Form FERC Form No. 552 FERC Form No. 552 Annual Report of Natural Gas Transactions

Form No. 552
OMB No. 1902-0242

THIS FILING IS
Item 1: □ An Initial (Original) Submission OR □ Resubmission,

No.

Expires (12/31/2018)

FERC TRANSACTION REPORT
FERC FORM No. 552: Annual Report of
Natural Gas Transactions

These reports are mandatory under the Natural Gas Act, Section 23(a)(2), and 18 CFR Parts 260.401.
Failure to report may result in criminal fines, civil penalties, and other sanctions as provided by law. The
Federal Energy Regulatory Commission does not consider these reports to be of a confidential nature.

Exact Legal Name of Respondent (Company)

Year of Report
End of
2017

FERC FORM No. 552 (R2.3)

i

INSTRUCTIONS FOR FILING THE FERC FORM NO. 552
GENERAL INFORMATION

I.

Purpose
FERC Form No. 552 collects transactional information from natural gas market participants.
The filing of this information is necessary to provide information regarding physical natural
gas transactions that use an index and transactions that contribute to, or may contribute to
gas price indices. This form is considered to be a non-confidential public use form.

II.

Who Must Submit
Physical natural gas buyers and sellers must complete and file the form annually if their
"reportable" natural gas purchases or sales are equal to or greater than 2.2 trillion British
Thermal Units (TBtu) or 2.2 million (2,200,000) MMBtu in the reporting year.
Note: Whether a Respondent operates under a Blanket Certificate is no longer used to determine who
must submit the form. See Order 704-C.

III.

What and Where to Submit
1. Complete all pages of the form, if your "reportable" physical natural gas purchases or
sales in the reporting year were equal to or greater than 2.2 million MMBtu or 2.2 TBtu.
(For example, if your reportable purchases were 1.0 million MMBtu and your reportable
sales were 2.8 million MMBtu, you must file the form)
2. Do not complete the form, if both your "reportable" physical natural gas purchases and
sales in the reporting year were less than 2.2 million MMBtu. (For example, if reportable
purchases are 1.8 million MMBtu and reportable sales are .75 million MMBtu, do not file
the form).
a. Note: Not all transactions involving physical natural gas are "reportable". Only
transactions that use an index, or that contribute to, or may contribute to the
formation of a gas index should be reported. See Definitions and lines 2-7 on page 4.
b. Review the Definitions to determine whether your "reportable" purchases or sales
meet or exceed this de minimis threshold of 2.2 million (2,200,000) MMBtu.
c. Signature of Company Officer - The Commission accepts a typed name in block 14
on page 1 as an electronic signature pursuant to 18 CFR § 385.2005(c). Type the
name of the officer whose signature legally binds the company with respect to the
accuracy and completeness of the submission.
d. Filing Form No. 552 is a two step process that requires filers to:
i. Download Adobe Acrobat Reader version 8.0 or greater.
ii. Download, complete, and save a fillable Form No. 552 PDF discussed above to
your computer.
iii. eFile the saved Form No. 552 PDF to the Commission.
iv. Paper and email filings will not be accepted.

ii

e. Users may obtain additional blank copies of FERC Form No. 552 for reference free of
charge from: http://www.ferc.gov/docs-filing/forms.asp#552.
f. Copies may also be obtained from the Public Reference and Files Maintenance
Branch, Federal Energy Regulatory Commission, 888 First Street, NE, Room 2A,
Washington, DC 20426 or by calling (202) 502-8371.
IV. When to Submit
FERC Form No. 552 must be eFiled by May 1st of the year following the reporting year
(18 CFR § 260.401).
V.

Where to Send Comments on Public Reporting Burden
The public reporting burden for the FERC Form No. 552 collection of information is estimated
to average 10 hours per response, including the time for reviewing instructions, searching
existing data sources, gathering and maintaining the data-needed, and completing and
reviewing the collection of information. This estimate was noted in the Notice of Proposed
Rulemaking and in the Final Rule (RM07-10-000) and addressed by commenters.
Filers may send additional comments regarding these burden estimates or any aspect of
these collections of information, including suggestions for reducing burden, to the Federal
Energy Regulatory Commission, 888 First Street NE, Washington, DC 20426 (Attention:
Information Clearance Officer, CIO) or email [email protected]; Office of
Management and Budget, via email to the Office of Information and Regulatory Affairs at
[email protected] (Attention: Federal Energy Regulatory Commission Desk
Officer). No person shall be subject to any penalty if any collection of information does not
display a valid control number (44 U.S.C. § 3512 (a)).

GENERAL INSTRUCTIONS
I.

All Respondents must identify themselves annually by completing the first part of
Form No. 552.

II.

