Public Advocate

COST CONTROLCOST DISTRIBUTIONCUSTOMER AGENCY

Last Updated September 22, 2025

AT-A-GLANCE

IMPACT TIME HORIZON

Short Term (0–2 Years)

POTENTIAL COST SAVINGS

Variable

CONTEXT AND BACKGROUND

Independent utility consumer advocate offices are state-level entities that represent the interests of consumers in utility regulatory proceedings. Though their remit varies across states, they always represent residential customers and are sometimes charged with representing all ratepayers or specific types of ratepayers (e.g., small business or rural customers).

Unlike other intervenors in regulatory proceedings, most state consumer advocate offices have a statutory right to intervene and have legal standing in all cases before their state's public utilities commission (PUC).

Consumer advocate offices sometimes also play a role in legislative processes. These offices are intended to help ensure customer voices are heard in decisions affecting utility rates, service quality, and energy affordability. While the vast majority of states have advocate offices either embedded in their attorney general's office or as standalone agencies, others may lack formal representation for utility customers. Establishing, funding, and strengthening these offices can help balance the influence of utilities in regulatory processes and improve affordability outcomes.

Impact Time Horizon

How long it typically takes for changes to materialize in utility behavior or customer bills

SHORT-TERM (0–2 YEARS)

Rate cases take place in individual states every few years, with multiple rate cases often happening independently of one another around the United States every year.

Potential Cost Savings

The level of cost savings that can reasonably be expected to result from this policy

variable

While cost savings will vary based on policy design and implementation, a 2013 study found that rate structures in select states where consumer advocates intervened between 1990 and 2007 resulted in a reduction of $42 per year, or 3.6%, in average annual residential electricity bills. Notably, this study is limited to lower rates for residential customers and reduced return on equity, though other benefits may go unmonetized.

Target Cost Drivers

The policy can help to ease customer cost pressures created by these drivers

Aging grid infrastructureFuel price volatilityExtreme weather/wildfiresLoad growthMisaligned utility incentives

This policy addresses overall affordability rather than providing a solution specific to certain cost drivers.

Legislative Design & Implementation Considerations

While legislation establishing or strengthening public advocate offices will vary state-to-state, it can include the following:

ADMINISTRATION

Ensuring the office is structurally and financially independent from utilities and regulators will help consumer advocate offices pursue issues that are in the best interests of consumers.

SCOPE OF SERVICES

Clearly defining the office's authority to intervene in rate cases, participate in regulatory proceedings, and advocate in legislative processes helps remove ambiguity or confusion about the office's ability to intervene in utility customer affordability issues.

SOURCE OF FUNDING

Establishing a stable funding mechanism, such as a small surcharge on utility bills or a dedicated state budget line item, will help with continuity in the office's ability to provide services.

CUSTOMER OUTREACH AND SUPPORT

Requiring the office to prioritize affordability and equity, particularly for low-income and historically underserved communities, helps ensure the office's electricity affordability priorities are centered around groups most affected by rate changes.

The table below provides examples of how authority and responsibility for public utility advocate offices may be distributed across key entities.

VENUE	POTENTIAL ROLES
Legislature	• Establish the public advocate office • Define the office's scope and authority • Determine the office's funding mechanism • Direct how the office coordinates with other state agencies and regulators
Regulator	• Coordinate with the public advocate office as part of the office's participation in regulatory cases • Adhere to the office's requests for reviews or regulatory procedure • Include office representatives in regulatory engagements like public hearings
Administration	• Appoint members to the public advocate office • Authorize funding for the office in annual budgets • Provide direction for how the office should coordinate with other executive agencies
RTO/ISO	• Support regional consumer advocates, like Consumer Advocates of PJM States (CAPS)

REAL-WORLD EXAMPLES

Over 40 states and the District of Columbia have consumer advocate offices, with some states having multiple consumer advocates. The majority of utility consumer advocates are members of the National Association of State Utility Consumer Advocates. In states without these offices, consumer advocacy may be handled by other agencies or left to nonprofit organizations.

Georgia

Members of the Georgia legislature introduced legislation in recent sessions to reestablish an Office of the Consumers' Utility Counsel that state senators have said was removed due to 2008 budget cuts. Though it did not pass, legislation introduced in the 2025-2026 legislative session would see the director of the office appointed by the governor and entitled to appear before authorities including the Georgia Public Service Commission and federal or state administrative agencies.

Ohio

The Office of the Ohio Consumers’ Counsel (OCC) is an independent Ohio state agency, created by the Ohio legislature in 1976, that represents residential utility customers in issues related to investor-owned utilities before the Public Utilities Commission of Ohio (PUCO), the Supreme Court of Ohio, federal regulatory agencies, appellate courts, and the Ohio General Assembly. OCC leadership is selected by the office’s nine-member governing board, each of whom is appointed by the Ohio Attorney General. Unlike other state agencies, OCC’s operating budget comes from a fee on the gross interstate earnings of utilities regulated by the PUCO, and OCC estimates it has saved consumers $29 for every dollar spent.

Wisconsin

The Wisconsin Citizens Utility Board (CUB) was originally created by the state legislature in 1979 before reorganizing into a private nonprofit organization in response to a federal Supreme Court ruling. While CUB receives funding from a variety of groups, including small businesses, a 2021 act allowed the Public Service Commission to authorize CUB to receive up to $900,000 in annual funding from investor-owned utilities.