grouped data points to identify early themes across listening sessions. Then we looked for relationships
between themes to surface deeper learnings and key insights.
Conclusion
Too often the programs designed to serve low-income households without consideration of their lived
experience or expertise. The methodology used in this report offers a different approach rooted in human-
centered design and that puts the needs of low-income households front and centered in discussions about
the very programs intended to serve them.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 117
Appendix G: Household surveys
Executive summary
What are the primary reasons you are enrolled or may want to enroll in an energy
assistance program?
"I asked and was told there are no programs - I skip my medicine to pay my bills"
— Survey participant
"Retired, fixed income, need to make my dollars stretch"
— Survey participant
"Don't get much on disability, can hardly afford basics as is"
— Survey participant
"I have had fires and floods and other disasters and I have run out of money. I had no insurance as every
insurance place applied said I live too far away for them to cover."
— Survey participant
"I am new to America and I need help with electricity"
— Survey participant
"Energy Assistance program helps me to save money for other electrical expenses as a disabled person"
— Survey participant
What would you recommend the state do to maximize participation in a potential
statewide monthly low-income energy bill assistance program?
“Be available. The systems in place create more barriers”
— Survey participant
"I believe the more people that hear about the program the more will ultimately join. Advertisement in every
form should maximize that"
— Survey participant
"Make it easier to sign up. We've had folks being told to all sign up at 11 am and by 11:02 the slots are full"
— Survey participant
“More people who speak Spanish. Not so many requirements - Mas personas que hablan espanol. No tantos
requisites”
— Survey participant
“More people who can help you in Spanish. Longer the period to be able to register - more open hours. Mas
personas que te puedan ayudar en espanol. Mas prolongedo el periodo para poder registrars - horario mas
abierto”
— Survey participant
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 118
"Have more access - more locations"
— Survey participant
"Offer through avenues well-known to participants"
— Survey participant
"Have it easily accessible to apply, i.e. at DSHS, online, over the phone, at resource centers, through their bills.
List the income guidelines to qualify"
— Survey participant
"Those enrolled in low-income programs get a call/email letter inviting them to enroll - or automatically enroll
them"
— Survey participant
“Have trained personnel to help apply and provide information to all low-income people”
— Survey participant
"Provide interpretation, be accessible for blind and deaf individuals"
— Survey participant
Background
This survey pilots equitable community engagement and relies on equity and environmental justice best
practices. Commerce partnered with low-income advocates and community-based organizations across the
state to administer the surveys to households.
The survey was available in nine languages to better reach a diverse sample of respondents. The survey was
provided digitally and physically in Arabic, Chinese (simplified and traditional), Spanish, Vietnamese, Somali,
Russian, Ukrainian, and Tagalog.
337 individuals completed surveys. Open-ended questions were translated and standardized by Commerce.
The survey did not ask for demographic information such as age, race, income, or household size.
These survey results are not statistically significant, but provide insights into how low-income households
currently access energy assistance programs and their thoughts around certain program design elements. The
survey results align with findings from listening sessions with low-income households, statewide participation
rates in utility low-income energy assistance programs, and workshops with community organizations.
Highlights
Almost all (95%) of the survey participants said low-income households should have the same ability to
access bill assistance regardless of where they live
Most survey participants (63%) believe low-income households with lower incomes should receive a higher
bill discount, and those with more income should receive less of a discount
Most survey participants (78%) agree that the enrollment process for assistance should be minimal if a
household is already enrolled in another statewide low-income program
Almost all survey participants (96%) agree that enrollment should be available online, over the phone, or at
any local community service center serving low-income households
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 119
Conclusion
The survey results suggest Washington's electric utility customers are often unaware about home heat and
power bill assistance programs.
Survey participants included households from Clark, Ferry, King, Snohomish, Spokane, and Yakima counties.
Their primary languages included Spanish, Arabic, Somali, Ukrainian, and Russian.
Most participants frequently expressed that utility bill assistance would help them manage their finances in
terms of saving money for current and future expenses including food and other housing costs. Some
participants were specifically concerned about avoiding disconnections.
Most of the survey households are not enrolled in an energy assistance program. When asked why, most said
they did not know about the programs, did not know how to sign up, or did not know they were eligible.
When asked for recommendations the participants had for maximizing participation in a potential statewide
energy assistance program, the participants were largely in support of increased awareness of programs
through methods such as in-person advertising, word of mouth, social media, TV, and radio. Participants also
stated that increasing participation could be done by expanding eligibility requirements, increased guidance on
how to sign up, and bundling the information and enrollment process with other low-income assistance
programs.
Survey results
Demographics
Language
• 232 participants (69%) responded to the English survey
• 58 participants (17%) responded to the Spanish survey
• 20 participants (6%) responded to the Arabic survey
• 18 participants (5%) responded to the Ukrainian survey
• 4 participants (1%) responded to the Russian survey
• 4 participants (1%) responded to the Somali survey
County
• 124 (37%) of the survey results came from King County
• 75 (22%) of the survey results came from Spokane County
• 43 (13%) of the survey results came from Snohomish County
• 39 (12%) of the survey results came from Yakima County
• 34 (10%) of the survey results came from Clark County
• 22 (7%) of the survey results came from Ferry County
Cities:
• Everett
• Kent
• Republic
• Seattle
• Spokane Valley
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 120
• Renton
• Vancouver
• Yakima
Current enrollment in energy assistance programs
When asked if they were enrolled in the federal Low-Income Home Energy Assistance Program (LIHEAP):
• 237 participants (72%) said no
• 31 participants (9%) said they were not sure
• 64 participants (19%) said yes
When asked if they were enrolled in an assistance programs offered by their electric utility:
• 237 participants (72%) said no
• 34 participants (10%) said they were not sure
• 59 participants (18%) said yes
When asked if they had applied Low-Income Home Energy Assistance Program (LIHEAP):
• 227 participants (69%) said no
• 73 participants (22%) said yes
• 29 participants (9%) said they were not sure
When asked if they were enrolled in a federal or state social services program such as, 44% of the participants
said "yes." 8 participants skipped the question. The remaining participants said they were not enrolled in a
state or federal program.
Energy assistance awareness
When asked how aware they were of assistance programs offered by their electric utility:
• 35 participants (16%) said they were very aware
• 128 of the participants (39%) answered they were somewhat aware of the programs offered by their
electric utility
• 166 participants (51%) said they were not aware or unsure
Survey participants were asked why they were not enrolled in utility assistance programs excluding LIHEAP
and 303 participants responded. 249 of the participants selected just one response.
When asked what the primary reason was for why they were not enrolled in a program with their utility:
• 131 participants (43%) said they did not know about the programs
• 90 participants (30%) said they did not know they were eligible
• 41 participants (14%) said they did not know how to sign up
• 15 participants (5%) said it takes too much paperwork and personal information to enroll
• 25 participants (8%) said they were already enrolled in a program
• 35 participants (12%) said they didn't want assistance
• 44 participants (15%) said they were not sure.
• Four participants said it wouldn't help enough to be worth their time
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 121
Responses for "If you are not enrolled in a monthly energy bill discount program, what is the main reason you
haven’t enrolled? The Low-Income Home Energy Assistance Program (LIHEAP) is not a utility assistance
program.
I want to save money for me or my family 42%
I want to save money to help afford other housing
26%
costs
I want to save money for food 16%
I want to avoid being disconnected from power 14%
My home is not comfortable, it is either too hot or too
1%
cold
0% 5% 10% 15% 20% 25% 30% 35% 40% 45%
Accessing resources regarding assistance programs
When asked where they would most want to be able to sign-up for statewide or local energy assistance
programs, participants overwhelmingly said online. 119 participants selected more than one answer.
• 206 participants (62%) selected online
• 146 participants (44%) selected phone
• 74 participants (22%) selected local DSHS office
• 61 participants (18%) selected community action agency
• 56 participants (17%) selected multicultural service center
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 122
Responses for "Where would you most want to be able to sign-up for a statewide or local electric utility
assistance program?"
62%
44%
22%
18%
17%
16%
0% 10% 20% 30% 40% 50% 60% 70%
Online
Phone
Local Department of Social and Health Service Office
Community Action Agency
Multicultural service center
Other local community service center
What participants would recommend to maximize awareness and
participation
Survey participants were asked for recommendations on how to maximize participation in a statewide
program, as well as how to increase awareness to eligible people.
Participants also stated that increasing participation could be done by expanding eligibility requirements,
increased guidance on how to sign up, and bundling the information and enrollment process with other low-
income assistance programs.
Methods recommended to increase awareness included traditional methods such as flyers, TV and news ads,
texts, social media posts, radio, and bill inserts. Some participants recommended specific public places that
could help spread awareness such as the local PUD, community centers, parks schools, food banks, grocery
stores, and libraries. A few participants noted the importance of disseminating information in culturally
relevant ways, such as in languages in addition to English and through unbiased facilitators.
Others noted that places who already offer low-income assistance would be good places to provide the
information, such as refugee centers, non-profits, senior centers, and DSHS offices.
Participants also stated that increasing participation could be done by expanding eligibility requirements,
increased guidance on how to sign up, and bundling the information and enrollment process with other low-
income assistance programs.
How would energy assistance help households
Survey participants were asked what the primary reason they were enrolled or would want to be enrolled in an
energy assistance program. Of the 337 survey respondents, 51 skipped the question of which 45 responded
"other" and mostly stated that they were not eligible for assistance programs.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 123
Respondents who selected more than one answer to "What are the primary reasons you are enrolled or may
want to enroll in an energy assistance program?"
I want to save money for me or my family 42%
I want to save money to help afford other housing costs 26%
I want to save money for food 16%
I want to avoid being disconnected from power 14%
My home is not comfortable, it is either too hot or too cold 1%
0% 5% 10% 15% 20% 25% 30% 35% 40% 45%
188 respondents selected one answer
• 79 participants (42%) selected I want to save money for me or my family
• 49 participants (26%) selected I want to save money to help afford other housing costs
• 27 participants (14%) selected I want to avoid being disconnected from power
• 31 participants (16%) selected I want to save money for food
•
95 respondents provided more than one answer:
• 44 participants selected two of the answers
• 34 participants selected three of the answers
• 16 participants selected four of the answers
• 1 participant selected all five of the answers
The most common response was wanting to save money for food (70 respondents, 73%). The next most
common answer was to save money to help afford other household costs (67 respondents, 70%). The third
most common response was to save money for them or their family (56 respondents, 59%).
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 124
Respondents who selected only one answer to "What are the primary reasons you are enrolled or may want to
enroll in an energy assistance program?"
I want to save money for food 74%
I want to save money to help afford other housing costs 71%
I want to save money for me or my family 59%
I want to avoid being disconnected from power 53%
My home is not comfortable, it is either too hot or too cold 17%
0% 10% 20% 30% 40% 50% 60% 70% 80%
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 125
Appendix H: Community Organization Listening
Sessions Summary
Overview
Commerce conducted seven in-person workshops across Washington to co-design principles with community
organizations that specialize in serving low-income households (hereafter referred to as "community
organizations") that are traditionally not part of program design or policy discussions. Commerce held one
virtual listening session for organization leaders who could not attend in-person. Interpretation services were
offered and provided upon request. These listening sessions were in addition to Commerce's other listening
sessions with utilities and statewide advocacy organizations, as well as focus groups and surveys with
households.
This appendix summarizes the learnings from the in-person and virtual listening sessions with community
organizations.
Methodology
Commerce conducted seven listening sessions in community spaces across Washington and one virtual
listening session. Each listening session was two hours long. In total, 128 people from over 95 distinct
organizations participated. Commerce sent direct invitations to participate and those that registered to
participate were provided a reminder email the day before the listening session.
The listening sessions were tailored to community organizations. Great effort was taken to host a session that
provided opportunity to share opinions and thoughts using adult education best practices. Small group work
allowed for collective written and verbally shared thoughts and welcome activities centered participants.
Roughly half of the meeting participants reported over 10 years of experience serving low-income households,
and roughly 25% reported over 20 years of experience serving low-income households. Additional details are
summarized below in the Community Participation and Expertise section of this appendix.
Regional diversity
The in-person listening sessions occurred in seven cities:
Spokane
Colville
Port Angeles
Kennewick
Stevenson
Tacoma
Seattle
Each listening session had participants from nearby communities. For example, participants in Spokane
included community organizations from Clarkston (107 miles), and the listening session in Kennewick had
participants from Granger (56 miles). This inter-regional diversity provided insights into nearby communities.
Community organizations from across the state participated in Commerce's virtual listening session.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 126
Meeting participants
More than 128 attendees from 95 organizations that participated in the listening sessions. Attendee
participation is broken out by region:
• Western Washington and the Olympic Peninsula: 44 participants
• Northwest Washington: 36 participants
• Eastern Washington: 29 participants
• Central Washington: 18 participants
Organizational diversity
Many different types of community organizations participated in the listening sessions, including:
• Multi-cultural service providers
• General social service providers
• Youth and family support organizations
• Community Action Agencies
• Housing authorities
• Food banks
• Faith-based organizations
• Tribal service providers
Notably, multi-cultural service organizations were the largest group of organizations to participate.
The meetings were designed for community organizations that specialize in providing social services to low-
income households. They were open to the public and general attendance, and several utilities and statewide
advocacy organizations participated.
Participant expertise
Participants had extensive experience serving low-income households:
• 70% of participants had over five years of experience serving low-income households
• Nearly 50% had over 10 years of experience
• Roughly 25% of meeting participants had over 20 years of experience serving low-income households
Only 109 of 128 participants indicated years of experience. Those who did not are not included in the
percentages above.
Meeting in community spaces
Commerce met community organizations in community spaces, including:
• A local food bank
• A community economic development center
• A local non-profit organization serving overburdened communities
• Community centers
• Public libraries
Commerce's virtual listening session was held on Zoom.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 127
Key findings
There is a great deal of interest from community organizations across the state in the design of a
statewide program and general agreement on the principles developed through earlier listening sessions
with utilities and statewide advocacy organizations
Common challenges expressed by community organizations include lack of services, limited awareness of
programs and overall program navigation
A common sentiment expressed was the hope that a statewide program could provide greater visibility and
certainty to monthly low-income bill assistance, fast and easy applications and enrollment processes, and
multiple doors to access the program to help provide services to households and help households get
assistance, particularly for community organizations and households from historically marginalized
communities
Community organizations overwhelmingly expressed a preference for a tiered bill assistance program
based on household income — which would provide greater benefits to households with less income, and
less assistance to households with more income
Question: What challenges do you encounter most when serving clients?
Common response themes:
• Adversarial program requirements
• Absence of services and challenges navigating application process when programs are available
• Inequitable distribution and access to resources
• Inadequate support for households and community organizations and administrative constraints
• Institutional racism
• Poverty stigmas
Question: What do clients need to successfully access resources?
Common response themes:
• Greater programmatic visibility
• Multiple doors to access assistance
• Multicultural services
• Structure, predictability, certainty
• Easy, concise and fast applications with no unnecessary barriers to access
• Follow-ups
• Households need to be treated with dignity
Program accessibility principles
Community organizations were supportive of the following principles, developed over the course of four
listening sessions and comment periods with utilities and statewide low-income advocacy organizations and
additional conversation with community organizations:
• No systems that are long and complicated
• The program should have a quick turnaround time from application submission to receiving benefits
• The program should use plain language for all materials and communications
• Communications should be vetted by first-language speakers in communities
• The program should acknowledge that low-income seniors tend to live on fixed incomes, and the
program should reduce the need for low-income seniors to reapply
• The program should avoid benefits cliffs
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 128
• A statewide monthly low-income energy bill assistance program should have representation of Black,
Indigenous, and People of Color and other historically marginalized communities
Community participation and expertise
Commerce asked listening session participants to fill out sticky notes responding to the three questions
below:
• What is most inspirational about the clients you serve?
• What challenges do you encounter most when serving clients?
• What do clients need to successfully access resources?
At the seven in-person listening sessions, participants posted their responses on easel pads with the
corresponding questions. At the virtual listening session, participants shared these responses using Mural, an
online collaboration space. This activity offered a different way of collecting thoughts and were summarized
verbally by listening session hosts to center thoughts around households before diving into the program
feedback.
Commerce shared background information about the Legislature's statewide energy assistance program
design study. Commerce compiled a list of program accessibility principles developed over four program
design listening sessions and comment periods in 2023 with utilities and statewide advocacy organizations.
Participants were asked to review the principles and provide feedback.
Participants reviewed the benefits and limitations of different monthly energy bill discount mechanisms and
ranked them. Participants were provided a handout with a summary of benefits and drawbacks of types of bill
discounts based on feedback from utilities and statewide advocacy organizations. Participants could add
other benefits and drawbacks, or strikethrough or amend statements on the sheet. There were also open-
ended discussions at each listening session.
What is most inspirational about the clients you serve?
Resilience
The most common response was "resilience." Most of the time, this was the sole word used to describe
households.
