On November 12, APGA submitted comments in response to the Energy Information Administration’s (EIA) proposed collection of information in the Residential Utility Disconnections Survey, Form EIA-112.
Form EIA-112 is a proposed annual survey collecting information on the number of monthly natural gas and electric service final notices, disconnections, and reconnections for bill nonpayment across residential customers.
APGA’s comments focused on the specific concern about the burden that such reporting would place on all public natural gas utilities. The proposed survey is especially burdensome for the hundreds of smaller, community-owned gas utilities that have limited staff and resources.
The proposed survey respondents will include residential-serving utilities that file Form EIA-176 (Annual Report of Natural and Supplemental Gas Supply and Disposition). 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 this proposed survey, Form EIA-112.
Additionally, EIA has underestimated the burden hours of this proposed survey and has not established a clear benefit for obtaining this information from small natural gas utilities.
Recall, in August, APGA submitted joint comments with the American Public Power Association (APPA) and the National Rural Electric Cooperative Association (NRECA), voicing concerns with the proposed survey. Joint commentors highlighted 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. Joint commentors recommended that EIA forgo the proposed survey.
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.