Natural Gas Supporting Statement Pt A

Supporting Statement A
for the
Natural Gas Data Collection Program Package
Office of Management and Budget (OMB) # 1905-0175
Introduction
Request is made for a 3-year extension of the following currently-approved natural gas survey
forms with proposed revisions listed below:
EIA-176, “Annual Report of Natural and Supplemental Gas Supply and Disposition,”
EIA-191, “Monthly and Annual Underground Natural Gas Storage Report,”
EIA-757, “Natural Gas Processing Plant Survey,”
EIA-857, “Monthly Report of Natural Gas Purchases and Deliveries to Consumers,”
EIA-895, “Annual Quantity of Natural Gas Production Report,”
EIA-910, “Monthly Natural Gas Marketer Survey,” and
EIA-912, “Weekly Underground Natural Gas Storage Report.”
Forms EIA-176, EIA-191, EIA-757, EIA-857, EIA-910, and EIA-912 are all mandatory. Form
EIA-895 is voluntary.
Summary of Changes
The U.S. Energy Information Administration (EIA) is proposing the following changes to each of
the survey forms:
•
•
•
•
•

•
•

For Form EIA-176: Add the collection of the respondent’s participation in retail choice
programs as well as whether the respondent has acquired or sold parts of its service
territory.
For Form EIA-191A: Discontinue annual form and add the data elements to the monthly
form EIA-191M.
For Form EIA-191M: Add data elements currently collected on EIA-191A including
storage field capacity and maximum deliverability. Re-name form EIA-191 and increase
burden from 2.4 to 2.6 hours per response.
For Form EIA-757: Remove data protection and release information at the processing
plant-level .
For Form EIA-857: Add the collection of natural gas used by the reporting company as
well as monthly deliveries to the vehicle fuel sector. Decrease the number of sampled
companies from 400 to 310 via a change in sample methodology from the current
probability proportion to size (PPS) design to a cutoff design.
For Form EIA-895: Discontinue collection as other sources of the data collected have
been identified.
For Form EIA-910: Reduce the collection to 6 States instead of the currently collected
12.
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•

For Form EIA-912: Increase number of respondents from 70 to 85.

In the Federal Register notice posted March 2, 2011, 76 FR 41-4622, the EIA proposes that the
above mentioned changes related to monthly forms become effective with the collection of
data for the January 2012 reference period, and those changes related to annual forms become
effective with the collection of data for the 2011 reference period. The current versions of the
monthly forms will be used until data are collected for January 2012.
Status of Reporting Burden on Form EIA-857
In 2010, OMB granted approval for a non-substantive change to the EIA-857 “Monthly Natural
Gas Report of Purchases and Deliveries” with the following Terms of Clearance: Terms of the
previous clearance remain in effect. Upon resubmission at the currently approved expiration
date, it is suggested the agency revisit the suggested non-substantive change and determine
whether it imposed any respondent burden.
The EIA began collecting the new data element on the EIA-857, “monthly total system sendout
of reporting utilities,” for reference month August 2010. The introduction of the sendout
question to the EIA-857 imposed a temporary burden to some respondents that had to locate
the associated records. However there were no respondents that did not have the information
already in their records. Also, pipeline companies that make up 10 percent of the 400 monthly
respondents did not have to report this information as it is not applicable to their operations.
Similarly, smaller respondents, typically municipal gas systems that account for approximately
20 percent of the 400 respondents, were already reporting the equivalent of total system
sendout in their citygate purchases, line 1. For those companies, no additional burden was
assessed to locate any additional records to comply with the additional question.

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Table of Contents
A. JUSTIFICATION.................................................................................................................. 1
A1. LEGAL AUTHORITY ..................................................................................................................... 1
A2. NEEDS AND USES OF DATA ......................................................................................................... 2
A3. DESCRIPTION OF INDIVIDUAL SURVEYS IN EIA’S NATURAL GAS DATA COLLECTION PROGRAM PACKAGE .. 4
A3.1. Form EIA-176, “Annual Report of Natural and Supplemental Gas Supply and
Disposition”.............................................................................................................................. 4
A3.2. Form EIA-191, “Underground Natural Gas Storage Report” ....................................... 6
A3.3. Form EIA-757, “Natural Gas Processing Plant Survey” ................................................ 7
A3.4. Form EIA-857, “Monthly Report of Natural Gas Purchases and Deliveries to
Consumers” .............................................................................................................................. 9
A3.5. Form EIA-895, “Annual Quantity and Value of Natural Gas Production Report”..... 11
A3.6. Form EIA-910, “Monthly Natural Gas Marketers Survey” ......................................... 12
A3.7. Form EIA-912, “Weekly Underground Natural Gas Storage Report”........................ 13
A4. TECHNOLOGICAL CONSIDERATIONS TO REDUCE BURDEN ................................................................ 14
A5. EFFORTS TO IDENTIFY DUPLICATION AND ANALYSIS OF SIMILAR EXISTING INFORMATION ..................... 14
A6. IMPACTS ON SMALL BUSINESSES OR OTHER SMALL ENTITIES........................................................... 16
A7. CONSEQUENCES OF LESS FREQUENT REPORTING ........................................................................... 17
A8. SPECIAL CIRCUMSTANCES.......................................................................................................... 17
A9. SUMMARY OF CONSULTATIONS OUTSIDE THE AGENCY................................................................... 18
A10. PAYMENTS OR GIFTS .............................................................................................................. 20
A11. PROVISIONS FOR DATA PROTECTIONS ....................................................................................... 20
A12. JUSTIFICATION FOR QUESTIONS OF A SENSITIVE NATURE .............................................................. 21
A13. ESTIMATES OF RESPONDENT BURDEN HOURS ............................................................................ 21
A14. ESTIMATE OF COST BURDEN TO RESPONDENTS - CAPITAL/START-UP COSTS AND OPERATION/ .......... 22
A15. ANNUAL COST TO THE GOVERNMENT ....................................................................................... 22
A16. CHANGES IN BURDEN OR COSTS TO RESPONDENTS ...................................................................... 22
A17. DATA COLLECTION AND PUBLICATION ....................................................................................... 24
A18. DISPLAY OF EXPIRATION DATE ................................................................................................. 25
A19. EXCEPTIONS TO CERTIFICATION ................................................................................................ 25

