Good morning, Mr. Chairman and members of the Subcommittee. Thank you for the opportunity to appear before you today. I want to speak to you very briefly on the issue of consumer education. I provided comments on this issue to the full Subcommittee, so I'll try not to repeat myself too much.

VACAP's first concern for the low-income residents of Virginia is the lack of public information regarding the changes that will come with the restructuring of the electric utility industry. Because it seems that the issue has consumed my every waking moment all summer long, I've found myself talking to a lot of people about it. I'm talking about friends, family, people just like you and me, who read the newspapers every morning, watch Eyewitness News every evening at 6 and 11, who keep up with what's going on in the world. I'll tell them I've been working all summer following the electric utility deregulation issue. And what I hear back is--"WHAT ARE YOU TALKING ABOUT???" And I spend the next 45 minutes or so trying to explain. So the first issue is--people need to be told NOW that restructuring is coming and what it will mean to them. Beginning as quickly as possible, Virginia's consumers need information on what changes are being made in the electric utility industry, why change is happening, how the change may effect them, and what they can realistically expect from a restructured electric industry.

But even more important will be the information low-income and other consumers will need later in order for them to make informed choices among providers of electric service. This information must be carefully designed, easy to understand, and targeted specifically to those populations that are most vulnerable. Small consumers, especially low-income consumers, are unprepared to shop wisely for electricity. It is imperative that Virginia prepare its citizens with publicly-sponsored consumer education and information, through a program administered by the Commonwealth and conducted by organizations experienced in working with these vulnerable populations.

The Structure and Transition Task Force has spent a lot of time this summer listening to discussions on the issue of default provider. VACAP started out adamantly opposed to the incumbent utility being the default provider. We've come off that position a little bit because we realize that consumer education is going to have a great deal to do with the number of people who "choose not to choose." A well-conducted consumer education program, with easy-to-understand information and a broad range of methods used to impart that information (everything from all forms of media to meetings in churches and community centers to one-on-one explanations by agency outreach staff and case managers), with concerted effort to target Virginia's most vulnerable residents, will help to minimize the number of residential consumers who remain with their incumbent utility because they're too confused to do otherwise.

I want to make just a few specific points with regard to consumer education. First of all, with all due respect for the State Corporation Commission, on the one hand, I think that they should be responsible for consumer education, but on the other hand, I don't. What I mean is, yes, the SCC staff are the experts here. The SCC is responsible for oversight of the industry, and will continue to have a role to play after restructuring. Staff understand the industry, and would easily be able to determine the accuracy of the information provided in a consumer education campaign. And yet, the SCC has no consumer affairs department, nor has it, to my knowledge, ever had experience in contracting with groups to provide outreach, information and services to such populations such as low-income families, the elderly and the disabled.

If legislation ultimately provides that the SCC has responsibility for administering the consumer education campaign needed due to electric utility restructuring, that legislation must be specific in directing the SCC to develop plans for the campaign in coordination with the Department of Social Services, the Department of Housing and Community Development, the Department for the Aging, and any other state agency which has program responsibility for our vulnerable target populations. In addition, the legislation should also specifically direct the SCC to enter into contractual agreements with Community Action Agencies, Weatherization Providers, Local Departments of Social Services, Area Agencies on Aging, and other human services providers and community organizations who currently provide advocacy and outreach to Virginia consumers and to specific populations of consumers that are recognized to be more vulnerable.

The consumer education campaign must be adequately funded, with the understanding that the cost of providing this education to members of targeted vulnerable groups will be greater per capita than the cost of providing the information to the average residential consumer. In order for the educational campaign to successfully reach members of vulnerable population groups, a number of barriers must be overcome. One tremendous barrier is that of trust--low-income, the elderly, the disabled will more readily accept new information from people they already work with and know to be trustworthy. In addition, studies have shown that one-to-one education is the best way to reach these groups. In order to get them to meetings where the information can be discussed and explained, transportation, child care and other logistical issues must be addressed.

As we have stated on previous occasions, VACAP believes that consumer education should be funded through a non-bypassable wires charge assessed on generation and based on each consumer's monthly usage of electricity.

On the issue of aggregation, the Virginia Council Against Poverty believes that legislation should encourage, to the greatest extent possible, residential and small-business consumer aggregation. I have invited Dr. Meg Power, Director of the Economic Opportunity Research Institute, to provide you with some written comments suggesting ways that you could legislatively encourage aggregation. I will forward those comments to staff as soon as I receive them.