SS-PartA-PM-10-26-2006

Supporting Statement for
Energy Information Administration
Petroleum Marketing Surveys
OMB# 1905-0174
Forms EIA-14, 182, 782A/B/C, 821, 856, 863, 877, 878, and 888
Introduction
In order to fulfill its responsibilities under the Federal Energy Administration Act of 1974
(P. L. 93-275) and the Department of Energy (DOE) Organization Act (P. L. 95-91), the
Energy Information Administration (EIA) is obliged to publish, and otherwise make
available to the public, high-quality statistical data that accurately reflect national and
regional petroleum marketing activities.
To meet this responsibility, as well as internal DOE requirements that are dependent on
accurate data, the EIA conducts statistical surveys that encompass major petroleum
marketing activities in the United States.
In keeping with its mandated responsibilities, EIA proposes to extend the petroleum
marketing data collection forms listed below for 3 years through December 31, 2009:
Form EIA-14, “Refiners’ Monthly Cost Report,”
Form EIA-182, “Domestic Crude Oil First Purchase Report (monthly),”
Form EIA-782A, “Refiners’/Gas Plant Operators’ Monthly Petroleum Product Sales
Report,”
Form EIA-782B, “Resellers’/Retailers’ Monthly Petroleum Product Sales Report,”
Form EIA-782C, “Monthly Report of Prime Supplier Sales of Petroleum Products Sold
for Local Consumption,”
Form EIA-821, “Annual Fuel Oil and Kerosene Sales Report,”
Form EIA-856, “Monthly Foreign Crude Oil Acquisition Report,”
Form EIA-863, “Petroleum Products Sales Identification Survey (quadrennial),”
Form EIA-877, “Winter Heating Fuels Telephone Survey (weekly October through
March),”
Form EIA-878, “Motor Gasoline Price Survey (weekly),”
Form EIA-888, “On-Highway Diesel Fuel Price Survey (weekly).”
In addition to the extension, EIA proposes revisions to:
Forms EIA-782A, “Refiners’/Gas Plant Operators’ Monthly Petroleum Product Sales
Report”,
EIA-782B, “Resellers’/Retailers Monthly Petroleum Product Sales Report,”
EIA-782C, “Monthly Report of Prime Supplier Sales of Petroleum Products Sold for
Local Consumption,”
EIA-821, “Annual Fuel Oil and Kerosene Sales Report,”
EIA-863, “Petroleum Product Sales Identification Survey,”
EIA-878, “Motor Gasoline Price Survey,”
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EIA-888, “On-Highway Diesel Fuel Price Survey”.
The changes proposed by EIA to its collection of diesel fuel statistics are to accommodate
recent changes in the industry. From 1993 until June 2006, all highway diesel fuel had
been limited to no more than 500 ppm sulfur content. Non-road, locomotive and marine
engines could still use higher sulfur diesel fuel, and heating oil had no federal sulfur
requirements. Another diesel fuel has just been added. In order to continue to reduce
harmful air emissions, EPA’s Highway Diesel Rule (40 CFR Parts 69, 80, and 86,
Control of Air Pollution From New Motor Vehicles: Heavy-Duty Engine and Vehicle
Standards and Highway Diesel Fuel Sulfur Control Requirements; Final Rule, January
18, 2001) was established. This rule required a large reduction in the sulfur content of
highway diesel fuel from 500 to 15 ppm, beginning in June 2006. The new fuel is
referred to as ultra-low sulfur diesel fuel (ULSD). However, suppliers may still provide
as much as 20 percent of their highway diesel fuel with 500 ppm sulfur until 2010, when
all highway diesel fuel must be ULSD. In addition, EPA established sulfur restrictions
for fuel used in non-road, locomotive and marine engines (40 CFR Parts 9, 69, et al.,
Control of Emissions of Air Pollution from Non-road Diesel Engines and Fuel; Final
Rule, June 29, 2004). Starting in 2007, these engines will be required to use diesel fuel
with not more than 500 ppm sulfur. In summary, diesel fuels with 15 ppm or less, greater
than15-500 ppm, and greater than 500 ppm will be in the market place until 2014, thus
will require EIA to change its forms in order to track these volumes and prices. The
survey forms are being changed to reflect the fact that the petroleum industry already has
the data available.
The information collection proposed in this supporting statement has been reviewed in
light of applicable information quality guidelines. It has been determined that the
information will be collected, maintained, and used in a manner consistent with the
OMB, DOE, and EIA information quality guidelines.
EIA will be requesting a three-year extension of approval to its petroleum marketing
surveys with the following survey changes.
1. Forms EIA-782A, “Refiners’/Gas Plant Operators’ Monthly Petroleum Product
Sales Report”, EIA-782B, “Resellers’/Retailers Monthly Petroleum Product Sales
Report,” and EIA-782C, “Monthly Report of Prime Supplier Sales of Petroleum
Products Sold for Local Consumption”
Forms EIA-782A, EIA-782B, and EIA-782C currently collect No. 2 Low Sulfur Diesel
and No. 2 High Sulfur Diesel. New regulations issued by the Environmental Protection
Agency mandate the use of lower sulfur fuels in diesel engines beginning in 2006 for
highway diesel fuel, and 2007 for nonroad diesel fuel. The regulations are posted at
http://www.epa.gov/otaq/regs/fuels/diesel/420f06033.htm. In order to measure market
conditions for this new category of diesel fuel, EIA proposes to collect Ultra-Low Sulfur
Diesel (ULSD) in addition to Low Sulfur and High Sulfur No. 2 Diesel. ULSD contains
less than or equal to 15 parts per million (ppm) sulfur. The definitions for low and high
sulfur will be converted to their equivalent parts per million, i.e. Low Sulfur No. 2 Diesel

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is greater than 15 ppm and less than or equal to 500 ppm sulfur and High Sulfur No. 2
Diesel is greater than 500 ppm sulfur.
The surveys referenced above also collect Reformulated, Oxygenated and Conventional
motor gasoline at the regular, mid-grade, and premium grades. EIA proposes to
discontinue the collection of Oxygenated motor gasoline as a separate data item, but to
include it in the collection of Conventional motor gasoline. Sales of oxygenated gasoline
have declined over the past 10 years as most of the participating cities no longer
implement winter oxygenated gasoline programs. There are only 12 areas in the U.S.
remaining out of the original 39 areas that still implement an oxygenated gasoline
program during the winter months. A list of those participating areas is shown at
http://www.epa.gov/oms/regs/fuels/420b05013.pdf . The consolidation of Oxygenated
gasoline into Conventional gasoline will also allow more data to be published because
fewer cells in published tables will need to be suppressed when applying primary and
complementary suppression rules. In addition, the change will be consistent with
petroleum supply survey changes which combined the collection of Oxygenated motor
gasoline with Conventional motor gasoline beginning in January, 2005. Maintaining
consistency across the petroleum survey forms will allow for better data comparison
across surveys.
Data on low sulfur diesel, high sulfur diesel, and Oxygenated gasoline will continue to be
collected through December 2006 reference period to complete the data series for 2006.
The new survey changes with the addition of ultra-low sulfur diesel and the consolidation
of Oxygenated motor gasoline into Conventional motor gasoline will commence with the
January 2007 reference period.

2. Form EIA-821, “Annual Fuel Oil and Kerosene Sales Report”
Form EIA-821 currently collects “No. 2 Diesel Sulfur, Low” and “No. 2 Diesel Sulfur,
High” for Commercial Use and Total On-highway Use. For the same reasons discussed
above that relate to EPA’s new ultra low-sulfur diesel regulations, a new low sulfur diesel
category will be added to Form EIA-821. For data collected in 2007 for the 2006 report
year, EIA proposes to collect “No. 2 Diesel Sulfur, Ultra Low” in addition to “No. 2
Diesel Sulfur, Low” and “No. 2 Diesel Sulfur, High” for Commercial and “No. 2 Diesel
Sulfur, Ultra Low” and “No. 2 Diesel Sulfur, Low” for On-highway Use. Currently Form
EIA-821 collects Diesel for Military and Farm Use. In the 2007 reference period EIA
proposes to split Military Diesel and Farm Diesel uses into “No. 2 Diesel Sulfur, Low”
and “No. 2 Diesel Sulfur, High.” Currently, Form EIA-821 does not breakout distillate
for Oil Company, Railroad, Vessel Bunkering, Electric Power, Off-highway
Construction, and Off-highway Other uses. For the 2007 report period, EIA proposes to
split Oil Company, Railroad, Vessel Bunkering, Electric Power, Off-highway
Construction and Off-highway Other uses into “No. 2 Diesel Sulfur, Low,” “No.2 Diesel
Sulfur, High”, and “Other Distillate.”

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3. Form EIA-863, “Petroleum Product Sales Identification Survey”
Form EIA-863 currently collects No. 2 Distillate for Residential, to all other end users, as
well as, sold to Dealers, Resellers, and Refiners, and Total. EIA proposes to report No. 2
Fuel Oil and No. 2 Diesel separately for the two sales types: for all other end users and
sold to Dealers, Resellers, and Refiners.
4. Form EIA-878, “Motor Gasoline Price Survey”
Form EIA-878 collects the retail price including tax for motor gasoline. EIA proposes
the elimination of the collection of state and local taxes as separate data items.
5. Form EIA-888, “On-Highway Diesel Fuel Price Survey”
Form EIA-888 currently collects the retail price and tax for diesel fuel. EIA proposes to
discontinue the collection of state and local taxes as separate data items. EIA proposes
that the EIA-888 collect the retail price of Ultra-Low Sulfur Diesel and Low Sulfur
Diesel fuel since both types of fuel will be sold as on-highway diesel fuel as new
regulations are implemented

A. JUSTIFICATION
1.

Legal Authority

The authorization for collecting data on the eleven Petroleum Marketing Program survey
forms is set forth in the Federal Energy Administration Act of 1974, as amended (FEAA,
Public Law 93-275). The mandate for collecting these data is in Section 13(b) of the
FEAA, 15 U.S.C. ‘772(b) which states:
“All persons owning or operating facilities or business premises who are engaged
in any phase of energy supply or major energy consumption shall make available
to the [Secretary] such information and periodic reports, records, documents, and
other data, relating to the purposes of this Act, including full identification of all
data and projections as to source, time, and methodology of development, as the
[Secretary] may prescribe by regulation or order as necessary or appropriate for
the proper exercise of functions under this Act.”
The data provided by means of the forms will assist the Secretary to carry out the
functions and duties described in Section 5(b) of the FEAA, 15 U.S.C. ‘764(b), which
states that the Administrator of the FEA (now the Secretary of DOE) shall(1)

advise the President and the Congress with respect to the establishment of
a comprehensive national energy policy in relation to the energy matters
for which the [Secretary] has responsibility, and, in coordination with the

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Secretary of State, the integration of domestic and foreign policies relating
to energy resource management;
(2)

assess the adequacy of energy resources to meet demands in the
immediate and longer range future for all sectors of the economy and the
general public;

(3)

develop effective arrangements for the participation of State and local
governments in the resolution of energy problems;...

(9)

collect, evaluate, assemble, and analyze energy information on reserves,
production, demand, and related economic data;... and

(12)

perform such other functions as may be prescribed by law.

As the authority for invoking Section 5(b) above, Section 5(a) of the FEAA, 15 U.S.C.
‘764(a), states:
Subject to the provisions and procedures set forth in this Act, the [Secretary] shall
be responsible for such actions as are taken to assure that adequate provision is
made to meet the energy needs of the Nation. To that end, he shall make such
plans and direct and conduct such programs related to the production,
conservation, use, control, distribution, rationing, and allocation of all forms of
energy as are appropriate in connection with only those authorities or functions(1)

specifically transferred to or vested in him by or pursuant to this Act; ....

(3)

otherwise specifically vested in the [Secretary] by the Congress.

Authority for invoking Section 5(a) of the FEAA in turn is conferred by Section 52 of the
FEAA, 15 U.S.C. ‘790a, which states:
(a)

It shall be the duty of the Director to establish a National Energy
Information System (hereinafter referred to in this Act as the "System") ...
[which] shall contain such information as is required to provide a
description of and facilitate analysis of energy supply and consumption
within and affecting the United States on the basis of such geographic
areas and economic sectors as may be appropriate to meet adequately the
needs of-(1)

the [Department of Energy] in carrying out its lawful functions;

(2)

the Congress;

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(b)

(3)

other officers and employees of the United States in whom have
been vested, or to whom have been delegated energy-related policy
decision-making responsibilities; and

(4)

the States to the extent required by the Natural Gas Act and the
Federal Power Act.