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A. Justification
A1. Legal Authority
The authority for these data collections is provided by the following provisions:
15 U.S.C. §772(b), of the Federal Energy Administration Act of 1974 (FEA Act), Public Law 93275, outlines the types of individuals subject to the information collection authority delegated
to the [Secretary] and the general parameters of the type of data which can be required.
Section 772(b) 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 exercise of
functions under the Act.”
The functions of the FEA Act are set forth in 15 U.S.C. §764(b), of the FEA Act, which states that
the Administrator shall, to the extent he is authorized by Section 764(a) of the FEA Act,
“(2) assess the adequacy of energy resources to meet demands in the immediate and
longer range future for all sectors of the economy and for the general public; . . .
(4) develop plans and programs for dealing with energy production shortages;
(5) promote stability in energy prices to the consumer, promote free and open
competition in all aspects of the energy field, prevent unreasonable profits within the
various segments of the energy industry, and promote free enterprise;
(6) assure that energy programs are designed and implemented in a fair and efficient
manner so as to minimize hardship and inequity while assuring that the priority needs of
the Nation are met;...
(9) collect, evaluate, assemble, and analyze energy information on reserves, production,
demand, and related economic data.”
“(12) perform such other functions as may be prescribed by law.”
As the authority for invoking Section 764(b) above, 15 U.S.C. §764(a), of the FEA Act in turn
states:
“Subject to the provisions and procedures set forth in this Act, the [Secretary] shall be
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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 Administrator by the Congress.”
Additional authority for this information collection is provided by 15 U.S.C. §790a of the FEA
Act, which states that the Administrator:
“… [Shall] establish a National Energy Information 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 ...
“(b) the System shall contain such energy information as is necessary to carry out the
Administration's statistical and forecasting activities ..., and 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 nonmineral energy resources and the
production, distribution, and marketing of mineral fuels and electricity;
“(2) the consumption of mineral fuels, nonmineral energy resources, and electricity by
such classes, sectors, and regions as may be appropriate for the purposes of this Act;
“(3) the sensitivity of energy resource reserves, exploration, development, production,
transportation, and consumption to economic factors, environmental constraints,
technological improvements, and substitutability of alternate energy sources; ...
“(5) industrial, labor, and regional impacts of changes and patterns of energy supply and
consumption.”
A2. Needs and Uses of Data
The purpose of the Natural Gas Data Collection Program Package is to collect basic and detailed
data to meet the EIA’s mandates and energy data users’ needs. Adequate evaluation of the
natural gas industry requires collection and processing of data related to natural gas
production, processing, transmission, distribution, storage, marketing, and consumption.
(1) The data that the EIA collects are used to address significant energy industry issues. In
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line with its mandated responsibility to collect data that adequately describe the natural
gas marketplace, the EIA evaluates the lifecycle of natural gas from its reserves and
production to consumption and prices throughout the upstream and downstream
markets. The data collected by the Natural Gas Data Collection Program Package
surveys are among those that are required to address the status and future of the role
of natural gas in the energy mix and overall economy. Among the data series resulting
from the information collected in these surveys is the rate, location, and source of
natural gas produced and entering the market, the quantities being stored and the
location of the storage, and the quantities being delivered to various consuming sectors.
Prices are also reported on at various points in the production and distribution stream.
(2) EIA must collect some data at the State level. Congressional and State Agency users
have strongly emphasized their need for such data. EIA’s collection of these data is
consistent with its mandated responsibilities to collect specific product information for
appropriate geographic areas and economic sectors, to act as a central clearinghouse,
and to disseminate relevant information to the States. At the same time, the EIA is
committed to operate its data collections in a manner that will minimize the industry’s
reporting burden to the extent possible.
(3) Timely data are essential to policy makers and industry planners who make decisions
affecting all aspects of the natural gas industry. Customer surveys have increased the
EIA’s awareness of the need for data as quickly as reliable, accurate data can be
released.
(4) Alternative data sources do not adequately satisfy the needs of the 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.
The data collected by the EIA 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 comprehensive data provided by the
Natural Gas Data Collection Program Package survey forms.
Data from the forms in the Natural Gas Data Collection Program Package are published in the
Annual Energy Outlook, Annual Energy Review, Natural Gas Annual, Natural Gas Monthly,
Natural Gas Weekly Update, Weekly Natural Gas Storage Report, Monthly Energy Review,
Short-Term Energy Outlook, State Energy Profiles, and numerous other EIA products.
EIA’s natural gas data are published in papers, trade journals, and technical reports as well as
cited and republished in reports by consulting firms, financial institutions, and numerous other
entities. A number of State agencies republish EIA data in reports to the public including
Florida, Indiana, Iowa, Montana, New Hampshire, New Mexico, South Carolina, Tennessee,
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Utah, Washington, Wisconsin, and Wyoming.
A3. Description of Individual Surveys in EIA’s Natural Gas Data Collection Program Package
Following is a listing of the survey forms across all OMB Collection Packages that comprise the
EIA’s natural gas data collection program. For reference purposes, current OMB numbers of the
surveys described in this section, as well as surveys referenced throughout this package, are
described below:
EIA-64A, “Annual Report of the Origin of Natural Gas Liquids Production”: OMB# 1905-0057,
EIA-176, “Annual Report of Natural and Supplemental Gas Supply and Disposition”: OMB#
1905-0175,
EIA-191, “Monthly and Annual Underground Natural Gas Storage Report”: OMB# 1905-0175,
EIA-757, “Natural Gas Processing Plant Survey”: OMB# 1905-0175,
EIA-816, “Monthly Natural Gas Liquids Report”: OMB#1905-0165,
EIA-857, “Monthly Report of Natural Gas Purchases and Deliveries to Consumers”: OMB# 19050175,
EIA-895, “Annual Quantity of Natural Gas Production Report”: OMB# 1905-0175,
EIA-923, “Power Plant Operations”: OMB# 1905-0129,
EIA-910, “Monthly Natural Gas Marketer Survey”: OMB# 1905-0175, and
EIA-912, “Weekly Underground Natural Gas Storage Report”: OMB# 1905-0175.
The following describes the natural gas forms included in this clearance, 1905-0175 and their
proposed changes:
A3.1. Form EIA-176, “Annual Report of Natural and Supplemental Gas Supply and
Disposition”
Natural gas supply and disposition data collection was initiated in 1910 and was conducted as a
voluntary annual natural gas supply and disposition survey by the Department of Interior,
Bureau of Mines (BOM) until 1977. With the establishment of the Department of Energy (DOE)
in 1977, responsibility for the survey was transferred to the EIA within DOE. The voluntary
survey was continued through 1979 by EIA using the BOM Forms 6-1340-A, “Supply and
Disposition of Natural Gas,” for non-producing distribution companies and 6-1341-A, “Supply
and Disposition of Natural Gas,” for all other respondents. The EIA received approval to
continue the survey using a slightly-modified mandatory survey form EIA-176, “Supply and
Disposition of Natural Gas,” for report years 1980 and 1981. Approvals of the use of a
substantially-revised form were granted for report years 1982 through 1986, and for the use of
the form with minor revisions for report years 1987 through 2001. In 2002, EIA requested and
received approval to revise the EIA-176 to collect data on natural gas deliveries to nonutility
generators of electricity. In 2008, EIA requested and received approval to collect revenues
collected from the deliveries of gas delivered on behalf of third-parties.
The Form EIA-176 provides the EIA with the major elements of information required to
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combine and merge with data collected in other EIA surveys to develop gas supply and
disposition balances and relevant cost, price, and related information at the State level. The
data collected are necessary to continue a long-term consistent, but evolving, data series of
basic summary information on natural gas. These data are essential to provide analysts with
the tools necessary to make informed assessments of the variations in natural gas supply,
demand, and prices over time and geography.
The EIA requests approval of the following significant change to Part 3 of the Form EIA-176:
(1) Collection of the reporting company’s participation status in State retail choice
programs.
(2) Collection of information on changes in the reporting company’s service territory due to
sale or acquisition.
In requesting the addition to Part 3 of Form EIA-176 of the reporting company’s status in State
retail choice programs, EIA is proposing to collect information on whether respondents,
comprised primarily of natural gas utilities and municipal gas systems, have active customer
choice programs for certain customer types and their rates of participation. This information
will permit EIA to monitor the extent to which customer choice programs are being
perpetuated and utilized. These data will allow the EIA to reduce spending on monitoring
customer choice programs. Also in Part 3 of the form, the EIA proposes a question that asks
companies to report whether their distribution service territory has changed via sale or merger
in order to maintain the accuracy of the survey frame.
The burden estimate of 12.0 hours per response remains the same as status of participation in
a customer choice program is readily available information respondents typically feature on
their website. The information should correspond with an indication of service to
transportation customers listed on Part 6, Line 11 which typically only affects larger companies.
The information requested on Part 3, C related to sale or merger activity is already typically
reported by most respondents in the Comments section on Part 7. It has been moved to the
front of the form to make it more prominent, lower total survey error, as well as prevent
unnecessarily follow-up with the respondent when data changes related to sale or merger
activity are observed through the data editing process.
Approximately 2,000 companies are currently in scope of EIA-176 and the EIA-176 anticipates
that the number of active respondents will remain at approximately 2,000 for the next 3 years.
The information collected on the Form EIA-176 is needed and used by the EIA for the following
purposes:
(1) to develop and make available to the Congress, the States, and the public an accurate
quantified assessment of the supply of natural and supplemental gas available to each
of the various States from all sources, both internal and external, and the manner in
which such supply was used, consumed, or otherwise disposed of,
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(2) to determine the quantity of natural and supplemental gas consumed within each of the
various States by market sector, the average prices for such gas, and the changes in
consumption and price patterns over time from the first purchase through the final
price paid by consumers,
(3) to produce the Natural Gas Annual (NGA),
(4) to provide natural gas data for the State Energy Profiles,
(5) to provide natural gas input data to energy supply, demand, and price forecasting
models especially EIA’s National Energy Modeling System and Short-Term Integrated
Forecasting System,
(6) to supply the Federal Energy Regulatory Commission (FERC) with background and
baseline information on the total natural gas market by State and groups of States,
(7) to provide natural gas input data to the following EIA publications: Annual Energy
Review, Annual Energy Outlook, Short-Term Energy Outlook, and Monthly Energy
Review, which are distributed to all members of Congress,
(8) to respond to Congressional and internal departmental requests for analysis of policy
and regulatory issues, and
(9) to provide a frame for selecting respondents of the EIA-857, “Monthly Report of Natural
Gas Purchases and Deliveries to Consumers” survey.
(10) to provide a portal of company-level utility information collected on EIA-176 for
external analytic purposes at http://www.eia.gov/cfapps/ngqs/ngqs.cfm.
A3.2. Form EIA-191, “Underground Natural Gas Storage Report”
Form EIA-191 requests monthly and annual data on the location, ownership, capacity, and
operations of all active underground natural gas storage reservoirs in the lower-48 States.
Substantial underground natural gas storage facilities are necessary because of fluctuating
seasonal, daily, and even hourly marketing requirements. Natural gas is usually injected into
storage when market requirements are below available gas flows in transmission lines, and
then is withdrawn from storage when supplies from producing fields and/or the capacities of
transmission systems are inadequate to meet peak requirements.
The EIA proposes the elimination of the EIA-191A form and the addition of the elements it
collects (storage field type, working and total capacity as well as maximum deliverability) to the
monthly form, now EIA-191. This will enable changes in natural gas storage field capacities to
be recorded on a timelier basis and will improve the quality of the monthly and related weekly
natural gas storage activity estimates. The EIA will continue to protect the confidentiality of
proprietary information, including monthly working and base gas levels, and injections and
withdrawals into storage, but will publish storage field type, location, capacity and maximum
deliverability in disaggregated form as it currently does with data collected on the EIA-191A.
The EIA also proposes to increase the monthly burden of EIA-191 from 2.4 hours per response
to 2.6 hours per response to include the elements formerly being collected annually on form
EIA-191A. The number of underground storage operators reporting on EIA-191 is 131 and the
EIA anticipates that the survey frame will stay close to 131 for the next 3 years.

