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Parties filed comments on self-attestation regarding the DPU’s inquiry to examine energy burden with a focus on energy affordability for residential ratepayers and to consider improvements to the programs currently offered to address energy affordability, including participation in existing programs and the creation of new programs.

In particular, AGO said that:

(1) based on Portland General Electric data for 2024-2025: (i) “the empirical evidence regarding the eligibility status of nonresponders for post-enrollment verification after self-attesting to income suggests the vast majority of non-responders are income-eligible”; (ii) “only 4–5 percent of participants were above the program’s eligibility threshold”; and (iii) “amongst customers in the wrong discount tier, [there was] an approximately equal distribution between customers who over-reported and under-reported their household income”;

(2) while it “does not have data to present from [other] programs, their numerosity and persistence suggests the incidence of fraud and error does not impose exorbitant costs”;

(3) “Existing programs also demonstrate the availability of guardrails—primarily audits—for reducing fraudulent enrollment”; and

(4) it concludes that “it is likely that allowing customers to enroll in the LIDR through self-attestation will reduce overall LIDR program cost,” but also “supports implementing an auditing policy for self-attesting customers that includes post-enrollment income verification for a small percentage of customers.”

Next Steps:

• Utility self-attestation proposal due by 9/30/26.
• Utilities’ initial enrollment reports due by 11/16/26; utilities’ reports on additional costs incurred due by 8/30/26.
• Utilities’ first annual reports due by 11/1/27;
• Utility year one lessons learned report due by 1/31/28.
• Inquiry to examine energy affordability for residential ratepayers