Analysis - The Institute for Southern Studies

how much they use or indeed how much electricity costs until after the fact. Thus consumers cannot react to high prices easily by cutting
consumption. 182
o Cost Pass-Thru Conclusion
Based on the above three cost pass-thru factors consisting of (a) 20 examples of recent (2008) PUC-regulated rate hikes which average almost
19% per company which far exceeds the 1% and 3% SISNOSE screening analysis thresholds defined by EPA’s guidance, (b) 11 of the 18
deregulated states which have de-regulated the price of electricity, and (c) the fact that consumer demand for electricity has been relatively
inelastic, this RIA concludes that it is likely that electric utility suppliers could pass-thru all, or nearly all, of the future average annual
regulatory compliance costs for the CCR proposed rule such that a significant impact on small entities and non-small entities would not occur.
182 Source: “Power Price Volatility and Risk Management: An Introduction”, Anne Ku, Sept 2000 (this is the original, unedited article, later submitted to Global Energy
Business magazine Sept/Oct 2000) at: http://www.analyticalq.com/energy/volatility/default.htm
215