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The information collected on Form EIA-191 is used by the EIA for the following purposes:
(1) to provide State-level data on underground natural gas storage with respect to
injections, withdrawal capabilities, inventories, type of storage facility, location of
facilities, and capacity for the EIA's Natural Gas Monthly. State-level storage data are
comparable to State-level production and consumption data published in the Natural
Gas Monthly. This monthly data collection also provides reliable baseline data on
storage operations necessary for analyses, modeling, and comparison with normal
industry operations in case of severe weather, natural disaster, or other extreme
circumstances. The data are also used in natural gas industry deliverability studies as
described in item (6).
(2) to serve as the universe from which the sample for the weekly survey EIA-912 is drawn,
(3) to provide data on underground natural gas storage injections, withdrawals, and
inventories for the EIA's Natural Gas Weekly Update, Monthly Energy Review, and
Annual Energy Review,
(4) to provide data on underground natural gas storage inventories for the forecasts
contained in the EIA Short-Term Energy Outlook,
(5) to provide data on all aspects of underground natural gas storage to enable the EIA,
FERC, and other elements of the DOE to identify and assess the supplies of gas in
storage by geographic location on a timely basis,
(6) to provide data for system deliverability studies undertaken by the EIA as a part of its
analysis tasks. Capacity information is collected at the reservoir level to allow
comparisons of the utilization of the individual reservoirs. Storage data are a critical link
in understanding the peak day deliverability of the natural gas system and overall
system operations, and
(7) to produce the Natural Gas Annual (NGA).
(8) to provide a source of storage field-level capacity and deliverability information
collected on EIA-191 that is available at
http://www.eia.gov/naturalgas/data.cfm#storage.
A3.3. Form EIA-757, “Natural Gas Processing Plant Survey”
The purpose of Form EIA-757 is to collect data on the operational status and capacity of natural
gas processing plants to understand their production levels and characteristics, as well as to
monitor constraints resulting from natural gas supply emergencies. The information is used to
develop periodic reports presenting aggregate information on processing plant capacity and
operations. In an emergency situation that disrupts natural gas supplies, the information
collected from Schedule B of this form is used to assess the severity of the disruption to market
conditions. The location of natural gas processing plants in the supply chain, between
production and consumption, allows quick and relatively low-cost information about the impact
of a natural gas supply disruption. For example, EIA used EIA-757 information to develop an
energy fact sheet on the Gulf of Mexico available at
http://www.eia.gov/special/gulf_of_mexico/map.cfm. This information is crucial during a
natural gas supply disruption, for informed decision and policy making during emergency
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periods of disruption of natural gas supplies. The information collected through this survey is
used widely by Federal and State agencies, Congress, industry analysts and the general public to
understand the operational capabilities and characteristics of natural gas processing plants. In
the event of a natural gas supply emergency, it is used to understand the plant constraints and
expected recovery from an emergency. The Office of Electricity Delivery and Energy Reliability
within the U.S. Department of Energy uses information reported on Form EIA-757 in their
Emergency Situation Reports available at http://www.oe.netl.doe.gov/emergency_sit_rpt.aspx.
These reports are released daily on the U.S. Department of Energy’s website after the impact of
a hurricane to alert the affected region on what gas plants and other energy facilities are in the
path of the storm so alternative supply arrangements can be made. After the storm, or other
intervening natural disaster that may affect a region, daily reports are issued to inform the
nation on what damage the event has caused and what energy supplies are available and the
location of those supplies. The company level information shown in these reports are obtained
either from the company’s website or by informed consent at the time of collection.
Using information reported on Form EIA-757, EIA can publish periodic reports on the
operational characteristics, status, and constraints of natural gas processing plants, providing
aggregate statistics. EIA will report aggregate information from Schedule A each time Schedule
A is filed, at most every 3 years. EIA will determine the frequency of reporting aggregate
information from Schedule B at the time the schedule is activated. Activation requires advance
written notification to the Office of Management and Budget from the Administrator of EIA
who will indicate the nature of the emergency, the number of plants that will be surveyed, and
the anticipated duration and frequency of the collection. Aggregate statistics, based on the
Form EIA-757, will be published every 3 years or less frequently depending on resources so that
State Government emergency preparedness plans can accurately estimate energy allocations in
the event of an emergency. In the case of a natural gas supply disruption, aggregate statistics
may be published either daily or weekly, in emergency status reports prepared by the EIA and
the DOE, and used in the production of several other EIA information products. It is used:
(1) to develop and make available to the Congress, the States, other Government agencies,
and the public a timely and accurate quantified assessment of current natural gas
processing plant operations and operational capacity
(2) to develop and make available to the Congress, the States, other Government agencies,
and the public a timely and accurate quantifiable assessment of natural gas processing
plant outages and operational constraints
(3) as an input to other EIA statistical information products, such as energy status reports,
(4) to provide an input to supply, demand, and price forecasting models, such as the ShortTerm Integrated Forecasting System, and
(5) to respond to Congressional, internal Departmental and inter-Agency requests for
analysis of natural gas supply constraints and operating levels in the United States, as
well as policy and regulatory issues.
The EIA proposes to continue the collection of the EIA-757 in its present form but remove the
data’s protected status and publish it in disaggregated form so that State and local
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Governments can access this information and develop and update emergency preparedness
plans for their communities. Contact information would not be publicly released and would
only be provided to another Federal agency that is consistent with their official purposes. EIA
intends to develop a public query system and publicly release the reported survey responses
through its website. This would allow media sources, local governments and other interested
members of the public to access accurate information to either prepare or respond to an
energy emergency. This also eliminates EIA’s need to obtain informed consent from the
respondents during an energy emergency and release objective information reports that
accurately assess the energy supply conditions of a region that is in the path of a natural
disaster event. Attribute information including location and capacity of gas processing plants
are also collected and publicly released through other websites. For example, the Office of
Natural Resources in the U.S. Department of Interior releases plant level capacity information
available at http://www.onrr.gov/fm/PDFDocs/gas99.PDF. State government agencies such as
the Texas Railroad Commission release company and plant level information available at
http://www.rrc.state.tx.us/data/online/index.php. Private websites such as “The Right to Know
Network” available at
http://www.rtknet.org/db/rmp/rmp.php?all_naics=211112&datype=T&reptype=a&detail=0&s
ubmit=GO also release this type of information at the facility level. EIA did not receive any
comments on the proposal to make the information reported on Form EIA-757 publicly
available when it published its federal register notice in March, 2011.
As of 2008, the last time EIA-757 A was collected, approximately 500 processing plants were in
the scope of the survey. The EIA anticipates that the number of gas processing plants in scope
of EIA-757 to remain at approximately 500 based on subsequent frame updates.EIA surveyed
39 plants on EIA-757 B when it was collected in 2008 due to Hurricanes Gustav and Ike and is
assuming a similar number of plants may be affected by any future supply disruption for the
purposes of estimating burden for EIA-757B.
A3.4. Form EIA-857, “Monthly Report of Natural Gas Purchases and Deliveries to Consumers”
Form EIA-857 was designed to collect monthly natural gas data at the State level consisting of
average natural gas purchase prices, consumption of natural gas by sector, and average price by
sector from a sample of the respondents reporting on the EIA-176. These data are necessary to
provide timely information needed to measure the combined impact of Government, industry,
and consumer actions; geographic location; interfuel competition; climatic or seasonal
conditions; and a host of other factors upon the natural gas industry and natural gas
consumers.
The EIA requests approval of the following significant changes to the Form EIA-857:
(1) The collection of company-use gas
(2) The collection of deliveries to the vehicle fuel sector
These changes are in addition to a new question asking for monthly system sendout by
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responding companies added to the EIA-857 via a nonsubstantive change request approved by
the Office of Management and Budget in 2010. The addition of monthly company-use gas and
monthly deliveries to the vehicle fuel sector will further improve the calculation of monthly
natural gas consumption so it better aligns with the calendar month, as consumer deliveries are
reported according to billing cycles for some of the respondent population. These items are
currently collected on an annual basis on the EIA-176, Annual Report of Natural and
Supplemental Gas Supply and Disposition. However, their inclusion on the EIA-857 will facilitate
more accurate consumption estimates on a monthly basis. The burden estimate to EIA-857 will
remain at 3.5 hours per response; cognitive testing of the EIA-857 in 2010 revealed that the
current burden estimate was generous and that data for the additional questions are in most
cases readily available on internal gas operations reports respondents currently utilize to fill out
EIA-857.

