On August 16, APGA jointly submitted comments in response to the Energy Information Administration’s (EIA) request for comments on the proposed collection of information in the Residential Utility Disconnections Survey, Form EIA-112. APGA responded jointly with the American Public Power Association (APPA) and the National Rural Electric Cooperative Association (NRECA). Joint commenters voiced various issues with the proposed survey, including that the proposed information request is unnecessary due in part to the misalignment of the proposed data collection and stated purpose, and this lack of necessity could cause undue burden on public gas utilities.
Form EIA-112 is a proposed annual survey that would collect information on the number of monthly natural gas and electric service final notices, disconnections, and reconnections for bill nonpayment across residential customers. The survey would be conducted annually, and non-exempt utilities would be required to report the data.
EIA's notice explained that the data collected in the proposed form “aims to better inform state and federal policy makers on utility disconnections by providing reliable data that can help inform appropriate levels of budgetary support for various assistance programs across the United States.”
There is specific concern about the burden that such reporting would place on impacted utilities. The proposed survey is especially burdensome for smaller utilities that have limited staff and resources. EIA intends for the proposed form to be completed by those residential-serving utilities that also file Form EIA-176 (Annual Report of Natural and Supplemental Gas Supply and Disposition) and Form EIA-861 (Annual Electric Power Industry Report). Since every natural gas utility in the U.S. is required to complete Form EIA-176, no matter the size of the gas utility, all appear to be burdened with completing Form EIA-112, especially the hundreds of small, often community-owned gas utilities, many with 10 or less employees.
Read the filed comments here.
APGA will continue to work on this issue and will inform members of any future actions by EIA concerning this proposed survey.
For questions on this article, please contact Sydney Novoa of APGA by phone at 202-464-0834 or email at snovoa@apga.org.