At a minimum, the System shall contain such energy information as is
necessary to carry out the Administration's statistical and forecasting
activities, and shall include, at the earliest date and to the maximum extent
practical subject to the resources available and the Director's ordering of
those resources to meet the responsibilities of his Office, such energy
information as is required to define and permit analysis of(1)

the institutional structure of the energy supply system including
patterns of ownership and control of mineral fuel and non-mineral
energy resources and the production, distribution, and marketing of
mineral fuels and electricity;

(2)

the consumption of mineral fuels, non-mineral energy resources,
and electricity by such classes, sectors, and regions as may be
appropriate for the purposes of this Act;...

(5)

industrial, labor, and regional impacts of changes in patterns of
energy supply and consumption;

(6)

international aspects, economic and otherwise, of the evolving
energy situation; and

(7)

long-term relationships between energy supply and consumption in
the United States and world communities.

In addition, these surveys partially satisfy the requirements of Section 507 of Part A of
Title V of the Energy Policy and Conservation Act of 1975 (42 U.S.C. ‘6385) as
amended by the Energy Emergency Preparedness Act of 1982, P.L. 97-229, which states:
“The President or his delegate shall, pursuant to authority otherwise available to
the President or his delegate under any other provision of law, collect information
on the pricing, supply, and distribution of petroleum products by product category
at the wholesale and retail levels, on a State-by-State basis, which was collected
as of September 1, 1981, by the Energy Information Administration.”
Sections 252 through 254 of the Energy Policy and Conservation Act of 1975 (P.L. 94163) (EPCA) provide for the U.S. participation in the International Energy Agency (IEA)
through its Emergency Allocation System and its special information systems. The

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EPCA provides additional authority for collection of the EIA-856 data as provided in 42
U.S.C. ‘6274 (a)(1) which states:
“Except as provided in subsections (b) and (c), the Secretary, after consultation
with the Attorney General, may provide to the Secretary of State, and the
Secretary of State may transmit to the International Energy Agency established by
the international energy program, the information and data related to the energy
industry certified by the Secretary of State as required to be submitted under the
international energy program.”
In addition, Section 407(a)(3) of the Energy Policy Act of 1992 (P.L. 102-486) (EPACT)
(42 U.S.C. ‘13233) requires the Energy Information Administration to establish a data
collection program which collects cost data on alternative fuels. EPACT provides
additional authority for collection of EIA-782A and B data on propane sales as provided
by Section 407(a)(3) which states:
(a)

“Not later than one year after the date of enactment of this Act, the Secretary,
through the Energy Information Administration, and in cooperation with
appropriate State, regional, and local authorities, shall establish a data collection
program to be conducted in at least 5 geographically and climatically diverse
regions of the United States for the purposes of collecting data which would be
useful to persons seeking to manufacture, convert, sell, own, or operate alternative
fueled vehicles or alternative fueling facilities. Such data shall include-...
(3)

2.

cost, performance, environmental, energy, and safety data on alternative
fuels and alternative fueled vehicles.”

Need for and Uses of Petroleum Marketing (PM) Data

The purpose of the EIA petroleum product price, supply, and market distribution data
program is to collect the basic data required to meet DOE legislative mandates and user
community data needs. The program provides a set of basic data pertaining to the nature,
structure, and efficiency of petroleum markets. Adequate evaluation of market behavior
requires price, demand (or sales), product supply, and market distribution data.
Specifically, these data collection efforts are predicated upon the following points:
(a)

EIA has clearly mandated specific data collection responsibilities. These
responsibilities are delineated in the Federal Energy Administration Act of 1974,
as amended (FEAA, Public Law 93-275) and the Energy Policy and Conservation
Act of 1975 as amended by the Energy Emergency Preparedness Act of 1982,
P.L. 97-229. General energy data collection responsibilities are granted by the
requirements to collect information on the institutional structure of the energy
supply system; on the production, distribution, marketing and consumption of
energy commodities; and on the international aspects of the energy situation. EIA
is also explicitly directed to collect energy price data and to collect such data (i.e.,

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both supply and price data) with particular reference to the distribution area of
States.
(b)

The data that DOE collects are used to address significant energy industry issues.
In line with its mandated responsibility to collect data that adequately describe the
petroleum marketplace, DOE has been and will continue to be asked to evaluate
the significance of a number of important issues related to the energy industry in
general and the petroleum industry in particular. Topical issues such as
divorcement, mergers, market pullouts, predatory practices, and product margins
require DOE’s continuing involvement. According to the significant users within
the Congress, the Executive Branch, and among the States, the data collected by
the PM surveys are among those that are required to address these issues.

(c)

DOE must collect some data at the State level. Congressional and State users
have strongly emphasized their need for such data. DOE’s collection of these
data are consistent with its mandated responsibilities to collect specific product
information for appropriate geographic areas and economic sectors, to act as a
central clearing house, and to disseminate relevant information to the States. In
addition, DOE has a continuing mission to minimize the industry burden that
might be caused by the institution of a large number of individual and disparate
State data collection systems.

(d)

Alternative data sources do not adequately satisfy the needs of EIA and its user
communities. Accurate, meaningful, and independent price, supply and demand
statistics are essential to describe and measure phenomena in the marketplace. It
is necessary that this information be collected by an unbiased, independent
source, if the data are to be credible.

EIA maintains that the data collected on these forms are unique. While somewhat similar
or related data may be available from private and/or industry sources, as well as from
other Federal agencies, such data are not reasonable alternatives for the data provided by
the PM survey forms.

DETAILS ON THE USE AND PURPOSE FOR EACH FORM:
(A).

“Refiners’ Monthly Cost Report”: EIA-14

The EIA-14 survey provides data used to determine the acquisition cost of crude oil paid
by refiners. These statistics are widely used primarily for the following purposes:
•
•
•
•

Projecting crude oil and petroleum product prices.
As an input component for calculation of the Gross Domestic Product (GDP).
Monitoring current national price levels.
Performing market analyses.

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The Department of Energy uses the foreign, domestic and composite prices as inputs to
various models in the Short-Term Integrated Forecasting System (STIFS). Refiners’
acquisition costs of crude oil collected on the EIA-14 are input to models to forecast
prices of refined product in various sectors, and to determine the sensitivity of demand
and supply to changes in inventory and prices. These prices are used in the preparation of
the crude and product price projections published in the Short-Term Energy Outlook.
The EIA-14 based costs are also published in EIA’s Monthly Energy Review, Annual
Energy Review, Petroleum Marketing Monthly, and Petroleum Marketing Annual. These
reports are widely used by Congress, the public, and industry to represent the raw
materials component cost of finished petroleum products.
The Bureau of Economic Analysis, Department of Commerce uses the EIA-14 statistics
to determine the costs of crude oil to refiners for calculating the U.S. Gross Domestic
Product (GDP). EIA-14 statistics are used as an index to adjust the cost of crude oil.
Data collected by the EIA-14 on the composite (domestic and imported) acquisition cost
per barrel of crude oil by refiners are used by the Bureau of Economic Analysis on a
monthly basis to calculate a measure of price change for purchases of crude oil.
(Information on crude oil prices from the Producer Price Index covers only domestically
produced oil.) This price index is used to deflate crude oil held in inventory by refiners
for the change in private inventory component of GDP.
The Canadian Ministry of Energy Mines & Resources use EIA-14 data on a monthly
basis to compare Canadian and U.S. prices of crude costs, taxes, refinery costs, and retail
margins.
Congress, DOE, and State energy offices use aggregate statistics based on EIA-14 data,
in conjunction with EIA’s other petroleum price data, to monitor current national price
levels and to benchmark State-collected data. The data are also used to meet State and
congressional requirements for price projections and to determine the impact on national
or State demand. The planning/purchasing offices of a number of oil corporations also
use the crude oil prices which are published by EIA from EIA-14 collected data.
The statistics serve as the most reliable and accurate indicators of price paid by U.S.
refiners for crude oil. These price indicators are used to compare a company’s average
purchasing price to the U.S. and PADD average price, and as a key variable in models
used to forecast future price trends. EIA-14 statistics are also used throughout the
industry as a basis for adjusting prices in escalator clauses in contracts.
The importance and usefulness of EIA-14 data to industry are demonstrated by the
frequent appearance of these data in industry newsletters, trade journals and the general
press. Articles quoting the EIA-14 data are regularly found in a variety of publications.
(B).

“Domestic Crude Oil First Purchase Report”: EIA-182

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The EIA-182 survey provides the only detailed Federal information on the wellhead price
of domestic crude oil. The survey collects total cost and sales volume data for all first
purchases of domestic crude oil for the current month by the State of production. A
weighted average first purchase price is then calculated from the cost and volume data.
EIA-182 data have a variety of users, including Federal and State government agencies,
private industry firms and universities. The information is most frequently used for the
following purposes:
•
•
•
•
•
•
•
•
•
•
•
•

Projecting prices for crude oil markets.
Forecasting prices downstream for refined products at the refinery gate and
subsequent wholesale and retail sales.
Forecasting tax revenues - State severance taxes.
Forecasting State-level production volumes for the Short-Term Energy Outlook,
Monthly Energy Review, and Petroleum Supply Monthly.
Calculating income tax credits.
Verifying futures, spot and posted prices, and revenues.
Conducting market analyses and economic studies.
Evaluating legislative, administrative, and regulatory issues involving domestic
crude oil markets.
Measuring the level of industry concentration and the distribution of ownership of
domestic crude oil.
Monitoring the petroleum refining industry.
Emergency preparedness planning.
Publication by a variety of State and private users, as well as EIA.

The California Energy Commission publishes EIA-182 data on their website at
http://www.energy.ca.gov/oil/statistics/crude_prices_1st_purchase.html and uses the data
to assess crude oil market conditions within the state.
The EIA-182 data are used extensively by EIA and other Federal agencies. EIA uses the
data primarily for forecasting revenues and production of crude oil, monitoring key
energy markets, and conducting economic analyses and projections. The Dallas Field
Office of EIA inputs State level data to a forecasting model to project U.S. production
levels and associated prices for domestic crude. The DOE Naval Petroleum Reserve and
Strategic Petroleum Reserve offices use the EIA-182 for modeling issues and as a source
of benchmark data. EIA publishes the crude oil first purchase price data in the Monthly
Energy Review, Petroleum Marketing Monthly, Petroleum Marketing Annual and Annual
Energy Review.
Crude oil data are used frequently and routinely by other Federal agencies including, but
not limited to: the Internal Revenue Service (IRS), Treasury Department; the
Congressional Joint Committee on Taxation; Bureau of Economic Analysis, Department
of Commerce; and the Minerals Management Service, Department of Interior. These
Federal agencies represent the variety of usages that EIA-182 data receive in the Federal
sector.

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The IRS relies on data obtained from the Form EIA-182, to publish notices required
under the Internal Revenue Code, in order to calculate the available amount of the nonconventional source fuel credit under Section 45K of the Code. The tax credit is subject
to an annual adjustment and potential phase-out, calculated by reference to the IRS’s
determination of the annual average wellhead price per barrel for all domestic crude oil.
The domestic crude oil first purchase price is also used to determine the available
percentage depletion under Section 613A and the enhanced oil recovery credit under
Section 43. The EIA-182 data are the only source of information available to the IRS for
these purposes and are critical to the proper administration of these Code sections.
The Joint Committee on Taxation and the IRS use the data to validate severance tax
receipts, which have been a major component of Federal excise tax receipts. In addition,
estimates based on EIA-182 data are used in fiscal projections and economic forecasts.
The only available alternative is IRS data, which are not available for three to six months
after EIA-182 data are published. Data reported on the EIA-182 have also been used
extensively by the Joint Committee on Taxation and the IRS in analyzing the economic
effects of possible oil supply disruptions, as well as various tax proposals.
The Bureau of Economic Analysis (BEA) of the Department of Commerce is responsible
for preparing the official estimates of the Gross Domestic Product and related measures
that are widely used by government and business to formulate and evaluate policy
decisions. The EIA-182 data are used by BEA as an input to the petroleum component in
the energy sector of the input-output model for the US economy. Data collected on the
domestic weighted average first purchase prices for crude oil, along with EIA first
purchase volume data, are used to prepare estimates of the total value of production of
domestic crude oil in gross product originating by industry and the annual input-output
accounts. EIA-182 data are also used to estimate monthly price changes for petroleum
products purchased by the electric and gas utilities in BEA’s estimates of constant-dollar
value added by industry. These historical tables are used widely by economic analysts
and forecasters.
(C).

