The American Public Power Association recently filed comments with the Office of Management and Budget in response to an Energy Information Administration proposed survey on residential utility disconnects.
At issue is an EIA October 11, 2024, notice: Agency Information Collection Proposed New Survey.
EIA is seeking a three-year clearance for Form EIA-112 Residential Utility Disconnections Survey, which requires OMB approval.
This notice follows a June 20, 2024, notice and request for comment on the new survey.
APPA, the American Public Gas Association, and National Rural Electric Cooperative Association filed joint comments in response to the initial notice, urging EIA to forgo this proposed survey because the data requested is unnecessary, burdensome, and does not align with the Notice’s stated purpose of informing federal and state energy assistance programs.
In an email response to the comments, EIA largely rejected arguments raised against the survey.
The most recent notice showed that the survey as described remains unchanged.
As such, APPA’s filing explains that its initial concerns remain but focuses on the impact to smaller public power utilities.
Should EIA continue to pursue this new survey, APPA strongly recommends increasing the threshold for reporting to exclude small entities, or at the very least to exclude the utilities with less than 200,000 MWh in sales that EIA purports to intend to exclude.
Survey Overview
This proposed new annual survey will collect information on the number of monthly natural gas and electric service final notices, disconnections, and reconnections for bill nonpayment.
EIA’s stated purpose is “to better inform state and federal policymakers on utility disconnections by providing reliable data that can help inform appropriate levels of budgetary support for various assistance programs across the United States.” The data will be published publicly on the EIA website, including individual utility data, aggregated state data, and aggregated national data.
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.