Aggregation across Affiliates (or members of a public joint action agency) is
permitted, though not required. The Respondent must complete the “Schedule of
Reporting Companies” (page 3) which lists those Affiliates and a separate “Price
Index Reporting” schedule for itself and each affiliate.

III.

Asset managers may not report aggregated information for their customers in Form
No. 552. Customers of asset managers are individually responsible for determining
whether they must file Form No. 552. An asset manager may itself be required to
submit Form No. 552 to the extent that its activities are not undertaken on behalf of
an asset management client.

IV.

Report all gas quantities in trillion British Thermal Units (TBtu) unless the schedule
specifically requires the reporting in another unit of measurement. (Divide MMBtu by
1,000,000 to convert volumes to TBtu.)

V.

For reported volumes, enter numbers to the tenth unit only, except where otherwise
noted.

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VI.

Enter volumes of “reportable” physical natural gas as explained in the definitions.

VII.

Complete each question fully and accurately, even if it has been answered in a
previous report. Enter the word "None" where it truly and completely states the fact.

VIII.

Enter the month, day, and year only on page 1, blocks 11 and 15. The Form No. 552
will auto-populate the dates in all other pages.

IX.

For any resubmissions, upload and complete a new fillable Form No. 552 and eFile it
with the Commission. Please explain the reason for the resubmission in the
description of your eFiling.

X.

Do not make references to reports of previous periods/years or to other reports in
lieu of required entries, except as specifically authorized.

XI.

Regarding reportable transactions that involve deliveries that occur or may occur
over multiple calendar years, only volumes for delivery that use, contribute to, or may
contribute to the formation of an index during the subject calendar year should be
reported. For a multi-year contract that relies on an index to establish a natural gas
price, volumes should be reported in the year in which the index is referenced.

XII.

Company Officer- any person who can legally bind the company regarding the
completeness and accuracy of the submission.

DEFINITIONS
I.

Affiliate– An affiliate means a person who controls, is controlled by or is under common
control with another person. For purposes of the completion of Form No. 552, a joint public
action agency may submit members’ collective information as if those members were
Affiliates.

II.

Date of Report – The date the report is submitted to the Commission.

III.

Fixed Price – A “Physical Natural Gas Transaction” price determined by agreement
between buyer and seller and not benchmarked to any other source of information.
Generally these transactions are not reportable except for Fixed Price Next-Day or Next
Month Delivery transactions. (See other definitions and lines 2 and 4 on page 4.)

IV.

Physical Natural Gas Transaction – For purposes of Form No. 552, physical natural gas
transactions are only those transactions that either use an index, or that contribute to, or
may contribute to the formation of a gas index during the calendar year. These transactions
are generally included in lines 2 through 7 of page 4 of the form and are referred to as
“reportable” transactions.

A physical natural gas transaction is an obligation to deliver natural gas at a specified
location and at a specified time, with the exception of physically-delivered futures contracts.
It is not necessary that natural gas actually be delivered under the transactions, only that
the delivery obligation existed in the agreement when executed. Certain Physical Natural
Gas Transactions may not remain in existence through the time of delivery because they
were traded away or “booked out.” For purposes of this form, these transactions should be
included whether they went to delivery or not. Order No. 704 and 704-A discuss a variety of
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particular instances. Order No. 704-C clarified transactions that use an index.
Reportable Physical Natural Gas Transactions are only those transactions that refer to
an index, or that contribute to, or could contribute to the formation of a gas index during the
calendar year. The following physical natural gas volumes should be included in
volumetric data submitted in Form No. 552:
Reportable physical natural gas transactions that use an Index are as follows:
a. Transactions that Use Daily Indices (line 3 of page 4)- delivery of natural gas pursuant to a
transaction that refers to a published daily index, which is used to price natural gas. The
index is usually a gas index, but other indices such as coal, petroleum, LNG, inflation, etc.
or a basket of indices may be used.
b. Transactions that Use Monthly Indices (line 5 of page 4)- delivery of natural gas pursuant
to a transaction that refers to a published monthly index, which is used to price natural
gas. The index is usually a gas index, but other indices such as coal, petroleum, LNG,
inflation, etc. or a basket of indices may be used.
Note: the referenced index need not be solely a gas index. Thus, a transaction that relies
on a basket of indices which includes a gas index and other daily or monthly indices such
as coal, petroleum, LNG, inflation, etc. would also be reportable on Lines 3 and 5. Please
identify indices used on page 4, lines 8 and 9.
Also transactions that refer to “weekly,” “yearly,” or other gas price indices may, in fact, be
based on daily gas price indices and are reportable on page 4, line 3 of Form No. 552.
For example, a transaction that references a “weekly” index that is formed by averaging
multiple daily indices is reportable as referencing a daily index. Similarly, a transaction
that refers to a yearly index that is formed by averaging twelve monthly indices would be
reported as referencing a monthly index.
Reportable transactions that can or may contribute to gas index formation are as follows:
a. Fixed Price Next-Day Delivery (line 2 of page 4)– delivery of natural gas pursuant to a
transaction executed prior to NAESB nomination deadline (1:00 pm Central Prevailing
Time) on one day for uniform physical delivery over the next pipeline day. Transactions
executed on Friday are usually for flow on Saturday, Sunday, and Monday inclusive.
Trading patterns may vary in the case of holidays or the end of a month that occurs on a
weekend.
b. Fixed Price Next-Month Delivery (line 4 of Page 4)- delivery of natural gas pursuant to a
transaction executed during the last five (5) business days of one month (bidweek) for
uniform physical delivery over the next month.
c. Trigger Agreements (line 6 of page 4)- a NYMEX trigger transaction that is contingent upon
a futures contract that trades on an exchange, resulting in an automatic physical trade at an
agreed upon price. If such a Fixed Price physical transaction was triggered or originated by
a NYMEX futures contract during bid week and can contribute to an index, it is reportable.