“Monthly Petroleum Product Sales Reports”: EIA-782A, B, and C

The EIA-782 surveys collect State-level information on petroleum product price, supply,
and market distribution on an end-use-sector basis. This information is used as basic
statistical data by a wide range of Federal, State and public users such as oil companies
and trade publications.
The most frequent users include Congress, State governments, other Federal agencies
(such as the Bureau of Economic Analysis, Federal Trade Commission, Federal Highway
Administration, and the Defense Energy Support Center), private users such as industry
analysts, trade publications, and the Northeast-Midwest Institute.
Most requests for petroleum and petroleum product information are handled by DOE’s
National Energy Information Center (NEIC). NEIC oversees both subscriptions and
phone requests for information. EIA-782 data, as evidenced by NEIC requests, are

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widely used throughout the private sector and academia. EIA-782 data are so highly
regarded that they are reprinted and/or cited in various publications and journals.
Within DOE, the data are used as input to the State Energy Data System (SEDS) (and its
related output) and the Short-Term Integrated Forecasting System (STIFS) model (and its
resulting publication, The Short-Term Energy Outlook). DOE also includes the data in
other widely used publications, including the Petroleum Marketing Monthly (PMM),
Petroleum Marketing Annual (PMA), Monthly Energy Review (MER), Annual Energy
Outlook, and Annual Energy Review. DOE analysts use the EIA-782 information for a
variety of statistical and analytical purposes.
The EIA-782 data series are primarily used to track, review and analyze petroleum
product supply, marketing, and distribution; and to anticipate and respond to potential
supply disruptions or market structure changes.
Congressional users (primarily members of the Northeast-Midwest Congressional
Coalition) use State-level energy information on a regular basis and for a wide variety of
purposes, including:
•
•
•
•
•

Predicting the consequences to State economies of future energy supply
disruptions or market changes;
Evaluating and implementing relevant legislative proposals, programs, and
policies (for example, the Federal Low Income Energy Assistance and
Weatherization Programs);
Allocating Federal energy block grants to the States;
Evaluating the effects and impacts of energy prices on State-level cost-of-living;
and
Responding to Congressional inquiries regarding petroleum product seasonal
price trends.

EIA is the only independent source of price and distribution data covering all energy
sources and key products, markets, and end-use sectors at the State level. The 1982
passage of the Energy Emergency Preparedness Act, and subsequent requests for analysis
using EIA-782 data during energy emergencies, attest to the ongoing Congressional
interest in having access to reliable and timely petroleum marketing data at the State
level.
State government agencies are frequent and regular users of petroleum product supply,
marketing and distribution data. EIA-782 data are utilized by many - if not most - States
in developing and managing their energy programs. Petroleum data offer States (and
industry analysts) a valid base upon which to analyze, and develop an understanding of
energy production, flow, use and markets. Because a wide variety of energy production
and consumption patterns exist among States and industry, their needs for and uses of
petroleum data also vary. States have a common need for petroleum data from the
following categories.

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•
•
•
•
•

Prices - petroleum prices, including crude oil, motor gasoline, residual fuel oil,
distillate fuel oil, kerosene, propane, and aviation fuels.
Supplies - the availability of petroleum supplies, including crude oil and finished
products.
Consumption - petroleum consumption by end-use sectors, including residential
and commercial, industrial, transportation, and utilities.
Imports - petroleum imports, including crude oil and refined products.
Production - field production of crude oil, stock withdrawals of crude oil and
petroleum products, and ending stocks.

Through analyzing data associated with the above petroleum-related categories, each
State is able - from its unique perspective - to establish a baseline showing the amounts
and patterns of energy supply, distribution, and use over time. Having formulated a
baseline, each State is favorably positioned to analyze and develop energy emergency
contingency plans and other policy alternatives. In fact, State officials concur that, were
an oil shortage to occur, the EIA-782 derived data base would serve as a reliable
historical reference-point from which to measure and respond to the resulting changes
that would occur in the supply and consumption of crude oil and petroleum products.
On the whole, State officials consider EIA data important to their energy emergency
planning and analysis. According to these officials, an important aspect of EIA data is
their uniformity and comparability from State to State. In their view, this allows
comparison of similar data from one State to another and provides a common base from
which to assess the effects of an oil supply disruption.
The value States place on EIA-provided data is by no means confined to the formulation
and implementation of energy policies. EIA data serve States in more practical, day-today ways, such as in investigative hearings, statistical applications, analysis, forecasting
and responding to constituents.
Specific uses of the data by State governments include:
•
•
•
•
•
•
•
•

to compare sales volumes and prices in their State compared with other State data.
The data are used in emergency management to track major suppliers in case of
fuel shortages.
to determine the amount of diesel and distillate produced by State
to track the economy of the State versus the nation based on gasoline
consumption.
to compare consumption of refined petroleum products and national consumption
on a monthly basis.
to analyze and forecast demand for refined petroleum products and long term
planning.
to analyze and forecast petroleum product prices.
to establish semi-annual road tax rates.
to obtain historical data for crisis intervention.

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•
•

to track petroleum product demand for short-term forecasting. The data are also
used to make projections of monthly supply for emergency management
purposes.
to investigate price increases of refined petroleum products during periods of
supply instability.

In summary, the EIA-782 series surveys are heavily depended upon and valued by States.
EIA-782 data are widely recognized and used by the Federal sector for the
comprehensive and unbiased portrait they offer of national, regional, and State petroleum
marketing activity. The EIA-782 surveys provide valuable information to Federal
analysts and policy makers for varying types and levels of analysis.
The Bureau of Economic Analysis of the Department of Commerce uses EIA-782A and
B data (unit prices) in the preparation of the benchmark input-output (I-O) tables of the
United States. The data collected by the EIA-782A and B are important to the quality of
the I-O tables. These tables are prepared every five years and trace purchases and sales
among all industries in the economy, and serve as the benchmark for estimates of the
Gross Domestic Product. Volumetric data collected on these forms, by end-use category
are used to prepare estimates of the types of fuel consumed by broad categories of
intermediate and final users. The price data collected on Forms EIA-782A and B, by
end-use category, are used to convert the quantity data to dollar values for the quarterly
estimates of consumption by various consumers for selected products. Specific data used
are:
•
•
•
•
•

No. 2 diesel fuel (EIA-782A and B) - Unit price for residential sales and for sales
through company-operated retail outlets.
No. 2 fuel oil (EIA-782A and B) - Unit price for residential sales.
No. 1 distillate (EIA-782A) - Unit price for retail sales and for wholesale sales.
Residential fuel oil (EIA-782A and B) - Unit price for retail sales.
Propane, consumer grade (EIA-782A) - Unit price for retail sales and for
wholesale sales.

Data collected on the EIA-782C on volumes of first sale of motor gasoline by grade are
used by the Bureau of Economic Analysis to prepare estimates of the gasoline and oil
component of personal consumption expenditures (a major component of GDP). The
volumetric data, by grade of gasoline, are used in constructing a weighted price per
gallon, which is then used to prepare estimates of gasoline and oil expenditures in real
dollar terms.
EIA-782 data are also useful in the investigation of company mergers. The Federal Trade
Commission (FTC) requests data from the EIA-782C survey to perform market shares
impact studies relating to impending company mergers.
The Defense Logistics Agency, Defense Energy Support Center (DESC), regularly uses
EIA-782 data to ascertain the going market prices or price ranges for the products they
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buy. The data serve as a measure of price reasonableness in connection with exempting
sellers from submitting cost data. Certain prices published by EIA are used in DESC
contracts as escalator indices. Additionally, the data provide an indicator to evaluate
consumer price series for the purpose of price adjustments, and they provide a basis for
possible resolution of conflicts over price or contract prices.
DESC specifically uses the gasoline data shown on the EIA-782A survey for gasoline
market analysis in support of gasoline procurement, and also to determine the alternate
use value of the naphtha portion of JP-4. DESC also requires price data for kerosenebased jet fuel and aviation gasoline. The price data are not available from any other
source and are used by DESC to perform market price analyses in support of JP-4, JP-5
(grades of kerosene-type jet fuel), and aviation gasoline procurement. EIA-782 data are
indispensable to DESC in satisfactorily demonstrating the legality of their fuel purchases.
The DESC uses the PMM data as an economic price adjustment index in conjunction
with their handling of virtually all domestic bulk contracts issued by Department of
Defense. Such contracts involve more than five billion gallons each year.
The Field Operations and Support Division of Environmental Protection Agency use
EIA-782C data to analyze trends between states in the consumption of refined petroleum
products.
The Federal Highway Administration (FHWA) uses the data for their annual regulatory
analysis of sales of aviation fuel, and for such other special studies as their evaluation of
non-highway uses of gasoline at the State level. Highway Trust fund disbursements to
States are determined by FHWA in part through using EIA-782C data to validate Stateprovided data.
Petroleum industry analysts find EIA-782 data useful for performing market evaluations,
trend analyses, and planning. EIA regularly receives data requests from both large
energy producers, and numerous small-to-medium size energy firms.
The diversity of private firms using PMM data, suggests the varied purposes and
applications to which the data are applied. Publishing companies, computer software
firms, consultants, automobile manufacturers, and stock brokerage/investment firms, as
well as, oil industry and oil and gas trade group analysts are among the users of PMM
data.
Some oil industry uses include:
• Department of Pacific Resources, Inc. oversees fuel oil and military marketing.
They depend on the PMM to develop contract pricing formulas for fuel oil and
military marketing.
• to oversee sales to airlines and sales of JP fuel to the military.
• for a variety of forecasting-related applications.

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• to input into energy models, to project U.S. energy market futures, and to try and
simulate interaction between markets.
Many firms and individuals request EIA-782 related data for various purposes.
Rounding-out the diverse users of EIA-782 data are national and regional oil industry
institutes, associations, and organizations. The American Gas Association, American
Petroleum Institute (API), Petroleum Marketers Association of America, Independent
Petroleum Association of America, and Empire State Petroleum Association represent
some of the petroleum industry associations that frequently solicit data from the EIA-782
data system.
The range of coverage (from exploration/production to end-use data) of the petroleum
marketing publications was remarked upon by Robert Lynch, an Executive Vice
President of the Empire State Petroleum Association, who found the data to be a valuable
and credible reference with regard to supplies, prices, and trends. David Morehead, a
Vice President at Petroleum Marketers Association of America, uses the EIA-782 data
for the associations’ weekly newsletter and magazine.
The Northeast-Midwest Institute considers EIA-782 data essential for congressional
research, analysis of legislative proposals, gas tax, and oil import fees.
(D).

“Annual Fuel Oil and Kerosene Sales Report”: EIA-821

The EIA-821 survey collects annual sales volumes of distillate and residual fuel oils and
kerosene by a variety of end-use categories at the State level. These data are used by the
Federal Government for energy policy activities, and for forecasting and consumption
programs to determine current and projected fuel oil needs on a national, regional and
State basis. Aggregations of these data are also used by Congress, State government
agencies and petroleum industry analysts for a variety of analytic studies.
Within the Energy Information Administration, the Office of Oil and Gas uses end-use
data for a variety of statistical analyses. The Office of Energy Markets and End Use
enters the data into the State Energy Data System’s (SEDS), a database of end-use
consumption price and expenditure data for all fuels categorized by State. SEDS
supplies the regional historical data for EIA’s demand-side forecasting models.
Aggregate data are included in following DOE publications, the Fuel Oil and Kerosene
Sales and Annual Energy Review. This published information is used by Federal, State,
and petroleum industry analysts to determine marketing patterns to evaluate end-use
consumption patterns, and to analyze how changes in fuel oil supplies affect economic
conditions at the State, regional and national level.
Data collected on Form EIA-821 on the quantity of kerosene and fuel oil sold by end-use
category are used by all levels of government from the federal through state and regional
to local jurisdictions.
Numerous federal departments and agencies make use of data in the EIA-821. Federal

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energy policy development, forecasting and consumption programs would be impaired if
this data collection were discontinued. The widespread use of these data became
apparent when EIA discontinued the predecessor survey, the EIA-172, for one year.
Numerous letters were received from State Governors, Congress, trade associations, oil
companies, trade publications, and industry analysts citing their need for the data.
•
•
•

•

Department of Commerce’s Bureau of Economic Analysis used the data in
estimating personal consumption expenditures (PCE) of these fuels by broad
consuming categories in the annual I-O accounts.
In 1991, the National Oceanic and Atmospheric Administration used the data to
determine whether to assess a fuel tax on ocean-going vessels.
The U.S. Environmental Protection Agency (EPA) and the petroleum industry
used the EIA-821 data to analyze the impact on end-use consumption patterns of
new EPA regulations to lower the sulfur content of diesel fuel oil. The EPA also
relies on the EIA-821 and makes regular use of the data especially in inventory
modeling as a cross check on their own numbers.
Other Federal agencies have also demonstrated practical applications for EIA-821
data. The Administration for Children and Families currently uses EIA-821 data
to calculate allocations for approximately 1.8 billion dollars annually to the Low
Income Housing Energy Assistance Program. These data have been determined
by Congress to be vital to the allocation of funds to the Low Income Housing
Energy Assistance Program. The Internal Revenue Service currently uses the data
to determine taxes on products such as diesel fuel and kerosene.

