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Winter and COVID-19 Utility Shut-off Moratoriums

March 15, 2021

If this was a normal year, 40 states would have implemented some form of utility shutoff moratoriums during the winter months to protect customers from losing their home heating when the temperature drops. Under normal circumstances, these policies can be difficult to track since they vary between states. This year, the addition of temporary shutoff moratoriums put in place to protect customers affected by the pandemic has muddied the waters even further. As spring approaches and many winter moratoriums end, millions of utility customers are finding themselves unprotected by moratoriums for the first time in over a year. This is a list of all utility actions and state-mandated moratoriums that NEADA is aware of at the time of release. Please contact Mark Wolfe (mwolfe@neada.org) or Cass Lovejoy (clovejoy@neada.org) with questions and Elizabeth Eagles (eeagles@neada.org) with additions or updates with source documentation.

 

  1. How many people were covered by COVID moratoriums on utility shutoffs?

Over the summer and into the fall of 2020, a patchwork of states implemented temporary moratoriums to prevent shutoffs for customers affected by the pandemic. Some moratoriums were extended beyond their initial end dates to coincide with annual winter shutoff moratoriums that many states implement every year to protect customers during cold winter months. Others were allowed to expire.

Table 1. Population covered by COVID-19 moratoriums, Jul. – Oct. 2020

  31-Jul 31-Aug 30-Sep 31-Oct
Population covered 184,944,156 155,527,034 138,112,481 131,102,944
% of U.S. covered 56% 48% 42% 40%

 

  1. Projected population covered by utility moratoriums January 31 – April 30, 2021

The number of people protected from utility shutoffs is projected to decrease as annual winter moratoriums begin to expire in March and April of 2021. There are three types of state moratoriums currently at play: 1) emergency COVID-19 moratoriums that were first implemented in the spring and summer, 2) annual date-based winter moratoriums that cover all customers for a set period of time, and 3) temperature-based winter moratoriums, which only prevent utility shut-offs when the temperature drops below a certain threshold. Table 2 shows the actual and projected number of people covered by COVID-19/date-based winter moratoriums. We have combined these because they provide guaranteed coverage for a set time period. Table 3 shows the actual and projected number of people covered by temperature-based winter moratoriums, which only provide temporary protection during cold snaps.

Table 2. Projected population covered by COVID-19/date-based utility moratoriums, January – April 2021

  31-Jan (actual) 28-Feb (actual) 31-Mar (projected) 30-Apr (projected)
Population covered 185,786,993 185,786,993 174,061,751 107,094,655
% of U.S. covered 57% 57% 53% 33%

 

Table 3. Projected population covered by temperature-based utility moratoriums, January – April 2021

  31-Jan (actual) 28-Feb (actual) 31-Mar (projected) 30-Apr (projected)
Population covered 104,354,835 104,354,835 93,737,412 51,665,872
% of U.S. covered 32% 32% 29% 16%

 

  1. Active Moratoriums

 The intersection of COVID and annual winter moratoriums complicates matters significantly. Some states that had COVID moratoriums in place extended them until winter date-based moratoriums went into effect. Others let theirs lapse for a month or more before winter set in. Some states that would normally have temperature-based moratoriums are still operating under COVID shutoff bans that protect customers regardless of the weather. And then there are states that do not normally have an annual winter shutoff moratorium, some of which have ongoing COVID moratoriums, while others either never had any or let them expire. A full list of COVID and winter shutoff moratoriums, including start and end dates, can be found at the bottom of the page.

Type of moratorium Count States
No active COVID-19 or winter moratorium 11 Alaska, Florida, Georgia, Idaho, Indiana, Kentucky, Louisiana, North Dakota, Oregon, Utah, West Virginia
Active annual winter moratorium (no additional COVID protection) 10 Alabama+, Arizona+, Michigan, Minnesota, Missouri+, Nebraska, Nevada+, Oklahoma+, South Dakota, Wyoming+
Moratoriums that will expire between March and July of 2021 27 Arkansas, California, Colorado, Connecticut, Delaware+, Hawaii, Illinois*+, Iowa*+, Kansas*+, Maine, Maryland+, Massachusetts, Mississippi*, Montana*+, New Hampshire*, New Jersey*, New Mexico, North Carolina*, Ohio*, Pennsylvania*, Rhode Island*, South Carolina+, Tennessee+, Texas+, Vermont, Washington, Wisconsin
Indefinite COVID moratoriums 3 DC, New York, Virginia
+ States that only have temperature-based winter moratoriums.
*States with an unprotected gap between COVID-19 moratoriums and winter moratoriums.

