Eia-112 Ssa_9.16.2024

EIA-112 SSA_9.16.2024.docx

Residential Utility Disconnections Survey

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Part A: Justifications
OMB No. 1905-0XXX

Form EIA-112, Residential Utility Disconnections Survey

Supporting Statement for Residential Utility Disconnections Survey

www.eia.gov

U.S. Department of Energy

Washington, DC 20585

October 2024













































The U.S. Energy Information Administration (EIA), the statistical and analytical agency within the
U.S. Department of Energy (DOE), prepared this report. By law, our data, analyses, and forecasts are independent of approval by any other officer or employee of the U.S. Government. The views in this report do not represent those of DOE or any other federal agencies.



Table of Contents



Introduction

  

The U.S. Energy Information Administration (EIA) is the statistical and analytical agency within the U.S. Department of Energy (DOE). It collects, analyzes, and disseminates independent and impartial energy information to promote sound policymaking, efficient markets, and public understanding regarding energy and its interaction with the economy and the environment. EIA is required to publish and otherwise make available independent, high-quality statistical data to federal government agencies, state and local governments, the energy industry, researchers, and interested parties through the EIA website.


EIA requests a three-year clearance for Form EIA-112, Residential Utility Disconnections. EIA-112 is an annual form that will collect 12 months of data from electric and natural gas providers about final termination notices sent to residential customers due to bill nonpayment, service disconnections of residential customers due to bill nonpayment, and service reconnections of residential customers who were disconnected due to bill nonpayment.

Collecting this data will meet a demand for national data on utility disconnections. Some states collect some of the data described above, but the data is inconsistent. The survey aims 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.

A.1. Legal Justification  


The authority for this information collection is provided by the following general provisions:  

  1. Title 15 U.S.C. 772(b), of the Federal Energy Administration Act of 1974 (FEA Act), Public Law 93 275 authorizes mandatory collection of energy supply and consumption data by the Administrator.

  2. Title 15 U.S.C. 764(a and b) establishes the Administrator's powers to plan, direct, and conduct mandatory and voluntary energy programs related to the production, conservation, use, control, distribution, rationing, and allocation of all forms of energy that are designed and implemented in a fair and efficient manner, including duties to collect, evaluate, assemble, and analyze energy information on reserves, production, demand, and related economic data and work with business, labor, consumer and other interests and obtain their cooperation.

  3. Title 15 U.S.C. 790(a) establishes a National Energy Information System that is the enclave containing energy information collected by EIA as required to provide a description of and facilitate analysis of energy supply and consumption within and affecting the US on the basis of such geographic areas and economic sectors to carry out the Administration's statistical and forecasting activities to meet the needs of DOE, Congress, and the States.


A.2. Needs and Uses of Data 



2.1. Overview of Data Uses 

EIA is collecting this information in response to a direction from the Joint Explanatory Statement to the Fiscal Year 2023 budget appropriations act1, which directed EIA to conduct a monthly survey of electric and natural gas providers about final termination notices sent to residential customers due to bill nonpayment, service disconnections of residential customers due to bill nonpayment, and service reconnections of residential customers who were disconnected due to bill nonpayment. After iterative cognitive testing and a pilot study, EIA is proposing to being data collection for the EIA-112. The EIA-112 aims to better inform policymakers with authority over the Low-Income Home Energy Assistance Program (LIHEAP), previously named the Low-Income Heating Energy Assistance Program. Data from the new survey will aid in setting appropriate levels of budgetary support for LIHEAP by providing reliable metrics on the frequency of utility disconnections among energy sources and between states.

2.2 Overview of Residential Utility Disconnection Survey Data Collection

EIA data forms collect a wide range of information while seeking to minimize respondent burden and avoid duplicative data collection. The proposed form will be handled in the same manner. This will be an annual form, but the data will be collected at the monthly level for the previous 12-months. Data will be collected from the universe of respondents that provide information on electric and natural gas service.


