Massachusetts Attorney General’s Office

Expert Testimony Secures Self-Attestation Pilot for Income-Qualified Customers

In a high-stakes National Grid rate case, the Massachusetts Attorney General’s Office engaged Hawks Peak Strategies to provide expert testimony on income eligibility verification and customer participation. Within an accelerated timeline, Dr. Courtney Henderson delivered research-backed insights that contributed to the adoption of a self-attestation income pilot—reducing barriers for low-income households.

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The Challenge

Two months. That’s all the time between initial testimony deadlines and evidentiary hearings in a high-stakes National Grid rate case affecting Massachusetts’ most vulnerable energy customers.

The Massachusetts Attorney General’s Office rapid, rigorous analysis of:

  • Income eligibility verification processes
  • Participation targets for discount rates
  • Outreach and education strategies

All while navigating the complex regulatory requirements and utility rate design considerations.

 

Our Approach

Hawks Peak combined regulatory expertise with customer-centered research.

Dr. Henderson didn’t just analyze data, she listened to the people behind it. Working with precision and agility, she conducted discovery, prepared testimony, and developed case strategy alongside the MA AGO. But the breakthrough came from elevating voices rarely heard in utility rate cases: the income-qualified customers themselves.

Through innovative qualitative research conducted mid-litigation, Dr. Henderson documented the real-world barriers customers faced in proving their income eligibility. The findings were undeniable—and they directly shaped her expert recommendations.

 

The Outcome

    The Massachusetts Department of Public Utilities adopted Dr. Henderson’s recommendation for a self-attestation income pilot—a significant policy win that removes bureaucratic barriers for the households facing the highest energy burdens.

    When customers who lack resources to participate in regulatory proceedings finally have their voices heard, policy changes. This case proves it.

    Why This Work Is Different

    Expert testimony informed not only by data analysis, but by documented customer experience—bridging regulatory rigor with lived reality.

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