Ryann Busillo | 1/27/2025
Introduction
Following up on my latest blog, Arrears and DPAs—where I examined troubling correlations in Central Hudson’s monthly collection reports, in addition to years of missing satisfied DPA data—this post turns to another utility company. My aim here was to determine whether the trends I observed at Central Hudson were unique or more typical among investor-owned utilities (IOUs), to assess Orange and Rockland’s satisfied DPA reporting, and to evaluate the effectiveness of DPAs in reducing utility debt. To refresh, DPA stands for Deferred Payment Agreement, and arrears refer to the amount of debt customers owe to their utility company.
Connor, my co-author, and I chose Orange and Rockland because it shares key similarities with Central Hudson. Both serve between 200,000 and 290,000 residential accounts (attained from collection reports), with seemingly comparable customer compositions. That said, we do not have detailed demographic or socioeconomic data, such as whether households are experiencing greater financial stress or more variable incomes, so we can only assume the two are broadly comparable. In contrast, a utility like Con Edison—whose customer base is concentrated in New York City—might show very different patterns due to a long list of variables.
Review of Central Hudson Findings
In my last blog, I found that the relationships between debt, payment plans, and shutoffs are strongly correlated. More specifically, when I compared the number of households enrolled in a DPA to total arrears, average arrears, and terminations, the results underscored patterns in the data that require further explanation. Moreover, these strong correlation values indicate that DPAs are not functioning as a mechanism to alleviate debt. This is problematic because DPAs are intended to help customers pay down their utility debt, but we know this is not happening on a systemic level in Central Hudson, as arrears continue to grow. While the relationships between payment agreements, arrears, and terminations warrant concern, the last relationship I examined—Terminations for non-payment vs. reconnections via DPA—demonstrates a case where the system is functioning as it should. It shows that, while DPA’s don’t provide debt relief, they do allow customers to avoid shut offs.
Analysis of Orange and Rockland
I then applied the same analysis to Orange and Rockland to see if Central Hudson’s trends were present in Orange and Rockland’s collection data. What I found was the opposite: the relationships between debt, DPAs, and terminations are weakly correlated, meaning there is little to no relationship between the categories I measured. This stands in contrast to my findings for Central Hudson, where the R² value represents a strong correlation (see Table 1 for a comparison of the two datasets).
A Note on Central Hudson’s Shut off Practices: Central Hudson’s collections team is small, so staff focus on terminating accounts with the oldest or largest debt; if another field action account happens to be along the same route, it might get shut off, too.
Interpreting Correlations
If Deferred Payment Agreements (DPAs) were effectively helping households reduce their debt, we would expect to see a negative relationship between DPA enrollment and arrears. This means that as DPA enrollment increases, arrears would decrease in tandem. We would expect to see this pattern because DPAs are meant to help pay down arrears, yet this expected relationship does not appear in either Central Hudson’s or Orange and Rockland’s case.
Instead, Central Hudson’s data displays strong positive correlations across the categories we examined. It is important to emphasize that these correlations do not mean causation. For example, when interpreting these correlations, a strong positive R² does not mean one variable is causing the other to increase: increased DPAs are not causing arrears to rise and vice versa. Rather, as more households enter DPAs, arrears also grow. In the context of Central Hudson, this suggests DPAs are not functioning as a mechanism to reduce debt. By contrast, Orange and Rockland’s data does not show a strong relationship in either direction, which indicates that arrears and DPA enrollment are not tightly linked.
Key Differences Between Utilities
This is crucial to highlight because it reveals a key difference in the way collections in Central Hudson and Orange and Rockland are functioning, at least from a data standpoint. For Orange and Rockland, while we do not see strong negative correlations that would indicate debt reduction, their arrears remain relatively steady over time (see Figure 1). This suggests that while DPAs are not driving down debt, they are at least not coinciding with a steady upward climb in arrears.
Central Hudson, on the other hand, paints a different picture. The strong positive correlations in its data highlight how debt continues to rise despite more customers participating in DPAs. Again, this does not mean DPAs are responsible for the increase. Instead, it points to other, unexplained dynamics that are preventing DPAs from having their intended effect. This pattern is unusual compared to what we see at Orange and Rockland, and it raises important questions about Central Hudson’s operations.
In short, DPAs appear to fulfill their role in helping households restore service after disconnection, but they are not proving to be an effective tool for addressing the underlying challenge of household energy debt. The stability seen in Orange and Rockland’s data—though not ideal—shows that debt can be held steady, but Central Hudson’s numbers suggest deeper problems that merit further investigation.
Figure 1. This graph presents average household arrears for Central Hudson and Orange and Rockland from June 2023 to June 2025. Central Hudson’s average arrears are not only higher than Orange and Rockland’s, but they also show a clear upward trajectory over the two years. In contrast, Orange and Rockland’s arrears remain relatively stable, indicating that while debt persists, it does not steadily climb as it does in Central Hudson’s case.
Furthermore, when I looked at active DPAs at the start of each month, I was surprised to find that Orange and Rockland had consistently higher percentages of accounts enrolled in DPAs in comparison to Central Hudson. I hadn’t expected this pattern, as I assume the utility with higher arrears would have more accounts enrolled in their DPA program. Still, this highlights how differently the two datasets behave: Central Hudson shows higher arrears, lower DPA enrollment, and a strong positive correlation between the two, while Orange and Rockland display steadier arrears, higher DPA enrollment, and a weak correlation between the two.