To mitigate respondent burden, EIA will conduct a census of both electric and natural gas utilities’ disconnection data in the first year of collection and in the subsequent years, collect data from a sample of electric and natural gas utilities. Respondents that do not provide natural gas or electric retail service to residential customers will be excluded from the frame. In addition, small electric utilities (those on the EIA-861S) will be excluded from the frame. Including these companies would dramatically increase the size of the frame but contribute to limited improvement in the estimation of aggregate totals. This methodology will repeat every clearance cycle.


The data will be reported or used in new EIA products comparable to the official governmental statistics reported in the Electric Power Monthly and supporting utility-level web files, including:

  • Web reports with estimates of National and State-level Residential Utility Disconnections for both natural gas and electricity customers,

  • Excel files with utility-level detailed reports on Residential Utility Disconnections,

  • Select tables added to the Electric Power Annual and Natural Gas Annual.


Federal and State agencies that will use this survey include:

  • State Public Utility Commissions, for comparing data reported from their utilities to national averages,

  • Low Income Home Energy Assistance Program (LIHEAP) at the Department of Health and Human Services, for understanding funding requirements for state-level programs.


A.3. Use of Technology 

Form EIA-112 will use Computer-Assisted Web Interviews (CAWI), or web surveys, as the primary means of data collection. The majority of contact with respondents (e.g., notification that a survey has opened for a collection cycle) is done by email.  

CAWI allow respondents to enter their data directly into the EIA survey databases, which reduces the time needed for data collection and processing. The systems identify reported data that fail edit specifications prior to submission, which allow respondents to make necessary corrections or explain unusual situations affecting the reported data. This process aids in detecting and minimizing response errors, data validation procedures are used to check current data.  It also improves the timeliness of reporting the information to the public. The only equipment and software respondents require are a connection to the Internet and a standard industry web browser.  

Initial online edits that improve data collection accuracy and reduce follow up with respondents will also be included in the system and improved over time as data edits can be refined after the initial collection cycle.



A.4. Efforts to Identify Duplication

The collection and publication of this data is directly responsive to the current data gap in utility disconnections. EIA will provide a comprehensive dataset on the frequency and intensity of utility disconnections at the state level. EIA will also plan to publish the data collected at the utility level, which can inform more granular estimates than our state-level aggregate estimates. Currently, four sources are collecting some of this information, the Residential Energy Consumption Survey (RECS), the Census’ Current Population Survey (CPS), Public Utility Commissions, and the Low-Income Home Energy Program (LIHEAP). However, these data sources are not able to produce the level of information required by the language in the 2023 Appropriations Act. EIA-112 data are not duplicative of existing data because there is no public data source of comprehensive disconnection due to nonpayment.   

RECS is a quadrennial household voluntary survey that does not collect data on the number of disconnections and reconnections. The household survey is used to inform end use estimates for energy consumption, among other things. Due to the survey’s frequency in data collection, the low probability that a respondents will be disconnected at the time of the data collection, and the voluntary nature of the data collection, RECS would not provide the necessary data needed to accurately inform the public about utility disconnections and reconnections. Similarly, the CPS is used to inform population estimates and other social and economic indicators of the population within given geographic areas. The CPS is a voluntary survey using a sample of 60,000 occupied household, which will not accurately capture data on utility disconnections and reconnections on a monthly basis. We also learned from evaluating the Public Utility Commissions (PUCs) data that it was inconsistent across the States and frequently included many gaps that resulted in it not being a sufficient replacement for a primary data collection.  Data utilized in the LIHEAP is informed by these data sources, none of which purport to estimate the current level of disconnections at a state or utility service area. Additionally, data from grant recipients are useful at evaluating the effectiveness of grants but are only submitted from grant recipients, not the entire population of utilities providing natural gas and electric services. These collections are not duplicative as they are answered by different populations of respondents and are attempting to evaluate different research questions.

As stated above, EIA evaluated the PUCs data. We found that several states have PUCs that require reports on disconnections from select utilities within the state. We compared these data with those collected from a pilot study on the topic in 2023 and found substantial differences in most states. Some states collect natural gas and electricity disconnections separately; some collect only the total number of accounts disconnected. Because a joint service disconnection could be counted either as a single disconnection or as two disconnections (one of natural gas and one of electricity), any state used in a blended data product must use the same convention as the federal collection. Although these partial data collections exist, their inconsistent format makes direct comparison difficult to impossible.