In addition, the EIA is proposing to reduce the sample size of the EIA-857 by approximately 25
percent (400 to 310) by moving to a cut off sample that can achieve a similar level of quality as
the current sampling and estimation protocol.
The purchased gas data collected on the Form EIA-857 are needed to develop average
delivered, or city gate, prices to provide analysts and decision-makers with information on the
levels and rates of change in “wholesale” prices to distribution systems and the differences in
such prices across the Nation. This information provides direct measures of the combined
effect of producer prices, transportation costs, and pipeline-provided services upon
distributors’ purchased gas costs and the variations geographically, seasonally, and under
changing market conditions. The information also enables analysts to monitor the effects of
Public Utility Commission actions at the State level.
The consumer price information collected enables the EIA to provide information on the prices
by major consumer class on a monthly basis. Consumer prices provide analysts and
decision-makers with direct measures of average consumer prices and price changes,
geographically, seasonally, among consumer classes, and under changing market conditions.
Collection of revenue data associated with gas distributed to end users for the account of
others is used by the EIA to analyze changes in distribution tariffs and for projections of future
natural gas prices in EIA’s Short-Term Energy Outlook and Annual Energy Outlook. Specifically,
EIA calculates the average cost of distribution services charged by local natural gas utilities to
end-use consumers. EIA exempts pipeline companies in the EIA-857 sample from reporting
transportation revenues that are outside the scope of the reporting requirement.
The EIA currently collects information about the number of customers, for each of the end-use
sectors for gas sold and transported to residential, commercial, industrial, electric power, and
other customers. Having these data enables EIA to better monitor fluctuations in monthly
volume reporting that are commonly the result of changes to the number of customers being
served.
10

Current data on consumption by the major consumer classes by State are necessary to enable
the EIA to provide timely information on any changes in the levels of consumption at the State
level by sector, analyze the patterns of change over time and the underlying drivers, and
develop projections of future usage patterns for inclusion in the Short-Term Energy Outlook and
Annual Energy Outlook.
State-level data are necessary, as indicated above, to enable the EIA to provide information on
the frequently substantial differences in prices and consumption patterns among the various
States. The cumulative effect of location relative to supply sources, climatic conditions,
regulatory agency policies, interfuel competition, industrial activities, sources of supply, storage
and peak shaving requirements, and location of transmission facilities result in significantly
different price and consumption profiles across the Nation. Information on consumption
profiles is necessary to enable analysts and decision-makers to assess ultimate impacts of
various legislative or industry actions upon particular areas or regions.
The information collected on the Form EIA-857 is used to estimate:
(1) monthly average price by State of natural gas delivered by local distribution companies,
(2) monthly average price of natural gas billed to residential, commercial, and industrial
consumers in each of the various States, and
(3) total quantity of natural gas used by residential, commercial, industrial, electric power,
and vehicle fuel consumers each month in each of the various States.
State and national level aggregate data are published in EIA's Natural Gas Monthly, Monthly
Energy Review, and Winter Fuels Report, and made available to the Executive Branch, Congress,
State governments, industry, and the public.
If the collection of information on the Form EIA-857 were not conducted, the EIA would be
unable to provide information on the actual effects upon the natural gas market of current or
future legislation and regulation in the detail and time frame necessary to adequately monitor
and evaluate the market. Seasonality of the market is an important driver of the price and
supply. Monthly data are the minimum level of reporting that will allow for assessment of the
impacts of weather and other seasonal factors on the consumption and price patterns.
A3.5. Form EIA-895, “Annual Quantity and Value of Natural Gas Production Report”
The EIA-895 provides a standard reporting system for the amount of natural gas produced by
State by month. The form is filed, on a voluntary basis, by 32 of the 33 natural gas producing
States. It provides information on gross withdrawals from gas and oil wells , coalbeds, and
shale, on volumes vented and flared, volumes used for repressuring, nonhydrocarbon gases
removed, natural gas used as fuel on leases, and the amount of natural gas available for
marketing. These data are collected by the States for taxation and statistical purposes.