• An individual’s resiliency and ability to overcome adversity
• Their resiliency, determination, and hopefulness
• Their resilience when overcoming barriers and being able to advocate for themselves
• Many of them are going through a lot of challenges but still keep going
• They are demonstrating persistence and resilience in the face of adversity but that adversity is often
the result of trauma and oppression
• They are incredibly resilient, determined, and strong
• Fighters, survivors, and unwavering.
Individual growth and betterment
Another theme was individual growth and betterment. These responses highlight the direct link between
accessing social services and increased wellbeing.
• Their ability to change and grow for the better
• Being able to see [their] economic advancement and commitment
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 129
• Desire to better themselves
• Their will to live productive, caring, and socially responsible lives
• They are persistent and clearly know what they need to help improve their quality of life
• Witnessing growth, overcoming barriers and achieving goals
• Their time and being willing to share their story and invite us into their journey to a more healthy life
Thankfulness and desire to help their family and willingness to help others in their community
Community organizations stressed the gratitude of households when they receive assistance and their desire
to help their family.
• Desire to provide for families
• They try hard to be there for their children
• They are part of a community
• Passion for service of their community, presenting their heritage/culture
• They want to be part of the solution
•
Another theme was the selflessness and empathy of low-income households despite their limited resources
and personal hardships.
• They lift each other up by sharing knowledge, resources, or time and words
• How they hold strength for themselves and others unable to advocate for themselves
• Resistance to use of services others may need
• When they help others even if they don’t have enough
•
Some community organizations specifically pointed to the positive contributions and uplifting dispositions that
multicultural households bring to their communities:
• The cultural knowledge that clients bring with them
• Their positive attitude even though our elders suffered and survived a genocide; they are nonetheless
grateful and optimistic
A little assistance can make a big difference for household outcomes
Community organizations highlighted how grateful households are when they receive assistance, and how
rewarding it is to see the positive impact assistance has on their lives.
• Grateful, humble, and appreciative towards the little things
• They are appreciative, kind, thankful, open to assistance, and grateful
• Witnessing the positive impact that our support has on their lives
• Getting to see clients able to utilize resources offered
• Relieving stress
• Knowing our work will secure basic needs for families
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 130
What challenges do you encounter most when serving clients?
Adversarial program requirements
A common observation was that the design of low-income programs, intentionally or unintentionally, limit
program accessibility.
• Complexity of requirements to access programs
• Documentation stress and complicated requirements
• Amount of personal information required to access systems or resources
• How difficult resources are to access
• Gaps in eligibility leave families in need
• Too many steps to access resources
• They become overwhelmed with how confusing it can be to access services
• Strict guidelines that are not flexible
• Having clients over income standards but not enough to meet basic needs
Absence of services and challenges navigating application process when programs are available
Many community organizations said they encounter difficulties navigating program specific requirements.
Community organizations highlighted that the processes are confusing and overly complex, which prevents
them and their clients from understanding what is available.
• Lack of clarity on how to access programs
• Access to services
• Lack of services in the area
• Lack of clarity on how to access programs
• Application barriers
• Navigating the application process
• Access to programs due to navigating the system
• Navigating the system
• Process barriers and unnecessary complexity
• Knowing the correct paths to get them the help they would like
• Complexity of accessing services
• Having to be creative to connect dots between service agencies – lack of collaboration
• Miscommunication due to reliance on oral or verbal communication
• They become overwhelmed with how confusing it can be to access services
Inequitable distribution and access to resources
Community organizations said that, even when resources are available, they are difficult to access and
perpetuate inequities faced by their clients. Challenges included lack of resources in both urban and rural
areas, as well as limited access to technology.
• Inequitable distribution and access of resources
• Challenges are lack of resources in our rural area
• No access to be able to apply
• Getting documents needed
• Accurate information and other resources
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 131
• Digital divide
• Digital and technological navigation
• Technology limitations (phone, internet), particularly for older clients
• Needing an e-mail address is a barrier
• Being able to find information in their language
• Getting people to come to resource events, despite many methods of advertising
• Digital and technological navigation
• Funder restrictions
• No access to be able to apply
• No resources to address need
• Lack of services in the area
Administrative constraints and inadequate support for households and community organizations
Community organizations said complex applications and extensive documentation requirements increase staff
time spent on each applicant, and that they do not have enough staff to meet demand.
• Not enough staffing or funding
• Lack of time to serve households
• Outdated technology
• When resources run out and you hit a dead end in ways to help
Institutional racism
Community organizations noted that racial divides and disparities show up in program designs and access.
• Being underserved, marginalized, and [facing] racial discrimination
• Institutional racism
• Explicit and implicit biases
• Language barriers
Poverty stigmas
A theme most often heard in rural parts of the state was that households feel stigmatized if they seek or
receive assistance.
• Some aren’t open to speaking, they are resistant or closed off
• Client’s pride – some are too ashamed to ask for help
• Clients do not always identify as low-income
What do clients need to successfully access resources?
Greater programmatic visibility
Community organizations stated that more outreach is needed for clients to have awareness about resources.
• It sometimes seems like services and resources are hidden
• They need to know about what is available or a place they can connect to many resources
• Outreach efforts should rely on the community relationships with us community providers that are an
established trusted source for the clients
• Put more info on social media about these programs
• Information provided by radio, podcast, ads, or announcements
• More promotion
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 132
There should be multiple doors to access assistance
Community organizations stated that multiple access points would help overcome the challenges that prevent
clients from seeking assistance.
• Multiple entities enrolling customers, and categorical eligibility should be provided based on
participation in other programs all support the mindset that no door is a wrong door when it comes to
applying for and receiving assistance. This supports ease of access and allows staff to help client
apply for multiple programs
• Having it all at one location is a barrier
• For providers to make resources accessible with multiple access points and mediums
Community organizations said multiple application forms are needed. They also expressed that diverse client
needs require a range of both in-person and digital resources.
• Websites that they can work with on a mobile device
• Easy to navigate one-stop website with QR code for additional information
• Households need human touch – not just filing out an application
• It is difficult for folks to get to physical location and population people serve, have documents ready,
and long wait times
• Help line they can call into for assistance
Community organizations emphasized a statewide assistance program should take into account where clients
currently receive resources, and barriers they often encounter when trying to access programs.
• Both outreach and engagement should be conducted with trusted community partners; would add
interested parties to that, because often those trusted community partners have no bandwidth to do
new work, so it would be important to consider how to bring new partners into this work
• Variety of ways to access that don’t tax resources
Structure, predictability, certainty is needed for low-income households to access programs
Community organizations said the uncertain nature of program funding, eligibility determination,
documentation requirements, among other things, are barriers for households pursuing enrollment.
• For resources to be there now and in the future
• Households need structure, predictability and certainty
Easy, concise, and fast applications
There was broad consensus that households need to be able to have easy, concise, and fast applications that
are easily accessible.
• Easy paperwork
• If the money is available for people, they should not have to run through a maze to access that money
• Easy applications and few barriers
• Quick and direct access to resources
• Program enrollment should be easy for service providers and administrator in addition to households
• Less red tape
• Give what is needed and get out of the way
• Minimizing documentation and self-attestation help reduce documentation and barriers. Clients can get
discouraged when the see all of the documents that are required
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 133
• Clear, simple processes to access resources not having to jump through hoops to access what they
need
• What information does a program administrator really need to enroll in a program?
• Being able to use a different low-income program, like SNAP, to cross-enroll households would be a
nice thing to have
A couple of specific suggestions include:
• Clear and understandable language
• Instructions in various audio and visual formats
• Support to follow through with application
Follow-ups are an important element of programmatic design
Community organizations noted that following up with applicants is needed to ensure households were able to
access resources and receive notifications to either re-apply or update their information.
• Follow-ups to make sure they were able to get resources
Households need to be treated with dignity
Community organizations noted that basic respect and kindness need to be reflected in both individual
interactions between staff and clients and within the program overall.
• Treated with dignity
• Kindness and compassion
Multicultural services should be provided
Community organizations said that language access and representation should be considered in the creation
of a new program.
• Systems that reflect who they are
• Culturally appropriate services and accommodations
• Help from people who look like them
• Language access
• Culturally specific resources
• Translation materials are needed for providers
Multicultural service providers serving Hispanic immigrant communities noted challenges with existing social
service programs with the hope that a statewide monthly energy bill assistance program would avoid these
barriers.
• I work with a Hispanic immigrant community and many of them do not qualify due to them not having a
SS# for certain energy assistance programs
Support for program principles
Commerce presented principles developed over months of conversations with utilities and statewide advocacy
organizations through public listening sessions and comment periods. Local service participants asked
clarifying questions and overwhelmingly expressed support of the principles.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 134
The principle that "The program should have multiple application and enrollment methods, including methods
that do not require internet access or travel to a physical location" results in significant discussion across the
listening sessions.
Community organizations highlighted potential benefits and drawbacks to different ways to access the
program. There comments illustrate that community organizations and households may have different needs
when it comes to learning about and accessing a program.
Some community organizations stressed the importance of households being able to access services virtually:
• The program should be accessible using computers, telephones, or other means of technology besides
going to a physical location
Other community organizations stressed the importance of having in-person enrollment and outreach options:
• Not having the ability to enroll folks through in-person means would create a barrier that would exclude
some people in need of assistance, such as older people or those without access to the internet or the
phone
• We have seen issues with households with limited technological access doing things like scanning
documents
However, other service providers noted that in-person outreach and engagement can be challenging and that
some households may benefit from more ways to access programs. Rural and multicultural service providers
also said that in-person meetings may be stigmatizing for many households.
• Access to services in rural communities and not having access to transportation is a huge challenge,
not having access to the time needed to go to appointments or interviews is another
• Trusting an online application is sometimes scary, but providing even more assistance and ways of
applying (including doing it with someone in real time) could help
• In person applications can also be stigmatizing
Community organizations raised additional ways to reach households and encourage program enrollment:
• On the outreach piece, one example to look at would be the billboard campaign for the working family
tax credit
• From the radio ad perspective, applications online is a big barrier for those who don’t have computers.
Many complaints come in about this
Additional principles
The discussions with low-income service providers led to additional principles to guide the design of a
statewide program.
No systems that are long and complicated
Community organizations believe in a simplified system of providing assistance that will not be redundant or
frustrating for clients.
• They should not have to run through a maze to access assistance
• It is especially good to be able to only tell your story once and be connected to as many assistance
programs that you’re eligible for
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 135
The program should have a quick turnaround time from submission of the application to receiving the benefit
Community organizations noted that applications should be processed quickly for applicants to receive
benefits in a timely manner.
• Another barrier is the amount of time enrollment takes whether online or in-person
• Basing eligibility on net not gross income would be important, as would be enabling people to enroll
immediately instead of requiring a waiting period after a life event like losing a job
The program should use plain language for all materials and communications
Community organizations requested an expansion of accessibility by simplifying language used in outreach
efforts.
• Importance of supporting community partners in providing things like outreach and enrollment
• Use enrollment terms that are at a 4th grade level
Communications should be vetted by first-language speakers
Community organizations expanded on the need for increased language access through translation and
verification from first-language speakers in communities to ensure that delivery matches the intent and tone.
• Communications and services should be available in multiple languages, but these communications
should be vetted by first-language speakers in communities
The program should acknowledge low-income seniors tend to live on fixed incomes, and the program should
reduce the need for low-income seniors to reapply
Community organizations noted that low-income seniors often do not see any year-to-year material changes in
their circumstances, and that the program should try and reflect their static income in the re-application
process.
• For people with a fixed income, having to re-apply year after year is unnecessarily burdensome since
their material circumstances are not changing much year to year
The program should avoid benefits cliffs
Community organizations mentioned that the program should find ways to avoid abruptly pulling away support
for households whose incomes rise to the point where they are ineligible for program benefits.
• Women and children are often the most vulnerable people in need of assistance, and often get caught
in situations where once they are no longer eligible for assistance programs (only to face a sudden
drop in the support system that helped them get to where they were going); bill assistance (without
benefit cliffs) would help people in these kinds of situations, and it is important to keep this dynamic in
mind
• Think through a solution to avoid loss of SNAP benefits that trickle to other disparities, and prevent
advancement. Consider a transitional component, such as a three month grace period
The program should ensure protection of personal identifiable information
The idea of multiple methods of enrollment and categorical eligibility sparked discussions about data sharing
and protecting information. Ensuring the security of personally identifiable information would be important for
establishing community trust.
• Ensuring confidentiality and privacy may be particularly important program design features for tribes
and rural households
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 136
• How to ensure cybersecurity and IT integrity
Some conservation education
• Education along with program helps with (reduce energy) consumption
Any program should have representation of Black, Indigenous, and People of Color and other historically
marginalized communities
A few community organizations expressed that lack of representation of Black, Indigenous, and People of
Color communities on local and state boards and committees. Community organizations said that the lack of
representation discourages these historically marginalized and oppressed groups from speaking up in their
hometowns or state forums to shape the policies that most impact them.
• One problem with local and state advisory boards/committees is that through observation, many
people who sit on these groups are not sensitive to the needs of the people they are
serving/representing
• There is discomfort around people making decisions about communities they don’t have a connection
with
Community organizations said there were community benefits of having more multicultural service providers
be able to connect households directly to services.
• People who look like clients sharing stories, experiences and information helps build trust and spread
the word
Monthly bill discount mechanisms
Commerce presented a table of monthly bill discount mechanisms with benefits and drawbacks of each. The
table was developed over months of conversations with utilities and statewide advocacy organizations
through public workshops and comment periods. Community organizations were invited to add additional
benefits or drawbacks to the worksheet or revise those put forth by utilities and statewide low-income
advocacy organizations.
The worksheet did not include a monthly grant option, because it did not receive support from utilities or
statewide advocacy organizations. Community organization responses to the fixed percentage discount
suggest that a lump sum grant would not have been favored either, because it would not adjust to income and
not account for different needs of households.
The three mechanisms discussed were:
A fixed percentage discount: Every households would receive the same flat percentage off their total
monthly bill.
A tiered percentage discount based on income: Households would receive a percentage off their total
monthly bill that would vary based on household income tiers.
A personalized discount based on household energy burden: Households would receive a lump sum
amount or tiered percentage discount off their monthly energy bill based on their unique energy burden.
Community organizations expressed that all the options had pros and cons. There was an overwhelming
consensus that a tiered percentage discount based on income was the best option because it was the most
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 137
equitable mechanism. The fixed percentage discount was nearly always the last choice of community
organizations.
Community organizations generally agreed that the fixed percentage approach was inequitable. They generally
rated a personalized discount based on household energy burden second or last of the three options, because
of the administrative challenges of accounting for all the variables that can affect energy burden and potential
negative impacts on energy conservation.
A hybrid option was explored, where a program would offer a tiered percentage discount based on income
where the discount amount was tied to an approximate of amount of assistance needed to eliminate energy
burden for households in each income tier. While there was not extensive feedback on this option at each
listening session, this hybrid option appeared to receive general support from community organizations who
favored either a tiered percentage discount or a personalized discount based on household energy burden.
Additional discussions
Discussion of the benefits and tradeoffs of pursuing energy assistance through energy efficiency or
weatherization
Some community organizations raised energy efficiency as the primary solution to energy burden. Other
community organizations said energy efficiency or weatherization cannot meet energy burden in its entirety or
effectively reach many households, such as renters. They offered a number reasons why the state should
focus on bill assistance.
• In community action agency partnership experience, these households (low-income households) are
often most adept at conserving energy through sheer need
• [It takes a] long time to provide energy efficiency and weatherization [services]
A few providers noted the benefits a statewide bill assistance program could have on increasing awareness
about conservation. Some community organizations said that once a utility knows a household is receiving a
discount, it will be able to know if the household has excessive energy use and qualifies for low-income energy
efficiency and weatherization programs:
• Excessive energy use might indicate weatherization/efficiency
Others noted that a statewide bill assistance program could be used to make households categorically eligible
for energy efficiency and weatherization programs.
• By getting qualified for weatherization and get this at same time would be good
Community organizations in Tacoma, Stevenson and Colville also suggested that program materials for a bill
assistance program could provide education about conservation and energy efficiency and weatherization
programs.
Raising awareness of utility programs
A handful of community organizations suggested Commerce explore funding "navigators" for low-income
energy bill assistance or lead outreach for utility programs. Commerce staff said they had considered
navigators as part of its work under Sec. 120, and concluded any form of outreach on behalf of utilities would
be difficult given the vast array of utility programs, lack of bill assistance programs in many areas of the state,
and non-standardized eligibility requirements, enrollment processes, and benefit levels. This idea would layer
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 138
an administratively expensive outreach option on top of an already administratively expensive set of
fragmented programs. It is also beyond the scope of the report, which is to look at a statewide program.
Conclusion
Commerce's listening session series took place across a wide range of rural and urban communities and utility
service territories. The results of these conversations and listening sessions was the identification and
refinement of program design principles and a preferred bill assistance mechanism to help inform
Commerce's recommendation to the Legislature on a design of a statewide program.
Community organizations shared that low-income households are resilient, care for their families and
communities, and often sacrifice their resources to support fellow community members in need. Low-income
households are valuable community members and are grateful when they receive assistance. Community
organizations noted that even a little bit of assistance can make a big difference in the ability to meet basic
needs.