Currently Iowa and the District of Columbia are the only regions that collect identical information to the EIA-112, but even in those cases, observed differences between the state data and the pilot data necessitate further investigation. Below is a table that displays the coverage and frequency of utility commission data by state.

Table 1. Coverage and Frequency of PUC Data by State 

Note: Coverages are based on reports for the month of October 2023. All regions listed had current information available as of May 2024, except for Ohio, where the most recent data (May 2023) was used instead. 

We investigated which of these state reports, if any, could serve as an alternative to an independent federal collection designed to provide a national accounting of disconnections, reconnections, and final notices. We have discovered inconsistencies in reporting conventions, frequency, time lag, comprehensiveness, and sector specification (Table 2). 

Table 2. Item Coverage of PUC Data by State 

Region 

Electricity and Natural Gas Reported Separately Y/N 

Sector 

Disconnects 

Reconnects 

Final Notices 




CA 

N 

Residential 

Yes, but may be “currently experiencing disconnection” instead of “disconnected during month” 

Yes 

Gives 15-day and 48-hour notices, not clear if final 


DC 

NA 

Residential 

Yes 

Yes 

Yes 


CO 

Y 

Residential 

Yes 

Sometimes 

No 


GA 

NA 

Residential 

Yes 

Sometimes 

Sometimes 


HI 

NA 

Residential 

Yes 

No 

No 


IA 

Y 

Residential 

Yes 

Yes 

Yes 


IN 

N 

Residential 

Yes 

Yes, not for small companies 

Yes, not for small companies 


MA 

Y 

Residential 

Yes 

Yes 

Sometimes 


MD 

N 

Residential 

Yes 

Yes 

Yes 


MI 

Y 

Residential 

“Currently experiencing” instead of “disconnected during month” 

Yes 

Yes 


MN 

N 

Residential 

Yes 

Yes 

Yes 


NC 

Y 

Residential 

Yes 

No 

No 


ND 

N 

Residential 

Yes 

No 

No 


NY 

N 

Residential 

Yes 

Yes 

Yes 


OH 

Y 

Residential 

Yes 

Yes 

Yes 


OR 

NA 

Residential 

Yes 

Yes, but only within 7 days 

No 


SC 

N 

Residential 

Yes 

Sometimes 

No 


UT 

NA 

Unspecified 

Yes 

No 

Yes 


VT 

NA 

Unspecified 

Yes 

Yes, but only within 15 days 

Yes 


WA 

N 

Residential 

Yes, doesn’t specify nonpayment. 

Sometimes 

Sometimes 


 

 

Note: Coverages are based on reports for the month of October 2023. All regions listed had current information available as of May 2024, except for Ohio, where the most recent data (May 2023) was used instead. NA = Not Applicable due to only single service utilities reporting. 


Some states collect the information monthly, and others collect it quarterly or annually. Our review of state utility websites identified 11 states (and Washington, DC, for a total of 12 regions) as currently requiring monthly reports, and we found an additional 8 states that require quarterly or annual submissions. No PUC data are available for the remaining 31 states. To provide further insight into the potential suitability of these data, the values reported to EIA in the pilot survey were compared to those reported to the states for the handful of entities that happened to report to both collections. After review, differences in reporting conventions did not appear to be the cause of these discrepancies. Even though many of these regions provide a joint disconnection number while the pilot split disconnections out between electricity and natural gas, the companies reporting were typically single service. These data are displayed in Table 3.

 

Table 3. Discrepancies Between Pilot Survey Data and PUC Data by State 

Region 

Disconnections 

Reconnections 

Final Notices 

Notes 

 


NY 

>20% 

>20% 

>20% 

The large difference may be a reporting error by a single company. Other companies provide comparable reports. 



DC 

>20% 

>20% 

2% 

Comparison based on a single company. Would need follow up to understand the difference. 



MN 

>20% 

4% 

0% 

Comparison based on a single company. Would need follow up to understand the difference. 



MI 

>20% 

9% 

6 

Comparison based on a single company. Would need follow up to understand the difference, but likely due in part to difference in “Currently Experiencing Disconnection” versus “Disconnected in Month” report conventions. 