11

EIA proposes to discontinue the EIA-895 because of the inconsistencies with which many of the
data elements are reported by the responding States. For instance, some of the responding
States do not keep records that allow for gross withdrawals to be reported by source type or
for the valuation of marketed production to be consistent with the Form instructions.
However, EIA has identified alternative public and private sources that will allow for all data
series related to the EIA-895 to continue until resources permit the development and fielding of
a permanent replacement survey(s) that can serve as the data source for gross production by
source type, gas vented and flared, gas used for repressuring, nonhydrocarbon gases removed,
gas used on leases, and the value of marketed gas. All data series will continue to be reported,
but components (some unmarketed components and wellhead prices) may be estimated.
A3.6. Form EIA-910, “Monthly Natural Gas Marketers Survey”
To ensure the coverage of all natural gas sales to residential and commercial consumers in its
natural gas price data, the EIA is requesting continued use of the Form EIA-910, “Monthly
Natural Gas Marketers Survey.” This survey was first approved for use in May 2001, under ICR
1905-0202. The survey collects State-level monthly data on sales to residential and commercial
customers by companies that market natural gas but are not involved in the physical final
deliveries of gas to customers. Form EIA-857, “Monthly Report of Natural Gas Purchases and
Deliveries to Consumers,” collects information on direct sales and gas transported for others
from companies making deliveries of natural gas. Combining information from the EIA-910 and
EIA-857 helps ensure complete price coverage of natural gas deliveries in the States surveyed.
In 2008, the OMB granted permission for EIA to continue data collection activities of natural gas
marketers in 11 States and the District of Columbia. Respondents were selected to report data
for States with active customer choice programs; data are currently collected for the States of
Florida, Illinois, Michigan, New Jersey, Virginia, West Virginia, Georgia, Maryland, New York,
Ohio, Pennsylvania, and the District of Columbia. EIA was concerned about residential and
commercial coverage and missing price data in these States. EIA estimates that the current EIA910 survey frame brings the percentage of volumes represented by published prices in the
commercial sector to 100 percent in those areas.
The EIA compiles and incorporates the EIA-910 data collected from marketers who sell natural
gas to residential and commercial customers into EIA’s monthly and annual natural gas
databases to improve the completeness and accuracy of the EIA’s price estimates. Data from
the EIA-910 supplements information already tabulated and published in the EIA’s publications.
The data are used in EIA’s modeling and analytical efforts, and to answer questions from
Federal policymakers, Congress, and the general public. These data are needed for policy
making; for assessing supply, demand and price developments within the industry; and for
assessing the competitiveness of the industry. The data are not intended to be collected for
regulatory purposes and no rulemaking is involved.
Originally, the EIA had proposed to continue the monthly EIA-910 in its present form but also
proposed to add an annual schedule that would ask respondents to report on a new form, EIA910A, the annual totals of all the existing elements on the monthly survey broken out for each
12

local distribution company’s territory in which the respondent operates. Due to recent budget
reductions, the EIA has recently discontinued collecting the EIA-910 in all States except Georgia,
New York, and Ohio and does not have the resources to field the originally proposed annual
schedule at this time. While the EIA currently collects EIA-910 from three States for 2012, it
proposes to clear collection of the current EIA-910 for up to six States in 2013-2014, if resources
and priorities allow, in order to improve the coverage of residential and commercial prices in
States with the heaviest participation rates by natural gas marketers. If the EIA were to expand
the EIA-910 beyond Georgia, New York and Ohio, the additional three States would be selected
based on the extent to which natural gas is being sold by marketers in those States based on
the most recent data collected on form EIA-176. Based on the current collection in Georgia,
New York, and Ohio, approximately 100 respodents are currently in the collection and the
number of respondents could grow to 200 if an additional three States were included in the
survey in 2013 or 2014.
The EIA had also proposed to publish company-level data collected on the proposed EIA-910A 9
months after its collection period and to change the confidentiality protection on the current
monthly EIA-910 from the Confidential Information Protection and Statistical Efficiency Act
(CIPSEA) to exemptions under the Freedom of Information Act and provisions in the Trade
Secrets Act. Now that the EIA-910A proposal is being withdrawn, EIA also withdraws its
request to change to the confidentiality protection used for the monthly EIA-910; the data
collected on the form will remain protected under the Confidential Information Protection and
Statistical Efficiency Act (CIPSEA.)
A3.7. Form EIA-912, “Weekly Underground Natural Gas Storage Report”
Form EIA-912, “Weekly Underground Natural Gas Storage Report,” provides a data series for
natural gas in underground storage similar to that formerly published by the American Gas
Association (AGA). AGA began data collection in 1994 and discontinued its data collection on
May 1, 2002. EIA initiated data collection on March 15, 2002 under an emergency clearance
(ICR 1905-0202). The emergency clearance allowed EIA to survey a sample of underground
storage operators on a weekly basis to continue the data series.
The Weekly Natural Gas Storage Report (WNGSR) is the EIA’s only report designated a Principal
Federal Economic Indicator (PFEI). The WNGSR was designated as PFEI in January 2008, because
it is a key source of weekly natural gas volumetric data, a market signal of readily available
natural gas supply. Each week, EIA collects data about the amount of working natural gas in
underground storage facilities as of 9 a.m. Friday. EIA compiles and processes these data for
release on its website the following Thursday at 10:30 a.m. Summary totals are presented for
the United States broken into three regions: the West, the East, and the Producing Region. The
total volume of natural gas in underground storage reservoirs is classified as either base gas or
working gas. Underground storage facilities may be reservoirs in depleted oil and gas fields,
aquifers, or salt caverns.
Respondents are also instructed to submit revisions to data for previous weeks if those
13

revisions were greater than 500 million cubic feet and to include notes explaining any unusual
activity. Examples of unusual activity might include reclassification of working and base gas, or
changes in ownership or operation of storage fields. In practice, respondents do not often have
the need to provide notes on unusual activity.
The EIA-912 data are used to respond to requests from industry to provide weekly measures of
natural gas underground storage operations. EIA uses the data to prepare analytical products
assessing storage operations in the three geographical regions of the survey and the impact of
those operations on supplies available for the winter heating season.
The EIA proposes to continue the collection of the EIA-912 in its present form but expand the
sample size from 70 to 85 in order to maintain the same level of market coverage given recent
and further anticipated expansion in the number of natural gas storage fields in operation.
A4. Technological Considerations to Reduce Burden
All survey forms are available electronically and may be completed using an Excel spreadsheet,
or hand or typewritten on a PDF form for transmission via mail, fax, or email. Form EIA-176 is
also available to respondents as an electronic filing system and can be downloaded from the
EIA website. Due to time constraints on the weekly survey, EIA-912 respondents are required
to file by e-mail or facsimile. More than 95% of forms are submitted electronically.
A5. Efforts to Identify Duplication and Analysis of Similar Existing Information
A discussion of similar data items is provided below.
EIA-176, “Annual Report of Natural and Supplemental Gas Supply and Disposition”
Certain data elements similar to those reported on the Form EIA-176 are collected and
compiled or estimated from other EIA surveys. Data on electric power sector consumption and
price available from Form EIA-923, “Power Plant Operations Report,” is used for electric power
sector consumption and price summaries to maintain consistency in published consumption
information. Electric power data collected on the Form EIA-176 are for internal balancing of
individual reports and for cross-checking data collected on the Form EIA-923. This cross-check
enables the EIA to identify misreporting or double reporting by electric power consumers, a
benefit which far outweighs the negligible burden involved. The inclusion of lines for reporting
deliveries to electric power generators and volumes transported to electric power generators
for the account of others allows the respondent to account for all volumes of natural gas
delivered to end users. The respondent then can perform reasonableness checks on the
supply/disposition balance and for unaccounted volumes . This internal check is designed to
eliminate some follow-up calls and reduce reporting burden for the respondent.
Certain data collected in the Form EIA-176 survey are similar to data reported by interstate
natural gas pipeline companies on FERC Form 2, “Annual Report of Major Natural Gas
14