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d. NYMEX Plus Contracts (line 6 of page 4)- delivery of natural gas pursuant to a transaction
contracted during bidweek that uses a NYMEX Natural Gas Futures price and a differential
(premium or discount) to establish a Fixed Price. These transactions are for uniform
physical delivery over the next month.
e. Physical Basis Transactions (line 7 of page 4)- transactions in which the basis value is
negotiated on one of the first three days of bidweek and the price is set by the final closing
value of the near-month NYMEX Natural Gas Futures contract plus or minus the negotiated
basis. These transactions are for uniform physical delivery over the next month.
f.

Volumes attributable to royalty-in-kind transactions, gas provided for processing such as plant
thermal reduction (not including unprocessed gas), and purchases and sales related to the
production and gathering function.

g. Regarding transactions involving possible international transportation, we clarify that:
i. volumes originating from inside the lower 48 states and delivered outside the lower 48
states are reportable; and
ii. volumes delivered inside the lower 48 states are reportable.
Thus, any volumes that originate or are delivered into the lower 48 states should be reported
to the same extent as purely domestic volumes.
h. Operational volumes of natural gas sold or purchased by an LDC to operate the distribution
system, address one-time operational events, or to maintain system pressure or line pack.
i.

Lean unprocessed natural gas that will not undergo processing to remove natural gas liquids
before consumption. See Order 704-C, paragraphs 38 and 39.

Not Reportable Transactions- notwithstanding the above, the following volumes are not
reportable and should, in all cases, be excluded in volumetric data submitted in Form No. 552:
a. Cash-out and imbalance makeup volumes,
b. All unprocessed gas transactions that use a percentage of proceeds contract,
c. Transactions of natural gas that is both:
i.
Unprocessed, i.e. natural gas liquids have not been removed from the gas, and
ii.
Upstream of a processing facility (that is, volumes reasonably expected to travel
through a processing facility before consumption.)
Some lean unprocessed gas may be reportable. Please see Order No. 704-C at paragraphs 38
and 39.
d. Regarding transactions involving possible international transportation volumes originating
outside the lower 48 states and delivered at locations outside the lower 48 states.
e. Sales to and purchases by retail consumers of natural gas pursuant to a state commissionapproved bundled tariff,
f.

Volumes associated with transactions among Affiliates,
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g. Volumes associated with any type of financially-settled transaction,
i.

Volumes traded in futures contracts, even those that go to physical delivery,

j.

Volumes of imported LNG traded prior to regasification and exported LNG traded after
liquefaction, and

k. Fixed Price transaction volumes that are not Next-Day Delivery or Next-Month Delivery.
V.

Price Index Publisher – Companies that report price indices for U.S. wholesale natural gas
markets. The list of companies can change over time.

VI.

Quantity – Amount of purchases or sales expressed in trillion Btu (TBtu). The quantities to
be reported in the ”Purchase and Sales Information” schedule should be measured to the
nearest tenth of a TBtu. One TBtu is equivalent to one Bcf. One million MMBtu are, by
definition, the same as one million decatherms. A volume of one million Mcf of natural gas
contains approximately one million MMBtu of energy depending on the exact energy content
of the natural gas.

XI.

Reporting Company – The person, corporation, licensee, agency, authority, or other legal
entity or instrumentality on whose behalf the report is being submitted by the
“Respondent.”

XII.

Respondent – The person, corporation, licensee, agency, authority, or other legal entity or
instrumentality that is submitting the report either on its own behalf, or on behalf of itself
and/or its Affiliates. A Respondent may choose to either report for all its Affiliates
collectively, or may choose to have each of its Affiliates report separately as their own
“Respondent.” If reporting collectively, the “Respondent” must report for each “Affiliate” in
the “Schedule of Reporting Companies” and the “Price Index Reporting Schedule,” and
collectively for all its Affiliates in the “Purchase and Sales Information” schedule.