Community organizations shared that, far too often, they and the households they serve encounter
complicated and confusing requirements that often intentionally or unintentionally keep households from
accessing services or find no assistance program exists at all. While some community providers have direct
access to program enrollment, others may not have the ability to directly enroll households in programs.
Community organizations shared that households may travel significant distances to access services, only to
be turned away because they do not have proper paperwork. Program materials may not be available in the
language spoken by the low-income households.
Community organizations expressed that low-income services need to be highly visible with multiple doors to
access assistance. Structure and predictability need to be embedded in program eligibility criteria, enrollment
processes, and communications. Easy and concise applications and the elimination of unnecessary barriers to
access are important for successful programs, and can reduce administrative constraints and the time it takes
for households to apply and receive assistance. Community organizations also stressed the importance of
elevating historically marginalized communities and addressing poverty stigmas.
Community organizations overwhelming favored a tiered bill discount program based on household income,
because it was perceived to be the most equitable and not as administratively burdensome as other options.
A flat discount was not perceived to be equitable and a personalized household discount based on energy
burden was widely thought to be complicated and administratively burdensome.
Commerce suggested in the listening sessions that a tiered bill assistance program could provide benefits that
approximate the amount of assistance needed to eliminate household energy burden for different income
tiers. Community organizations that favored either a tiered bill discount based on income or a personalized
household discount based on household energy burden seemed generally receptive to this approach.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 139
Appendix I: Program design principles and the
recommended program design summary
The following principles were co-created with Washington utilities and low-income advocates over a series of
workshops and comment periods. The table below summarizes some of the ways those principles are
incorporated into the program design.
Table Q: Embedded Community Principles in the Program Design
Recommended statewide program design
Principle Summary of how the principle was incorporated into the program design
The program administrator should limit the information that households are required to
report when applying, and should structure documentation requirements to balance
The program should only require application
ease of completing an application and preventing fraud. Strategies to accomplish this
information that is required for program
could include:
implementation and minimize
Self-attestation with random post-enrollment auditing of a small sample of households
documentation required to enroll
Categorical eligibility for households already enrolled in other public assistance
programs
Application methods for a statewide energy assistance program could include:
The program should have multiple
In-person at any social service organization, with assistance available if necessary
application and enrollment methods,
User centric, mobile friendly online application
including methods that do not require
Phone
internet access or travel to a physical
Mail
location
Potential integrated benefits application
The program provides categorical eligibility for federal and statewide low-income
programs that align with program eligibility requirements. These include, but are not
Categorical eligibility should be provided limited to:
based on participation in other low-income The Supplemental Nutrition Assistance Program (SNAP)
assistance programs Temporary Assistance for Needy Families
Low-Income Home Energy Assistance Program
Aged, Blind, or Disabled Cash Assistance Program
Expands organizations that provide assistance and connects programs to Washington
The program administrator should be able
Connection.
to cross-enroll customers in other low-
income assistance programs
Potential integrated application.
Any organization or individual can enroll a household, including:
Multiple entities should be able to enroll Commerce
customers in a statewide program Community action agencies
Multi-family community service organizations
The discount will be applied to the household’s current billing statement if the
There should be a quick turnaround time
application is received within a certain number of business days before next month’s
from submission of application to receiving
billing cycle. If the application is received closer than that to the next billing cycle, the
the benefit
discount will be applied on next month’s bill.
The state agency will have the option to provide self-attestation.
Self-attestation with limited documentation
A unique advantage of a statewide program is the ability to use the Benefits
and small set of random income verification
Verification System (BVS) to check whether household is already enrolled in a
could balance program accessibility and
statewide energy assistance program and remove them from verification pool. This
integrity
would focus on households who are not already known to be low-income and improve
the integrity of current self-attestation processes
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 140
Recommended statewide program design
Immigration status should not affect The program only requires what is needed to identify the household as low-income and
eligibility enroll them in the program.
Entities that could conduct outreach or engagement for a statewide energy assistance
program include:
Commerce
Community resource providers
Administrators of other statewide assistance programs
DSHS offices and subcontractor organizations
Both outreach and engagement should be
Energy efficiency providers
conducted with trusted community partners
Multicultural service organizations
Tribes
Outreach would be supported by standardized materials designed with input of
Washington low-income households and community resource providers. These
materials would be translated into commonly spoken languages.
Utilities could post or distribute outreach Utilities would be required to post materials on their webpages (and integrate into their
materials with consistent messaging connection to service processes), and advertise the program at least twice a year.
Program materials and communications should:
Program materials and communications Be written at a grade school reading level
should use plain language and be trauma Not use technical jargon or legalistic language
informed Follow plain talk guidelines
Be respectful and aim to avoid reinforcing poverty stigmas
Interpretation services should be available on-demand for clients who have limited
Communications and services should be
English proficiency, and program materials should be translated into commonly
available in multiple languages with
spoken languages among enrolled households. Language access could be guaranteed
interpretation services available on request
through a mix of certified multilingual staff and contracted language services.
Outreach and awareness-raising campaigns should begin well before a program
Outreach efforts should precede program launches to prevent slow uptake. An illustrative schedule is initial outreach beginning
launch 12 months before launch of the program, and ramping up 6 months before program
launch.
Program materials and communications Program will be designed to include information about ways households can conserve
should raise awareness about the benefits energy, and can connect households with available energy efficiency and
of conservation weatherization programs.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 141
Appendix J: Survey of utility programs and webpages
Overview
In March 2024, Commerce surveyed utility webpages to assess the availability and accessibility of utility low-
income energy bill assistance programs, and to better understand the availability and accessibility of programs
from an individual household perspective.87
Methodology
Commerce surveyed the webpages of Washington's 50+ electric utilities for low-income energy bill assistance
program information and followed relevant hyperlinks posted on utility webpages to view all readily available
program information. Great care was taken to thoroughly document this information to minimize potential data
collection errors. Commerce collected data from utility webpages in an Excel workbook and preserved the
webpages and program information in PDFs, which are posted on Commerce’s Sec. 120 webpage. Any
information that was not readily available was labeled as "unknown."
This survey does not include important information, such as program participation rates, which will be
available in Commerce's Biennial Low-Income Energy Assistance Legislative Report (Sec. 120(6)), expected
before January 1, 2025.
Key findings
• Although utilities offer low-income bill assistance, nearly all (88%) of the offered programs have
restrictive eligibility criteria that do not match state law (RCW 19.405.120, Sec. 120) or administrative
rules (WAC 194-40-030).
• The inconsistencies across Washington's patchwork of utility bill assistance programs most often
extend beyond programmatic eligibility requirements to include significantly different application
requirements, varied and often limited enrollment processes, often incomplete information about
eligibility and application requirements, and other barriers to understanding and enrolling in utility low-
income programs.
• The Clean Energy Transformation Act (CETA) Sec. 120 set in statute the importance of providing low-
income utility assistance, but it has not made a uniformly accessible bill assistance option for all low-
income households statewide.
Findings
The data collected in this study shows little change in utility programs since Commerce's 2023 Legislative
Report, which found Washington’s utility bill assistance programs constitutes a patchwork of programs with
many gaps with unavailable, inaccessible, or insufficiently funded programs. Furthermore, it finds much of the
information communicated to households is incomplete or not self-evident, and in some cases outdated.
The survey's principal findings are summarized below:
87 RCW 19.405.120 (Sec.120) requires utilities submit data on their programs on a biennial basis. Commerce last published data on
utility assistance programs in 2023. Utilities were required to submit data for the reporting years 2022 and 2023 by April 1, 2024. That
data will be aggregated, cleaned, and published before Jan. 1, 2025. It will be made available on Commerce's Clean Energy
Transformation (CETA) Energy Assistance webpage at that time.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 142
Most programs funded through utility operations are not open to all low-income households.
• Over half (59%) of utility-funded bill assistance programs exclusively serve certain low-income groups
such as seniors or individuals with disabilities.
• Of the remaining programs, 75% (15 out of 20 programs) use income criteria that are more restrictive
than what is set out in state law (Sec. 120) and administrative rules (WAC 194-40-030).
• Roughly 9% (5 out of 58) of Washington utilities do not offer bill assistance.
Many of the programs have unreliable funding sources insufficient to meet all energy assistance need.
• 42% (35 out of 84) of low-income bill assistance programs are funded through donations.
• Donation-based programs tend to only serve customers who are facing emergency situations or
hardships and need to request financial assistance.
Bill assistance mechanisms have inconsistent design.
• Utility-funded programs are comprised of the following benefit mechanisms:
• 51% of programs provide a monthly discount rate.
• 18% of programs provide a monthly lump sum bill credit.
• 12% of programs did not provide publicly available information on the bill assistance mechanism or
assistance amount.
Donation-based bill assistance programs are comprised of the following benefit mechanisms:
• 22% of programs provide a yearly lump sum bill credit.
• 77% of programs did not provide publicly available information on the bill assistance mechanism or
assistance amount.
Low-income households see a wide range of assistance levels depending on which utility happens to serve
them.
• The amount of benefit a household may receive can vary widely for utility-funded bill assistance
programs.
• Donation programs offer significantly less assistance and are often only available once per year or
heating season to households.
Households must navigate vastly different enrollment processes depending on their electric utility.
• The program application processes and the information available about enrollment processes vary in
detail and levels of accessibility.
• 77% of donation-based programs do not list application information, and only a few offer office
appointments. Less than a quarter (23%) of donation programs provide an online application.
• Utility webpages rarely provide information about when and how households can reapply for their
programs.
• Utility webpages often do not provide program information in languages other than English. In many
cases, utilities redirect customers to a local community action agency webpage.
Income eligibility criteria listed was found to be in some cases inaccurate and outdated
• Roughly 5% (4 out of 84) of utility webpages for low-income programs reference outdated income
eligibility criteria used to determine whether a household may be eligible for bill assistance.
Information about donation-based programs is often sparse and the programs are often limited to
households who can demonstrate financial hardship or emergency needs
• 77% of donation-based programs did not provide information about how to enroll in the program.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 143
• 60% of donation-based programs provide no information on utility webpages about the amount of
assistance that may be provided to households.
• 71% of donation-based programs are geared towards households facing financial hardships or
emergencies.
Households interested in applying for assistance may not find information on their utility's website about
how long it may take from application to receipt of benefits
It is often not clear when households will begin receiving benefits after applying for programs. Webpages that
do measure timeliness often say households can wait as long as 90 days just to receive an appointment to
begin the application process. This may prevent households from receiving help when they need it most.
This survey found utility low-income bill assistance program eligibility requirements often fall far below
thresholds set by state laws and administrative regulations; they also deem many low-income households
ineligible due to non-income-related criteria. The survey points to a number of inefficient and inequitable
aspects of utility program design beyond program eligibility requirements, including inaccurate or missing
information posted on utility webpages, long waitlists for appointments, an inability to enroll households
through online applications, and more.
It is important to note many of these programs have existed for more than 25 years, with some nearly 50 years
old. The inability to align these programs to match state laws and administrative requirements for program
eligibility since the passage of CETA suggests significant challenges within the utility-by-utility approach to
energy bill assistance that undermine equitable assistance to low-income households.
This would not be needed if the Legislature opts to relocate energy assistance from utilities broadly across the
state through the establishment of a statewide monthly low-income energy bill assistance program.
Eligibility
Income eligibility criteria
Low-income is defined under state law (RCW 19.405.020) and administrative rule (WAC 194-40-030) as
household incomes that do not exceed the higher of 80% of area median income (AMI) or 200% of federal
poverty level (FPL), adjusted for household size.
Many utilities use eligibility criteria that fall below the higher of 80% of the Area Median Income (AMI) or 200%
of the Federal Poverty Level (FPL). Washington's three investor-owned electric utilities and three consumer-
owned utilities appear to be the only utilities to deliberately match the eligibility requirements set out in state
law (RCW 19.405.020) and administrative rules (WAC 194-40-030). Okanogan County PUD No 1 and Benton
County PUD No 1 use 80% AMI for their donation programs, but also limit those programs to households who
are deemed to be in emergency situations.
Income criteria that fall significantly below state standards.
There are 15 utilities with income eligibility guidelines below 200% of FPL. Even if these programs raised their
requirements to 200% FPL, these utilities would still have income eligibility criteria that fall below 80% AMI,
adjusted for household size.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 144
Table R: Utility-funded programs with Income Eligibility Limits below 200% FPL
Utility Program Name Income Eligibility Limit (FPL)
Port Angeles City Light Low Income Discount 100-125% FPL88
Chelan County PUD No 1 Low Income Disabled Discount 125% FPL
Ellensburg Energy Services Dept. Low Income Rate Seniors or Disabled 125% FPL
Richland Energy Services Low Income, Senior Citizens, and Disabled Discount 125% FPL
City of Port Angeles Utility Discount Program 125% FPL
Franklin County PUD No 1 Low Income Disabled Discount, Low Income Senior Discount 125% FPL, 125% - 175% FPL
Clallam County PUD No 1 Low Income Energy Assistance 138%-150% FPL89
Jefferson County PUD No 1 Standard Low Income 150% FPL89
Columbia Rural Electric Assn, Inc. Senior Citizen Discounts 150% FPL
Pend Oreille County PUD No 1 Low-Income Senior Discount 150% FPL
Mason County PUD No 1 Canal Comfort Fund 150% FPL
Cowlitz County PUD No 1 Discounted Rate (SDDR) Program 175% FPL
City of Milton Electric Division Reduced Utility Rates 175% FPL90
Centralia City Light Senior/Disabled Discount 199% FPL91
Income eligibility above 200% FPL may still fall below 80% AMI.
60% of utility-funded programs list eligibility requirements at 200% FPL or higher. However, even in cases
where utilities use above 200% FPL for income eligibility, Commerce found the county 80% AMI to be
significantly higher.
For example, Tacoma Power’s Bill Credit Assistance program uses 300% FPL for determining income eligibility.
For a one-person household, 300% FPL would be $45,165. In comparison, 80% AMI in Pierce County is $60,200.
Use of other income eligibility metrics does not match state law (RCW 19.405.020) or administrative rules
(WAC 194-40-030) and may make a considerable number of households ineligible.
Seattle City Light has elected against both FPL and AMI. The utility uses 70% state median income (SMI). The
selection of this income criteria produces a gap in eligibility. The figure below shows the comparison between
standard income limits in Washington and the city of Seattle.
88 Range denotes programs with tiered income eligibility
89 Utility using an income that was closest to FPL % using HHS 2024 figures
90 Utility using an income chart that matched 200% for household sizes of one, but for households of 2+, income was not adjusted in
line with 200% FPL
91 Utility states eligibility as $30,000 per year or less for a household size of one, 2024 HHS states that 200% FPL is $30,120
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 145
Table S: Seattle Area AMI, SMI, and FPL Comparisons
Household/Family Size 80% AMI (2023) 70% SMI Difference
1 $70,650 $44,268 $26,382
2 $80,750 $57,900 $22,850
3 $90,850 $71,520 $19,330
4 $100,900 $85,140 $15,760
5 $109,000 $98,760 $10,240
6 $117,050 $112,392 $4,658
Utility webpages without listed eligibility criteria
There are handful of utilities with utility-funded programs that do not list any eligibility criteria on their
webpages:
• Chewelah Electric Dept.
• City of Coulee Dam Light Dept.
• Modern Electric Water Company
• Peninsula Light Company
• Peninsula Light Company does not share income eligibility requirements and requests income on
the application (see screenshot below)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 146
Figure 1: Peninsula Light Co Application for Electric Rate Discount Program
Non-income eligibility criteria
Currently, over a third (41%) of utilities only provide programs designed for senior citizens and/or individuals
with disabilities. One program includes veterans in its program for seniors and individuals with disabilities, and
another program includes widows and widowers.
Different definitions for non-income eligibility criteria
Distinctions in defining non-income eligibility criteria, such as age requirements for senior assistance
programs, underscore the diversity in programmatic approaches across utilities. While the majority of
programs adhere to a benchmark age of 62 and over for seniors, a minority us an age threshold of 65.
Utilities defining “senior” as 65 years or older:
• Columbia Rural Electric Assn, Inc.
• Ellensburg Energy Services Dept.
• Pend Oreille County PUD No 1
Categorical eligibility for often limited programs
A handful of utilities use categorical eligibility in addition to or in place of income eligibility criteria. This
approach can eliminate the need for separate income verification, simplifying the application process for
customers. However, categorical eligibility may exclude individuals who do not qualify for or currently
participate in the categorically eligible programs.
Many of the programs below offer categorical eligibility only for programs with income thresholds below 200%
FPL or 80% AMI, adjusted for household size, and many do not include statewide low-income programs with
relatively high participation rates at or above 200% FPL.
Orcas Power & Light Cooperative
OPALCO's Energy Assist program states that eligibility is determined based on participation in other programs
that serve low-income households. Members who meet the qualifications for other assistance programs such
as Federal Free Lunch, LIHEAP, or OPALCO’s donation-based program, Project Pal, do not have to verify their
income.
Seattle City Light
The application process for Seattle City Light's Utility Discount Program and Emergency Bill Assistance
eliminates income verification by accepting a SNAP (food stamps) Approval Letter for Benefits. It is unclear
why the City requires an approval letter versus information readily available on an EBT card.