Companies.” However, the content and format of the FERC Form 2 are not directly comparable
to the data requirements of the Form EIA-176 survey, particularly in terms of State specific,
physical custody data. State-by-State data necessary to develop individual State gas balances,
compatible with data collected from respondents other than interstate pipeline companies on
the Form EIA-176, cannot be extracted from the FERC Form 2 report. The tracking of
movements of natural gas across State lines and tracking of flows of natural gas from
production areas to end users are two of the essential purposes of the EIA-176 survey.
Transport of natural gas across State lines is performed almost entirely by interstate pipeline
companies and the volumes transported State-to-State are not reported on the FERC Form 2.
Each of the above mentioned systems collect data that are similar in some respects to data
collected on the Form EIA-176. However, with the exceptions noted, data collected cannot be
reasonably substituted, in whole or in part, for data collected on the Form EIA-176.
EIA-191, “Monthly and Annual Underground Natural Gas Storage Report”
Data similar to the underground storage information on the monthly Form EIA-191 are
collected on the weekly form EIA-912, “Weekly Underground Natural Gas Storage Report.”
However, the weekly survey is collected from a sample of the monthly survey respondents in
order to provide more timely measures of this market information. The EIA-191 is collected
from the universe of underground storage operators and is used as the benchmark for
adjustments to EIA-912 data.
EIA-757, “Processing Plant Survey”
Data similar to the capacity and design of gas processing plants collected on the Form EIA-757
are not currently gathered by EIA or any other organization. EIA investigated alternative ways
to obtain timely and precise natural gas processing plant information for use in assessing
processing plant operations, damage and expected restoration during a supply emergency. The
alternatives considered were use of monthly data from natural gas processors, Form EIA-816,
Monthly Natural Gas Liquids Report, and a new survey of natural gas processing plants.
A summary of the review of the alternatives to the Form EIA-757 follows: EIA has collected
monthly data from operators of natural gas processing plants on Form EIA-816, “Monthly
Natural Gas Liquids Report” (OMB No. 1905-0165) for many years. The survey collects
information on the supply and disposition of natural gas liquids from operators of natural gas
processing plants (which extract liquid hydrocarbons from a natural gas stream) and
fractionators (which separate a liquid hydrocarbon stream into its component products.) The
EIA considered revising the form to collect additional information, in order to assess processing
plant operations and capabilities during a natural gas supply emergency. The EIA found that, in
addition to not being sufficiently timely to provide information about emergency operations
and constraints, certain aspects of the survey would result in undue burden and, further, would
prevent the generation of reliable information about processing plant operations, capabilities
and recovery during a supply emergency. The current reporting lag for data collected on Form
15

EIA-816 is 60 days after the end of the month and this is insufficient for the EIA to satisfy the
need for information during a supply emergency. For instance, if a supply emergency happened
on September 4, data from the Form EIA-816 would not be available until the end of December.
The use of Form EIA-816 would not satisfy EIA’s need for timely information during a natural
gas supply emergency.
EIA-857, “Monthly Report of Natural Gas Purchases and Deliveries to Consumers”
Certain elements of data similar to these collected on the Form EIA-857 are available to the EIA
from other surveys or sources but none that could be used or modified for the purposes
described above.
Monthly information on the average price of natural gas to residential consumers is available
from the Bureau of Labor Statistics (BLS) but the price is only for given quantities of gas in major
metropolitan areas. Volume information is not available. The data cannot be presented by
State and do not represent average prices of quantities actually consumed.
Annual information is available by State on purchased gas prices, consumer prices by market
sector, and consumption by market sector from the Form EIA-176, “Annual Report of Natural
and Supplemental Gas Supply and Disposition.” The Form EIA-857 complements the Form
EIA-176 by providing current information reflecting monthly and seasonal variations. The Form
EIA-176 information is used to develop the Form EIA-857 sample frame and provides an annual
control for testing and adjusting the Form EIA-857 estimation procedures.
The Form EIA-923 survey of power plants collects fuel used for electric power generation. The
data are used as the measure of natural gas consumed by this sector. However the data are
also collected on the EIA-857 to assure that gas delivery agents have a full list of appropriate
sectors to completely account for all gas deliveries.
EIA-910, “Monthly Natural Gas Marketer Survey”
The data elements collected on the EIA-910 are not duplicated in other surveys or sources.
EIA-912, “Weekly Underground Natural Gas Storage Report”
Data similar to the underground storage information on the monthly Form EIA-912 are
collected on the monthly form EIA-191M, “Monthly Underground Natural Gas Storage Report.”
However, the monthly survey is collected from the universe of underground storage operators
and is used as the benchmark for adjustments to EIA-912 data. The EIA-912 is collected from a
sample of the monthly survey respondents in order to provide more timely measures of this
market information.
A6. Impacts on Small Businesses or Other Small Entities

16

Data requested provide the minimum information necessary to fulfill the EIA's responsibility to
provide meaningful, timely, objective, and accurate energy data. Respondents to the survey
complete only those data elements applicable to their operations. For small firms, fewer data
elements are generally applicable and are easily obtained from generally existing records. EIA
staff members are also available during normal business hours to provide assistance by
telephone.
The EIA encourages electronic reporting on all natural gas surveys.
For the EIA-857 survey, burden on all gas companies has been reduced to the minimum
necessary to achieve the desired accuracy. The new sampling plan for the EIA-857 will in most
cases relieve smaller respondents of a reporting obligation on EIA-857.
Companies responding to the Form EIA-191 and EIA-912 are not small businesses.
The EIA-176 is required of all companies with natural gas deliveries to end-use customers
regardless of size. However, the majority of the small-sized respondents only have to fill out a
small percentage of the data elements on the form as the majority of the questions asked are
not applicable to small-sized respondents. Therefore, the burden to small businesses on the
EIA-176 is the minimum necessary to gather the information required.
The Form EIA-910 survey burden is the minimum necessary to gather the information required.
Similarly, the natural gas processing plant operators that complete Form EIA-757 are not small
businesses or other small entities.
A7. Consequences of Less Frequent Reporting
Data are required at requested frequency in order to satisfy EIA's programmatic needs as
described in A2 above. Requested frequency of reporting is: EIA-176, annually; and EIA-191,
EIA-857, EIA-895, and EIA-910 monthly. The EIA-912 is filed weekly. The EIA-757 baseline
survey, Schedule A, is filed no more than once every 3 years. Without these data, natural gas
market participants including local distribution companies, producers, importers, gas
purchasers, Federal and State agencies providing income assistance for energy, and the gas
trading community would not have timely information about natural gas supplies. The
importance of timely information and the fact that there are no other sources are the basis for
the requested report frequency. If the Form EIA-757 collection is not conducted, EIA would not
be able to meet its goal, and could not provide essential natural gas processing plant
information prior to and during a supply emergency. Less frequent reporting would prohibit EIA
from meeting its mandate of providing timely and reliable energy information. The frequency of
reporting on Schedule B will be determined at the time the survey is activated in response to a
supply emergency.
A8. Special Circumstances

