Form 3-Q Justification for nonsubstantative Change

Supporting Documentation for a non-substantive change in

FERC Form No. 3-Q “Quarterly Financial Report of Electric Utilities, Licensees, and Natural Gas Companies”

As Proposed in Docket No. RM07-9-004, RIN: 1902-AE11

OMB Control Nos. 1902-0205

(Order on Rehearing issued August 22, 2011)

The Federal Energy Regulatory Commission (FERC or Commission) requests Office of Management and Budget (OMB) review and approval of FERC Form No. 3-Q "Quarterly Financial Report of Electric Utilities, Licensees, and Natural Gas Companies". This information collection is a current data requirement with modifications as proposed in Docket No. RM07-9-004, “Revisions to Forms, Statements and Reporting Requirements for Natural Gas Pipelines”, Order No. 710-C.¹

Background

In the order on rehearing the Commission generally denies rehearing and reaffirms the findings made in Order No. 710-B (Final Rule in Docket No. RM07-9-003). The Commission does, however, grant rehearing on the issue of whether to include Page 521d and grant additional time to comply with Order No. 710-B. Further, in response to comments, the Commission is revising its burden estimates for the FERC Form Nos. 2 and 2-A.

Non-substantive change justification for FERC Form No. 3-Q (Form 3-Q)

In Order No. 710-C the Commission recognizes, in response to concerns raised by the Interstate Natural Gas Association (INGAA) about burden, that some filers may have to modify existing systems in order to collect the necessary data. To account for this, the Commission estimated a one-time burden of 80 hours per filer. It is assumed that this one-time burden will be completed by April 18, 2012 (the required filing date of the modified Forms 2 and 2-A) and subsequently the Commission plans to remove the hours from the inventory for each form. Because the next filing of the Form 3-Q (May/June 2012) occurs after the one-time burden has been expended, the Commission has determined that this form is not affected by the one-time program change.

INGAA also raised a concern regarding whether to include Page 521d in Forms 2, 2-A and 3Q. This page is a continuation of the data that is requested on page 521b and has necessary data fields that the Commission requires. Page 521d was included in the Notice of Proposed Rulemaking and considered in the corresponding burden estimates. In the Final Rule the Commission, as an oversight, omitted the page but did not reduce the burden estimate. In Order No. 710-C FERC is correcting the oversight, adding Page 521d back in, and the burden is unchanged.

For these reasons the Commission is submitting the change to the Form 3-Q to OMB (adding back in page 521d) as a non-substantive change to the collection.

1 This Order affects the Form 2, 2-A, and 3-Q. The Form 2 has OMB approval number 1902-0028, expires 5/31/14; the Form 2-A has OMB approval number 1902-0030, expires 5/31/14; and the Form 3-Q has OMB approval number 1902-0205, expires 5/31/14.