Jefferson County PUD No 1
Jefferson County PUD No 1's Standard Low Income program uses automatic enrollment for any customer
receiving LIHEAP.
Kittitas County PUD No 1
Kittitas County PUD No 1's Low-income program also auto-enrolls customers receiving LIHEAP. Their webpage
states that "Customers who qualify will be automatically enrolled annually in October, and the discount will be
in effect for 12 months or until service termination." It is unclear what happens to customers who enroll in
LIHEAP past October.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 147
Public notice of eligibility requirements
Utilities typically state eligibility requirements for their assistance programs through a chart of incomes or by a
percentage of AMI, FPL, or SMI.
Relying on percentages may leave customers confused and deter them from seeking assistance as income
amounts based on percentages of FPL, AMI, and SMI are not readily apparent. Meanwhile, stating income
amounts means the data needs to be updated annually with changes in FPL and AMI.
As of March 2024, some did not have updated numbers per the updated FPL guidelines:
• Skamania County PUD No 1
• Ellensburg Energy Services Dept.
• PacifiCorp
• Pend Oreille PUD No 1
Examples of outdated or incorrect eligibility references
Skamania PUD No. 1
Skamania PUD uses a chart to display income eligibility requirements based on FPL levels. The chart states
200% FPL for a single person household is $29,160 (see Figure 2). However, according to HHS, the 2024 FPL
states that for a single-person household, 200% FPL is $30,120.
Figure 2: Skamania PUD No. 1 Low-Income CETA Assistance Eligibility Criteria
Ellensburg Energy Services Dept.
The Ellensburg Energy Services Dept.'s Low-Income Senior & Disabled Discount Rate Application includes 2019
guidelines for FPL:
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 148
Figure 3: City of Ellensburg Low-income Senior & Disabled Discount Rate Application
Pend Oreille PUD No. 1
The Pend Oreille PUD No. 1 application for their Low-Income Senior Discount states that 2024 150% FPL for a
single household is $20,783, but the 2024 FPL limit from HHS states $22,590. The numbers for two to nine
person households do not match the 2024 FPL numbers, either.
Figure 4: Pend Oreille PUD No. 1 Low-Income Senior Eligibility Requirements
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 149
PacifiCorp
The webpage for PacifiCorp's Low-Income Bill Assistance program provides an income eligibility chart.
However, when comparting them to the 2024 HHS FPL numbers, the chart references numbers for 2023 FPL.
According to HHS, the 200% FPL monthly income for a single person household in 2024 is $2,510. The LIBA
program states $2,430.
Figure 5: PacifiCorp Low-Income Bill Assistance Eligibility Requirements
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 150
Enrollment
Application
Utility webpages show differing levels of detail regarding the application process for utility-funded energy
assistance programs. Most utilities offer a PDF version of the program application online. There was often
little to no information on how to access donation-based programs.
The process of submitting applications also varies by utility.
Examples of application barriers
Chelan County PUD
Chelan County PUD offers a senior and disabled discount program. The application process does not include
an online submission option. Applicants can submit their applications at various designated locations or by
mail.
Figure 6: Chelan County PUD Senior Discount Rate Program Application
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 151
Klickitat PUD No. 1
Klickitat PUD No. 1 offers no direct link to its Low-Income Elderly Rate application or submission information
on its webpage. The webpage states that the Klickitat County Senior Services completes certification, but the
webpage for the county does not provide any information regarding the program.
Figure 7: Klickitat PUD information on Low-Income Elderly Rate
Application availability
Commerce found:
• 24% (12 out of 49) of utility-funded programs did not provide a link to the application
• 10% (5 out of 49) of utility-funded programs did not provide any application submission instructions
• 42% (21 out of 49) of utility-funded programs listed only one way to submit, including over the phone
(57%) or online (33%)
• 77% of donation-based programs did not provide a link to the application
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 152
Examples of barriers to submitting applications
Snohomish PUD No 1
Snohomish PUD No 1 offers a link to their PDF application and required it to be returned by mail or fax. These
submission options may be limiting for those without access to a printer or fax machine.
Figure 8: Snohomish PUD Application Instructions
Lewis County PUD No 1
Lewis County PUD No 1 does not provide a copy of the application and only provides information to schedule
an appointment with the local community action agency.
Figure 9: Lewis County PUD No 1 Application Process
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 153
City of Richland
Richland Energy Services provides a discounted rate program for low-income seniors and individuals with
disabilities. The webpage states that the application and proof of income must be verified in person at the
local community action agency, and then submitted to the City’s customer service office. The webpage does
not specify if the verified application can be mailed.
Figure 10: Richland Energy Services Discounted Rate program
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 154
City of Chewelah
The utility bill assistance program administered by Chewelah Electric Department operates through Rural
Resources and offers limited application dates. Online applications may only be submitted at 11 a.m. on Oct. 2,
Feb. 1, and June 3. Applications can be taken over the phone starting at 11 a.m. on Dec. 1 and April 1. After
submitting an application, there may be a waiting period of up to 90 days for an appointment at the local
community action agency.
Figure 11: City of Chewelah Energy Assistance Program Application Dates via Rural Resources
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 155
Clallam County PUD No 1
Clallam County PUD No 1 subcontracts its low-income bill assistance program through the Olympic
Community Action Programs, or OlyCap. OlyCap serves both Clallam and Jefferson counties. It also
administers LIHEAP, which can be applied for in the same appointment scheduler on their webpage.
As of March 2024, OlyCap's webpage states that for both Clallam PUD and LIHEAP grants, there were no
openings for appointments. The earliest openings are in April and customers in immediate need are directed to
make payment arrangements with the utility directly. Appointments are conducted by phone.
Figure 12: Clallam County PUD No. 1 Low Income Energy Assistance Application Dates
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 156
Columbia Rural Electric Co-op
Columbia REA provides eligibility and documentation requirements for its senior discount on its webpage.
However, low-income seniors must call the utility to request a certification letter to be mailed, which they add
their documents to and then send back.
Figure 13: Columbia Rural Electric Co-op Senior Citizen Discounts Application Information
Grant PUD No 1
Grant PUD No 1 posts information for its assistance program under the "About Your Bill" portion of the
webpage, which is hidden by a dropdown arrow on the "Billing & Payments" Page. Information about the
assistance is not linked under "Ways to Pay", "Pay Your Bill" or "Ways to Save" The layout of the webpage does
not help customers find information about assistance, as searching "assistance" did not result in a link to the
program's page.
Figure 14: Grant PUD Bill Assistance Webpage
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 157
Benton County PUD No 1
Benton County PUD's Low-income discounts program requires the applicant to go to their community action
agency for income verification before mailing or dropping off the application at the PUD.
Figure 3: Benton County PUD No 1 Low-Income Discount for Seniors Application
Availability of applications in multiple languages
Program information is widely available exclusively in English. A handful of utilities provide information on the
application process as well as the applications in languages in addition to English. Only three utilities included
languages in addition to Spanish, which highlights a key accessibility barrier for households from a variety of
cultural backgrounds.
Programs providing language translations in addition to English:
• Avista Corp: Application available in Marshallese, Spanish, Russian, Ukrainian
• Benton County PUD: Application provided in Spanish
• Benton Rural Electric Association: Application provided in Spanish
• Cowlitz County PUD No 1: Application provided in Chuukese and Spanish
• Douglas County PUD: Application and information provided in Spanish
• Franklin County PUD No 1: Program information provided in Spanish
• Mason County PUD No 3: Application provided in Spanish
• PacifiCorp: Application provided in Spanish
• Puget Sound Energy: Website language options include Spanish, Chinese, Russian, Vietnamese, Korean
and Hindi
• Snohomish County PUD No 1: Application provided in Spanish
• Tacoma Power: Flyers English, Ukrainian, Vietnamese, Spanish, Russian, Korean, Khmer
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 158
Timeliness
The time between when a customer submits their application for benefits and when they begin receiving them
is important information for household budgeting. This information is often not transparent.
When utilities do disclose wait times, they are often long. For example, the Chewelah Electric department said
there could be a waiting period of up to 90 days for an appointment. They did disclose when benefits would
begin to be applied to customer accounts after a successful appointment.
Verification and renewal process
Customers receiving benefits must undergo reapplication or reverification of income to maintain eligibility for
continued benefits. Some utilities specify expectations for continuation of benefits on a biannual or annual
basis. However, many programs did not provide information on the reapplication or verification process.
Examples of barriers to eligibility verification and renewal
Franklin PUD No 1
The Low-Income Disability Discount offered by Franklin PUD No 1 requires an annual re-verification of income
eligibility and disability verification. This obligation for continued benefits could prove to be an unnecessary
barrier for individuals, especially for those with fixed incomes or permanent disabilities.
Figure 16: Franklin PUD Low-Income Disabled Discount program requirements
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 159
Orcas Power & Light Cooperative
Orcas Power & Light Cooperative requires applications be submitted yearly by April 30. It adds a disclaimer
that benefits might change due to program capacity. If a customer first applied for the program in January, it is
unclear if they would still have to reapply in April despite only receiving the benefit for a few months, for
example.
Figure 17: OPALCO FAQ Section for Energy Assist Program
Peninsula Light Company
On the Senior Discount and Disabled Discount applications, Peninsula Light Company states that the
"Applicant must reapply annually in the month of April to ensure they continue to meet the program criteria."
Other programs that provide a longer timeline for program eligibility include The City of Richland’s Utility Rate
Discount program, which states “applicants who are eligible to receive the discount must re-apply every two
years to continue their discount.” Another example includes Benton Rural Electric Association’s Low income
Senior/Disabled Member Discount program, which is valid for three years.
Seattle City Light states that if the applicant is ineligible for the program, “Customers determined ineligible for
the Utility Discount Program must wait thirty (30) days/one month to reapply.” The timeline listed on their
webpage for application processing is four to six weeks.
Bill assistance program design
The bill assistance programs in Washington utilize a number of mechanisms to deliver benefits to enrolled
customers. The 49 low-income bill assistance programs funded through utility operations use the following
mechanisms:
• 51% of the programs utilize monthly discount rates to provide ongoing relief to eligible participants
• 18% of the programs opt for monthly lump sum payments
• 12% of the programs do not specify on their webpages how benefits are determined and only provided
the maximum benefit available per year
• 6% of the programs choose to reduce basic charges as a form of assistance
• 12% of the programs did not state any information regarding the benefit mechanism
Seasonal bill assistance programs and potentially confusing benefit
calculations
Some utilities off bill assistance during certain months of the year. These programs aim to provide financial
relief to households during periods of heightened energy consumption or increased energy costs, typically
during winter. With increased cooling needs during summers, the merits of offering assistance only during the
winter months is questionable.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 160
Households may struggle to pay their energy bills at any time during the year, and the disparity between the
months they may get assistance and the months they do not may pose significant challenges to them.
Examples of seasonal barriers to program access
City of Ellensburg
The City of Ellensburg states “Applications for low-income utility rate discounts are accepted year round.”
However, the webpage states that applications received before November 1 are considered for the upcoming
calendar year's discount. This could create confusion for customers who are not aware of the program prior to
November 1.
Lewis County PUD No 1:
Lewis County PUD No 1's donation-based program, Project Share, is available for customers in need. However,
the webpage states that the program "begins on November 15 and ends on May 31 of the current energy
season."
Conclusion
Based on a survey of data from utility webpages in March 2024, low-income households across Washington
experience a wide array of eligibility and ease of access to billing support programming based on whichever
utility district they live in. The requirements of CETA did not create equity of assistance across the state. With
exception of Mason County PUD No 3, only the investor-owned utilities have adopted the low-income
definitions laid out by the statue and administrative rule, perhaps because their regulator, the Utilities and
Transportation Commission, told them to adopt the state's income criteria.
This survey highlights that issues with utility bill assistance program design run deeper than program eligibility
and touch on the human experience of searching for assistance. Perhaps not be as impactful as restrictive
income eligibility criteria, inaccurate information about programs and the inability to expeditiously enroll in
programs can have profound impacts on the ability of households to receive assistance.
It is unclear whether utilities can ever reach the participation rates of statewide low-income programs;
however, it is clear that significant efforts would be needed to overhaul and harmonize all of these program
design elements across utilities under a utility-by-utility approach to energy assistance.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 161
Appendix K: Bill discount mechanisms
Background
There are three common bill discount programs:
• Fixed percentage discount
• Tiered percentage discount
• Percentage payment plan
These discount types are described below.
Types of discounts
A fixed percentage discount: A bill assistance discount mechanism where every household receives the same
flat percentage off their total monthly bill. Some existing utility bill assistance programs provide assistance in
this way, such as Seattle City Light.
A tiered percentage bill discount: A bill assistance discount mechanism where households receive a
percentage off their total monthly bill, which would vary based on household income tiers. Households with
lower incomes would receive a higher discount percentage and households with higher incomes would receive
a lower discount percentage. Avista and Puget Sound Energy provide examples of tiered bill discount
programs that target assistance to households in greatest energy assistance need.
Percentage payment plan: A bill assistance discount mechanism where a household receives a lump-sum
amount off its monthly energy bill to eliminate its energy burden on a month-to-month basis. Energy burden is
the percentage of household income spent on energy bills. If the energy burden threshold were to be set at 6%,
for example, households would receive a bill discount calculated to keep their monthly energy bill no higher
than 6% of monthly household income.
Table T: Summary of benefits and drawback of different bill assistance mechanisms
Monthly bill discount
Description Benefits Drawbacks
mechanisms
Assistance is proportionate to
Funds are not targeted to those with less
energy usages.
Households would receive an income.
Fixed percentage
amount off their monthly
discount Less household information is
energy bill Funds are not targeted to those with higher
required to administer the
energy burdens.
program.
Households with less income
receive greater benefits than
Households would receive a households with more income.
percentage off their total
Tiered percentage Perhaps more difficult to administer than a
monthly bill that would vary The assistance amount could
discount flat bill discount
based on household income be tied to an approximate
tiers. amount of a discount rate to
eliminate energy burden for a
households in each tier
Percentage payment Households would receive an Requires the most information and may be
Energy burden specific.
plan amount off of their monthly the most difficult to administer.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 162
Monthly bill discount
Description Benefits Drawbacks
mechanisms
energy bill to reduce based on
a percentage of household Concern that it would cap energy costs at
income spent on home energy. a percent of income and discourage
energy conservation more than the other
approaches.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 163
Appendix L: Data sharing to streamline enrollment
Background
In the proviso directing Commerce to prepare this report, the Legislature specifically directed Commerce to
investigate data sharing across statewide programs serving low-income households. As part of investigating
such data sharing possibilities, Commerce consulted extensively with the Department of Social and Health
Services (DSHS).
Commerce focused on two key data sharing questions in its consultations: the possibility of using DSHS’s
Benefits Verification System to streamline enrollment in a statewide energy assistance program, and the
possibility of using Supplemental Nutrition Assistance Program (SNAP) data to auto-enroll households in a
statewide energy assistance program.
Benefits Verification System
DSHS’s Economic Service Administration’s (ESA) Benefit Verification System (BVS) is public facing web-based
system that allows authorized users to search for and receive a pre-determined set of information about
people receiving public assistance. The BVS system requires that service providers obtain client authorization
prior to searching for their information.
Commerce and DSHS discussed whether the BVS system could export data to identify and enroll households
in a statewide energy assistance program. The agencies also explored if BVS could be used to identify
individuals potentially eligible for energy assistance based on their receipt of public assistance benefits
administered by DSHS.
The Washington State Courts attempted a similar project in 2018 to address SB 6215, “establishing a
collaborative process to alleviate the burden on local courts to determine indigency through proof of receipt of
public assistance.” While BVS is not able to produce a list of low-income households, the Courts were able to
search individual names and receive a yes or no response indicating the individual’s receipt of public
assistance benefits. The Courts currently use BVS for this verification, therefore potentially identifying them as
indigent.
DSHS indicates that households who are enrolled in certain existing statewide low-income programs could opt
to provide their social security number or DSHS Client ID number for verification purposes, and could authorize
a statewide energy assistance program administrator to query BVS with their information. With appropriate
data sharing agreements in place, and as allowable by federal and state laws, the state administrator could
then attempt to query the household’s information and verify the household is low-income.
Auto-enrollment with SNAP data
In addition to discussing use of BVS to streamline enrollment in a statewide energy assistance program,
Commerce and DSHS discussed the possibility of using Supplemental Nutrition Assistance Program (SNAP)
data to auto-enroll households in a statewide energy assistance program. Since SNAP uses an income
threshold of 200% of the federal poverty level, and a statewide energy assistance program would likely use an
income threshold of the greater of 200% of the federal poverty level or 80% of area median income,
households that are enrolled in SNAP would also be eligible for an energy assistance program.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 164
Through those discussions, it became clear that there are both federal and state legal barriers to sharing
confidential information needed for auto-enrollment of SNAP recipient households in a statewide energy
assistance program. ESA provided an analysis of these barriers, which comprises the remainder of this
appendix.
