On May 12, APGA filed joint comments, along with the American Public Power Association (APPA) and the National Rural Electric Cooperative Association (NRECA), urging the Office of Management and Budget (OMB) to rescind clearance of the Energy Information Administration’s (EIA) new Residential Utility Disconnections Survey, Form EIA-112.
Joint commenters filed comments in response to OMB's notice and request for information on ideas for deregulation.
Form-EIA 112 requires utilities to report data on disconnections, final notices, and reconnections. The survey places a significant burden on utilities, especially smaller ones. EIA’s estimate of two hours to complete the form does not accurately reflect the actual effort involved in gathering this data, coordinating across departments, and updating internal systems, particularly for utilities with limited staff.
The survey is mandatory for all 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 regardless of size, all are required to complete Form EIA-112. This means even the smallest utilities, which may lack the resources of larger ones, are affected by the added reporting burden.
Joint commenters reiterated additional prior concerns about the survey’s lack of practical utility and necessity and misalignment of the proposed data collection and stated purpose. Recall, in August 2024, APGA, APPA, and NRECA filed joint comments in response to EIA’s initial notice, urging EIA to forgo the proposed survey. Additionally, in November 2024, APGA submitted comments highlighting the burden on smaller utilities in response to EIA’s notice seeking a three-year clearance for the survey.
To read the filed comments, including all sets of APGA’s prior comments, click here.
Public gas utilities can learn more about how to comply with this mandatory reporting requirement .