 

When do COVID-19 and winter utility moratoriums start and end in each state?

  COVID-19 Start Date COVID-19 End Date Winter Start Date Winter End Date Temperature-based?
Alabama         ≤32° F
Alaska 4/9/20 11/15/20      
Arizona         ≤32° F
Arkansas 4/10/20 5/3/21 11/1/20 3/31/21 ≤32° F
California 3/16/20 6/30/21      
Colorado 3/20/20 6/12/21      
Connecticut 3/12/20 10/31/20 11/1/20 5/1/21  
Delaware 3/24/20 11/1/20 11/15/20 4/15/21 ≤20° F
DC 3/17/20 15 days after emergency     ≤32° F
Florida          
Georgia     11/15/20 3/15/21 ≤32° F
Hawaii 3/27/20 3/31/21      
Idaho     12/1/20 2/28/21  
Illinois 3/18/20 8/1/20 12/1/20 3/31/21 ≤32° F
Indiana 3/19/20 8/14/20 (protections till 10/14/20) 12/1/20 3/15/21  
Iowa 3/13/20 7/1/20 11/1/20 4/1/21 ≤20° F
Kansas 3/16/20 5/31/20 11/1/20 3/31/21 ≤35° F
Kentucky 3/16/20 11/6/20      
Louisiana 3/13/20 7/16/20      
Maine 3/16/20 11/1/20 11/15/20 4/15/21  
Maryland 3/16/20 11/15/20 11/1/20 3/31/21 If 72 hr. forecast is ≤32° F
Massachusetts 3/13/20 7/1/21 11/15/20 3/15/21  
Michigan     11/1/20 3/31/21  
Minnesota     10/15/20 4/15/21  
Mississippi 3/15/20 6/14/20 12/1/20 3/31/21  
Missouri     11/1/20 3/31/21 ≤32° F
Montana 3/30/20 6/30/20 11/1/20 4/1/21 ≤32° F at 8am or in forecast
Nebraska     11/1/20 3/31/21  
Nevada         ≤20° F
New Hampshire 3/17/20 7/15/20 11/15/20 3/31/21  
New Jersey 10/15/20 6/30/21 11/15/20 3/15/21  
New Mexico 3/19/20 Large IOUs (>100,00 meters) under moratorium until 5/14/21 followed by 90-day transition period. Water utilities and smaller gas and electric under moratorium until 3/20/21 with 45-day transition period. 11/15/20 3/15/21  
New York 3/13/20 180 days after emergency or 3/31/21 11/1/20  4/15/21 <32° F
North Carolina 3/31/20 8/31/20 11/1/20 3/31/21  
North Dakota          
Ohio 3/13/20 4/1/20 10/20/20 4/15/21  
Oklahoma     11/15/20 4/15/21 ≤32° F day, ≤20° F night
Oregon          
Pennsylvania 3/13/20 11/9/20 if above 300% FPL 12/1/20 3/31/21  
Rhode Island 3/17/20 7/17/20 (11/1/20*) 11/1/20 4/30/21  
South Carolina 3/16/20 5/15/20 12/1/20 3/31/21 Forecast ≤32° F for 45 hrs.
South Dakota     11/1/20 3/31/21  
Tennessee 3/31/30 8/29/20     <32° F
Texas 3/26/20 8/31/20, (9/30/20*)     ≤32° F
Utah     11/15/20 3/15/21  
Vermont 3/18/20 Ended 10/15/20, then on 12/22/20, was extended through 3/31/21 11/1/20 3/31/21 ≤10° F, ≤32° F for elderly
Virginia 3/16/20 Ended 10/5/20, then on 11/18/20, was extended until 60 days after emergency      
Washington 3/19/20 7/31/21 11/1/20 3/31/21  
West Virginia          
Wisconsin 3/13/20 11/1/20 11/1/20 4/15/21  
Wyoming 11/1/20 4/30/21 ≤32° F
*Extended moratorium for qualified low-income customers

 Note: the above table is only meant to provide a generalized summary of temperature-based moratoriums, which in some states, have a number of caveats and further age/income restrictions. For a comprehensive list of temperature-based moratoriums, visit https://liheapch.acf.hhs.gov/Disconnect/SeasonalDisconnect.htm

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