State agencies, including energy offices and environmental agencies, also widely use
EIA-821 data for energy planning, analysis, and information dissemination. A number of
state agencies assert that discontinuance of the data would have broad, adverse effects on
their State energy or air quality programs. The following are examples of how States
made use of data from the EIA-821:
•

•
•
•

•
•

The California Air Resources Board has used EIA-821 data to analyze No. 2
diesel fuel consumption patterns in the State of California, in order to estimate the
impacts arising out of lowering the sulfur and aromatic content of No. 2 diesel
fuel.
The California Board of Equalization uses the EIA-821 in on-going research.
Connecticut has used EIA-821 data to evaluate energy use patterns, conservation
and fuel switching among sources.
Ohio Public Utilities Commission relies on the EIA-821 every year for kerosene
and petroleum product data for long-term analysis, they also use data by end-use
sector, and for their biennial reports. They consider the EIA-821 very important
for the work of the Ohio PUC.
Maine Environmental Protection and Air Quality Agency relies on data available
only in the EIA-821 to refine emissions inventory for EPA on an annual basis.
Maryland Energy Administration has used the EIA-821 to check supply data on
an on-going basis, to a certain extent to help establish base levels to determine
emergency conditions.

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•
•

•

•
•

•

•
•
•

Massachusetts uses the data on an annual basis in forecasting energy demands and
future prices.
Michigan uses EIA-821 data extensively to estimate sulfur dioxide (SO2)
emissions from for all end use sectors, from No. 1 distillate, No. 2 distillate, and
residual fuel. The Michigan Department of Natural Resources needs data on sales
of No. 2 diesel fuel separated into two categories of less than or equal to .05
percent sulfur and greater than .05 percent sulfur. Michigan requires low sulfur
fuels in certain geographic areas as an alternative to installing pollution control
devices to reduce SO2 emissions. Michigan is interested in using the data for low
sulfur diesel fuel to improve their estimates of SO2 emissions and to evaluate the
effectiveness of their state regulations on low sulfur fuels.
Michigan Department of Natural Resources, Air Quality Division depends on the
EIA-821 to meet EPA filings of county emission estimates. The agency regularly
uses the data in conjunction with their own sample estimates to derive county
totals by end use category. The EIA-821 is seen as indispensable to this effort.
Minnesota uses the data for energy analysis and information dissemination
activities.
New York develops, reviews and updates a comprehensive, long-range State
Energy Master Plan using EIA-821 data. New York also uses the data to develop
the State end-use energy accounts, for the New York Annual Energy Review, and
for a variety of energy analyses and assessments.
New York State Energy Research and Development Authority uses the EIA-821
along with other EIA reports to produce Patterns and Trends a report that looks at
supply and demand and is published on Internet. [The Internet site gets 40,000
hits per year.]
Wisconsin uses EIA-821 information to inform the Governor and Legislature on
energy usage in Wisconsin. They also prepare a detailed forecast of future energy
usage within the State by economic sector.
Wisconsin Department of Administration, Division of Energy &
Intergovernmental Relations, Bureau of Energy uses the EIA-821 on a regular
basis for energy statistics by end use segment in Wisconsin.
Other States, including Ohio, Arkansas, Vermont, and Illinois have also
forwarded correspondence to EIA stating strong support and genuine need for the
data reported on the EIA-821 survey.

Local agencies also regularly use data from the EIA-821 such as:
•
•

South Coast Air Quality Management District has used EIA-821 data in the
analysis of diesel fuel consumption patterns in southern California with respect to
the impact of changing No. 2 diesel fuel specifications.
Maricopa County Air Quality, Phoenix, Arizona makes on-going use of most
recent information to develop emission estimates for Maricopa County by end use
category. The agency uses state data and applies population data to derive their
estimates. They consider the EIA-821 the sole source of needed information
since there are no reliable local data available.

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•
•

City of Baltimore, Bureau of Budget Management Research made use of EIA-821
data to help establish a base year for a new tax on energy.
Metropolitan Washington Council of Governments uses data from the EIA-821 as
part of the input to strategic planning process for the metropolitan region.

The Petroleum industry makes extensive use of the data collected through the EIA-821.
National and regional trade associations, as well as individual companies, have made use
of EIA 821 data in analysis and forecasting. For example:
•

•

•

Along with other EIA and DOE publications, data from the EIA-821 are also
republished in the American Petroleum Institute publication Basic Petroleum
Data Book, Petroleum Industry Statistics, widely used by industry analysts. In
addition, the American Petroleum Institute uses EIA-821 data for analyzing total
distribution sales of No. 2 distillate by end-use and the National Petroleum
Council uses the EIA-821 from time to time for various statistical purposes and
reports.
The New England Fuel Institute has stated that its 1,100 members (independent
retail and wholesale home heating oil distributors) depend on the EIA-821 data to
project the supply needs of the New England States, to estimate appropriate
product inventories, and to direct their marketing practices. The Independent Fuel
Terminal Operators Association, composed of 16 companies operating deep water
oil terminals, use the data to make purchase decisions and estimate necessary
inventory levels.
Petroleum companies, such as Citgo, Texaco and Marathon, have made frequent
use of the data uniquely available in the EIA-821 survey. Companies have used
the data in forecasting, trend analysis, and market segment analysis.

Other users of EIA-821 data include:
•
•
•
•
•
•

Bechtel Corporation has used data from the EIA-821 for internal reports, and for
articles they write for the trade publications.
Colonial Pipeline has used EIA-821 data in developing new business markets and
assisting in planning system expansion.
Woodrock and Company uses the EIA-821 on an on-going basis in their work as
investment banking. They view the data as an important component for their
analysis of the economic drivers underlying the general economic conditions.
Data Resources Incorporated (DRI) has used EIA-821 data to update a refinery
model at the PADD level and to monitor the industry in bench marking for
modeling prices and supply.
Detroit Diesel Corporation has used EIA-821 data for congressional testimony
and for a breakdown of fuel oil by diesel engines.
Allegro Energy Consulting regularly uses the EIA-821 in analysis of various enduse sectors including residential, agriculture, and industrial. The user sees the
EIA-821 as a vital unique source, the only source for data by sector at the state
level.

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•
•
•
(E).

Cohen & Dax PC used data from the EIA-821 for an article about alternative uses
of Bio-diesel including the possibility of using Bio-diesel as a heating fuel in the
New England and Mid Atlantic regions of the U.S.
Muse Stancil uses the EIA-821 regularly for fuel oil market studies, for heavy fuel
oil in particular
Tamura Environmental has used the EIA-821 for estimating air emissions.
“Monthly Foreign Crude Oil Acquisition Report”: EIA-856

Foreign crude oil prices and volumes are key components of the U.S. balance of trade
picture, and are necessary for evaluating the impacts of oil market trends on the U.S.
economy and future product wholesale and retail prices. The EIA-856 survey supplies
comprehensive information, not available from other sources. Form EIA-856 continues
to be the only source of U.S. crude oil imports which collects cargo-level prices and
actual gravities associated with specific crude types. The EIA-856 data are essential in
evaluating any impacts to the petroleum industry as a result of changes in the quality of
U.S. imports due to trade embargoes, supply shortages, or cut-offs such as those
experienced during the Persian Gulf crisis.
The statistically reliable information collected by the survey is also used by EIA, other
Federal agencies, and the private sector, primarily for the purposes of analysis and
forecasting. For example:
•

The EIA-856 data were used to assess the impact to the U.S. economy of the trade
embargo on Iraq and cut-off of Kuwait oil as a result of Iraq’s invasion of Kuwait.
The EIA Administrator, as well as the staff of the Secretary of Energy, analyzed
EIA-856 data by the gravity/sulfur content of U.S. crude oil imports to evaluate
the impacts of the loss of high gravity Iraqi crude on the petroleum industry.

•

The Bureau of Labor Statistics (BLS) of the Department of Labor uses the
EIA-856 as a primary input for calculating the price indices for foreign crude oil
as a component of the U.S. Import Price Index.

•

Over the years, the EIA-856 data have been used in a number of studies. The
Bureau of Economic Analysis of the Department of Commerce requested EIA856 quantity and price information for those countries engaged in net back pricing
arrangements, and to aid in a quarterly analysis of the petroleum industry,
inventory stocks of crude oil, and active rig levels of crude oil. The data were
used by the Balance of Payments Division to adjust the value of crude oil imports
reported by the Census Bureau to more accurately reflect the true value of oil
imported into the United States.

•

DOE uses EIA-856 data to support their legislatively mandated responsibilities,
some of which reside in the areas of modeling and forecasting. In an effort to
alleviate confusion about the difference between imported refiners acquisition
cost and the prices for premium crudes typically reported in the media, the Office

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of Integrated Analysis and Forecasting, used crude oil prices collected on the
EIA-856 to forecast the Annual Energy Outlook 2006 world oil price path for
imported light sweet crude. EIA-856 data are also published in the Monthly
Energy Review, Petroleum Marketing Monthly, Petroleum Marketing Annual,
Annual Energy Review, Annual Energy Outlook, and International Energy
Outlook. The Office of Strategic Petroleum Reserve for DOE uses EIA-856 data
to assess distribution capabilities of domestic crude oil versus foreign crude oil.
The Financial Analysis Team in the Office of End Markets and End Use uses the
EIA-856 data to create a graph of the price spread between light and heavy crude
oil in the publication, Performance Profiles, as a discussion on refinery
investments.
•

The data are also frequently used by petroleum company analysts, consultants,
and investment bankers to assess their company’s crude oil purchasing
performance relative to the industry average, and on forecasting the cost of
various foreign crude oil streams.

•

These data are used to perform the important function of providing the U.S. data
submissions to the International Energy Agency (IEA). The IEA is an
intergovernmental organization with binding commitments from 20 signatory
nations. The Standing Group on the Oil Market within the IEA is responsible for
tracking developments in the international oil market. Two IEA requirements,
which were established in June of 1979, are supported by data collected on the
EIA-856.
The first requirement is to maintain the Crude Oil Import Register of oil imported
into the United States on a cargo-by-cargo basis. The second requirement is to
produce a monthly price report of average prices and total volumes of imported
oil for selected crude streams. The United States agreed at the November 10,
1981 meeting of the IEA Governing Board to extend the IEA agreement. The
Crude Oil Import Register and the monthly price report allow the United States to
fulfill this multinational obligation.

(F).

“Petroleum Product Sales Identification Survey”: EIA-863

The EIA-863 collects information on size, type and geographic location of fuel oil related
businesses to form an attribute sampling frame for use by EIA sample surveys.
Specifically, the data are used to provide:
•

•

A comprehensive frame file for sampling. The information is also used to
identify births (new companies including sales and mergers) and deaths
(companies going out of business) in the universe, as well as updates to mailing
addresses and contact information.
Volumetric State-level data necessary for efficient use of stratified or probability
proportional to size sampling. These sampling methods yield substantial

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•
•
•
•

reductions in respondent burden and reduce sampling error in the weekly,
monthly and annual sample surveys.
Basic aggregate data to determine aggregate population estimates. These
estimates are used to design efficient samples and estimators, and to measure
previous sample deterioration and changes in the distribution of the population.
Parent/subsidiary relationships to avoid both under reporting and double counting,
and to minimize sample sizes and company burden.
Company-level profiles and detail which allow for sample rotation to minimize
individual company burden.
Data for examining edit and imputation procedures and methodologies in the
monthly and annual sample surveys, and testing those methodologies. The data
are also directly used for editing and imputation procedures as a benchmark for
new sample members and for nonrespondents.

The list of companies, their operational status, volumetric data and information on their
corporate relationships together serve as the sampling frame for the following EIA
surveys:
•
•
•
•
•

EIA-782B, “Resellers’/Retailers’ Monthly Petroleum Product Sales Report,”
EIA-821, “Annual Fuel Oil and Kerosene Sales Report,”
EIA-877, “Winter Heating Fuels Telephone Survey,”
EIA-888, “On-Highway Diesel Fuel Price Survey,”
Ad hoc surveys, such as the National Petroleum Council Surveys.

