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Extensive Comments Filed in Utility Termination Procedures And Payment Arrangement Rulemaking
On August 28, 2026 parties filed comments in the Pennsylvania PUC Notice of Proposed Rulemaking to update Chapter 56 residential utility service regulations following the expiration of Chapter 14 of the Public Utility Code on December 31, 2024.
As background, Chapter 14 previously governed key aspects of utility billing, collections, terminations, and payment arrangements. More specifically, Chapter 14 aimed to prevent customers who are able to pay their utility bills from delaying payment and to help utilities reduce uncollectible accounts by revising delinquent collection procedures.
Overview of Comments Filed:
EAP supports the PAPUC’s EAP argues that reinstating these longstanding provisions will provide regulatory certainty, preserve utilities’ ability to collect unpaid bills, reduce uncollectible accounts, and protect ratepayers from higher costs. EAP strongly urges the Pennsylvania Commission to keep the rulemaking narrow and avoid reopening settled Chapter 56 collection procedures, warning that broader changes could increase arrearages, administrative burdens, and regulatory uncertainty. EAP specifically supports adding the former definitions of change in income and significant change in circumstances and codifying the longstanding payment-arrangement procedures in proposed Section 56.182. EAP also raises concern about the proposed prohibition on surcharges for uncollectible expenses, recommending that the PUC retain flexibility to use appropriate rate mechanisms if regulatory changes lead to increased arrearages.
PGW supports the PAPUC’s proposal to incorporate the former Chapter 14 utility customer protection provisions into 52 Pa. Code Chapter 56, following Chapter 14’s expiration in December 2024. PGW argues that the provisions have provided a predictable and consistent framework for utility termination procedures and payment arrangements for decades, and that maintaining them will protect responsible ratepayers by limiting uncollectible accounts and unnecessary costs. PGW supports the PAPUC’s narrow approach of reinstating the former requirements without making broader changes to Chapter 56, stating that this provides clarity for both customers and utilities while preserving safe, reliable service at reasonable rates. PPL supports incorporating expired Chapter 14 provisions into Chapter 56, including payment arrangements, assistance-program referrals, and payment of undisputed bills.
PPL seeks clearer standards for qualifying financial hardships, opposes fines for accounts over $10,000 and restrictions on uncollectible cost recovery, and recommends an informal complaint-resolution process and eliminating the same-day personal-contact requirement before termination.
UGI supports the PAPUC’s proposal to reenact the former Chapter 14 consumer protections in Chapter 56 without material changes. UGI states that these longstanding provisions provide utilities and customers with greater certainty regarding payment and collection practices and serve the public interest.
Duquesne Light supports the PAPUC’s proposal to codify former Chapter 14 provisions into Chapter 56, emphasizing regulatory certainty and consistent payment and collection practices. Duquesne Light supports clear payment-arrangement rules but cautions against excessively long plans. Duquesne Light also urges the PAPUC to later conduct a broader review of Chapter 56 to modernize outdated requirements, including greater use of electronic communications and smart-meter technology to reduce field activity, costs, and worker-safety risks.
Columbia Gas supports incorporating the former Chapter 14 provisions into Chapter 56 but objects to two proposed changes. Columbia Gas opposes requiring customers to pay only subsequent bills they do not dispute, arguing this could allow customers to repeatedly dispute bills, delay termination, and accumulate large uncollectible balances. Columbia Gas instead proposes that charges incurred during a complaint remain payable, subject to refunds if later found incorrect. Columbia Gas also opposes new language requiring utilities to waive improperly assessed late fees because existing Chapter 56 provisions already address these charges.
OSBA urged the PAPUC to expand Chapter 56 protections to small commercial businesses, arguing that the existing rules are primarily focused on residential customers and do not adequately address the financial and operational impacts of utility billing problems or service termination on small businesses. OSBA also recommends longer payment arrangements, regular and predictable billing, stronger protections against termination, and medical-emergency safeguards. In addition, OSBA proposes requiring utilities to separately report data on small commercial business accounts, including deposits, arrearages, payment arrangements, terminations, and reconnections, so the PAPUC can evaluate whether the protections are effective while maintaining customer confidentiality.
The Joint Commenters for Utility Access urge the PAPUC to significantly strengthen Chapter 56 rather than simply carry forward provisions of the former Chapter 14. The Joint Commenters for Utility Access argue that Chapter 14 contributed to record utility shutoffs without improving collections and recommend a prevention-based approach focused on affordable payment arrangements, including limiting monthly installments to 20% of a household’s average bill, providing longer repayment periods, allowing additional arrangements based on individual circumstances, and ensuring low-income customers can access payment plans and assistance programs. The he Joint Commenters for Utility Access also seek stronger protections for medically vulnerable customers, including a 7-day grace period for medical certificates, 90-day standard protection, 6-month chronic-illness certifications, and allowing registered nurses to certify medical conditions. In addition, they support a summer termination moratorium, elimination or reduction of deposits and punitive late/reconnection fees for low and moderate-income households, and expanded protections for domestic-violence survivors through a simplified self-certification process.
The Joint Comments of Pennsylvania Ratepayers urge the Pennsylvania Public Utility Commission to strengthen proposed Chapter 56 amendments to make utility billing, collection, and termination protections more practical for households facing high energy and water costs. The Joint Comments of Pennsylvania Ratepayers also emphasize making utility bills and assistance programs easier to understand and access, with the goal of helping customers resolve payment problems before they become crises and preventing avoidable service terminations.
