For future collections,FERC will provide a detailed explanation of burden hour reduction/increase estimates in the supporting statement.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
09/30/2012
36 Months From Approved
09/30/2009
222
0
222
222
0
444
84,825
0
0
In accordance with the Natural Gas Act (NGA), the Department of Energy Organization Act (DOE Act), and the Energy Policy Act of 2005 (EPAct 2005), FERC regulates the transmission and wholesale sales of natural gas in interstate commerce, monitors and investigates energy markets, uses civil penalties and other means against energy organizations and individuals who violate FERC rules in the energy markets, and administers accounting and financial reporting regulations and oversees conduct of regulated companies.
In order to carry this out, FERC (in Orders No. 677 and 644) imposed record retention requirement on sellers to retain, for 5 years, all information upon which they billed prices charged for natural gas sold pursuant to their market-based sales certificate and the prices reported for use in price indices. Regulations were promulgated in 18 CFR 284.288 and 284.403.
The requirement is necessary to ensure consistency with the rule prohibiting market manipulation (regulations adopted in FERC Order No. 670, implementing the EPAct 2005 anti-manipulation provisions) and the generally applicable 5-year statute of limitations where the FERC seeks civil penalties for violations of the anti-manipulation rules or other rules, regulations, or orders to which the price information may be relevant.
The reduction in industry burden and cost reflects the increased use, and less expensive cost, of electronic records storage.
The estimated change to the burden for FERC-916 (reduction of 1 hour per respondent per year) is due the following factors.
1. During the last clearance of the FERC-916 for the final rule in FERC Docket No. RM06-14, FERC increased the record retention period to 5 years from 3 years. That required changes to the companies procedures (for paper and electronic records that were retained), as well as programming changes for electronic records. It might also have necessitated changes to the companies off-site storage contracts to lengthen the retention period. That work has been completed, and companies have familiarity with the requirements.
2. Since the changes required in 2006 (by RM06-14, no. 1 above) have been completed, no substantive changes have been, or are being, made.
3. In the last three years, the industry trend has been for companies to maintain and retain their records electronically.
4. The cost of electronic storage has gone down in the last 3 years.
Therefore, companies would have reduced cost and burden of record retention, due to the economies of being able to retain a large amount of data on a small electronic medium, when compared to paper with the associated, required file cabinets, rental of storage space, etc.
Therefore we estimated a reduction of 1 hour per respondent per year.
$1,480
No
No
Uncollected
Uncollected
No
Uncollected
Patricia Morris 202 208-6990
Reginfo record details
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
burdendecrease explan.doc
FERC-916, Record Retention Requirements for Pipelines Providing Unbundled Sales Service, and Persons Holding Blanket Marketing Certificates