17

There are no special circumstances for these collections.
A9. Summary of Consultations Outside the Agency
A request for comments from interested persons was solicited in a notice describing the
proposed extension of the forms and proposed modifications to each form. The notice was
published May 2, 2011, in the Federal Register, pp. 11444-11446. An announcement of the
Federal Register notice was sent to a list of trade groups and others interested in natural gas
data programs. In addition, the notice and proposed versions of the survey forms were posted
on EIA’s website.
Summary of Responses to Federal Register Notice of May 2, 2011:
As of May 2, 2011, six responses to the Federal Register Notice were received which are
summarized below.
Comment1: National Energy Marketers Association (NEM), expressed opposition to the EIA’s
proposed changes to EIA-910 which included the addition of an annual schedule which would
require each respondent to report by each local distribution company in which they serve
customers instead of on a State-basis due to concerns over the reporting burden. NEM is also
concerned at the EIA’s proposal that such data collected on the newly proposed annual
schedule would be published on a company-level due to the perception of competitive harm it
would cause the reporting companies.
Response1: EIA’s position is that the proposed collection of annual data on the EIA-910A would
be a significant improvement to the accuracy of the EIA’s published prices. However, EIA is
withdrawing the proposal for this annual data collection due to a lack of funding and resources
to administer the survey. EIA withdraws the proposal to change the confidentiality provisions
and the monthly data reported on Form EIA-910 will continue to be protected under the
Confidential Information Protection and Statistical Efficiency Act (CIPSEA.)
Comment2: United States Department of Commerce, Economics and Statistics Administration,
Bureau of Economic Administration, strongly supported the continuation of forms cited in the
Federal Register notice. BEA uses information collected on Forms EIA-176 and EIA-895 to
prepare the U.S. input-output accounts. Also, Forms EIA-176, EIA-857, EIA-910, and EIA-895 are
used in the annual estimates of gross state product (GSP) and gross domestic product (GDP).
Response2: The EIA acknowledged BEA for their response and has no plans to discontinue any
data series the Bureau of Economic Analysis is currently using, despite the discontinuation of
the EIA-895. The EIA will be using publicly available as well as third-party information in order
to maintain the series at this time.
Comment3: A consortium of natural gas industry trade groups, the American Exploration &
Petroleum Council, the Independent Petroleum Association of America, the Natural Gas Supply
18

Association, the American Petroleum Institute, the National Ocean Industries Association, and
U.S. Oil & Gas Association, supports the continuation of the EIA-895 as it yields data of use to
the natural gas market. However, the group is opposed to the EIA collecting such information
directly from gas producers and/or processing plants as they maintain that collecting such
information from the States is more efficient and less burdensome to private firms who are
presumed to already be furnishing similar information in the States where they operate.
Response3: Though the EIA proposes to discontinue collection of the EIA-895 in lieu of
collecting the information from alternative public and private data sources, a permanent survey
replacement that would involve surveying natural gas producers and/or gas processing plants is
still being considered. Collecting information on gas production by type, gas vented and flared,
gas used for repressuring, gas used on leases, nonhydrocarbons removed and the value of
marketed gas which is used to produce wellhead prices, has proven difficult to collect from the
States as the States do not collect and/or report all of the information in a consistent fashion on
form EIA-895.
Comment4: The South Carolina Energy Office wrote a letter of support of the U.S. Energy
Information Administration’s natural gas data program, emphasizing the important role such
State-level data play for South Carolina and other States who do not have the resources to
collect State-level energy information required for policy and analysis.
Response4: The EIA acknowledges the South Carolina Energy Office’s use of the U.S. Energy
Information Administration’s natural gas data series and looks forward to engaging with them
and other States in the future as evaluations of the EIA’s various data collection programs are
made.
Comment5: The Montana Department of Environmental Quality stated that they support the
continuation of the State-level gross and marketed production data series as they are used for
Montana energy balances as well as their upcoming Montana Energy Assurance Plan.
Response5: The EIA acknowledges the Montana Department of Environmental Quality’s use of
the U.S. Energy Information Administration’s gross and marketed natural gas production data
series and looks forward to engaging with them and other States in the future as evaluations of
the EIA’s various data collection programs are made. The EIA plans to continue both these
series.
Comment6: Elliott Associates inquired as to whether increasing the sample size of the EIA-912
was adequate to insure proper coverage of natural gas storage operations, particularly in the
Producing Region.
Response6: The EIA responded that the new sample size increase of 70 to 85 should be
adequate to ensure optimal survey coverage in all regions as described in the Weekly
Underground Natural Gas Storage Report technical notes currently and during the next three
years.
19

A10. Payments or Gifts
No payments or gifts are made to the survey respondents.
A11. Provisions for Data Protections
The EIA considers information collected on Forms EIA-176, EIA-757 and certain data elements
collected on EIA-191 to be public information that does not need protection
The following statement of the confidential provisions below is included in the instructions to
the proposed versions of Forms EIA-176, and EIA-757:
Information reported on Form EIA-xxx is considered public information and may be publicly
released in company or individually identifiable form.
The following statement of the confidential provisions below is included in the instructions for
the proposed version of Form EIA-191:
Information collected in Parts 1, 2, and 3 on Form EIA-191 is considered public information and
may be publicly released in company or individually identifiable form. Information collected in
Part 4 (including Base Gas, Working Gas and Total Gas in Storage data), will be protected and
not disclosed 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. U.S.
The Federal Energy Administration Act requires the Energy Information Administration to
provide company-specific data to other Federal agencies when requested for official use. The
information reported on these forms 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 procedures are not applied to the statistical data published from EIA-191M
survey information. Thus, there may be some statistics that are based on data from fewer than
three respondents, or that are dominated by data from one or two large respondents. In these
cases, it may be possible for a knowledgeable person to estimate the information reported by a
specific respondent.
Forms EIA-910 and EIA-912 collect confidential data under the Confidential Information
Protection and Statistical Efficiency Act (CIPSEA). These data are considered confidential and
will be used exclusively for statistical purposes. The instructions to Forms EIA-910 and EIA-912
20

contain the following data confidentiality notice:
The information you provide on Form EIA-xxx will be used for statistical purposes only. U.S. In
accordance with the Confidential Information Protection and Statistical Efficiency Act of 2002
(Title 5 of 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, is subject to a
jail term, a fine of up to $250,000, or both if he or she discloses ANY identifiable information
about you.
EIA will protect the values reported on Forms EIA-857 and Form EIA-191. The instructions for
the proposed version of EIA-857 and EIA-191 contain following pledge of protection:
The name, address, and contact information of the responding company are considered public
information. These data elements may be released in company identifiable form. All other
information reported on Form EIA-xxx will be 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.
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); or to any Committee of Congress, the U.S. 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 procedures are not applied to the statistical data published from EIA-857
survey information. Thus, there may be some statistics that are based on data from fewer than
three respondents, or that are dominated by data from one or two large respondents. In these
cases, it may be possible for a knowledgeable person to estimate the information reported by a
specific respondent.
A12. Justification for Questions of a Sensitive Nature
The forms contain no questions of a sensitive nature.
A13. Estimates of Respondent Burden Hours
See Table 1 for the estimates of respondent burden for the individual forms contained in this
package. The overall annual respondent burden is estimated to be 50,131 hours. The
estimated costs to respondents for the burden hours are estimated to be $3,401,436 (50,429
21

hours times $67.45 per hour). $67.45 is average loaded hourly rate of a GS-13 Federal
employee in FY11. The EIA presumes the cost of a Federal worker for a private firm to be
commensurate with the cost of a Federal employee.
Table 1. Estimate of Respondent Burden
A
Form
EIA-176
EIA-191
EIA-757 Sch. A
EIA-757 Sch. B
EIA-857
EIA-910
EIA-912
Total

