Dear Chairman Glick:
We write to express our concern in regard to the effect that anticipated increases in heating and
energy costs will have on our constituents this winter. As the entity tasked with the regulatory
mission of ensuring consumers can access reliable energy at a reasonable cost, the Federal
Energy Regulatory Commission (FERC) has a significant role to play in promoting energy
justice and protecting United States residents from unfairly high energy costs. Under its statutory
authority, FERC has the power to influence retail rates for natural gas and electricity, including
by preventing market manipulation in wholesale natural gas and electricity markets and
enforcing gas spot market transparency. We urge the Commission to use its existing regulatory
authority to ensure that households' energy bills are not driven up by manipulation, obfuscation,
or other malfeasance from regulated entities, and to work collaboratively with other agencies to
address energy debt.
Disparate energy debt burdens are a serious economic, racial, and health justice issue. In
October, the U.S. Energy Information Administration (EIA) predicted that some households'
winter heating bills may rise by as much as 39 percent, compared to last year--a spike that will
most affect those with the fewest resources. Nationally, low-income households face energy
burdens that are three times higher on average than other households. This is also a racial justice
issue, with Black and Hispanic households having a median energy burden that is 43 percent and
20 percent higher than non-Hispanic white households, respectively.
The loss of utility service due to high energy burdens is one of the primary reasons for homelessness, especially for families with children. Accordingly, during this pandemic, the loss of utility service and
resulting homelessness directly led to higher COVID-19 death and infection rates among
There are many overlapping factors leading to this rise in energy prices, including profiteering
from oil and gas companies and high oil and gas exports. Additionally, as families across the
country struggle to pay their utility bills, utility companies received significant federal support
during the pandemic. Sixteen utilities received a combined $1.25 billion in financial support
through the Coronavirus Aid, Relief, and. Economic Security Act, and some utilities have seen
soaring profit margins during the pandemic. NextEra Energy, for example, dedicated a
combined $2.7 billion to CEO compensation and shareholder dividends between April 2020 and
For too long, the federal government has allowed too many utility companies to put profit above
the public. We have a responsibility to ensure that everyone has access to safe living conditions,
and we cannot let corporate greed or a quest for profit get in the way of fundamental human
With high winter energy costs, the ongoing threat of the pandemic, and racial and economic
justice issues surrounding energy debt, we urge FERC to use its existing statutory authority to
better protect consumers from energy market manipulation. FERC should use existing statutory
authority to provide more transparency on gas spot markets to protect consumers from companies
that use hidden prices to set or manipulate energy costs on a non-competitive basis.
Additionally, should prices increase this upcoming winter, FERC must closely monitor wholesale
natural gas and electricity market activity to determine if any market participants are engaging in
market manipulation or other violations.
Lastly, we are encouraged to see FERC's commitment to the creation of the Office of Public
Participation and the appointment of Director Elin Katz to spearhead transparency and consumer
participation in FERC proceedings. It is essential that FERC's Office of Public Participation
engage consumers around how FERC can protect vulnerable households in the long-term by
establishing new policies that limit harm from market manipulation, non-competitive gas
transactions, and other activities that put private profit above public access to affordable energy.
We also recognize that numerous agencies--including the Department of Health and Human
Services and the Department of Energy--have a collaborative role to play in supporting energy
consumers and promoting energy justice. Almost two years into the coronavirus pandemic,
families are experiencing immensely burdensome levels of utility debt that are approximately 67
percent higher than in the average year. Electric utilities carried out more than one million
disconnections during the pandemic, directly threatening the health and well-being of millions of
Americans. And according to a recent Census Bureau survey, nearly 30 percent of respondents
reported either minimizing or altogether foregoing other households expenses like food and rent
to pay their energy bills in the last year. In addition to using FERC's standalone statutory
authority, we encourage you to work as part of a whole-of-government response on this critical
Thank you, and we look forward to working with you on this matter.