Each of these surveys requires a frame that is relatively current because of the high
turnover rate and ongoing changes in the petroleum industry. Previous surveys have
shown a turnover of roughly 25 percent between surveys without including ongoing
updates made to align the larger petroleum sellers. It is necessary that the frame for
sampling be both comprehensive and up-to-date with the industry for unbiased and
efficient sampling. Lack of identification of out-of-scope and out-of-business firms
greatly increases sample sizes, respondent burden, and data error, as well as government
costs for nonresponse follow-up. The high birth and death rate of fuel oil dealers means
that samples deteriorate rapidly through time and must be updated to maintain sample
efficiency and estimation accuracy.
(G).

“Winter Heating Fuels Telephone Survey”: EIA-877

The EIA-877, “Winter Heating Fuels Telephone Survey,” is designed to collect data on
retail prices of No. 2 heating oil and propane during the heating season (October 1March 15) for 24 Eastern and Midwestern states. EIA selects the sample in each state
and defines the data elements to be collected. Each state energy office collects the data,
from the sample provided by EIA, over the telephone and the data are transmitted to EIA
using the Internet Data Collection (IDC) system. EIA tabulates the data and publishes
the aggregate estimates on the Internet. The data collected are used to monitor the price
of these heating fuels during the heating seasons and for reports to the Congress and
others when requested. The EIA-877 survey meets the need for timely price and supply
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information on these fuels. The data has been used by the Federal and State
governments, industry analysts, and Congressional Committees to assess the hardships
experienced by heating oil and propane users during periods of critical short supplies
such as during the winters of 1989 and 1999 in the Northeast and Mid-Continent areas.
The severe weather in those years contributed to supply shortages and large price
increases for both heating oil and propane. EIA responded to this need for timely
information by implementing the EIA-877 telephone survey to collect State-level, weekly
information during the heating season on the price of No. 2 heating oil and propane from
a sample of suppliers. The need for this information was expressed in Congressional
hearings and meetings of State energy office officials. Transcripts of these hearings are
available upon request.
Several major respondents and petroleum industry association representatives, including
the American Petroleum Institute [Dr. Edward Murphy, (202) 682-8495] and the Natural
Gas Processors Association [Mr. James Burroughs, (703) 979-3560], agreed that more
timely data on No. 2 heating oil and propane is required and that EIA should collect such
data.
(H).

“Motor Gasoline Price Survey”: EIA-878

The EIA-878 survey collects, on a weekly basis, the retail price by grade of unleaded
gasoline, self-service, cash only, including all taxes. The data may be collected on a
more frequent basis during emergency situations such as war, common disasters, severe
price fluctuations, and other supply shortages. When these emergency situations arise,
EIA notifies OMB before implementing the change in frequency and states the reasons
and what the effect is on burden. The EIA-878 survey provided daily estimates from
April 29, 1996 through August 2, 1996 to Congress, Federal officials, and the
transportation industry in order to measure the rapid price increases at both regional and
national levels. During the 1991 Iraq war, the data were used by Congress and Federal
officials to monitor the retail price of gasoline on a daily basis. The EIA-878 data
provide weekly information on retail market conditions and on the price impacts of
"clean fuel programs" mandated by the Clean Air Act Amendments of 1990 to both
government and industry. More recently, these data were used to monitor the effect in
2005 of hurricane Katrina on the retail gasoline market.
U.S., regional, and city retail gasoline price estimates calculated from EIA-878 data are
used in a wide range of analytical reports and are routinely accessed by the public
through a telephone hotline number (202) 586-6966 maintained by the U.S. Department
of Energy, as well as accessing the data from the EIA website at:
http://www.eia.doe.gov/oil_gas/petroleum/data_publications/wrgp/mogas_home_page.ht
ml.
Data are released for 9 states and 10 cities, in additional to the five PADD and three subPADD areas, and the U.S. During 2005, the telephone hotline, which disseminates both
gasoline prices from the EIA-878 survey and diesel prices from the EIA-888, received an

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average of 28,739 calls per month, ranging as high as 40,412 in October following
hurricanes Katrina and Rita.
The Secretary of Energy routinely uses EIA-878 data to monitor regional price levels and
relies on the data in his reports to the Congress and the White House. During periods of
rapid price fluctuations data from this survey have been used to prepare reports for
Congress during special hearing sessions. Most recently in September 2005, EIA’s
administrator used these gasoline price data in a briefing Gasoline Prices in the U.S. and
Recent Developments in World Oil Markets to the Committee on Energy and Commerce,
U.S. House of Representatives. Additionally in September 2005, these prices were used
in a statement before the Energy and Natural Resources Committee, U.S. Senate. Within
EIA, the Office of Energy Markets and End Use uses EIA-878 price data to forecast the
retail price of gasoline in their monthly Short Term Energy Outlook report released on the
web. EIA also uses EIA-878 price data each spring for its Summer Motor Gasoline
Outlook report on the web.
The EIA-878 data are routinely relied upon by the press, industry, the media and
government as a measure of retail prices of reformulated, oxygenated, and conventional
gasoline. Every major newspaper has cited and published retail gasoline price data from
the EIA-878 in stories concerning retail gasoline prices including the Los Angeles Times,
New York Times, Boston Globe, Chicago Tribune, Washington Post, Wall Street Journal,
and USA Today, along with hundreds of other local newspapers across the United States.
The financial markets have also become customers of the EIA-878 prices. Late in 2005,
the Chicago Board of Trade began offering new futures’ contracts with the cash
settlement price based on the published weekly retail gasoline price from the EIA-878
survey. The data are routinely published in all the major wire services including Reuters
Ltd, Bloomberg News, Dow Jones, and Associated Press. U.S. price estimates for
regular grade gasoline are regularly quoted on the CBS and NBC television news
networks. EIA-878 data are published in the Washington Daybook - Economic Reports.
Retail gasoline price estimates for the State of California are published on the California
Energy Commission’s home page at http://www.energy.ca.gov/gasoline/index.html.
The EIA-878 data are routinely relied upon as a measure of the price level by the State of
California. The EIA-878 data were used in the report by EIA, 2003 California Price
Study, to explain the high price levels for gasoline on the west coast. In April 2000, the
General Accounting Office released a special report, “Motor Fuels - California Gasoline
Price Behavior” which was based primarily on EIA-878 data.
The data are relied upon by both government, industry, and the public for explaining
price movements and levels across regions. EIA-878 data were used in the report An
Analysis of Gasoline Markets, Spring 1996 prepared by the U.S. Department of Energy at
the request of President Clinton. The data were used in two EIA reports, Why are
Gasoline Prices Falling So Rapidly, and Gasoline Prices: What’s Happening? in order to
explain large price swings in the market during the 2001 summer driving season. The
national and regional retail gasoline price estimates from the EIA-878 survey are
accessed daily by the public through a telephone hotline number (202) 586-6966

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maintained by the U.S. Department of Energy. During 2005, the telephone hotline, which
disseminates both gasoline prices from the EIA-878 survey and diesel prices from the
EIA-888, received an average of 28,739 calls per month, ranging as high as 40,412 in
October following hurricanes Katrina and Rita.
The New York State Department of Finance uses EIA-878 to measure the price level of
retail gasoline in that state and to forecast budget revenues from gasoline excise taxes.
The New York State Energy Research Development Authority uses retail gasoline price
estimates for New York State to monitor supply conditions and price levels in the state.
They also publish the price estimates in the New York State Gasoline Watch report. The
New York State Department of Taxation and Finance, Office of Tax Policy Analysis uses
EIA-878 retail gasoline price estimates, by grade and by formulation, to estimate gasoline
sales tax revenue in their quarterly forecasting models. These forecasts for gasoline sales
tax revenues are used by the New York State legislature to estimate future revenue for the
state’s annual budget. New York State also publishes EIA-878 data on their website at
http://www.nyserda.org/prices.html. Other state programs, such as Minnesota
Department of Public Services, and New Hampshire’s Office of Energy & Community
Services, use the EIA-878 prices also.
(I).

"On-Highway Diesel Fuel Price Survey": EIA-888

The EIA-888 survey collects the retail price of on-highway ultra low and low sulfur
diesel fuel, self service, cash only, including all taxes. The data may be collected on a
more frequent basis during emergency situations such as war, common disasters, severe
price fluctuations, and other supply shortages. When these emergency situations arise,
EIA notifies OMB before implementing the change in frequency and states the reasons
and what the effect is on burden. The data are used by Congress, Federal and state
officials, and the transportation industry to monitor the retail price of on-highway diesel
fuel. During 1994 and 1995, EIA-888 data was used to measure the price impacts of the
low sulfur diesel fuel requirements for on-highway diesel fuel as mandated by the Clean
Air Act Amendments of 1990. From April 29, 1996 through July 5, 1996 the data were
collected three times per week and used to measure national and regional price levels
during a period of rapid escalating retail prices for on-highway diesel fuel.
Since April 1996, EIA-888 data are regularly used by the California Energy Commission
to measure retail price levels for low-sulfur California Air Resources Board specification
diesel fuel in California. The EIA-888 price estimates for the State of California are
published on the California Energy Commission’s homepage at
http://www.energy.ca.gov/gasoline/index.html. New York State also publishes EIA-888
data on their website at http://www.nyserda.org/prices.html.
During February 2000, EIA-888 retail price data were used as part of testimony given by
EIA to the U.S. Congressional House Committee on International Relations, U.S. Senate
Energy Committee, and New York State General Assembly. These data were also used
in an EIA briefing to the White House during December 1999, and in an EIA briefing to

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the Secretary of Energy during January 2000, because of the rapid price rise in No. 2
distillate products on the East Coast during this time period.
Shipping contracts with the federal government, both military and civilian, require the
use of EIA-888 published data as the price mechanism for calculating fuel surcharges.
The General Services Administration Federal Supply Service uses EIA-888 data as an
indicator to determine when carriers should be allowed relief from sudden or unexpected
increases in fuel prices. Pursuant to GAO National Rules Tender No. 100-D, the GSA
Freight Program Management Office requires the use of EIA-888 data to calculate a 52
week moving average of the published Monday price as the baseline for the Neutral
Range when issuing a Standard Tender of Service notice. The annual average is updated
on the Monday before the first Monday in February and the first Monday in August of
each year. In addition to the standard tender of service notices, GSA has agreements with
customers that supplement government fuel contracts. These agreements, or fuel
policies, allow companies to raise their rates or get a discount depending on the cost of
diesel as measured by the EIA-888 survey. Fuel policies for civilian government shipping
contracts are revised every six months and are based on the previous 52 weeks of
published EIA-888 data. The Military Traffic Management Command for the
Department of the Army uses EIA-888 to measure price changes over a moving 12-week
period to determine when a fuel adjustment shall be granted to a shipper under a military
contract.
The EIA-888 data are used to provide weekly information to both government and
industry on retail market conditions. The EIA-888 data are routinely relied upon by the
press, industry and government as a measure of change in the fuel costs for transportation
and shipping contracts. Federal Express at
http://www.fedex.com/cgi-bin/fuelsurcharge.cgi?link=4&cc=us&language=english and
United Parcel Service at
http://www.ups.com/content/us/en/resources/find/cost/fuel_surcharge.html use EIA-888
published data in their fuel surcharge formula for adjusting shipping rates for ground
transportation. The EIA-888 data has generally been adopted by the majority of the
private trucking firms and shippers as the price adjustment mechanism in fuel surcharge
formulas.
The national and regional retail diesel fuel price estimates from the EIA-888 survey are
accessed daily by motor carriers, both haulers and bus companies, shippers, and other
members of the public through a telephone hotline number (202) 586-6966 maintained by
the U.S. Department of Energy as well as accessing the data from EIA’s website at
http://tonto.eia.doe.gov/oog/info/wohdp/diesel.asp . During 2005, the telephone hotline,
which disseminates both gasoline prices from the EIA-878 survey and diesel prices from
the EIA-888, received an average of 28, 739 calls per month, ranging as high as 40,412 in
October following hurricanes Katrina and Rita.
EIA-888 data are also published on a weekly and monthly basis in several trucking
industry newsletters including the American Trucking Association
www.ttnews.com/members/fuel/, Traffic World, www.trafficworld.com/index.asp, RPM

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magazine, www.rpmag.com and other transportation news services such as TCHEK,
www.tchek.com/estop.asp. The national and regional prices are broadcast twice per day
on Interstate Radio Network, a radio network with 40 affiliates (with coverage of 95% of
the continental United States) at www.midnighttrucking.com. The EIA-888 data are also
analyzed and used by the National Industrial Transportation League, the National
Association of Truck Stop Operators, and the American Automobile Manufacturer’s
Association. EIA-888 data are routinely quoted on all the major news and wire services
including Reuters Ltd, Bloomberg News, Dow Jones, and Associated Press.
3.

