Addressing Customer Assistance Program Barriers

The primary barriers to establishing customer assistance programs are legal prohibitions – perceived as well as actual – limiting the ability of public utilities to use rate revenues to “subsidize” different classes of water users.

In 2024, EPA requested its Environmental Financial Advisory Board (EFAB) to address a number of water affordability challenges including CAP barriers. EFAB’s 2025 report recommended among other actions that EPA:

  • Develop a policy statement recognizing the benefits of expanding the cost-of-service framework to incorporate affordability/public health
  • Provide examples of state statutes that may allow for funding CAPs
  • Study the effect of alternative rate structures on affordability
  • Study the costs of nonpayment, shutoffs, and other aspects of unaffordable bills for utilities.
  • Articulate key principles and evaluate alternative pathways for a federal water customer assistance program.

The issue of barriers to CAPs and the need to overcome has been a major water sector issue for some time. Check out the resources below on this topic.