Dear Messrs. Arriola and Nolan:
We write to express our disappointment with a number of the statements made by your staff in response to our criticism of utility bill collection practices during the pandemic. Those statements seemed to claim that the data we cited were inaccurate because any collection cases pursued during the pandemic were initiated prior to the pandemic's onset.
The reality is that our information came directly from your Companies' own submissions to the Public Utilities Regulatory Authority (PURA). These interrogatory responses are attached to this letter for reference.
These documents show irrefutably that your companies obtained judgments or wage garnishments through courts during the pandemic. You seek to distinguish or excuse this activity by claiming these court actions were initiated before the pandemic began. Even if true, that distinction makes little difference to a family deprived of housing or income because of the court judgment or wage garnishment you sought.
Many consumers were struggling to pay for housing, food, medicine and other basic needs -- including utilities -- even before the pandemic, and many found payment impossible after COVID spread and unemployment skyrocketed, hours were cut, and work imposed increased health risks and family sacrifices. It is scant comfort to consumers that Avangrid and Eversource may have halted new court actions and wage garnishments after the pandemic began while continuing those actions that began prior to the pandemic.
Our position is that all legal actions related to bill collection -- regardless of when they began -- should have been suspended until the pandemic ceased. Our hope was that you would agree and acknowledge that such collection practices -- which likely imposed additional pressure on families already struggling with hardship and heartbreak -- were misguided.
The circumstances and timing of the judgment and wage garnishment activity are under investigation by the Office of Consumer Counsel and other participants through a proceeding opened on March 29th by PURA. PURA will ultimately determine if such actions violated their orders during the pandemic based on the evidence presented in this proceeding.
Our concern is not merely with past actions -- and appropriate remedies and penalties for harms done -- but also preventing such actions in the future. We hope you share that concern.
In the meantime, we hope you will fully cooperate with the PURA investigation. Even if you disagree with us on some issues, we urge that you join in seeking to "evaluate and clarify specific directives and compliance orders to help ensure adequate protections for struggling consumers during the state of emergency" as the OCC petition requests from PURA.