Using Automated, Electronic, Mechanical, or other Technological Collection
Techniques to Reduce Burden on Respondents

All Petroleum Division survey forms are available in a Microsoft Excel spreadsheet format
(.XLS) on the EIA website at
http://www.eia.doe.gov/oil_gas/petroleum/survey_forms/pet_survey_forms.html
and may be downloaded by respondents. Respondents may fax or email their survey
forms using XLS survey file format. Since email is an unsecured means of transmission
because the data is not encrypted, and there is some possibility that data could be
compromised; EIA offers an additional method for submitting Excel files using a secure
method of transmission: HTTPS. Surveys can be sent using the secure method at:
https://idc.eia.doe.gov/upload/noticeoog.jsp.
The Petroleum Division also developed software, "PC Electronic Data Reporting Option"
(PEDRO) to allow the respondents on the EIA-14, EIA-182, EIA-782A/B/C, and EIA877 to transmit their data electronically through a modem. Data entry in the PEDRO
system may be done on-line using electronic images of the printed forms, or data may be
imported from mainframe or other microcomputer systems using a pre-defined format.
The PEDRO data entry programs include a wide variety of edit checks to detect data
errors at the time of entry. This reduces the amount of resources used to correct or
confirm questionable data items with the EIA.
The EIA-821 and EIA-863 surveys each utilize bar coding, which reduces processing
errors and costs.
EIA-877 data are collected by telephone.
EIA-878 and EIA-888 data are collected through a Computer Assisted Telephone
Interview (CATI) survey processing system.
4a.

Efforts to Identify Duplication

EIA has carefully examined all surveys and published data identified as having potential
overlap with any of these eleven petroleum marketing survey forms. There are data that
are somewhat similar to those available from several other sources, including other
Federal agencies, industry associations, and private firms. However, these data are not a
reasonable alternative for data collected by these eleven surveys. Specific surveys and
published data and the inadequacies of these data as a substitute for the eleven surveys
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are discussed in Section 4b. Below is a survey-by-survey discussion concerning
investigations (and their results) undertaken to identify possible duplication of data.
(A).

“Refiners’ Monthly Cost Report”: EIA-14

The EIA-14 provides the only source of comprehensive, current period-weighted costs of
crude oil as it is booked into the refinery. Form EIA-182, “Domestic Crude Oil First
Purchase Report,” is designed to collect data on the value and volume associated with the
physical and financial transfer of domestic crude oil from the property on which it was
produced. EIA-182 data are used to represent the initial market value of domestically
produced crude oil. The EIA-182 holds a similar relationship with the EIA-14, with
respect to domestic oil, that the EIA-856 does with respect to imported oil. Costs that
accrue subsequent to its first purchase (e.g., transportation, storage, resale markups and
markdowns, et cetera) are included in the EIA-14, but not in the EIA-182.
The EIA-14 provides a crucial link in the evaluation of crude oil and refined products
from the wellhead to ultimate consumption. EIA collects data at critical stages in this
process: the EIA-182 collects wellhead data; the EIA-14 collects data on crude oil as it
enters the refinery stage, and the EIA-782 collects data on the sales of the finished
products.
(B).

“Domestic Crude Oil First Purchase Report”: EIA-182

The EIA-182 is the only data collection instrument that gathers data on average crude oil
wellhead prices paid by the first purchasers to producers.
Similar statistics, such as those published in Platt’s Oilgram, Petroleum Intelligence
Weekly, and Oil Buyers Guide International focus on what refiners and resellers are
asking publicly for crude (posted prices and spot prices). These publications do not
provide data on sales of equity and non equity crude oil, nor information as to what the
actual price and amount of oil is involved; in fact, no actual transactions may occur as
posted prices.
The Bureau of Labor Statistics, in conjunction with its Producer Price Index, calculates a
price index for crude oil. Their primary source of data is posted prices for domestic
crude oil at the wellhead. A price index is published monthly, but no average price is
published or calculated. Furthermore, no regional or State-level prices are available.
The EIA-23, “Annual Survey of Domestic Oil and Gas Reserves,” collects data on the
reserves of crude oil, natural gas and natural gas liquids from well operators. No price
data are collected.
Annual collection of first purchase prices would not be adequate given the widely
fluctuating prices of crude oil in the current environment.

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(C).

“Monthly Petroleum Product Sales Reports”: EIA-782A, B and C

The State-level product price and volume data provided by the EIA-782 series are not
provided either by other DOE surveys, or by other government and private sources.
The Bureau of Labor Statistics (BLS) collects only voluntarily-provided wholesale and
retail price-related information on refined petroleum products. Furthermore, the
aggregate statistics provided by BLS not only fail to satisfy the needs of EIA-782 users,
but are inadequate as a base upon which to respond to various U.S. Congress inquiries.
Both the Consumer Price Index (CPI), and the Producer Price Index (PPI) are statistically
designed to measure price change and use fixed weights, i.e., they do not use current
volumes. However, EIA users require measures of both total volumes and actual average
prices as calculated using a current month’s weights for accuracy. More particularly,
user needs would not be met because of the following deficiencies in BLS data or
sampling frames:
•
•
•
•
•
•

Many retail sales of major products are not represented.
Disaggregation by sector is not provided for distillates.
Wholesale prices at the national, regional, and State levels are not provided.
Retail prices at the State-level are not provided.
Reseller activity is not reflected in the Producer Price Index.
BLS sampling frames, because they depend on North American Industrial
Classification System codes, may result in the exclusion of product sales by
secondary businesses.

The 1985 adoption by the Bureau of Labor Standards of a new/revised methodology for
pricing refined petroleum products at the wholesale level has also, albeit indirectly,
resulted in users ‘crossing-over’ from BLS-provided-data to EIA-provided-data. For
example, while the revised BLS methodology has improved the timeliness of their prices,
regional prices and indexes for products on the PPI were eliminated. Currently, BLS
refers users seeking regional data to the Petroleum Marketing Monthly publication.
Furthermore, due to the elimination of these data by BLS, industry and State
governments are now using EIA-782 data to determine contract prices for fuel sales.
The Petroleum Marketing Monthly (July 2004) feature article, titled “A Comparison of
Selected EIA-782 Data with Other Data Sources” describes and quantifies retail price
data (motor gasoline, on-highway diesel fuel and No. 2 fuel oil) differences between
EIA-782A/EIA-782B, BLS price data, and Federal Highway Administration motor
gasoline volume data. Retail price comparisons were made on annual data from 1994
through 2003 for regular grade finished motor gasoline, retail on-highway diesel fuel
prices, and residential No. 2 fuel oil.
BLS utilizes a fixed-volume weighted scheme to produce several levels of statistics of
which the U.S. city average price was used for comparison purposes in the article. The
BLS prices were based on 1982-1984 expenditures weights.

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Regarding motor gasoline, the biggest difference between EIA-782A/EIA-782B and BLS
surveys is the weighting. Major shifts in marketing strategies, such as cash discounts,
self-serve, geographic movements in gasoline markets, or the introduction of
reformulated gasoline into the market, would be identified immediately by the EIA
surveys through the current volume weighting it employs. The BLS fixed weights, in
comparison, lag behind in reflecting these changes in the average prices. Although the
BLS adopted (in 1987) a new pricing policy that allowed weights to be adjusted annually
by ongoing consumer data, the data still lagged by 4 to 5 years. In addition, the BLS
Point of Purchase Survey (POPS), which is rotated 20 percent each year, affects the BLS
averages, and how the mix of self-service, cash-discounts, etc., are represented. When
market conditions change, the BLS price data could lag behind until new sample units are
rotated into the survey and/or CPI survey weights are updated.
For Residential No. 2 Fuel prices, the change in the difference between EIA-782A/EIA782B and BLS data for the years 1995 through 2003 reflects the change in weights for
BLS. One reason for the discrepancy is that the EIA-782A/EIA-782B surveys use
current volumes while BLS uses fixed volumes to compute monthly weighted average
prices. Also, BLS collects prices mainly from urban areas. EIA studies have shown that
residential heating oil prices tend to be higher in urban areas.
On the average, one might expect the BLS prices to be higher because taxes are excluded
from the EIA, but are included in the BLS prices. If taxes increase over time, the price
spread between the data series would increase too. The BLS annual prices were derived
by using a 12-month simple average. However, residential fuel oil prices and volumes
are seasonal in nature, and computing a simple average for the BLS price would not
reflect this trend as would the EIA data series.
FHWA’s “Monthly Motor Gasoline Reported by States” report is a tabulation of gross
gasoline gallons reported by wholesale distributors to State motor fuel tax agencies. The
data are used to determine the disbursement of Federal highway trust funds to the States.
Some users of gasoline sales data have suggested the FHWA report as an alternative to
the EIA-782C. It is a weak alternative, however, if only due to the considerable time
(sometimes approaching six months) elapsing between gasoline sales data being collected
and published in the “Monthly Motor Gasoline Reported by States” report. Recent
analysis of FHWA data showed that not only did more than 90 days elapse between the
capture and publication of data, but State coverage was low. FHWA is a poor alternative
to EIA-782C data for other reasons. For instance, unlike EIA-782C data, FHWA data:
(1) does not cover other petroleum products, (2) is not published as timely as EIA-782C
data, and the methodology for reporting is based on sales and gross receipts taxes which
is not uniform across the States, and (3) does not break out the data by grade or
formulation of gasoline.
Furthermore, the FHWA report does not include prices. In conclusion, EIA-782 data are
more accurate, more timely, cover more products, and reflect a higher State response rate
than does FHWA data.

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Other private and public sources providing petroleum product data purportedly equivalent
to the EIA-782 survey series were also studied and were found to be inadequate in
fulfilling the mandated requirements of the EIA-782 series surveys. Each of the alternate
sources differed importantly and significantly from the EIA-782 in one or more of the
following areas: data collection methodology, periodicity, survey frame, sales category
disaggregation, product slate, geographic breakdown, and purpose. Furthermore, only
the EIA-782 series surveys provide detailed State-level breakdowns of information by
end-use sector.
(D).

“Annual Fuel Oil and Kerosene Sales Report”: EIA-821

There is no similar information available for sales of distillate, residual fuel oil and
kerosene by end-use at the State level. The EIA-782A and B collect monthly sales data
for distillate and residual fuel oil; however, the product breakouts and end-use categories
on the EIA-782A and B are more limited than the disaggregation provided by the annual
EIA-821 survey. Furthermore, the product slate for the EIA-782B is limited in order to
provide minimum burden on a monthly basis. Kerosene, No. 1 and No. 4 distillate are
not collected on the EIA-782B.
Notwithstanding the limitations imposed by the differences in reporting categories, it
would be impossible to obtain the same accuracy of annual volume statistics by summing
the 12 reported monthly numbers. Respondents to the EIA-782 do not provide priorperiod adjustments for their monthly estimated data. However, revisions to prior
estimates are figured into the reported EIA-821 annual volume totals. Also, the EIA782B, which uses reported volumes for weighting, does not have a sample large enough
to provide volume data with a reasonable degree of accuracy.
(E).

“Monthly Foreign Crude Oil Acquisition Report”: EIA-856

The EIA-856 collects information on costs and quantities of imported crude oil. There
are no data collected by alternate forms that provide similar information. One data
source that has been cited as a potential replacement for the EIA-856 is the U.S. Customs
Entry Document, CF-7501, which collects landed volumes and customs valuations for
crude oil by country of loading. The CF-7501 is the entry document filed for all imports
into the United States.
U.S. Customs, as the collector of import/export data and duties, is required to process
information for thousands of transactions each month. Given the range of goods crossing
the U.S. border, Customs must collect a limited, general class of data sufficient to
perform its primary duties. However, EIA requires more specific data elements which
are not collected by Customs. In particular, the requirement to provide a monthly crude
oil report to the International Energy Agency (IEA) is an important application of the
EIA-856 data. To create the report, data must include detailed, cargo-level information
not found in the Customs data. Specifically, the following data elements are required:

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•
•

API Gravity. Customs data provide only two TSUSA (Tariff Schedule of the
United States Annotated) codes for crude oil, distinguishing only oil above/below
25 degrees API. Actual API gravity is collected by the EIA-856 as needed.
Crude Stream. In order to place crude oil in the precise categories required by
IEA, the crude stream (e.g., Saudi Light) is necessary. Customs currently collects
only country-of-origin information which does not specify the crude stream.

