Connecticut Water Company is reviewing enrollment in one of its low-income assistance programs after learning it misinterpreted a new law and prematurely dropped an unknown number of households.
Participation in the utility's Water Rate Assistance Program (WRAP) has plummeted since July 2025, when Connecticut Water began requiring customers to document their income more frequently.
Through WRAP, the utility offers water bill assistance for households earning up to 60% of the state’s median income level.
Participants were previously required to reverify their eligibility every two years.
That cycle is set to change under a comprehensive energy bill passed last year. It requires income verification every 12 months for assistance programs approved by the Public Utilities Regulatory Authority (PURA).
Michelle Royce Williams, Connecticut Water's vice president of customer experience, said the utility believed it needed to implement the revised verification process by July 1, which is the law's effective date. However, a provision in the bill stipulates the change affects only PURA cases heard on or after October 2025.
“We attempted to comply with what we believed to be the law and were not made aware that if your rate case was decided prior to Oct. 1, 2025, this does not apply to you,” Williams said. “Clearly, we misunderstood.”
As of last June, 2,341 customers participated in the program. By October, WRAP enrollments dropped by more than half — to 960 participants.
Williams called it a "pretty significant drop" at a December meeting of the state's Low-Income Energy and Water Advisory Board, and pointed to the energy bill as the driving force.
While reporting on the change, Connecticut Public contacted PURA for information. The agency responded that it wasn't necessary under the law.
“The statute doesn’t require any change to existing programs until the applicable company's next rate amendment after October of 2025,” Taren O'Connor, PURA’s director of legislation, regulations and communications, wrote in an email. “PURA hasn't implemented a rate amendment that meets that criteria yet.”
A reporter conveyed that response to Williams from Connecticut Water. She acknowledged in an interview the utility missed a crucial detail.
“That's frustrating,” Williams said. “We really thought we had to comply with this effective July 1, 2025.”
It's unclear how many households were dropped from the discount program as a result.
Participation expanded in recent years after Connecticut Water changed its eligibility criteria. Many households were also automatically enrolled because they were approved for a separate federal low-income water assistance program.
Williams said some likely faced deadlines to reverify their eligibility over the last year under Connecticut Water's preexisting 24-month verification cycle.
“I think what it will take is looking and finding those customers who were in that sliver that did get impacted, who were maybe in that second year of the program, and making sure that we are identifying exactly who and how many those may be,” Williams said.
Connecticut Consumer Counsel Claire Coleman, who chairs the Low-Income Energy and Water Advisory Board, said she will monitor the circumstances surrounding the drop in enrollment.
“I acknowledge the substantial dip during this transition process and we will be monitoring it closely to determine whether other changes are needed going forward,” Coleman said.
Connecticut Water serves more than 100,000 customers in 60 Connecticut towns. The company is part of H2O America, a national investor-owned utility network.
Williams said Connecticut Water has not yet decided if it will stick with the new 12-month cycle or return to the 24-month cycle until its next rate case. She said the utility contacted all households before they were removed, and provided information about how to remain eligible.
“We're still kind of evaluating that because we’ve done all this outreach and because some of the people that are no longer in the program also have passed that 24 months, too,” Williams said.
State Sen. Norm Needleman, a Democrat who chairs the Energy & Technology Committee, said he intends to discuss the issue with leadership at Connecticut Water. It's apparent there was confusion about the intent of last year's bill, Needleman said.
“Sometimes a bill might not be 100% clear," he said.
Needleman said lawmakers implemented the 12-month recertification process for anyone receiving low-income rates on electric, gas or water bills as a cost containment measure to protect ratepayers.
“It was not an attempt to hurt anybody," he said. "It was just an attempt to make sure these programs are designed right."
Needleman and Coleman said the guardrails were a compromise to keep the programs running.
“There was a desire by some legislators to eliminate low-income discount rate programs altogether,” Coleman said. “What we've referred to as cost-containment measures were discussed and incorporated into the bill as sort of an insurance that the low-income discount rate programs would be cost effective and cost conscious.”
Electric utilities already had a 12-month verification process for their assistance programs.
On the water side, Williams said Connecticut Water funds WRAP itself. The cost of the program is one of many expenses PURA considers when setting the company’s water rates, she said.
Lawmakers passed the energy bill in June 2025. It was celebrated across party lines as an extensive package expected to save taxpayers millions in energy costs while expanding access.
Coleman said it will take years to evaluate the legislation’s impact on program participation and overall affordability.
Williams said Connecticut Water will continue its community outreach to get more people enrolled in its assistance programs.
“We want customers to receive the programs that they are entitled to,” she said.
