The FERC Information Collection Request, titled "Reporting of Natural Gas Sales to the California Market," is approved through 1/31/02. Should FERC decide to resubmit the ICR for renewal, it must address the practical utility and burden issues described below. FERC should include an explicit discussion of the way in which it addresses these issues as part of its supporting statement. (1) Practical Utility: The order requires detailed transaction information on gas sales to California -- that is, a daily reporting of price and quantity for each component of gas sold to the California market. Several commenters have reported that they do not maintain the data in a way that allows them to disaggregate price/quantity information in this way. Based on the comments, we are concerned that this data collection would require significant data manipulation by the industry in order to responsd to the request. The resulting disaggregation is likely to be articifial -- and therefore not reliable for individual transactions -- and respondents are likely to vary in their choice of method for disaggregating transactions. Further, FERC indicates in the Order (RM01-9-000) that "the Commission is seeking information here to understand the operation of the market for gas sales into California, not to investigate the conduct of particular participants in that market.... In these circumstances, the Commission concludes that the publication of aggregated information is sufficient to accomplish the purposes for which the Commission is seeking the information." Given the potential data quality problems associated with disaggregated reporting and the questionable need for the disaggregated data, we are concerned that such data may have little practical utility. Should FERC decide to resubmit the ICR for renewal, it should justify its decision to continue to require reporting at a disaggregated level. 2) Burden: Commenters also believe FERC has significantly underestimated the burden. In particular, the commenters indicated that they would likly have to hire additional staff in order to respond to the data request because of the significant manipulation required to provide data in the format FERC is requesting. After consulting with respondents, FERC should evaluate its burden estimates for reporting and recordkeeping requirements. FERC should provide a list of the names, affiliations, and phone numbers of the respondents it contacted. Finally, the ICR currently pending covers final reporting requirements that FERC initially proposed in a May 18, 2001 draft order. FERC did not submit an ICR to OMB for the proposed reporting requiremetns in the May order; instead FERC submitted a request for emergency processing at the end of July, after taking final action on the Order. FERC should make efforts to ensure that future information collections are conducted in a manner consistent with the Paperwork_Reduction Act and the procedures outlined in 5 CFR 1320.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
02/28/2002
02/28/2002
534
0
0
19,847
0
0
0
0
0
FERC 721 data will be used by FERC to monitor natural gas prices in California. In particular, FERC wants to understand why the disparity in the price of natural gas has occurred in California and continued to exist while other markets including those that are supplied by the same producing areas have experiencedd a decline in prices. The information will assist FERC to determine what percentage of volumes sold into the California Market is domestically produced gas sold by marketers affiliated with pipelines and Local Distribution Companies in sales for resale, which are the only sales of gas now being made that the ...
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Reporting of Natural Gas Sales to the California Market