The need for API gravity and crude stream data was particularly important during the
Persian Gulf crisis for comparisons of quality of Iraqi and Kuwaiti crude oils versus
replacement crude oils.
One difference between the data series is due to Customs’ treatment of net-back
purchases. Net-back purchases are peculiar in that a cargo’s value will not be assessed
until after the crude has landed. Because the EIA-856 allows companies to resubmit, an
estimated price or no price may be reported on the original submission when the crude is
first reported; but when the actual value has been calculated the company resubmits their
correct values. Since Customs does not have re-submissions, the original estimates do
not get corrected. The difference occurs because EIA uses a value based on after landing
adjustments and Customs uses invoice value which can differ significantly in a volatile
market. Thus, due to the lack of important information such as API gravity and crude
stream, the lack of accuracy due to using an unrevised bill of landing price, and timing
problems; the Customs’ data are not considered an adequate alternative to the EIA-856
data.
(F).

“Petroleum Products Sales Identification Survey”: EIA-863

The EIA-863 is the primary petroleum survey used to construct and maintain the
petroleum marketing sampling frame of petroleum product sellers. There are no known
surveys that collect data comparable to the EIA-863 that can be used by EIA. In
particular, EIA’s other surveys do not provide a comprehensive list of product sellers.
Lists or frames of the U.S. Census Bureau or the Bureau of Labor Statistics can not be
shared with EIA due to privacy/confidentiality restrictions. Lists constructed by private
firms, industry associations, and state governments are acquired by EIA to construct the
EIA-863 mailing lists, but these other lists do not contain measures of size, corporate
relationships, or other information needed for sampling.
(G).

“Winter Heating Fuels Telephone Survey”: EIA-877

As part of EIA’s review process, EIA examined all surveys and published data identified
as having potential overlap with this survey. The data are collected weekly from October
1 through March 15.
Monthly, State-level residential home heating oil and propane prices are collected by EIA
on Forms EIA-782A and EIA-782B, “Monthly Petroleum Product Sales Reports.”
However, since these prices are weighted by the volume of residential sales, the data are
not available until approximately 60 days after the end of the month. Thus, the EIA-782

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data do not provide timely enough or frequent enough information for monitoring a
potential emergency situation.
The Bureau of Labor Statistics publishes monthly residential heating oil prices for
metropolitan areas as part of the Consumer Price Index. As above, the BLS geographic
coverage of selected metropolitan areas does not meet the need for State-level prices for
each heating oil state in the Mid-west, East Coast, and West Coast regions.
(H).

“Motor Gasoline Price Survey”: EIA-878

The EIA-878 collects the retail price, by grade and formulation of gasoline at the
national, regional, and select state, and city levels. There is no comparable data series
available for the different formulations of gasoline in ozone non-attainment areas, and
attainment areas as designated by the Environmental Protection Agency that satisfy
EIA’s and EIA’s customers’ requirements for unbiased, representative, current price data.
The Lundberg survey is considered inadequate since it only collected prices every other
Friday which isn't frequent enough to monitor fast developing market shifts. The
American Automobile Association (AAA) releases daily retail price information from its
website at http://www.aaanewsroom.net/Main.asp based on data provided by OPIS.
These prices are credit card transaction based and do not represent a specific point in
time. In addition, it is not known how representative the set of transactions are of all
retail outlets. They also do not provide separate prices by formulation of gasoline, such
as reformulated or conventional gasoline. The EIA-782, "Monthly Petroleum Product
Sales Report" survey and the Bureau of Labor Statistics Consumer Price Index only
publish a retail gasoline price once a month. Thus, due to timeliness, frequency, and
reliability problems, other data sources do not meet DOE's needs for timely, independent
source prices.
(I).

"On-Highway Diesel Fuel Price Survey": EIA-888

The Oil Price Information Service, TCHEK, and AXXIS collect daily prices for onhighway retail diesel fuel from an unspecified sample of outlets and sell the data for a
fee. Their samples lack adequate refiner coverage in some regions, have an insufficient
rural/urban mix, and also draw heavily from outlets that have a data link with credit
companies and are not probability based. The Lundberg survey publishes a retail low
sulfur diesel fuel price by PADD and nationally. The Lundberg survey is inadequate to
monitor changes in retail motor vehicle diesel fuel prices because it only publishes
monthly prices. In addition, its methodology is not made publicly available. The EIA782, "Monthly Petroleum Product Sales Report" survey and the Bureau of Labor
Statistics Consumer Price Index also publish a retail on-highway diesel fuel price once a
month, one month after the reference period. A monthly data series available one month
later is not adequate to measure sudden price spikes in the retail market or supply
shortages such as the market shifts which occurred in November 1993, April 1996 and
December 1999, spring 2001 and 2003, and the fall 2005 and 2006. The Interstate
Commerce Commission (ICC) published a national diesel fuel price but discontinued
their weekly survey as of May 31, 1994 after meetings with EIA which resulted in the

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implementation of the EIA-888. The EIA-888, which makes use of statistical sampling
and estimation methodology, was designed to replace the ICC national diesel fuel price.
4b.

The Inadequacies of Similar Data

There are three different methodologies used for calculating crude oil and petroleum
product price data: posted or spot prices, base period weighted average prices, and
current period weighted average prices. Posted or spot prices are collections of bid/post
prices from a supplier or suppliers at a given location for a given size shipment. These
prices are primarily useful to purchasers and sellers who are intimately involved in
evaluating marginal prices in a volatile market on a daily basis. The primary
disadvantage of posted or spot prices is that they represent a small percentage of the
market. Therefore, these prices cannot effectively be used to represent State, regional, or
national average prices. Also, posted or spot prices do not reflect the extensive
contribution of contract transactions in determining the prices of crude oil or products;
nor do they indicate how much volume is purchased or sold at that price (i.e. no product
may have been sold at all at a particular posted price). Among the daily/weekly journals
publishing posted/spot prices are: Petroleum Intelligence Weekly, Oil Daily, Journal of
Commerce, Mid-East Journal, Arab Oil and Gas, Oil Express, Platts Oilgram, and Oil
Buyers Guide International.
Base period weighted average prices employ fixed weights. By using a fixed weight
methodology, only the current prices are collected each month, promoting rapid
turnaround for publication. Base period weighted average prices tend not to reflect the
contributions of structural and institutional changes, thus misrepresenting the market
when weights do not reflect current activity. For example, an overall shift in sales from
conventional gasoline to reformulated gasoline is a market shift that may not be reflected
using a fixed weight methodology. Among the best known sources using this method are
the Department of Agriculture, the Bureau of Labor Statistics, and The Lundberg Letter.
The current period weighted average price method employed by EIA takes the reference
month's sales volumes and the revenue for the reference month to calculate a weighted
average price for that month. This is the only method that takes into account all
transactions, including contracts, discounts, and distress sales weighted by their actual
volumes of sales, and aggregates them into a representative average price.
In addition, EIA provides the only available source of State prices for the full range of
petroleum products and by various types of sales. For reasons of content, methodology,
industry geography, customer coverage, and the purposes for which the data are
collected, EIA data are necessary to allow for the reliable macro/micro analysis of current
conditions and trends.
Regarding Form EIA-877, as stated in Section 4, "Efforts to Identify Duplication," an
evaluation of similar data found no other sources that provided the required frequency,
timeliness, and geographic coverage needed to monitor No. 2 heating oil and propane
prices and inventories.

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Regarding Form EIA-878, as stated in Section 4, "Efforts to Identify Duplication," an
evaluation of similar data found no other sources that provided the required frequency,
timeliness, and coverage needed to monitor regional retail motor gasoline prices.
Regarding Form EIA-888, as stated in Section 4, "Efforts to Identify Duplication," an
evaluation of similar data found no other sources that provided the required frequency,
timeliness, and coverage needed to monitor regional retail on-highway diesel fuel prices.
5. Reduction of the Burden on Small Businesses or Other Small Entities
Minimizing burden to small businesses is a primary concern to EIA. It is important that
all sizes of firms, large and small, participate in surveys such as the EIA-782, EIA-821,
EIA-877, and EIA-878 to obtain a proper representation of the petroleum industry. The
inclusion of smaller firms is necessary to accurately portray State volumes and prices.
Within the EIA-782B sample design, however, the EIA has taken several steps to
minimize burden to small, individual dealers:
•

•
•

•

The sample contains a certainty strata including multi-State companies dealing in
four or more States and dealers whose volumes account for 5 percent or more of a
State’s volume for either any sampling target variable or specific end-use
category. The certainty strata results in accounting for approximately 95 and 98
percent of residual fuel oil volumes, retail and resale, respectively; 88 percent of
wholesale distillate volumes; and 83 percent of the reseller motor gasoline
wholesale volumes by using only 2 percent of the number of companies that are in
scope.
Noncertainty respondents are sampled by State using a form of probability
proportional to size. This sampling method was shown to produce the minimal
total sample sizes that preserve the accuracy of the estimates required.
Sample sizes reflect sampling with respect to only published geographic areas to
reduce the total number of respondents, i.e. not all residential distillate States are
published so sampling in those areas occurs only as necessary for the estimates at
a more aggregated geographic level. Accuracy targets vary by product and
geographic level to further reduce burden.
The EIA-782 design also provides for sample rotation through the use of
permanent random numbers. Rotations generally rotate 50% of the smaller
volume dealers in order to not only reduce individual respondent burden but also
protect data continuity. The sample is rotated when it is decided that sample
deterioration and non -response is becoming a problem, subject to annual budgets.

Similarly, the EIA-821 is also required to collect data from both large and small
businesses. In the EIA-821 sample design, refiners, multi-State dealers and large
companies greater than five percent of the total sales for a particular category in a State
are selected with certainty. The remainder of the universe is cross-stratified by type of
sale and volume for each State. In general, this allocation yields smaller sampling
fractions for smaller companies and thereby reduces total small business burden.

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The quadrennial EIA-863 survey, by the nature of its purpose (to develop a sampling
frame), is mailed to all potential respondents to petroleum marketing surveys except
those firms already reporting on the EIA-821 form. This includes both large and small
businesses. The EIA-863 sampling frame, however, assists in maintaining low
respondent burden by allowing for the use of sophisticated sampling techniques, and by
providing up-to-date information that alleviates the need for over-sampling to correct for
sample frame limitations.
All sizes of firms, large and small, participate in the EIA-877 survey in order to
accurately estimate State-level residential prices. However, to minimize the burden on
small No. 2 heating oil dealers, a sample design similar to the EIA-782B,
“Resellers’/Retailers’ Monthly Petroleum Product is used for the EIA-877 survey. In this
design, dealers are stratified for each State by size of sales volumes, according to the
volumes reported in the EIA-863 frame. This results in smaller sampling fractions
overall and smaller sampling fractions for smaller dealers than for larger dealers.
To minimize the burden of propane dealers, certainty companies are selected in those
states where the company represents 5% or more of the state volume. Outlets within the
company are then selected to represent the company where the number of outlets is
defined by the multiples of 5% that the company represents. Non-certainty outlets are
then stratified by size, to further reduce burden. The sampling fractions varies by State
according to the variance in the State and the size of the population.
The EIA-14, EIA-182, and the EIA-856 surveys do not include small businesses in their
respondent populations.
6. Results of Collecting Data Less Frequently
The Petroleum Marketing survey forms vary in periodicity depending on the
requirements and uses for the subject survey data. Forms filed on a monthly basis
include EIA-182, EIA-856, EIA-14, and EIA-782A, B and C. All of these forms collect
product price and volume data, with the exception of the EIA-782C which collects only
product volumes. The annual survey, EIA-821, and the quadrennial universe frame
survey, EIA-863, collect only product volume data.
The forms collecting product price data must be current in order to be meaningful, which
necessitates monthly collection. The one monthly form that collects only volumetric
data, the EIA-782C, is widely used by State governments on a monthly basis. When the
EIA-782 survey was initially proposed in April 1982, a quarterly form, the EIA-783, was
included in the series. However, during the extensive public hearings and consultations
with data providers and users, State governments in particular objected strongly to the
quarterly data collection. State governments are frequent, regular, monthly users of
petroleum products supply, marketing and distribution data. The monthly EIA-782 data
collection and publication enables these governments and other data users to receive
accurate and timely data for use in trend analysis, demand modeling and forecasting,

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policy evaluation and analysis, contingency planning, and budgetary planning. At the
same time, data providers indicated that no savings in cost or effort would result from
implementation of a quarterly form. The data providers were also concerned that since
the State governments needed the data monthly, the States would conduct 50 separate
surveys. The data providers preferred to provide the data once to EIA rather than
separately to each State government.
The EIA-856, EIA-14 and EIA-182 are required on a monthly basis because of the
integral role these surveys play in the analysis of the nationally critical crude oil market.
The EIA-856 must fulfill the requirements of the IEA agreement, provide critical
information to the Strategic Petroleum Reserve Office for evaluating market conditions in
connection with its purchases of crude oil, and meet the analytic requirements of EIA and
other data users. Data gathered by the EIA-182 and EIA-14 are also used on a regular
monthly basis by Congress, DOE and other users for monitoring, forecasting and market
analysis. The price data collected by these survey forms would not be adequate for
realistic industry analysis if collected less than monthly.
The EIA-821 form is an annual collection. EIA uses the EIA-821 data to report to
Congress on fuel oil supplies by economic sector in the Annual Energy Review. Data
collected at greater intervals than annually would severely handicap modeling performed
by the Department for use in energy policy development, and in its energy forecasting
and consumption programs.
The EIA-863 is a quadrennial survey used to maintain the adequacy and currency of the
petroleum marketing sampling frame of petroleum product sellers. The four-year
schedule is necessary to correct for the frame deterioration that occurs as a result of the
dynamic nature of the petroleum industry. The sampling frame deteriorates rapidly over
time because of the high birth and death rate in the retail sector of fuel oil dealers and
other small businesses. The industry also has a characteristically high rate of mergers
and consolidations. If the identification survey is not performed on a quadrennial cycle,
then sample deteriorations would occur resulting in over sampling, increased burden and
decreased statistical quality.
The EIA-877 is a six month, weekly survey. Less frequent reporting would not permit
EIA to meet its obligation of providing timely, reliable information in order to monitor
these critical fuels during the heating season. The “Needs For and Uses of Petroleum
Marketing (PM) Data” describes the need by Congress for timely information.
The EIA-878 and EIA-888 are weekly surveys. Less frequent reporting would not permit
EIA to meet its obligation of providing timely, reliable information in order to monitor
these critical transportation fuels which are more volatile during market disruptions due
to short term supply disruptions, price fluctuations, natural disasters or other catastrophic
events.

