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.
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.