ESA: Legal barriers to SNAP data sharing
Washingtonians trust the government with personal information to receive vital public assistance
services. Public assistance information, especially food recipient data, is highly sought by many entities for
excellent reasons. As responsible stewards of private information, the government examines each request to
comply with state law, federal regulation, and responsibly uphold that trust.
Public assistance recipient information is private and confidential per RCW 74.04.060(1)(a). Specific federal
regulations also apply to information based on the program, such as 7 CFR 272.1 for SNAP. While both have
nuanced language differences, they prohibit us from disclosing client information outside of defined
parameters. Foundationally, state law allows client information to be disclosed to administer a handful of state
programs in Chapter 74. However, federal regulation allows SNAP client information to be used or disclosed
for the purpose of administering the food program.
State law
RCW 74.04.060(1)(a) prohibits the department from disclosing records except to administer the programs in
this title. Those programs include:
• WorkFirst
• Temporary Assistance for Needy Families (TANF)
• Child welfare, adoption
• Aged, Blind, or Disabled (ABD)
• Pregnant Women Assistance (PWA)
• Housing and Essential Needs (HEN) Referral
• Vulnerable Adult Abuse/Long Term Care
• Medical Assistance
Federal food client regulation
• 7 CFR 272.1 allows disclosure for:
• Persons directly connected with:
• administration or enforcement of the provisions of the Food Stamp Act
• other Federal assistance programs
• federally assisted state programs providing assistance on a means-tested basis to low income
individuals
• general assistance programs subject to joint processing requirements in 273.(j)(2)
• programs required to participate in IEVES in 272.8(a)(2), useful to establish/verify eligibility or
benefit amounts
• verification of immigration status or aliens applying for food stamp benefits through the SAVE
program
• administration of the child support program under IV-D of SSA
• Employees of the Comptroller General’s Office for audit
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 165
• Local, State, Federal law enforcement officials, on written request, to investigate alleged violation of the
Food Stamp Act
• Local, State, Federal law enforcement officials, on written request, to locate an individual fleeing to
avoid prosecution or custody of a crime
• Educational agencies for the National School
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 166
Appendix M: Funding options
Background
The Legislature asked Commerce to consider funding when it comes to designing a statewide low-income
energy assistance program. It did not ask Commerce to recommend a funding source for a statewide low-
income energy assistance program, and Commerce is not making a recommendation on a funding source.
Commerce identified and evaluated three potential funding sources to see if any of the funding choices would
have any unique qualities that would impact a program design. These three funding sources include:
• The State General Fund
• Washington’s Climate Commitment Account
• A system benefits charge
A commonality of all these funding sources is that they would reside within the state treasury.
The principal differences of these sources are that both the Climate Commitment Account and state general
fund exist today and competition for these funds are fierce, yet they do not impact utility rate bases. A system
benefits charge would need to be enacted by the Legislature and an account would need to be created within
the state treasury solely for the purposes of the monthly low-income energy assistance program. A system
benefits charge would be rate-based and show up on energy utility bills.
While the analysis below looks at each funding source separately, the Legislature could carefully blend funds
from different sources. For instance, there may be advantages to using the State General Fund to fund
program administration, a system benefits charge to fund a base amount of assistance for low-income
households, and the Climate Commitment Account to supplement a system benefits charge.
Climate Commitment Account
Washington’s comprehensive cap-and-invest program sets a declining cap on carbon. Carbon producers bid on
allowances to emit carbon at state sanctioned auctions. Most of the revenues from those auctions go into
accounts within the state general fund.
The Climate Commitment Account is one account within the state general fund funded with revenues from the
cap-and-invest revenues. The list of eligible uses includes bill assistance for low-income households.
A benefit of using funding from the Climate Commitment Account is that the costs of funding energy
assistance programs would not be borne electric and natural gas ratepayers. The drawbacks are that they are
subject to legislative appropriation on biannual basis, and funding for the statewide program would have to
compete with other priorities, albeit within a narrower range of options than the state general fund.
Sec. 47 of the Climate Commitment Act includes a statement of intent that the Legislature intends to establish
policies to mitigate the cost burden of the program established by this act on consumers who use home
heating fuels that are not electricity or natural gas. Funding from the Climate Commitment Account could be
appropriated to a statewide energy assistance program to address energy burden from other home heating
fuels, as contemplated under Sec. 47 of Washington's comprehensive cap-and-invest program, the Climate
Commitment Act.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 167
Washington Initiative 2117 (2024) would repeal the Climate Commitment Act. If the initiative passes, a
statewide low-income monthly energy bill assistance program would need to be funded through the state
general fund or a system benefits charge.
State General Fund
The state general fund operates on a 2-year budget cycle. The Legislature sets the biennium budget in the first
year, and supplements that budget in the second year.
Funds from the state general fund would not come from ratepayers. Drawbacks to state general funds include
competing needs for scarce tax dollars, the ongoing need to secure legislative appropriation, and the potential
for unreliable funding due to increase-and-decreases in tax revenues from ups-and-downs in the overall
economy.
System Benefits Charge
A system benefits charge is a statewide uniform charge, such as a percentage of revenue or an amount per
unit of energy, assessed on energy services to fund energy assistance programs. Revenues from the charge
would be placed in a state account with the explicit purpose of providing universal access and uniform benefit
levels to low-income households through a statewide low-income energy assistance program.
A systems benefit charge ensures all utilities contribute to utility bill assistance for low-income households
and spreads the costs across high-income and low-income areas of the state, which may mean utilities paying
the most on assistance programs would pay a lower percentage of program costs under a system benefits
charge.
A system benefits charge would avoid disproportionate impacts on customers of individual utilities by sharing
resources across utilities to address energy burden statewide, and would especially protect customers served
by small largely rural utilities with an above-average share of low-income customers with high energy burden.
A system benefits charge could be phased into the program to ensure reliable funding for a program over the
medium-to-long term with the opportunity for the Legislature to review the impacts of the charge on rate
payers on an annual or biennial basis. A system benefits charge would show up on customer bills.
Table U: Summary table of potential funding sources
Potential funding
Benefits Drawbacks Other
source
Avoids utility rate base Requires legislative appropriation
Climate Potential supplement for other funding Fluctuations in cap-and-invest Funding may not exist if voters
Commitment sources revenues repeal the Climate Commitment
Account Fewer competing priorities compared to Risk of funding not being Act
the state general fund consistently allocated
Competition for scarce tax dollars
Avoids utility rate base Requires legislative appropriation
State General Fund Potential supplement for other funding Cyclical economic dynamics
sources Risk of funding not being
consistently allocated
Dedicated funding that avoids legislative Hard to include non-utility energy, Everyone contributes to low-
System benefits appropriation such as firewood and propane income energy assistance
charge Spreads costs across high and low-
income areas of the state Dedicated account could be Potential net transfer from some
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 168
Potential funding
Benefits Drawbacks Other
source
subject to legislative change in utilities to other utilities
purpose
Uncertain if households served
Potential rate impacts to by utilities providing the most
households that do not energy assistance today would
participate in the program spend more on energy
assistance or less if subject to a
system benefits charge
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 169
Appendix N: Caseload Forecast Council
The Washington State Caseload Forecast Council (Council) is an independent state agency governed by a bi-
partisan council. The Council is charged with forecasting the entitlement and other caseloads for Washington.
The Council meets several times a year to adopt official forecasts that are used as the basis of the governor’s
budget and by the Legislature in developing the omnibus biennial appropriations act.
The forecasts cover programs and services broadly grouped under children’s services, public assistance,
education, long term care, medical assistance, education, and corrections. In the public assistance category,
the Council provides caseload forecasts for the following programs:
• Temporary Assistance for Needy Families
• Aged, Blind and Disabled Assistance Grant
• Working Connections Child Care
• Early Achievers Tiered Reimbursement Providers
• Working Families’ Tax Credit
RCW 43.88C.030 requires the Council to produce caseload forecasts at least three times a year. The Council
provides monthly monitoring reports that compare current actual caseloads with the caseload forecast. The
Council provides periodic caseload forecast updates for these programs, as well as historical caseload data.
The Council produces public assistance forecasts in June, November and February, to align with major state
budgetary milestones. Forecasting begins with a technical workgroup for each program. Technical workgroups
include council and program staff. From the technical workgroup, forecasts next move to formal workgroups,
which include more senior staff, and are then advanced to the body that oversees the agency, called the
governing council. The Council is made up of representatives from the House, Senate and Executive branch.
These forecasts estimate program demand through the end of the current budget period.
In combination with the Council’s caseload forecasts, the agencies that administer programs use estimates of
per capita program costs to estimate program costs. The Council does not forecast program costs.
If the Legislature were to create a statewide low-income energy assistance program, forecasting caseloads for
this program would be within the scope of the Council’s experience and mandate. The Council has recent
experience forecasting demand for new assistance programs, including the Working Families’ Tax Credit.
Caseload forecasts from the Council for a statewide low-income monthly energy bill assistance program
would provide an open and transparent process for regular, consensus-based estimates of future program
demand.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 170
Appendix O: Benefit cliffs
A benefits cliff occurs when a household experiences a sudden increase in household income that makes
them ineligible for assistance programs, triggering a sudden loss of assistance. Depending on the value of the
lost benefits compared with the income increase, these households can be left with fewer total resources than
when they had less earned income.
With a presumptive income threshold of the greater of 200% of the federal poverty level or 80% of area median
income, it is especially important for an energy assistance program to include a mechanism to avoid an abrupt
benefits cliff. This is near the income thresholds for several existing public assistance programs, notably the
Supplemental Nutrition Assistance Program (SNAP) and the Working Connections Child Care subsidy. SNAP
has an income threshold of 200% of the federal poverty level, and the Working Connections Child Care subsidy
has an income threshold of 60% of state median income upon initial application, and 65% of state median
income when reapplying for benefits.
This similarity in income thresholds means that some families receiving benefits from all three programs could
lose all of those benefits at the same time after a sufficiently large increase in household income. For families
with child care needs, this could be particularly impactful. A 2015 study from the Seattle Jobs Initiative found
that for Washington families with children, the loss of child care subsidies was often the benefits cliff with the
greatest impact on total household resources because of the high cost of child care. Losing energy assistance
at the same time could exacerbate this impact.
When public assistance programs and administrators take proactive action to smooth the transition from
receiving an income increase and becoming ineligible for public benefits, low-income households face one
less barrier to upwards economic mobility. While policy responses like earned income tax credits can help
mitigate the impact of the benefits cliff across many public assistance programs, there are also a number of
examples of program-specific strategies that a statewide low-income energy assistance program could
emulate.
Transition periods
One such strategy is to provide a transition period following an income increase that allows households to
receive benefits when they would otherwise be deemed ineligible for assistance. This transition period gives
households enrolled in public assistance programs time to plan for the transition off public benefits, instead of
facing a sudden loss of assistance.
Several states that have utilized or are piloting transitional periods for their social service programs. For
example, the New Hampshire Department of Social and Health Services is piloting a program to close the
benefits cliff, with one element of that pilot program being a temporary 100% income disregard for households
enrolled in Temporary Assistance for Needy Families (TANF) with members working in high-demand jobs. In
2019, Maine passed the STEP bill, which created a six-month stepped transition for households receiving TANF
that receive new income, with 100% of earned income disregarded for the first three months after an income
change, 75% of earned income disregarded for the following three months, and 50% of earned income
disregarded after that initial six-month period. TANF benefits reduce as a household’s income increases up to
the limit at which they are no longer eligible, so these income disregards allow enrolled households to work
and retain more of their income without immediately affecting the benefits they receive from TANF.
Washington instituted its own changes to TANF income rules aimed at addressing the benefits cliff in 2023.
Chapter 418, Laws of 2023 specifies that, effective August 1, 2024, families receiving TANF may keep the first
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 171
$500 of earned income each month that the family receives benefits. TANF families in Washington also retain
half of any monthly income earned above $500.
Transitional benefits
Another means of addressing the benefits cliff is providing dedicated transitional benefits aimed at bridging
the gap between an income increase and a loss of public assistance benefits. In Washington, the Transitional
Food Assistance (TFA) program provides temporary food assistance benefits once households are deemed
ineligible for these programs or request to leave them.
For households enrolled in TANF and SNAP, TFA provides up to five months of food assistance benefits
following a household being deemed ineligible for TANF. 92 For households enrolled in SNAP only, when their
reported gross income exceeds program limits, they automatically receive a $10 benefit called Temporary
Cash Assistance (TCA) in their last month of SNAP eligibility. Households eligible for the TCA benefit are then
also eligible for TFA for five months. 93 TFA benefits are calculated based on the monthly benefit a household
received in its last month of TANF eligibility or the month it was eligible for TCA. 94 By providing households an
additional five months of food assistance between becoming ineligible for TANF and SNAP, TFA aims to give
households additional time to plan for and adjust to the transition off public assistance while retaining access
to food benefits.
TANF support payment pass through
A TANF-specific strategy that Washington and other states have implemented is a pass through of previously
withheld support payments. In order to receive TANF benefits, households must assign their rights to any child
support, spousal support, alimony, maintenance, or medical support payments to the state for the duration of
the time they receive TANF benefits. 95 Federal law allows states to pass through up to $100 a month of these
support payments, or $200 a month for a family with two or more children, to households receiving TANF
without any requirement for states to reimburse the federal government for these payments. 96
Chapter 349, Laws of 2020 directed the Department of Social and Health Services (DSHS) to pass through up
to $50 a month of support payments, or up to $100 a month for a family with two or more children, to
households receiving TANF, effective February 1, 2021. Building on that, Chapter 174, Laws of 2024 directs
DSHS to pass through the full amount of all support payments to households receiving TANF, and also
requires DSHS not to count these pass through payments as income for the purposes of determining eligibility
for TANF, or the benefit amounts that enrolled households receive. This law is effective January 1, 2026.
With support payments disregarded for determining TANF eligibility or benefit amounts, households receiving
both TANF benefits and support payments can earn more income through work while remaining eligible for the
program than if support payments counted against their monthly benefits.
92 Washington State Legislature, “WAC 388-489-0005,” (2024), WAC 388-489-0005:
93 Department of Social and Health Services, “Transitional Cash Assistance,” (2022), Transitional Cash Assistance | DSHS (wa.gov)
94 Washington State Legislature, “WAC 388-489-0010,” (2024), WAC 388-489-0010:
95 Washington State Legislature, “WAC 388-422-0005,” (2024), WAC 388-422-0005:
96 Library of Congress, “S.1932 - Deficit Reduction Act of 2005,” (2024), S.1932 - 109th Congress (2005-2006): Deficit Reduction Act of
2005 | Congress.gov | Library of Congress
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 172
While pass through payments are helpful for programs that provide direct benefits to households, a low-
income monthly bill assistance program benefits would be applied to a household’s energy bill and would not
count as income.
Benefits calculators
A final strategy to reduce the effects of the benefits cliff is benefits calculators, which allow households
enrolled in public assistance programs to easily understand how changes in household income will affect the
benefits they are receiving. Tennessee funded a benefits cliff initiative in 2022 that combines a benefit
calculator with coaching and temporary assistance to cover household expenses like housing and childcare,
with the goal of easing household transitions off public benefits as incomes rise.
Statewide energy assistance program and the benefits cliff
Local service providers and low-income households in Commerce’s workshops suggested that a statewide
low-income energy assistance program should avoid creating or exacerbating benefits cliffs.
Even without dedicated transitional assistance, if a program featured a tiered bill mechanism — where a
household’s monthly bill discount was based on their income — there would be a gradual ramping down of
benefits as household income increases, until a household is no longer eligible. This could provide a smoother
transition off the program than with a uniform discount, where a household’s monthly bill discount would stay
the same as household income increases, until dropping to zero as soon as a household is no longer eligible
for the program.
Additionally, an income threshold of the greater of 80% of area median income or 200% of the federal poverty
level could help prevent a statewide energy assistance program contributing to a compound benefits cliff,
where multiple forms of assistance disappear following a single change in household income. Based on
analysis of area median income versus the federal poverty level for households up to eight people, 80% of area
median income exceeds 200% of the federal poverty level for more than 75% of household sizes across
counties statewide. Since SNAP uses an income threshold of 200% of the federal poverty level in Washington,
this means that as long as a household’s income was below 80% of area median income, many families
enrolled in a statewide energy assistance program would remain eligible for these benefits after an income
increase that put them over the threshold for SNAP eligibility.
For families where household size and geography means that 200% of the federal poverty level is greater than
80% of area median income, a single income increase could mean simultaneous ineligibility for both a
statewide energy assistance and SNAP, and a loss of these benefits at the same time or in close succession.
Additionally, even with a tiered benefits structure, the shift from the lowest tier of benefits to no benefits after
exceeding an energy assistance program’s income threshold could be abrupt and disruptive for enrolled
households, so it would be important to include measures to mitigate the impact of the benefits cliff, such as a
transitional assistance mechanism.
There are several examples a new energy assistance program might emulate. One is Maine’s stepped TANF
income disregards, detailed previously, where income increases are initially disregarded for determining
benefits and are gradually accounted for in increasing amounts. Under this mechanism, a household’s energy
assistance benefit would initially stay the same upon an increase in household income above the program
threshold, and would gradually decrease until eventually disappearing.