WA 

>20% 

>20% 

15% 

There were three companies in common; one provided a report that didn’t match. Would need follow up to understand the difference. 



IN 

4% 

>20% 

>20% 

Comparison based on a single company. Would need follow up to understand the difference. 



MD 

4% 

2% 

13% 

Comparison based on two companies; neither gave the same responses. Would need follow up to understand the difference. 



VT 

1% 

1% 

1% 

  



UT 

1% 

.     

1% 

  



IA 

0% 

2% 

4% 

Comparison based on two companies; notices reported differed for both of them. Would need follow up to understand the difference. 



CA 

0% 

0% 

0% 

  




A.5. Provisions for Reducing Burden on Small Businesses

The burden on smaller entities across surveys is reduced through a number of means including the use of cutoff sampling for monthly surveys, the exclusion of respondents on Form EIA-861S Annual Electric Power Industry Report (Short Form), and the use of Computer-Assisted Web Interviews (CAWI). Cutoff sampling on the monthly Forms EIA-861M Monthly Electric Power Industry Report and EIA-857 Monthly Report of Natural Gas Purchases and Deliveries to Consumers, obviates the need for many small entities to fill out the Form-112 outside of the initial census; they need only submit one form in the initial census year of the survey.

In addition, the annual Form EIA-861S (short form) was developed for the use of very small respondents that represent approximately one-half of the frame of the Form EIA-861 Annual Electric Power Industry Report, but only 2 percent of national retail sales. Electric utilities that file the Form-861S will be excluded from the frame of the Form EIA-112 as their inclusion significantly increases respondent burden but does little to improve the overall estimation procedure.  The pilot study also demonstrated some smaller electric utilities had differing records management practices and difficulty identifying residential only customers. 

Through CAWI, EIA uses dependent interviewing (pre-population) for many data elements for items that do not frequently change. This allows respondents (both large and small) to simply verify that the information has not changed, as opposed to entering the same information for each survey cycle. In addition, the CAWI system uses built-in edits has reduced the burden on businesses by reducing the call-backs to verify or correct questionable data.



A.6. Consequences of Less-Frequent Reporting

EIA plans to collect data annually, but the data will be reported at the monthly level. EIA planned to collect data on a monthly basis as specified in the pilot study. However, based on the results of both cognitive testing and the pilot test, EIA found conducting EIA-112 on annual basis would reduce the burden to respondents, while still collecting timely and relevant information for data users.

This balances the granular needs of the data users against the burden of more frequent reporting. Collecting the data less frequently than once a year would significantly delay the speed with which EIA can produce national and state-level estimates.

Policymakers and programs such as LIHEAP need data reported at the monthly level on a yearly basis to ensure accuracy in the program. Data reported less frequently would be less useful for these programs.

A.7. Compliance with 5 CFR 1320.5

The data for the collection instruments in this proposal are being collected consistent with the guidelines in 5 C.F.R. 1320.5.

A.8. Summary of Consultations Outside of the Agency

EIA staff conducted iterative cognitive testing and a pilot study in preparation for the EIA-112, and to increase their understanding of the current available data regarding utility disconnections.

First Round of Cognitive Interviews

Cognitive interviews were conducted with a sample of electric-only, natural gas-only, and dual-service utilities that are on the EIA-861M and/or EIA-857 sample frames. The interviews were both virtual and moderated via Microsoft Teams, and the online and unmoderated via Qualtrics. The moderated cognitive interviews were completed between April 21 to May 24, 2023. The unmoderated interviews were completed between May 31st and June 23rd, 2023. A total of 67 electric and natural gas utilities fully or partially participated in the interviews.

The cognitive interviews showed that a majority of responding electric and natural gas utilities said they can report the requested information as currently specified: monthly aggregate counts of residential (including multifamily) customer final notifications, disconnections, and reconnections due to bill nonpayment. A minority of the responding utilities said they cannot report or would have difficulties reporting one or more aspects of the requested information. Most of the responding utilities that cannot report or have difficulties reporting the information as requested can partially report some information, such as aggregate counts for all customers combined (not just residential), all services combined (electric and gas instead of each separately), all reasons combined (not just for bill nonpayment), and/or for only one or two of the requested records (disconnections and reconnections but not notifications, etc.). Furthermore, most of these respondents tended to be smaller in size (in terms of the number of residential customers) and many were also municipal and co-op utilities.