B

A*B

Number of
Number of
Reports
Respondents
Annually
2,000
131
500
39
310
200
85
3,265

1
12
0.33
0.33
12
12
52
90

C

(A*B)*C

Number of Burden
Annual
Hours per
Responses Response
2,000
1,572
165
13
3,720
2,400
4,420
14,290

12.0
2.6
0.5
1.5
3.5
2.0
1.0
n/a

Annual
Burden
Hours
24,000
4,087
83
19
13,020
4,800
4,420
50,429

* EIA-757 Schedule B will be collected only in response to a significant disruption in natural gas
supply. 39 respondents will be accounted for Schedule B based on the number of respondents
surveyed the last time EIA-757 Schedule B was collected in 2008 due to Hurricanes Gustav and
Ike.
A14. Estimate of Cost Burden to Respondents - Capital/Start-up Costs and Operation/
Maintenance/Purchases of Services
The EIA estimates that there are no additional costs to respondents associated with the surveys
in the Natural Gas Data Collection Program Package other than the costs associated with the
burden hours as set forth in item A13 above.
A15. Annual Cost to the Government
The six surveys in the clearance package are included in the Annual Operating Plan for the
Office of Oil, Gas and Coal Supply Statistics. The annualized costs for this data program are
estimated to be $2,300,000 in FY11 which is based on expenditures on contract survey analysts
of $825,000, and the balance, $1,475,000 in Federal salary expense.
A16. Changes in Burden or Costs to Respondents
The overall burden for the Natural Gas Data Collection Program Package is estimated to be
50,429 hours annually for all the forms included in this clearance package. The information
collections in this request are currently approved under OMB control number ICR 1905-0175
for a total existing burden of 52,569 hours. This request will result in a net decrease of 2,138*
22

hours for all the forms in this clearance package. The changes are due in part to the combining
of the EIA-191M and EIA-191 A (resulting in +451 hours-adjustment), a decrease in the number
of respondents in the EIA-857 (resulting in – 2,940 hours-adjustment), the discontinuation of
the EIA-895 (resulting in a -208 hours-adjustment), a decrease in the number of States and
respondents reporting on EIA-910 (resulting in a -240 hours-adjustment) and the increase in the
number of respondents on EIA-912 (resulting in a + 780 hours-adjustment.) Additionally,
annual burden was increased by 19 hours to account for the triennial EIA-757 Schedule B.
Table 2. Changes to Annual Time Burden Estimates (hrs)
Form
EIA-176
EIA-191M
EIA-191A
EIA-191
EIA-757 Sch.
A
EIA-757 Sch.
B
EIA-857
EIA-895
EIA-910
EIA-912
Total

Time Burden
From Most
Recent Clearance
(2008)

Proposed
Time
Burden

Program
Change due
to Agency
Discretion

Total
Change
in Time
Burden

Change due to
Adjustment in
Agency Estimate

24000
3514
122
0

24000
0
0
4087

0
-3514
-122
4087

0
0
0
0

0
-3514
-122
4087

83

83

0

0

0

1.5
15960
208
5040
3640
52569

19
13020
0
4800
4420
50429

0
-2940
-208
-240
780
-2157

19
0
0
0
0
19

19
-2940
-208
-240
780
-2138*

*Difference between previously approved annual total burden hours of 52,569 and 50,429
proposed is 2140 but sum of differences total to 2138 due to rounding error.
Table 3. Changes to Annual Number of Responses
Form

EIA-176
EIA-191M
EIA-191A
EIA-191
EIA-757 Sch.
A
EIA-757 Sch.
B
EIA-857

Annual
Response
from Most
Recent
Clearance
2000
1464
122

Proposed
Annual
Number
of
Responses
2000
0
0
1572

165
1
4560

Program
Change due
to Agency
Discretion

Change due to
Adjustment in
Agency
Estimate

Total Change
in Responses

0
-1464
-122
1572

0
0
0
0

0
-1464
-122
1572

165

0

0

0

13
3720

0
-840

12
0

12
-840

23

EIA-895
EIA-910
EIA-912
Total

416
2520
3640
14888

-416
-120
780
-610

2400
4420
14290

0
0
0
12

-416
-120
780
-598

A17. Data Collection and Publication
Annual Surveys
The data collected, reviewed, and tabulated by the EIA from the Form EIA-176 will be merged
with data collected in the Forms EIA-816, EIA-64A, EIA-923, EIA-857 and EIA-910 surveys to
develop quantitative overviews of gas available to each of the various States and the sources of
such gas; gas used or otherwise disposed of in each of the various States; average wellhead
prices, average prices of gas produced and purchased from producers; and the number of
consumers, total and average quantities consumed, and total and average prices paid by
consumers by market sector in each of the various States. The data will be used as input to the
State Energy Data System, the Short-Term Integrated Forecasting System, the National Energy
Modeling System, and other supply, demand, and price forecast models. They are published in
the Natural Gas Annual, and provide input to the Natural Gas Monthly, Annual Energy Review,
Annual Energy Outlook, Monthly Energy Review, Short-Term Energy Outlook, and State Energy
Profiles.
The time schedule for the Natural Gas Annual data collection, tabulation, and publication is
shown in the table below.
EIA Form

Due date

Extension Date

EIA-176

March 1

April 1

Processing
completion
September 30

Posted on
website
December 30

Monthly Surveys
Data gathered monthly on the Forms EIA-191, EIA-857, and EIA-910 will be reviewed, verified,
and aggregated to be used as input for the Natural Gas Monthly and the Monthly Energy
Review. In addition, data from the Form EIA-191 will be used in specific studies of peak day
supplies to major market areas, utilization of storage capacity, and the load leveling function of
storage in the market.
Individual company reports will be checked for reasonableness by comparing current reports
with prior responses. Mathematical calculations will be checked for accuracy and all data will
be checked for internal consistency. Respondents will be required to refile reports containing
any inconsistencies or errors.
A typical time schedule for the monthly EIA-191, EIA-857, and EIA-910 data collection
tabulation and publication is shown below using August data release for the example:
24

Natural Gas Monthly – August 20xx Issue
EIA Form
Data report
Due Date
month
EIA-191
June
July 20
EIA-857
June
July 30
EIA-910
June
July 30

Processing
complete
August 20
August 20
August 20

Posted on
website
August 31
August 31
August 31

A typical time schedule for the weekly EIA-912 data collection, tabulation and publication is
shown below using the first several weeks of August as example:
Weekly Natural Gas Storage Report – August 20xx Issues
EIA Form
Data report for
Due Date
Processing
week ending
complete
EIA-912
August 1
August 4
August 6
EIA-912
August 8
August 11
August 13
EIA-912
August 15
August 18
August 20
A18. Display of Expiration Date
The expiration date will be displayed on all forms.
A19. Exceptions to Certification
EIA takes no exception to the certification statement.

25

Posted on
website
August 7
August 14
August 21