Another example is Transitional Food Assistance, where households that exceed the SNAP income threshold
are eligible to receive benefits for an additional five months. Under this mechanism, a household’s energy
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 173
assistance benefit could stay the same as in their last month of eligibility for a set period following an increase
in household income above the program threshold.
Finally, an energy assistance program could develop a benefit calculator or otherwise make it easy for
households to understand how their bill discounts would change in response to a change in household
income. This could aid households in planning for the transition off energy assistance by showing them
exactly how their energy bills would change, including any available transitional assistance.
Benefits cliffs hamper households’ economic mobility, so a statewide low-income energy assistance program
should include design elements that can mitigate the potentially significant negative impacts of an abrupt loss
of benefits.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 174
Appendix P: Best practices in social service program
design
Background
Commerce researched common pitfalls to avoid and national best practices for program design to inform its
recommended design of a statewide monthly low-income energy bill assistance program.
The goal of this research was to learn from the body of research and experiences of existing federal and state
public assistance programs, understand what best practices and principles should guide the development of
specific elements of a statewide low-income assistance program, and provide background to guide further
research and consultation on specific topics.
This appendix summarizes that research, and draws on published governmental and non-governmental
sources, as well as information gained through consultation with community resource providers, low-income
households, state agencies and utilities.
Common public assistance program pitfalls
National research shows that while public assistance makes a significant difference for eligible people, many
struggle to access available benefits, leaving billions of dollars of assistance unclaimed each year
nationwide.97,98
Roadblocks to access take a variety of forms, including the items below.
Restrictive and complex eligibility criteria
Many existing public assistance programs have eligibility criteria beyond household income. These additional
criteria can exclude some communities entirely, and force households to make difficult choices to become
eligible. For example, immigration status criteria can exclude people who are not U.S. citizens or fall into other
categories of non-citizens, and some immigrants who are eligible for public assistance may choose not to
apply over fears, sometimes based on misinformation, that public charge determinations could impact their
ability to change their immigration status.99 Resource-related criteria can exclude people with assets over a
certain value, such as vehicles, and checking or savings accounts balances. This programmatic choice might
lead people to liquidate and spend down assets. These limits can discourage households from developing
savings.100
Program and eligibility awareness
In some cases, people cannot access available public assistance because they do not know a particular
program exists. In other cases, despite knowing a program is available, people may struggle to find
97 Code for America, “Social Safety Net,” (2024), Social Safety Net — Code for America
98 National Council on Aging, “$30 Billion Left on the Table: Connecting More Older Adults With Money-Saving Benefits,” (2024), Why Do
Older Adults Miss Out on Financial Benefits? (ncoa.org)
99 Food Research & Action Center, “Food Over Fear: Overcoming Barriers to Connect Latinx Immigrant Families to Federal Nutrition and
Food Programs,” (2020), NILC_Latinx-Immigrant-Families.pdf (frac.org)
100 Andrea Louise Campbell, “Trapped in America’s Safety Net,” (2014), Trapped in America’s Safety Net: One Family’s Struggle,
Campbell (uchicago.edu)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 175
information about its eligibility criteria.101 This uncertainty about whether they are eligible or likely to receive
benefits can discourage people from applying for assistance.
Application and recertification challenges
Finally, many existing public assistance programs have application and recertification processes that can be
challenging to navigate. Long application forms with legalistic or technical language and extensive
documentation requirements create high workloads for applicants and increase the chance of application
errors that require back-and-forth with program staff to resolve.102 The requirement for follow-up interviews
with clients after submitting an initial application can create an additional barrier if an interviewer is not
available same-day or during an applicant’s initial interaction with a program, since clients must then find
additional time in their schedules and are sometimes given limited options by program administrators.103
Recertifying that a household is still eligible for a program can be burdensome if the requirements for
recertification are not clear, or the recertification period is short.104
All of these challenges are compounded if it is difficult for households to access application information or
assistance from program staff.
Stigma and client experience
There is mixed research on whether poverty stigmas impact public assistance enrollment. Regardless, public
program messaging can help combat stigmas. Unfortunately, pro-actively addressing poverty stigmas does
not always happen, and people who interact with public assistance programs regularly report having
demeaning or rude interactions with program staff. Additionally, clients of public assistance programs
regularly report customer service challenges like difficulty accessing necessary information or navigating
application processes.
Case study of enrollment barriers
Supplemental Nutrition Assistance Program (SNAP) is one of the largest and well-known federal public
assistance programs in the county by enrollment, with an average of over 42 million monthly participating
households in fiscal year 2023.105 While SNAP’s prominence, broader eligibility criteria and large enrollment
make it more accessible compared with other federal programs, and there have been a host of state and
national initiatives to further improve its accessibility, nationwide it still suffers from some of the common
barriers above.
101 Congressional Hunger Center, “Barriers That Prevent Low-Income People From Gaining Access to Food and Nutrition Programs,”
(2011), Microsoft Word - Barriers to Food and Nutrition Programs, FRAC.doc (hungercenter.org)
102 101
103 Code For America, “Think Big, Start Small: How Implementing Flexible Interviews Improves Benefits Delivery,” (2021), Think Big, Start
Small: How Implementing Flexible Interviews Improves Benefit Delivery — Code for America
104 Congressional Hunger Center, “Barriers That Prevent Low-Income People From Gaining Access to Food and Nutrition Programs,”
(2011), Microsoft Word - Barriers to Food and Nutrition Programs, FRAC.doc (hungercenter.org)
105 U.S. Food and Nutrition Service, “Supplemental Nutrition Assistance Program Participation and Costs,” (2024), SNAP Participation
and Cost (azureedge.us)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 176
It is difficult to say with certainty why eligible households do not enroll in SNAP, but many individuals report
believing they are ineligible for the program or application challenges as reasons for not starting or completing
the enrollment process.106
Some groups, such as seniors, are more susceptible to some of these barriers than others. Nearly half of older
adults who are eligible for SNAP do not participate, and this group commonly reports reasons like the difficulty
of navigating long electronic application forms, stigma, or a lack of transportation to get to and from food
assistance offices for in-person appointments.
For immigrant families, particularly households with family members who have a mix of immigration statuses,
common barriers to accessing SNAP include fear or mistrust of government, fear or misinformation about
public charge rules, and language and transportation barriers.
General public assistance best practices
Given the important function of public assistance programs and the many existing barriers to access,
governments, non-governmental organizations and researchers have spent significant time developing best
practices and strategies to make assistance programs more accessible. While much of this research focuses
on mitigating barriers to accessing existing programs, the principles behind these best practices are still very
relevant to designing a statewide monthly low-income energy bill assistance program.
The following best practices were collected from both community engagement sessions and research, and are
organized according to their relevance to different components of public assistance programs.
Eligibility
There are several strategies a program can use to minimize the barrier that eligibility criteria might pose to
program accessibility.
Make eligibility criteria easy to understand
Perhaps the simplest strategy is ensuring that eligibility criteria are easy to understand for prospective clients.
Obviously a program cannot guarantee that a person is eligible before they complete the application process,
but if it is difficult for someone to know if they are likely to be eligible, they may be less inclined to apply.
Clearly communicating eligibility criteria can reduce the likelihood of misunderstandings that lead to an
erosion of trust in a program once someone reaches the application stage.
Carefully consider appropriate income criteria
The income criteria for a public assistance program is among the most important aspects of eligibility criteria.
Lower income thresholds will limit a program’s reach and exacerbate the impact of losing benefits once a
household exceeds the income threshold. In addition to the income threshold, it is important to consider what
a program will define as “countable income.” Including payments like child or spousal support can reduce the
amount of income a household can make from wages without exceeding a program threshold, and add
106 Economic Research Service, “Food Stamp Program Access Study — Final Report,” (2004), Food Stamp Program Access Study: Final
Report (usda.gov)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 177
complexity to the application and recertification processes. Income criteria must be carefully designed to
maximize accessibility within given parameters.
Forego resource thresholds
Resource eligibility thresholds can be a limiting part of existing public assistance programs. These limits can
prevent people from developing savings.107 Accordingly, raising or eliminating resource thresholds is a
common suggestion for improving the accessibility of public assistance programs and improving their ability
to help lift people out of poverty by allowing them to develop savings without being penalized by a loss of
benefits.
Application and enrollment
The application stage can include barriers that may prevent people from accessing benefits or add
unnecessary complexity and time to the process. Both the design of the process and the tools used to
implement it can affect the accessibility of a program application.
There are many technologies available to program administrators that can streamline application processes.
Online forms can work for many people, although they need to be designed intentionally so it is easy for users
to understand what they are being asked to provide, do not take an excessive amount of time to complete, and
are optimized for easy use on a smartphone.
The ability to accept telephonic signatures is another technology that can streamline the application process,
allowing program staff to complete an application with a client over the phone.108 Technology can also assist
program staff in conducting any required verification of client information, either electronically or over the
phone, which can further speed the application process.
Ensure availability of multiple application methods
While online forms work well for many people, others prefer applying over the phone with assistance from
program staff, and still others may lack the ability or comfort to use these application methods, instead
needing a paper application in a program office.
Differences in application preferences can be for a variety of reasons, such as low level of comfort with online
forms or limited internet access. Regardless of the reason, it is important that a program provide multiple
methods to accommodate everyone.
Streamline documentation requirements
If a program requires extensive documentation of household characteristics or does not clearly communicate
what documents are required, some households may not complete the application process and others may
end up going back and forth with program staff to meet the requirements. Documentation-related barriers can
be particularly difficult to navigate for people who are self-employed or work in certain fields such as
agriculture. Minimizing the documentation that households are required to provide, clearly communicating
107 Urban Institute, “Do Asset Limits in Social Programs Affect the Accumulation of Wealth?” (2005), Do Asset Limits in Social Programs
Affect the Accumulation of Wealth? (urban.org)
108 Urban Institute, “Strategies for Improving Public Benefits Access and Retention,” (2023), Strategies for Improving Public Benefits
Access and Retention.pdf (urban.org)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 178
what kinds of documents can meet program requirements, and giving applicants the ability to submit
documents online or have information verified over the phone can reduce these barriers.
Recertification
Public assistance programs that require enrolled households to periodically recertify, confirming that they still
meet all the program requirements and accounting for any changes in relevant household characteristics,
must ensure that recertification does not create unneeded barriers. Since it shares many similarities with the
application stage, recertification is subject to many similar best practices.
Carefully consider appropriate recertification periods and
requirements
Longer recertification periods mean fewer opportunities for unintentional errors that may lead to the loss of
benefits for a household and the resulting need to re-apply to a program. Additionally, less frequent
recertification reduces administrative burden on program staff. The information that a program requires at
recertification can also make a difference in the ease of the process.
The inclusion of extraneous information that does not have bearing on a household’s continuing eligibility or
that would not have changed during the recertification period requires additional time from both households
and program staff. Limiting the information that households are required to provide at recertification reduces
workload for households and staff, and helps prevent “benefits churn” as a result of unintentional errors and
resulting re-applications.
Leverage available technology to streamline recertification
Technology can help streamline recertification. It can include auto-populating online forms with already known
household information, accepting telephonic signatures to allow for recertification over the phone, or
maintaining a portal accessible online or over the phone that can provide information about approaching
deadlines.109
Ensure clear and timely client communication
Another challenging aspect of recertification is keeping track of required deadlines. For households enrolled in
multiple public assistance programs, recertification deadlines are unlikely to align, so it is beneficial for a
program to communicate with clients well before a deadline. This can be accomplished through automated
reminder notices like emails, phone calls or text messages. Reminder notices should include clear instructions
and information on how clients can recertify, and what documentation might be required.110
Outreach
Thoughtful outreach is an important way to raise general awareness of a public assistance program’s
existence, provide key information such as eligibility criteria, application, and benefit details, and reach
historically marginalized groups. There are several best practices that can improve the effectiveness of public
assistance program outreach.
109 Center on Budget and Policy Priorities, “Improving SNAP and Medicaid Access: SNAP Renewals,” (2024), Improving SNAP and
Medicaid Access: SNAP Renewals (cbpp.org)
110 12
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 179
Ensure information is accurate and current
One of the fastest ways a program can lose the trust of prospective clients is by giving them information that
turns out to be inaccurate. This can lead to discouragement and frustration. Ensuring program outreach
information is accurate and current is crucial, and is especially important when working with community
partners. Care needs to be taken to regularly ensure that partners from outside the program are not unwittingly
sharing inaccurate information with prospective clients, and that these partners are updated on any relevant
changes to program information.
Partner with trusted community messengers
The trust between community partners and prospective clients lends credibility to a program. People are often
more receptive to messages from peers or an organization they already have a relationship with than to social
media ads, flyers or text messages from an unknown program. Trusted community messengers may know
who in their community could benefit most from a particular program, and may be the most effective way to
communicate information. Finally, outreach by community partners that can assist with the application
process can make people more likely to act on information they receive.
Tailor outreach through data
Analyzing demographic data is an important way to improve the efficacy of outreach by identifying
communities or groups that are underrepresented in a program. With this information, a program administrator
can tailor outreach efforts to address this service gap.111 This can include seeking out new partnerships or
increasing the volume of outreach directed towards a particular community or group, or adjusting the
messaging of outreach for more effective communication.
Client experience
Finally, there are several important customer service best practices that involve interaction between clients
and program staff.
Treat clients with respect in all program interactions
As discussed previously, embarrassment and poverty stigmas can be significant obstacles to accessing public
assistance, and public assistance programs have a history of adding to feelings of indignity through practices
like requiring fingerprinting as a condition of receiving assistance.112 Treating clients with decency and
respect can reduce the stress of applying for and receiving public assistance, and ensure that program staff
are not making an already challenging situation even worse.
Ensure program information, materials and assistance is available in
multiple languages
Language access is critical if a program wants to offer assistance equitably to people who do not speak
English or have limited English proficiency. For a program administrator, this means ensuring that program
materials are easily accessible in commonly spoken languages other than English. It also means ensuring that
111 Urban Institute, “Strategies for Improving Public Benefits Access and Retention,” (2023), Strategies for Improving Public Benefits
Access and Retention.pdf (urban.org)
112 National Public Radio, “The Clash Over Fingerprinting for Food Stamps,” (2012), The Clash Over Fingerprinting For Food Stamps :
NPR
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 180
clients have ready access to interpretation services when interacting with program staff in-person or over the
phone.
Use plain talk and minimize legalistic or technical language
Finally, program materials should strive to use plain talk to the greatest extent possible, and avoid using
legalistic or technical language. This is especially important for application and recertification materials, as
well as information about eligibility criteria. While regulations and administrative rules form the structure of
public assistance programs, the requirements they create should be translated into plain language that can be
easily understood by someone with an elementary-school reading level. By doing so, a program ensures that
its information and forms are accessible to people from a variety of backgrounds, and can reduce the risk of
procedural errors due to misinterpreting or misunderstanding an unnecessarily technical form.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 181
Appendix Q: Categorical eligibility for a statewide low-
income energy assistance program
Categorical eligibility describes a method of determining a person or household’s eligibility for a public
assistance program in part based on their participation in a different public assistance program with
comparable eligibility requirements.
Categorical eligibility can relieve documentation-related burdens for clients and program administrators. If
certain client information has already been verified by another program and a program does not require
categorically eligible clients to submit documentation of this information again, administrative staff do not
have to spend time reviewing these documents and clients do not have to spend time collecting and
submitting them. This reduces administrative burden, application wait and processing times, and makes it
easier for households to complete the application process.
Supplemental Nutrition Assistance Program categorical eligibility
The Supplemental Nutrition Assistance Program (SNAP) has among the most well-documented categorical
eligibility standards of existing Washington public assistance programs. Per WAC 388-414-0001, the
Department of Social and Health Services determines that households are categorically eligible for the
purposes of SNAP if every member in the household receives cash assistance from one of the following
programs:
• Temporary Assistance for Needy Families (TANF)
• Tribal Temporary Assistance for Needy Families
• State Family Assistance
• Supplemental Security Income
• Aged, Blind or Disabled Cash Assistance
• Diversion Cash Assistance (this assistance only makes a household categorically eligible for SNAP for
the month it receives diversion cash assistance and the following three months)
Households are also determined to be categorically eligible if their countable income is at or below 200% of
the federal poverty level. These households are eligible for information and referral services funded by federal
TANF or state maintenance of effort dollars, which makes them categorically eligible for SNAP, according to
U.S. Department of Agriculture regulations.
Categorically eligible households automatically meet the following SNAP requirements:
• Countable resource limit
• Maximum gross monthly income
• Maximum net monthly income
Categorically eligible households do not need to provide the
following information if it is available from another program:
• Social Security number information
• Sponsored alien information
• Residency information
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 182
Households that are categorically eligible for SNAP still need to complete an application and interview, and
must meet other program requirements. Categorically eligible households also need to provide income
information for the purposes of calculating their SNAP benefit.