Pilot Study

After the first round of cognitive interviews, a pilot study was designed to collect data related to:

  • Final termination notices sent to residential customers due to bill nonpayment,

  • Service disconnections of residential customers due to bill nonpayment,

  • Service reconnections of residential customers who were disconnected due to bill nonpayment.

The target population was electric, natural gas, and dual-service utilities that serve residential customers, including multifamily buildings. The pilot survey was designed as a webform and provided a spreadsheet submission option. Data collection for the pilot study began on November 1, 2023. The reference period for this survey is October 2023.



The pilot study found that most utilities appear to be able to report this data without difficulty. In terms of difficulty, over half of respondents (52%) found it “very easy” or “somewhat easy,” and 73% of respondents said that completing the survey was either easy or neutral. Even respondents that reported difficulty were able to provide some but not all data as requested. For example, some dual-fuel utilities that provide both electricity and natural gas, found it difficult to separate the data by energy type.   In addition, some smaller utilities found it difficult to exclude non-residential customers from the data they could report.

Second Round of Pretesting Initiatives

EIA conducted additional exploratory unmoderated online interviews with a sample of utilities to follow-up on outstanding questions identified during the pilot study, such as the timing of utility final notices and disconnections, disconnection moratoriums, and the proper question wording for asking about customer disconnections. The exploratory unmoderated online interviews were conducted using Qualtrics in the summer of 2024. A sample of 152 electric, natural gas, and dual-service utilities that responded to the 2023 pilot survey were asked to participate in an interview, and 42 utilities partially or fully completed an interview for a response rate of 29.6% (AAPOR RR6).2

The findings demonstrate that most respondents send final notices to residential customers within a month of nonpayment, and most of these respondents send the notices within two weeks of nonpayment. Furthermore, the amount of time between respondents’ residential customer nonpayment and final notices, between final notices and disconnections, and between disconnections and reconnections should be sufficient for collecting information about each but they may occur in the same or different months due to the timeframes and billing cycles (e.g., a final notice, disconnection, and reconnection could occur in one month or over the course of three or more months). The results also showed that most respondents have customer disconnection moratoriums, and most moratoriums are based on temperatures or occur on single days or weekends instead of a longer timeframe like winter or summer. Lastly, most respondents understood the request for residential customer disconnections to include only the customers whose disconnection occurred during the month they are reporting for.  



60 Day Federal Register Notice

EIA published a 60-day Federal Register Notice at 89 Fed. Reg. 119 (June 20, 2024) announcing the new EIA-112 Residential Utility Disconnections Survey (RUDS). In response, EIA received 70 substantive comments from the public, 67 supporting the survey and 3 opposed.

The supporting comments came from three groups, the general public, advocacy groups and state or federal officials. The most common type of comment came from the public, they were in favor of the survey and did not ask for any additional questions, there were 35 in total. The remaining 32 comments wanted more data collected from the utilities. Twenty-three commentors wanted smaller geographic data such as zip codes or census tract data to be collected. There were also requests for more information on arrearages (debt), disconnection lengths, alternate payment plans and more demographic and economic data about customers.

EIA addressed these comments and explained why the current questions were the ones that will be used for this clearance. The pretesting and pilot study showed that finer gradation of geographic data would be overly burdensome to many utilities. The additional data requested would also be too burdensome for utilities or was not tested during this round of pretesting.

There were 3 comments from utility trade groups that were opposed to approving this survey. They expressed concerns over burden, duplicative data collection and misinterpretation of the data. Pretesting was used to help determine the amount of burden that would be imposed on utilities and very small electric utilities that filed the EIA-861S were excluded from the frame. Currently there is no repository of comprehensive disconnection data for every state, therefore there is no duplication of effort. While additional questions would have enhanced the value of the data collected, there needed to be a balance between too much burden on the utilities and the need for much more granular data.