Figure 2. This graph displays the percentage of customers in arrears with active DPAs from June 2023 to June 2025. Orange and Rockland (blue) had consistently higher DPA enrollment in comparison to Central Hudson.
Unexplained Factors at Play
Simply put, something is amplifying the link between Central Hudson’s arrears and DPA enrollment that cannot be explained by program design alone. A likely contributor is the utility’s troubled billing system rollout, which left many customers in arrears while driving up DPA participation at the same time. Yet this explanation cannot be applied to Orange and Rockland, which maintained steadier arrears and higher DPA participation. This contrast suggests that issues unique to Central Hudson may be shaping its outcomes.
Differences in customer populations may also play a role. As mentioned above, Central Hudson’s service area could include households facing greater financial stress or more variable incomes, making them more prone to arrears regardless of available payment plans. Still, without greater transparency into the utility’s internal practices and customer data, it is impossible to identify causes with confidence. What is clear, however, is that Central Hudson’s patterns diverge not only from expectations but also from what we observe at Orange and Rockland. This raises urgent questions: why are arrears climbing despite rising DPA enrollment, and to what extent are operational missteps, demographic pressures, or both driving the gap?
Orange and Rockland Satisfied DPAs
While Central Hudson’s collections data does not report on satisfied DPAs, Orange and Rockland’s does regularly report those numbers. This allows us to assess the impact of satisfied DPAs within Orange and Rockland and draw a broader conclusion: satisfied DPAs, in general, do not appear to significantly reduce household debt. Although this is not the outcome we hoped for, it underscores the need for deeper interventions—such as debt forgiveness and a system-wide revamp—to meaningfully support energy-insecure populations. If DPAs are a utility’s main response to debt, then DPA’s need to effectively address that debt.
To evaluate the effects of satisfied DPAs, I examined two metrics: Average Household Debt and Monthly Changes in Average Arrears. In both cases, the correlations were extremely weak, indicating that completing a DPA does not substantially change debt levels. While satisfying a DPA is a positive outcome for the individual customer who achieves it, the majority of customers do not reach that point, and for the system as a whole, DPAs have a limited impact on reducing arrears.
To highlight this further, when we examine DPA outcomes, the majority of plans default, and more are reinstated than satisfied (see Figure 5).
Figure 3. This graph shows the relationship between satisfied DPAs and monthly changes in average arrears, with an R² value of 0.055. This means there’s almost no connection between the number of completed DPAs and a reduction in arrears. Ideally, we would hope to see arrears go down as more DPAs are satisfied, but the weak correlation shows that completing DPAs doesn’t have much impact on overall debt.
Figure 4. This graph shows the relationship between satisfied DPAs and average household debt, with an R² value of 0.002. The extremely weak correlation suggests that completing a DPA has a minimal effect on reducing overall household debt. If DPAs were effective, we would expect debt to decrease as more plans are satisfied; however, as shown in Figure 3, the data indicate that satisfied DPAs do not significantly reduce average household debt across customers.
Figure 5. This graph shows the outcomes of DPAs, highlighting that most plans end in default, and more DPAs are reinstated than fully satisfied. This illustrates why DPAs have a limited impact on overall arrears reduction. They don’t lead to debt relief.
Closing Thoughts
This comparison with Orange and Rockland makes one thing clear: Central Hudson’s troubling patterns are not inevitable or universal among utilities. While DPAs can help households restore service after disconnection, they do little to reduce arrears or lower household debt. Orange and Rockland’s data reinforces this point—their satisfied DPAs show almost no relationship to declining debt, while also demonstrating that arrears can be held relatively steady even without significant debt reduction.
Central Hudson, by contrast, shows a far more troubling trajectory. Arrears continue to climb even as more customers enroll in DPAs—a pattern that cannot be fully explained with the data currently available. While operational issues, such as the problematic billing system rollout, may play a role, gaps in satisfied DPA reporting do not drive this trend but instead make it difficult to fully understand and analyze. What the data does make clear is that the connection between arrears and DPA enrollment at Central Hudson is unusually strong compared to Orange and Rockland, pointing to underlying dynamics that warrant closer examination.
Nonetheless, in both cases, this analysis articulates the limits of DPAs as a tool for addressing energy debt. DPAs may serve an important role in helping households reconnect after termination, but they are not designed to resolve chronic utility debt. To truly support energy-insecure households, utilities and regulators will need to look beyond DPAs toward deeper interventions—such as debt forgiveness, billing reform, and targeted support for vulnerable populations. Until such measures are pursued, burdensome arrears will persist, and utilities like Central Hudson will remain case studies in the consequences of inaction and opacity.
If you need help navigating a Final Termination Notice or understanding your DPA, don’t hesitate to reach out. And if you’re looking for additional support to manage your energy bills, MHET has programs and resources that can help. We’d love to connect and help you find the options that work best for you. For researchers or anyone interested in exploring these trends further, we welcome conversations and collaboration.