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7. Special Circumstances
The justification requiring respondents to report information more frequently than every
quarter has been described above. Form EIA-782C is requested in only 20 days after the
end of the reporting period because the state energy offices need information on supply
conditions by the earliest review of the prime supplier reports which are generated by the
EIA-782C. In the event of fuel shortages, the prime supplier reports are used by a
governor to request that 3% of the total volume expected to be sold in a state be set aside
as a special product reserve for that state.
8. Summary of Consultations Outside the Agency
On June 7, 2006, EIA published a Federal Register Notice (Volume 71, Number 100,
page 32941) inviting public comments on the proposed extension of the Petroleum
Marketing (PM) survey forms. The Bureau of Economic Analysis responded to the
notice with a letter of support for the Petroleum Marketing Surveys. BEA stated that it
uses the EIA-14 and the 782C to prepare the national income and product accounts. BEA
supports the proposed addition of ultra-low-sulfur diesel (ULSD) fuel, although it has no
immediate plans to incorporate the information into its programs. In addition, the Diesel
Technology Forum wrote “The diesel industry is at the precipice of a number of
significant regulatory changes mandated by the Environmental Protection Agency (EPA)
that affect both highway and non-highway diesel fuel specifications over the next 5 years.
The importance of this information is even greater now as this information becomes
essential for understanding the state of the petroleum product market, supply and pricing
owing to these major changes form 2007-2014” in support of the Petroleum Marketing
Surveys. To prepare for the introduction of Ultra-Low Sulfur Diesel, EIA had
teleconferences with representatives of NACS (National Association of Convenience
Stores), Sigma (Society of Independent Gasoline Marketers of America), and NATSO
(National Association of Truck Stop Operators), and coordinated with the Clean Diesel
Alliance.
In the March 23, 2006 Federal Register (71 FR 14690), EIA announced its plan to
discontinue the collection of Forms EIA-182 and EIA-856 due to budget constraints after
the data for July 2006 was collected. As a result of that notice, users of the survey data
from US Legislature, International Energy Agency (IEA), Federal and State Government
Agencies and Petroleum Industry/Private Sector submitted letters requesting EIA to
reconsider the decision to discontinue the forms citing the importance of the information.
EIA subsequently released a second Federal Register Notice announcing the continuation
of the collection of the surveys through the October 2006 reference month which are due
by November 30, 2006. After EIA’s budget for Fiscal Year 2007 is finalized, EIA will
make a decision regarding further continuation of those two surveys based on funding
availability and EIA priorities. On October 17, 2006, the Federal Register notice (71 FR
61033) was published stating its submission of the Petroleum Marketing Program to the
Office of Management and Budget.
To avoid the disruption and costs that would be inherent in any temporary suspension
followed by a restart, EIA had informed the Congress that it would try to continue the

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surveys until the Congress completes action on EIA’s FY 2007 budget. Since the timing
of final Congressional appropriations action still remains uncertain, EIA subsequently has
secured bridge funding to enable continuation of the surveys pending completion of
Congressional budget action. EIA will defer a final decision regarding the
discontinuance of the EIA-182 and 856 forms until the Congress completes all action on
EIA’s Fiscal Year 2007 budget. EIA is therefore requesting clearance for the EIA-182
and 856 survey forms.

9. Remuneration
There are no plans to pay respondents to respond to these surveys.
10. Provisions for Confidentiality of Information
The information reported on the petroleum marketing survey Forms EIA-863 (only Parts
II, Preparer Information, and III, Total Sales Volumes by State, of the EIA-863),
EIA-878, and EIA-888 is considered confidential in accordance with the Confidential
Information Protection and Statistical Efficiency Act of 2002 (P.L. 107-347) and the
information will be used solely for statistical purposes. Instructions to the forms will
include the following:
The information you provide will be used for statistical purposes only. In
accordance with the Confidential Information Protection provisions of Title 5,
Subtitle A, Public Law 107-347 and other applicable Federal laws, your responses
will be kept confidential and will not be disclosed in identifiable form to anyone
other than employees or agents without your consent. By law, every EIA
employee as well as every agent has taken an oath and is subject to a jail term, a
fine or up to $250,000, or both if he or she discloses any identifiable information
about you.
The information reported on the petroleum marketing survey Forms EIA-14, EIA-182,
EIA-782A, EIA-782B, EIA-782C, EIA-821, EIA-856, EIA-863 (only Part I, Respondent
Identification Data of the EIA-863), and EIA-877 will be treated as protected, but is
excluded from coverage under the Confidential Information Protection and Statistical
Efficiency Act of 2002 (P.L. 107-347). The information collected on these forms will be
used for statistical purposes and may be made available for non-statistical purposes.
Except for Form EIA-821, disclosure limitation methods will be applied to protect
against any unauthorized or inadvertent disclosure through publication of aggregate
estimates in tables. The respondents are informed of the confidentiality provisions by the
following statement that appears in the instructions for these forms.
The information reported on this form will protected and not disclosed to the public to
the extent that it satisfies the criteria for exemption under the Freedom of Information
Act (FOIA), 5 U.S.C. §552, the DOE regulations, 10 C.F.R. §1004.11, implementing
the FOIA, and the Trade Secrets Act, 18 U.S.C. §1905.

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The Federal Energy Administration Act requires the EIA to provide company-specific
data to other Federal agencies when requested for official use. The information
reported on this form may also be made available, upon request, to another
component of the Department of Energy (DOE); to any Committee of Congress, the
Government Accountability Office, or other Federal agencies authorized by law to
receive such information. A court of competent jurisdiction may obtain this
information in response to an order. The information may be used for any
nonstatistical purposes such as administrative, regulatory, law enforcement, or
adjudicatory purposes.
Disclosure limitation methods are not used on tabular information for statistics based on
information reported on Form EIA-821. For Form EIA-821, the following will also be
included in the forms instructions.
The statistical tables based on the EIA-821 survey information are not subject to
statistical nondisclosure procedures. Thus, there may be some table cells which
are based on data from only one or two respondents, or which are dominated by
data from one or two large respondents. In these cases, it may be possible for a
knowledgeable user of the data to make inferences about the data reported by a
specific respondent.
Respondents to Form EIA-782C are informed that State energy offices are interested in
receiving a copy of the EIA-782C and the respondent may chose to provide a duplicate of
each monthly report directly to the appropriate state energy office where the respondent
made sales.
For Form EIA-782C, the following will also be included in the forms instructions.
Information provided to state energy offices are not subject to federal regulations
governing disclosure of company level data. Contact your state energy office for details
on their data confidentiality policies and regulations.

11. Justification for Sensitive Questions
There are no questions of a sensitive nature asked on the eleven Petroleum Marketing
survey forms.
12. Estimated Average Reporting Burden
The overall annual burden for this package is estimated to be 121,156. Below is the
reporting burden estimates for Petroleum Marketing surveys, for the burden for the
individual forms contained in this package.

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Survey
Number

EIA-14
EIA-182
EIA-782A
EIA-782B
EIA-782C
EIA-821
EIA-856
EIA-863
EIA-877
EIA-878
EIA-888

Freq
.

M
M
M
M
M
A
M
Q
S
W
W

Size
Avgerage
of
Number of
Universe Respondents
Annually

67
84
95
24400
185
24400
39
24400
14000
115000
24400

TOTAL

Number of
Response
Responses Burden Per
Annually Respondent

67
84
95
2067
185
4041
39
5017
1200
800
350

804
1008
1140
24804
2220
4041
468
5017
30000
41600
18200

13945

129302

1.75
4.3
15
2.5
2.1
4.4
6.1
1
0.1
0.05
0.05

Total Response
Burden
Rate
Hours

1407
4334.4
17100
62010
4662
17780
2854.8
5017
3000
2080
910

99.8
100
99.5
91
98.8
90.9
99.7
90
99
98
99

121156

Q=Quadrennial
A=Annually
M=Monthly
S=Semi-monthly
(October-March)
W=Weekly

13. Total Annual Cost Burden to Respondents
There are no additional capital, start-up, or operation and maintenance costs associated
with these surveys. Based on the reporting burden, the Cost to the respondents is
estimated to be:
$6,905,892 (121,156 hours x $57 per hour).
An average cost per hour of $57 is used because that is the average loaded (salary plus
benefits) cost for an EIA employee. EIA assumes that the survey respondent workforce
completing surveys for EIA is comparable with the EIA workforce.
14. Estimate of Costs to the Federal Government
The annual cost including personnel, for development/maintenance, collection,
processing, analysis, and publication for the eleven Petroleum Marketing survey forms is
$3,675,000.
15. Changes in Burden
Respondent burden has decreased by 1,378 hours (program change) primarily due to the
consolidation of Oxygenated gasoline into Conventional gasoline. The decline would
have been more substantial except for the additional break-out necessary for Ultra-Low
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Sulfur Diesel. See Section 3. ”Using Automated, Electronic, Mechanical, or other
Technological Collection Techniques to Reduce Burden on Respondents” and Section 12,
reporting burden estimates by PMD survey, for additional burden information.
16. Schedule for Collecting and Publishing Data
(A)

The data reported on Forms EIA-878 and EIA-888 is collected on Monday of
each week. Prices are as of 8:00 a.m. The data are compiled and published the
same day on EIA’s website at www.eia.doe.gov by 5:00 P.M, and also 2 days
later in the Wednesday 9:00 A.M. release of Weekly Petroleum Status Report.
The data are also published daily internally within EIA in the Energy Situation
Analysis Report.

(B)

The data reported on Form EIA-877 are collected weekly from October 1 through
mid March. The data are compiled and published on EIA’s website at
www.eia.doe.gov.

(C)

Monthly Surveys - (EIA-14; EIA-182; EIA-782A, B, C; EIA-856)
(1) EIA-782C forms due

20 calendar days after end of
reference month

(2) All other monthly forms due

30 calendar days after end of
reference month

(3) Processing of data completed

45 calendar days after end of
reference month

(4) 782C data reports
published electronically

50 calendar days after end of
reference month

(5) Petroleum Marketing Monthly
(PMM) production completed
(D)

60 calendar days after end of the
reference month

Annual Survey (EIA-821)
(1) Forms Mailed

Mid January

(2) Responses due

Early March

(3) Second Mailing to nonrespondents

Early April

(4) Close-out data collection

Early August

(5) Completion of analysis/validation

Mid August

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(6) Post on Internet
(E)

End August

Quadrennial Survey (EIA-863 collecting 2006 sales information)
(1) Forms Mailed

Mid January, 2007

(2) Responses due

Early March, 2007

(3) Second mailing to nonrespondents

Late April, 2007

(4) Load EIA-821 data

Mid August, 2007

(5) Complete validation phone calls

End of August, 2007

(6) File ready for sampling purposes

September, 2007

17. OMB Expiration Date
The expiration date will be displayed on the petroleum marketing survey forms.
18. Exception to Certification Statement
There are no exceptions to the certification statement of OMB Form.

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