Combining categorical eligibility with other programmatic features
One feature of the Supplemental Nutrition Assistance Program’s (SNAP) worth highlighting is its broad-based
categorical eligibility, which provides a means of mitigating the effect of the benefits cliff and making it easier
for program participants to develop savings by effectively raising income and asset thresholds.113
Broad-based categorical eligibility for SNAP refers to the ability of states to make households categorically
eligible for SNAP if they are eligible for a non-cash benefit funded by Temporary Assistance for Needy Families
funds or state maintenance of effort funds. In Washington, this nominal non-cash benefit is a notification
about information and referral services, available to households with gross incomes at or below 200% of the
federal poverty level. This effectively raises the SNAP gross income threshold from the federal standard of at
or below 130% of the federal poverty level, to 200% of the federal poverty level, and removes the federal SNAP
asset limits. With this higher gross income threshold and no asset limit, households can make more earned
incomes, and keep and grow savings while remaining eligible for SNAP.
Categorical eligibility program recommendations
When considering which existing public assistance programs would be good candidates for categorical
eligibility for a statewide monthly low-income energy bill assistance program, there are several eligibility
factors a program administrator could use to filter out programs with compatible requirements. The most
salient eligibility factor is income, as additional requirements of other programs, like resource or immigration
status requirements, would not disqualify applicants from a statewide energy assistance program.
Accordingly, existing public assistance programs with income thresholds that fall at or below the proposed
energy assistance income threshold (whichever is greater of at or below 200% of the federal poverty level or
80% of area median income) would be good initial candidates for categorical eligibility. The following
programs meet these criteria:
Assistance program Applicable income threshold
Supplemental Nutrition Assistance Program (SNAP) At or below 200% of federal poverty level
State Food Assistance Program Same as SNAP
Women, Infants and Children Nutrition Program (WIC) At or below 185% of federal poverty level
Based on set monthly gross income by household size, but does
Temporary Assistance for Needy Families (TANF)
not exceed 200% of federal poverty level
State Family Assistance Same as TANF
Refugee Cash Assistance Same as TANF
Pregnant Women Assistance Same as TANF
Based on set monthly gross income and household
Supplemental Security Income (SSI)
circumstances, but does not exceed 200% of federal poverty level
113 Center on Budget and Policy Priorities, “SNAP’s Broad-Based Categorical Eligibility Supports Working Families and Those Saving for
the Future,” (July 2019), SNAP’s “Broad-Based Categorical Eligibility” Supports Working Families and Those Saving for the Future |
Center on Budget and Policy Priorities (cbpp.org)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 183
Assistance program Applicable income threshold
Based on set monthly gross income and household
Aged, Blind or Disabled Cash Assistance Program (ABD)
circumstances, but does not exceed 200% of federal poverty level
Housing and Essential Needs Referral Program (HEN) Same as ABD
Same as TANF; clients are only eligible for this program for one
Diversion Cash Assistance
30-day period per year
At or below 133% of federal poverty level for adults who are not
Washington Apple Health modified adjusted gross income-based
parents or caretaker relatives; at or below 193% of federal poverty
adult programs
level for people who are pregnant
Washington Apple Health Medical Care Services Program Same as ABD and HEN programs
Washington Apple Health SSI-related programs Same as SSI
Washington Apple Health TANF-related programs Same as TANF
At or below 60% of state median income for initial application, at
Working Connections Child Care Program
or below 65% of state median income when re-applying
Making categorical eligibility a feature of a statewide low-income energy assistance program would streamline
the application process for households and the program administrator, particularly in the absence of an option
for households to self-attest to their income. By taking advantage of the fact that households already enrolled
in other public assistance programs have had their incomes verified, these efforts would not need to be
duplicated and households would not need to collect and submit income-related documentation.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 184
Appendix R: Department of Commerce outreach and
community engagement
Overview
Commerce conducts outreach and community engagement through statewide outreach and community
engagement teams, resources and best practices that support the work of more than 100 programs. These
teams, resources and practices ensure that program information reaches those who need it, and that
communities across the state can contribute to shaping agency programs so they can best fulfill their mission.
Among those 100 programs are several public assistance, housing and energy programs that could also be
valuable outreach partners for a statewide low-income energy assistance program.
The Healthy Environment for All
Washington’s environmental justice law, introduced as the Healthy Environment for All Act (HEAL), passed in
2021. Now in statute, Chapter 70A.02 RCW provides a roadmap for integrating environmental justice into state
agencies. Commerce is one of seven agencies required by that statute to take certain actions to
institutionalize environmental justice into its operations, including adopting an environmental justice-centered
community engagement plan and a tribal consultation framework.
Commerce’s provisional environmental justice community engagement plan introduces Commerce staff to
environmental justice principles and provides guidance on implementing an environmental justice lens for
community engagement. It seeks to provide resources for staff to be inclusive and proactive when engaging
Washington residents in program planning and delivery, especially overburdened communities and vulnerable
populations who have been exposed to a high degree of pollution and environmental harm. Additionally, it
provides methods and tools for reporting key screening, assessment and engagement practices data that will
help Commerce measure its engagement practices.
Community Engagement and Outreach Team
Commerce has a dedicated community engagement team and external communications team. This team has
dedicated staff who live across the state and regularly engage with community organizations, leaders,
businesses, and households. The team’s priority is to support and advocate for Washington communities
furthest from equity.
In 2019 the Community Engagement Team was asked by Commerce to design and implement a pilot to test
community engagement practices in small and underserved communities. The pilot has informed engagement
plans and practices across the agency, such as the environmental justice-centered community engagement
plan.
The community engagement team assist agency staff with designing and facilitating community engagement
activities, and developing effective program communications for external audiences. This team was integral to
designing and facilitating the series of co-design workshops with community organizations across the state
that Commerce hosted as part of this program design study.
Tribal Outreach Team
Commerce’s Office of Tribal Relations is a standalone unit within the Director’s Office that serves as the main
conduit between the agency and tribes within Washington. The office coordinates formal government-to-
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 185
government consultations between Commerce and tribes when these consultations are offered or requested.
It also provides consultation and support for agency programs that are engaged with tribal coordination or
informal consultation.
In addition to coordinating and supporting specific consultations between agency programs and tribes, the
office also develops agency tribal engagement policy and resources, provides internal trainings on tribal
engagement, and hosts the Commerce Tribal Advisory Committee. The committee, which meets annually,
serves as a formal and regular means of communicating between Commerce and tribal partners. The office
maintains a list of publicly available resources and agency funding opportunities for tribal communities.
Programmatic overlap
Outreach for Historically Underserved Community Grant Program
Commerce houses a new grant program that specifically supports outreach for aid in accessing public
assistance programs. In 2021, the Legislature created the Outreach for Historically Underserved Communities
Grants, appropriating $4 million for this program in fiscal year 2022 and $6 million in fiscal year 2023. These
funds were designated for "grants to community organizations that serve historically disadvantaged
populations to conduct outreach and assist community members in applying for state and federal assistance
programs."
Commerce has awarded outreach grant funds to 25 community organizations in 17 counties. These
organizations have contacted over 20,000 people through grant-funded outreach, and these interactions have
generated over 4,900 outcomes.
Housing programs
Commerce administers a number of housing and homelessness assistance programs, including the Housing
Trust Fund, the Office of Apple Health and Homes and Permanent Supportive Housing, the Office of Family and
Adult Homelessness, and the Office of Homeless Youth.
Since 1986, the state’s Housing Trust Fund has invested over $2 billion in capital funding and helped build or
preserve more than 58,600 affordable housing units statewide. The Housing Trust Fund provides capital
financing through loans or grants to affordable housing projects through annual competitive application
cycles. Properties financed by the program can house people earning up to 80% of area median income, but
most of these properties house households with special needs or incomes below 30% of area median income.
The Office of Apple Health and Homes and Permanent Supportive Housing administers the Apple Health and
Homes Initiative and Commerce’s other permanent supportive housing initiatives. The Apple Health and
Homes Initiative is a multi-agency initiative that pairs healthcare services with housing resources for some of
the state’s most vulnerable residents. It provides capital and operating funding for acquiring or developing
housing units, supportive services, rental subsidies and other permanent supportive housing assistance. This
office also provides capital funding for new permanent supportive housing, operations and maintenance
funding for existing permanent supportive housing developments, and rental assistance for people with
behavioral health and other disabling conditions.
Both the Office of Family and Adult Homelessness and the Office of Homeless Youth fund community
organizations that provide homelessness crisis services, street-level outreach, homelessness diversion, rental
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 186
assistance, residential programs, and other support services and community based initiatives. The Office of
Homeless Youth funds over 100 community programs in 37 counties.
Low-Income Home Energy Assistance Program
The Low-Income Home Energy Assistance Program (LIHEAP) is a state-run but federally funded program
provides energy assistance to households in Washington through a network of community action agencies
and local partners, primarily assisting households by making an energy assistance grant directly to the energy
provider on behalf of the eligible household. LIHEAP may also help repair or replace an unsafe, dysfunctional,
and inoperative heating or cooling system in some situations. Households eligible for LIHEAP may also qualify
to have their homes made more energy efficient through Commerce’s weatherization programs.
LIHEAP assistance is available to qualifying households whose income is at or below 150% of the federal
poverty line. Households apply to the LIHEAP program by scheduling an eligibility determination appointment
with one of the local partners that Commerce works with to administer the program.
Each year, Commerce must submit an annual LIHEAP plan to the U.S. Department of Health and Human
Services, which includes a description of planned outreach activities. These have historically included activities
such as placing flyers or posters in local service offices, placing notices in media outlets, including inserts in
utility billing notices, contacting prior-year LIHEAP recipients, providing LIHEAP information upon intake for
other public assistance programs, and partnering with other public assistance program administrators.
Weatherization Programs
In addition to administering LIHEAP, providing energy assistance in the form of annual lump-sum payments to
cover bill payments, Commerce also provides energy assistance in the form of weatherization assistance.
Commerce runs several different weatherization programs, all of which center on funding home upgrades for
eligible low-income households like added insulation that reduce heat loss and energy consumption. These
programs are funded by dedicated allocations from the U.S. Department of Energy, the Bonneville Power
Administration and Washington state, and waivers that transfer up to 25% of LIHEAP funding to weatherization
assistance. Utility companies that sell gas and electric heat also provide matching funds for qualified low-
income households.
General weatherization assistance is available to households whose income is at or below 200% of the federal
poverty line, or 60% of state median income, whichever is greater. The Weatherization Plus Health program
provides both weatherization assistance and upgrades that improve homes for people with asthma, and is
available to households whose income is at or below 80% of area median income. The Home Rehabilitation
Loan program funds deferred loans to rural, low-income households needing repairs and improvements on
their primary residence to increase health, safety and durability, and is available to rural households whose
income is at or below 200% of the federal poverty line.
Commerce contracts with local providers in all 39 counties to provide weatherization assistance to eligible
households, and the Weatherization Plus Health program uses community health education partnerships for
client recruitment, assessment, and intensive home education and follow-up.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 187
Appendix S: DSHS outreach and community
engagement
Background
The Department of Social and Health Services (DSHS) contracts with two organizations to conduct outreach
and community engagement for the Supplemental Nutrition Assistance Program (SNAP): People for People
and WithinReach.
These contractors coordinate several different services related to food assistance, including subcontracting
with over 38 community organizations. These organizations include:
• Non-profits
• Community action agencies
• Food banks
• Health districts
• Call centers
• Senior service providers
These 38 subcontracted community organizations use their networks to conduct engagement and outreach
activities for SNAP. These organizations primarily interface with SNAP clients by providing application
assistance through Washington Connection, an online portal that helps Washington residents and businesses
to services.
How DSHS coordinates with its statewide contractors
DSHS works with People for People and WithinReach to develop individual outreach plans for each of its 38
subcontractor organizations, which then are collected into annual state outreach plans that are submitted to
the United States Department of Agriculture's Food and Nutrition Service (FNS). DSHS bases its state outreach
plans on FNS templates and guidance, and the plans include a statement of need, project overviews,
contractor budgets and staffing details. DSHS works with its 38 subcontractor organizations to ensure that
individual outreach plans lead to data driven results.
Outreach plans include goals and performance metrics that DSHS tracks on a monthly basis to assess the
performance of the agency’s annual outreach plan. The specific outreach goals and performance metrics that
DSHS tracks are based on the outreach activities listed in a particular outreach plan. For example, if one
planned outreach activity was staffing exhibits or booths at community events, DSHS might track the number
of community events attended, and the number of contacts made with community members at those events.
In its outreach plan template, FNS encourages that goals be measureable, and numeric if possible, and that
outreach goals focus on increasing SNAP participation.
In its annual SNAP outreach plan for fiscal year 2024, the New Mexico Human Services Department indicated
that its primary outreach project would be partnering with a food bank that would provide application and
recertification assistance, and distribute accurate, culturally relevant, bilingual and developmentally
appropriate materials and information about the state SNAP program. The goal for this project was for New
Mexicans who are eligible for SNAP to receive “accurate, culturally relevant, and developmentally appropriate
information regarding SNAP in providing application and recertification assistance for those community
members.” The outreach plan detailed that the food bank would assess its performance of these activities
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 188
based on the state SNAP participation rate, number of individuals reached via outreach work, number of
applications submitted, number of applicants that asked questions, and number of materials distributed. 114
WithinReach reports that SNAP outreach partner organizations have fairly wide latitude within certain
guidelines to develop their own outreach materials targeted to the populations that they serve, although some
organizations lack the resources or the capacity to do this, relying on standardized materials from WithinReach
and DSHS.
Outreach partner organizations report on their activities to People for People and WithinReach, and DSHS
provides quarterly holdback payments to organizations that meet their performance goals, delaying the release
of a portion of matching funds until subcontractors demonstrate progress towards meeting their performance
goals. These holdback payments are designed to encourage subcontractor performance and have been
implemented to align with federal guidance from FNS.
WithinReach regularly aims to recruit new partner organizations as SNAP subcontractors, although it reports
that the biggest challenge to bringing on new partners is the federal funding structure. SNAP outreach is
funded through a 50/50 match, so organizations that cannot meet the 50% funding obligation are effectively
unable to participate as subcontractors.
WithinReach convenes quarterly Basic Food Education Forums to facilitate information-sharing and the wide
dissemination of best practices among SNAP subcontractors. These forums present an opportunity to share
information like programmatic changes that may affect outreach messaging, and success stories and
strategies that subcontractor organizations can emulate to improve the efficacy of their outreach activities.
DSHS indicates that these quarterly forums would be an excellent opportunity for the administrator of a
statewide low-income energy assistance program to share information about the program, and direct SNAP
outreach subcontractors to program materials that they could distribute. WithinReach has also hosted
population-specific forums where subcontractors can share their experiences working with particular
geographic or ethnic communities so that other organizations can learn ways to better reach these
communities.
DSHS conducts specific consultation on the planning of the department's service programs with tribes and
recognized American Indian Organizations per its Administrative Policy No. 07.01.
Coordination with Other Public Assistance Programs
DSHS indicates that its 38 SNAP outreach subcontractor organizations are able to bring informational
materials about additional programs that may be relevant to SNAP clients to community events where these
partner organizations are conducting SNAP outreach. Typically, these additional materials are made available
by program administrators on the Department of Enterprise Services’ fulfillment services web site. Outreach
partner organizations can then request these materials through fulfillment services, and program
administrators can track how many of their publications are requested. Program administrators pay the costs
of printing and shipping these materials.
DSHS points to its ongoing collaboration with the Department of Health (DOH) SNAP Produce Match program
as an example of the kind of information-sharing partnership that could be possible with a statewide low-
income energy assistance program. The SNAP Produce Match program aims to incentivize SNAP clients to
buy more fruits and vegetables by providing either coupons or discounts for buying at least $10 worth of
114 New Mexico Human Services Department, “FY24 SNAP Outreach Plan,” (2023), FFY24-NM-SNAP-Outreach-Plan.pdf (state.nm.us)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 189
qualifying products at participating grocery stores. As part of its outreach for this program, DOH makes
informational materials available to SNAP outreach partner organizations, which are then able to share these
materials with their clients. A statewide low-income energy assistance program could follow a similar process,
making informational materials available on the fulfillment services web site, where DSHS’s 38 SNAP outreach
subcontractors could then access and distribute them.
While SNAP outreach partner organizations could access and distribute outreach materials such as pamphlets
for a statewide low-income energy assistance program, more involved outreach and enrollment activities
would require a separate contract and funding.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 190
Appendix T: Opportunities for partnership and lessons
learned from Department of Children, Youth, and
Families Outreach
The Department of Children, Youth, and Families (DCYF) is the lead agency for state-funded services that
support children and families to build resilience and health, and to improve educational outcomes. DCYF
accomplishes this by partnering with state and local agencies, tribes and other organizations in communities
across the state of Washington. DCYF’s focus is supporting children and families at their most vulnerable,
giving them the tools they need to succeed.
Given this focus, there could be opportunities for DCYF to share information about a statewide low-income
monthly energy bill assistance program through social media and other online channels. This would raise
awareness about the program and inform households about how to get more information or enroll.
The implementation of outreach for DCYF programs, such as the Working Connections Child Care Program,
provide examples of using community level outreach strategies to increase program participation in social
service programs.
