The American Public Power Association on May 12 filed joint comments with the American Public Gas Association and National Rural Electric Cooperative Association in response to the Office of Management and Budget’s (OMB) notice and request for information on ideas for deregulation.
The joint commenters urged OMB to rescind clearance of the Energy Information Administration’s new Residential Utility Disconnections Survey (Form EIA-112), which imposes an unnecessary and unjustified burden on utilities. The survey data does not align with EIA’s stated purpose of informing federal and state energy assistance programs, they said.
APPA members provided feedback upon survey completion that further supports how EIA underestimated the burden on respondents.
Members shared examples including the complex internal coordination, especially where customer service and reporting functions are handled by different staff or management systems, the inability or great difficulty in acquiring commodity level data for multi-service, the need to program new queries and reports in management systems, and the necessary manual review of available reports and data sets.
In 2024, APPA, APGA, and NRECA filed joint comments in response to EIA’s initial notice, urging EIA to forgo the proposed survey.
APPA also filed comments with OMB reiterating concerns and highlighting the burden on smaller utilities in response to EIA’s subsequent notice that the agency was seeking a three-year clearance for the survey.
Applicability to Public Power
In census years, utilities that complete the Form EIA-861, excluding small utilities that complete Form EIA-861S, will need to complete the form. For the years in between censuses, EIA will use cut-off samples from Form EIA-861M, based on utility size and state coverage.