A.9. Payments or Gifts to Respondents

Respondents to this proposed information collection will not receive any payments or gifts from EIA for their mandatory participation.



A.10. Provisions for Protection of Information  

The information reported on Form EIA-112 will be considered public information and may be publicly released in identifiable form.  



A.11. Justification for Sensitive Questions  

There are no questions of a sensitive nature. 

 

A.12. Estimate of Respondent Burden Hours and Cost  

The overall annual burden for this package is estimated to be 2,260 burden hours (see Table A1 below). The burden estimates are annualized over the three years. Table A1 shows an annualized estimated burden for the survey form.

Based on the pilot study and pretesting results, EIA determined that respondents would take on average 2 hours to complete and submit EIA-112.

A1. Annual Estimated Burden

EIA Form Number/Title

Annual Reporting Frequency

Number of Respondents

Annual Number of Responses

Burden Hours Per Response

Annual Burden Hours

EIA‐112 – Residential Utility Disconnections Survey

1

1,130

1,130

2 hours

2,260





Respondent cost

Based on the estimated rate of $91.16 per hour for respondents who complete EIA-112, the total annual respondent cost for all forms is estimated to be:

$91.16/hour x 2,260 hours/year = $ 206,021.60/year

The fully burdened hourly wage rate is calculated based on a weighted average of EIA management and staff full benefit salary.

Table A2: Average Hourly Loaded Cost of an EIA Employee, Fiscal year 2024

As of 2/05/2024

Number of Employees

Average Annual Salary

Average Benefit Percentage

Average Benefit Costs

Total Average Salary and Benefits

Average Hourly Loaded Cost

Administrative/ Professional (GS)

319

$145,911

25.98%

$37,908

$183,819

$88.37

Executive (EJ, ES, EX, SL)

25

$209,214

25.98%

$54,354

$263,567

$126.72

All EIA Employees

344

$150,512

25.98%

$39,103

$189,615

$91.16



A.13. Annual Cost to the Federal Government

The annual cost of operating EIA-112 is estimated at $749,032 and includes program start-up costs, contractor costs, and federal staff time for survey related activities. The survey related activities include frame maintenance, data collection and nonresponse follow-up, data processing and data quality, data dissemination, and data systems maintenance. EIA anticipates no additional respondent costs for generating, maintaining, and providing the information required in this Information Collection Request.





A.14. Changes in Burden

There are no changes, this is a new survey (see Table A.3).

Table A3 Changes in Burden




EIA Form Number/Title



Annual Reporting Frequency


Number of Respondents (Previously Approved)



Number of Respondents (Requested)

Annual Number of Responses (Previously Approved)


Annual Number of Responses (Requested)


Burden Hours Per Response (Previously Approved)



Burden Hours Per Response (Requested)


Annual Burden Hours (Previously Approved)



Annual Burden Hours (Requested)

Annual Number of Responses

Annual Burden Hours


Change Due to Agency Discretion

Change Due to Adjustment in Agency Estimate



Adjustment


Change Due to Agency Discretion

Change Due to Adjustment in Agency Estimate



Adjustment

EIA-112 – Residential Utility Reconnections Survey

1

New

1,130

New

1,130

New

2

New

2,260

0

1,130

0

0

2,260

0

TOTAL


New

1,130

New

1,130



New

2,260

0

1,130

0

0

2,260

0



A.15. Reasons for Changes in Burden

There are no changes, this is a new survey being implemented.

A.16. Collection, Tabulation, and Publication Plans

The data collected on this form will be released in EIA reports and will be made available on the EIA website.  



A.17. OMB Number and Expiration Date

The OMB number and expiration date will be displayed on each form.



A.18. Certification Statement

There will be no exceptions to the Certification for Paperwork Reduction Act Submissions of OMB Form 83-I.

































2 AAPOR Response Rate 6 (RR6) = I+P/[(I+P) +(R+NC+O)] where I = Completes, P = Partial Completes, R = Refusals, NC = Non-Contacts, and O = Other Nonresponse Reason; https://aapor.org/wp-content/uploads/2023/05/Standards-Definitions-10th-edition.pdf

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleSupporting Statement for Residential Utility Disconnections Survey
AuthorHarnish, Marc
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