The Working Connections Child Care Program
The Working Connections Child Care Program provides subsidies for child care to eligible families while
parents participate in activities like working or attending school. In addition to meeting Washington state
residency and resource requirements, with some exceptions, families must make no more than 60% of state
median income upon initial enrollment, or no more than 65% of state median income when re-applying in order
to be eligible for child care subsidies.
While DCYF does have staff stationed throughout the state that participate in local activities and outreach, it
conducts a significant amount of outreach with social media ads and mailers. DCYF contracts with several
groups to distribute these materials. Its primary outreach partner is Child Care Aware of Washington.
Child Care Aware of Washington is a non-profit whose mission is to improve access to affordable and high
quality child care. It has partnered with DCYF for decades, providing referral services in addition to advocacy
and training.
DCYF makes decisions about the content and targeting of outreach messaging in consultation with its
outreach partners. In a recent Working Connections Child Care outreach campaign, DCYF targeted outreach
efforts to Yakima County, where there is a high number of eligible families but low program enrollment
compared to the other parts of the state. DCYF assessed the efficacy of that campaign by looking at the
number of new program applications, and it found an increase in new applications over the same time frame
compared to the previous year.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 191
Appendix U: Office of Superintendent of Public
Instruction outreach and community engagement
Background
Migratory seasonal farmworker households face unique challenges accessing public assistance programs,
including language barriers, social isolation, fear or mistrust of institutions, and frequently moving to follow
crops. These challenges contribute to the negative economic, educational and health consequences that
affect this group. A statewide low-income energy assistance program would intentionally incorporate design
elements to mitigate these unique challenges, and leverage existing networks of state agencies and providers.
Migrant Education Program
The Office of the Superintendent of Public Instruction’s Migrant Education Program (MEP) is a federally funded
program created in 1965 that provides a variety of supplemental services for migratory children and their
families to ensure migratory children have the same opportunities to achieve educational success as their
peers. These supplemental services provide educational programs, supports and services, as well assistance
in connecting with available health and other social services.
Washington’s MEP is one of the largest by numbers in the country. During the 2020-2021 school year, over
30,000 students were eligible for the program, and over 15,000 received services. More than 2,600 students
received services during the summer of 2021.115 MEP uses a statewide network of recruitment teams to
identify students that may be eligible for the program, which is active in over 60 school districts. The program
works directly with four Education Service Districts, which provide support services for school districts in their
regions, to provide technical assistance and coordinate the activities of district-level programs.
Once connected with district-level programs, migratory students can receive support such as help with
connecting to public assistance programs, supplemental medical screening exams, transportation to and from
medical appointments, and supplemental nutrition assistance. When connecting migratory students and
families with public assistance programs, MEP generally refers families to the Department of Social and Health
Services or another appropriate service provider, but in some circumstances where families have greater need,
the program provides limited direct enrollment assistance.
Partnership with a statewide energy assistance program
According to MEP, both the network of recruitment teams and local educational agency program staff could be
utilized to help spread information about a statewide low-income energy assistance program. With the
appropriate information about eligibility criteria and the enrollment process, MEP staff could inform migratory
students and families about an energy assistance program’s existence and direct interested households to the
program application.
Under this kind of partnership, it would be important for an energy assistance program administrator to provide
regular communications to MEP staff about the program, and any relevant changes to eligibility criteria or
115 Meta Associates, “2020-2021 Evaluation Report – Washington Migrant Education Program,” (2022), Washington State Priority for
Service Definition (ospi.k12.wa.us)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 192
enrollment processes. This would ensure that the energy program would be top of mind for MEP staff, and that
the information they provide migratory students and families would be current.
MEP also indicated there are several important design elements that would make such a program more
accessible to migratory seasonal farmworker households. Chief among these elements are language access,
documentation requirements that are not overly burdensome, and multiple application methods. A waiver or
separate application stream for migratory seasonal farmworker households could also make the application
process easier.
Public charge considerations
According to MEP, it would also be important for communications to migratory seasonal farmworker
households about a statewide low-income energy assistance program to address public charge concerns. The
Department of Homeland Security can deny applications for a visa or change in immigration status from
noncitizens on the basis that they are likely to become a public charge, defined as becoming primarily
dependent on the government for subsistence.116 The public charge inadmissibility rules were modified in
2019 and 2022. MEP indicates that concern and confusion over these rules is common among migratory
households in Washington, and in some cases prevents families from accessing public assistance, even if
their concerns are unfounded. A 2022 survey by the Urban Institute found that one in four adults in families
with mixed immigration status avoiding accessing public assistance programs because of green card
concerns.
The most recent change to public charge inadmissibility rules clarified that being primarily dependent on the
government for subsistence is demonstrated either by receiving public cash assistance for income
maintenance, or long-term institutionalization at government expense. Public cash assistance for income
maintenance is defined as Supplemental Security Income, cash assistance for income maintenance under the
Temporary Assistance for Needy Families program, or state, tribal or local cash benefit programs for income
maintenance. Other kinds of benefits, like Supplemental Nutrition Assistance Program or housing benefits, are
explicitly excluded for the purposes of making public charge determinations.117
A statewide energy assistance program would intentionally develop clear communications that program
participation would not be considered for the purposes of making public charge determinations, and would not
impact the ability for participants to change their immigration status.
116,39 Federal Register, “Public Charge Ground of Inadmissibility,” (2022), Federal Register :: Public Charge Ground of Inadmissibility
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 193
Appendix V: Employment Security Division outreach and
community engagement case study
The beginning of the Paid Family and Medical Leave program provides an instructive case study for how a
statewide low-income energy assistance program might approach outreach, including pre-launch and ongoing
efforts. Since this program was new, it was crucial to raise awareness well before launch to ensure that people
who needed paid leave were aware of eligibility, benefits and how to apply, and so employers and employees
had sufficient time to understand how premium payments would be structured. A low-income energy
assistance program would likely encounter similar challenges and opportunities related to ensuring that
potential clients, community organizations and utilities have accurate and thorough information, both prior to
and following program launch.
In 2017, the Legislature directed the Employment Security Department (ESD) to create and administer a new
paid leave program for employees experiencing events like the birth of a child or a serious health condition.118
Premiums to fund the program started on January 1, 2019, and paid leave benefits became available January
1, 2020.
The Legislature mandated that ESD conduct outreach for the program. It further required that program
information be available in English and other primary languages, including Spanish, Vietnamese, Cambodian,
Laotian and Chinese.
ESD's outreach for Paid Family and Medical leave began 18 to 24 months before benefits were scheduled to
begin, and were ongoing by mid-2018. Outreach targeted employers, since premium payments began one year
before benefits began. Having outreach staff in workplaces speaking with employers presented opportunities
to communicate with employees about program eligibility, benefit accessibility, and other aspects of the
program. Staff also conducted community presentations and webinars, solicited public input, and utilized
mass communication. ESD employed two to three dedicated employees to conduct this outreach, although at
some points up to seven communications employees and several contractors supported outreach efforts.
More direct community outreach began about six months before the launch of the Paid Family and Medical
Leave program. Integrating with existing community outreach networks and utilizing trusted messengers were
key elements of outreach for Paid Family and Medical Leave. When working with trusted messengers and
community partners, ESD found that, given the program was entirely new, significant technical assistance was
required to ensure that outreach partners could provide accurate and timely information on elements, such as
program eligibility and benefits access.
The Perigee Fund, an organization focused on early childhood health and wellbeing, undertook an initiative
from 2020 to 2023 to expand Paid Family and Medical Leave enrollment and information sharing with
communities that have historically faced systemic barriers to accessing social services. Perigee’s mission is
to invest in policy and programmatic changes that support families from pregnancy through early childhood,
so ensuring that the rollout of Paid Family and Medical Leave was equitably implemented aligned with
Perigee’s priorities.
Perigee independently decided to invest grant funding in Washington to mitigate observed rollout challenges
experienced by other states that created paid family and medical leave programs, particularly concerning
118 Washington State Legislature, “SSB 5975,” (2017), 5975-S.SL.pdf (wa.gov)
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 194
access for groups that have historically lacked or underused paid leave. To accomplish this goal, Perigee
awarded outreach and enrollment grants to community partners in Pierce and Yakima counties, with
designated "convener" organizations providing leadership and other support to additional partner
organizations in their regions.
Through grant funding, community partner organizations integrated information about Paid Family and
Medical Leave into their existing practices in different ways, including making informational materials available
in organization spaces, incorporating program information into regular communications with clients, and
training staff on program details.
A cost-benefit analysis of Perigee's outreach and enrollment grant initiative found that approximately $1.8
million in grant funding contributed to an estimated $13.27 million in wage replacement for Paid Family and
Medical Leave participants.
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 195
Appendix W: Acknowledgements
Department of Commerce
Michael Furze, Assistant Director, Energy Division
Glenn Blackmon, Director, Energy Policy Office
Austin Scharff, Senior Energy Policy Specialist, Project Manager
Dave Pringle, Legislative Director
Marie Davis, Senior Policy Advisor
Rebecca Ponzio, Senior Policy Advisor
Julia Havens, Community Engagement Manager
Amelia Fujikawa, Research and Data Analyst
Alice Zillah, Research and Development Services Managing Director
James Vogl, Research Analyst
Amelia V. Lamb, Publications Manager and Editor
Scott Varga, Visual Communications Manager
Additional thanks to Commerce team members
Alden Andy, Deputy Tribal Liaison
Amanda Hathaway, Legislative Coordinator
Anneka McDonald, Contract Manager
Brian Sarensen, LIHEAP Program Manager
Cary Retlin, Policy and New Initiatives Manager
Dave Pringle, Government Affairs and Policy Director
Lynda Jensen, Publications and Web Content Editor
Michelle DeBell, IT Consultant
Michelle Gladstone-Wade, Tribal Liaison
Nick Manning, Energy Division Legislative and Rules Coordinator
Norma Chavez, Small Business Resiliency Network Director
Steve Dunk, Community Engagement Specialist
Tedd Kelleher, Housing Policy Director
Washington Office of Superintendent of Public Instruction
Armando Isais-Garcia
Washington State Caseload Forecast Council
Erik Cornellier
Washington State Employment Security Department
Rebecca Grady
Washington State Department of Social and Health Services
Alexis Marx
Barbara Parry
Erik Peterson
Ian Hall
Josh Proel
Joyce Hensen
Matt Parascand
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 196
Nina DeCamp
Sanela Maksic
Shane Riddle
Suzy Young
Washington State Office of the Attorney General
Corey Dahl
Lisa Gafken
Rory Paine-Donovan
Shay Bauman
Tad Guy O'Neill
Washington Utilities and Transportation Commission
Andrew Sellards
Corey Cook
Greg Hammond
Heather Moline
Jimmy Nyanwapolu
Keith Quinata
Melissa Cheesman
Payton Swinford
Washington State Department of Children, Youth, and Families
Genevieve Stokes
Jason Ramynke
Sarah Holdener
Many thanks to the consultants who contributed mightily to this report:
The National Consumer Law Center, John Howat
Greater Good Studio, George Aye, Sara Cantor, Anthena Gore, Chavie Cramer, Sasha Yan, Hannah Martin
Artesia Systems, Steve Mullins, Terry Johnson
Many thanks to the experts with lived experience and the organizations who hosted the household focus
groups:
Central Area Senior Center, Anthony Cryer, Mdigo Kisimbo, Achilles Wynn and Dian Ferguson
Orion Industries, Cynthia Kim
RISE Center, Gerald Daniels
Many thanks to participants from the following organizations that participated in our service provider
workshops:
Alimentando Al Pueblo
Amara
American Indian Community Center Association
Asia Pacific Cultural Center
Benton PUD No 1
Bethel AME Church
Blue Mountain Action Council
Bridgeview Resource Center
Center for Inclusive Entrepreneurship
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 197
Cham Refugee Community of Seattle
Children's Home Society of WA
Chinese Radio Seattle
City of Bellingham
City of Gig Harbor
City of Port Angeles
City of Tacoma
CJK Community Homes
Clallam County
Clallam PUD No 1
Collaborative Partners Initiative
Community Action of Skagit County
Community Action Partnership
Community Health Association of Spokane
Company of Contractors
Compass Housing Alliance
Dept. of Social Health Services - Community Services
Domestic Violence Services of Benton and Franklin Counties
DSHS Stevenson Community Services Office
East African Community Services
El Centro de la Raza
Families of Color Seattle
FamilyWorks
First Step Family Support
Foundation for Healthy Generations
Friends of the Children SW Washington
Front and Centered
Greater Tacoma Community Foundation
Healthy Ferry County Coalition
Hearing, Speech & Deaf Center
Helping Hands Food Bank and Solutions Center Skagit County
Hispanic Metropolitan Chamber
Hope Sparks
HopeSource
I am Spokane
Inland Power
Khmer Community of Seattle King County
Kiemle Hagood
Latinos en Spokane
Libraries of Stevens County
Lopez Family Resource Center
Low Income Housing Institute
Metropolitan Development Council
Multicultural Child and Family Hope Center
Neighborhood House
Northeast Community Center
Northeast Tri-County Health District
Northwest Communities Education Center
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 198
Northwest Immigrant Rights Project
Okanogan County Community Action Council
Olympic Area Agency on Aging
Opportunity Council
Orange Child
Pend Oreille County Counseling Services
Pierce County Community Organizer
Puget Sound Energy
Puyallup Tribe of Indians
Room One
Rural Resources Community Action
Serenity House of Clallam County
Serving Our Community
Skamania County Council DV and SA
SNAP WA
Somali Family Safety Task Force
Southwest Youth & Family Services
Spokane Neighborhood Action Partners
Spokane Regional Domestic Violence Coalition
Spokane Valley Partners
St. Vincent de Paul Sequim
Tacoma Public Utilities
TC Futures
The Brotherhood R.I.S.E. Center
The Village on Casino Road
Thrive International
TPC Habitat for Humanity
Transitions Women’s Hearth
Unidos Nueva Alianza Foundation
United Way of Clallam County
Urban impact
WA State Commission on African American Affairs
Walla Walla Immigrant Rights Coalition
Washington State Coalition of African Community Leaders
Washington State Women's Commission
Washington West African Center
Widows of Might Spokane
Many thanks to the following organizations who distributed the household surveys:
4Tomorrow
Consejo Counseling
Educational Opportunities for Children & Families
Friends of Republic Library
Living Well Kent
NAMI Yakima
Partners INW
Volunteers of America - Western Washington
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 199
Additional thanks to:
Avista Utilities, Kelsey Solberg, Shawn Bonfield and Tamara Bradley
Benton County PUD No 1, Commissioner Lori Sanders
Big Bend Electric Cooperative, Kelly Haugh
City of Ellensburg, Julie Coppock and Nancy Lillquist
Chelan County PUD No 1, Andrew Grassell
Clallam County PUD No 1, Mattias Jarvegren
Clark Public Utilities, Lisa Fix
Climate Solutions, Megan Larkin
Community Action Council of Lewis, Mason & Thurston Counties, Stephenie Arnold
Cowlitz County PUD No 1, Dever Haffner-Ratliffe, Jennifer Langdon and Steve Taylor
Douglas PUD No 1, Shiloh Burgess
Empower Dataworks, Hassan Shaban
Ferry County PUD No 1, Commissioner Dan Fagerlie and Pam Allen
Front and Centered, Mariel Thuraisingham
Grant County PUD No 2, Ryan Holterhoff
Grays Harbor County PUD No 1, Tara Maynard
Inland Power and Light, Kim Gentle
Jefferson County PUD No 1, Drew McKnight
Klickitat County PUD No 1, Anita Clever
Lakeview Light and Power, John DeVore
Mason County PUD No 3, Michelle Patterson
Modern Electric Water Company, Chelsea Martin
Northwest Energy Coalition, Charlee Thompson
Okanogan County PUD No 1, Heidi Appel and Kim Johnson
Opportunity Council, Jen Rightsell
Orcas Power & Light Cooperative, Foster Hildreth and Jay Kimball
Pacific County PUD No 2, Commissioner Pam Hickey
PacifiCorp, Charity Spires
Peninsula Light Company, Jacob Henry
Puget Sound Energy, Ario Salazar, Carol Wallace, Kelima Yakupova, Theresa Burch and Wendy Gerlitz
Rural Resources Community Action, Stefanie Demmitt
Seattle City Light, Lars Henrikson, Mendy Droke and Thor Peterson
Sierra Club, Jim Dennison
Snohomish County PUD No 1, Jeff Feinberg and Ryan Collins
Spark Northwest, Andrea Axel and John Seng
Spokane Neighborhood Action Partners, Carol Weltz
Tacoma Public Utilities, Anne Larrabee, Brittany Broyles, Francine Artis and Jing Liu
The Energy Project, Yochi Zakai and Shaylee Stokes
Washington Conservation Action, Caitlin Krenn
Washington Public Utility Districts Association, George Caan and Nicolas Garcia
Washington State Community Action Partnership, Linda Garcia
Water Street Public Affairs, Isaac Kastama
WithinReach, Maricruz Sanchez
STATEWIDE MONTHLY LOW-INCOME ENERGY ASSISTANCE PROGRAM DESIGN 200
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