XIII.

Natural Gas Purchases – The volumetric “Quantity” of “Physical Natural Gas Transactions”
purchased by the “Reporting Company” during the “Year of Report.”

XIV.

Natural Gas Sales – The volumetric “Quantity” of “Physical Natural Gas Transactions” sold
by the “Reporting Company” during the “Year of Report.”

XV.

Year of Report – The calendar year for which the report is being submitted.

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ANNUAL REPORT OF NATURAL GAS TRANSACTIONS
IDENTIFICATION OF RESPONDENT
01 Exact Legal Name of Respondent

02 Year of Report End of

2017
03 Previous Name and Date of Change (If name changed during year)

04 Address of Principal Office at End of Year (Street, City, State/Provence, Postal Code)

05 Name of Contact Person

06 Title of Contact Person

07 Address of Contact Person (Street, City, State/Provence, Postal Code)

Copy Address

08 Email Address of Contact Person

09 Telephone of Contact Person, Including Area Code

10 This Report is:
(1)
(2)

An Original
A Resubmission

11 Date of Report
(MM/DD/YYYY)

ANNUAL COMPANY OFFICER CERTIFICATION
The undersigned officer certifies that:
I have examined this report and to the best of my knowledge, information, and belief all statements of
fact contained in this report are accurate and complete statements of the business affairs of the
Respondent.

12 Name

13 Title

14 Signature

15 Date Signed (MM/DD/YYYY)

Title 18, U.S.C. 1001, makes it a crime for any person knowingly and willingly to make to any Agency or
Department of the United States any false, fictitious or fraudulent statements as to any matter within its jurisdiction.

FERC FORM NO. 552 (R2.3) 

Page 1 

Name of Respondent*

This Report is:
(1)
An Original
(2)
A Resubmission

Date of Report*
(MM/DD/YYYY)

Year of
Report End of

2017

List of Schedules
This schedule should be completed only if you checked the Resubmission box on the front
of Form No. 552. Identify the schedule that you changed along with a brief remark.
Otherwise it should be left blank.

Line
No

Title of
Schedule

Reference
Page No.

Date Revised

Remarks

(a)

(b)

(c)

(d)

1

Schedule of Reporting Companies

3

2

Price Index Reporting

3

3

Price Index Reporting cont'd

3a

4

Purchases and Sales Information

4

FERC FORM NO. 552 (R2.3) 

Page 2 

Name of Respondent*

This Report is:
(1)
An Original
A Resubmission
(2)

Date of Report*
(MM/DD/YYYY)

Year of
Report End of

2017

Schedule of Reporting Companies and Price Index Reporting 
List the name of the Respondent, Reporting Company and any Affiliates that are included in this filing.
Then answer questions (b) - (e) for each company listed. Respondent* should complete the “Purchase
and Sales Information” schedule on page 4 only once for these companies collectively. *An asterisk
means that the previous term is explained in more detail in the definitions.
1) Did the Respondent, Reporting Company* or any Affiliates listed in column (a) report any transaction
information to Price Index Publishers* during the Report Year*?
2) If you answered yes on column (b), did the Respondent, Reporting Company* or any Affiliates comply
with the regulations governing reporting to Price Index Publishers* pursuant to 18 C.F.R. § 284.403. If
you answered no on column (b), the software will automatically answer Not applicable or NA in column
(c).
3) Were the Respondent, Reporting Company or the Affiliate’s reportable natural gas purchases* equal to
or greater than 2.2 million MMBtu for the Report Year*?
4) Were the Respondent, Reporting Company or the Affiliate’s * reportable natural gas sales* equal to or
greater than 2.2 million MMBtu for the Report Year*? 

Legal Name

Report
Transactions?

(a)

(b)

Line
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20

FERC FORM NO. 552 (R2.3) 

Page 3 

Reportable
Purchases >=
Comply with
2.2 Million
Regulations?
MMBtu
(c)

(d)

Reportable
Sales >=
2.2 Million
MMBtu
(e)

Name of Respondent*

Line
No.
1

This Report is:
(1)
An Original
(2)
A Resubmission

Legal Name

Report
Transactions?

(a)

(b)

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30

FERC FORM NO. 552 (R2.3) 

Additional Affiliates 

Date of Report*
(MM/DD/YYYY)

Year of
Report End of

2017
Reportable
Purchases >=
Comply with
2.2 Million
Regulations?
MMBtu
(c)

(d)

Reportable
Sales >=
2.2 Million
MMBtu
(e)

Name of Respondent*

Name of Reporting Company*

Date of Report*
(MM/DD/YYYY)

This Report is:
(1)
An Original
(2)
A Resubmission

Year of
Report End of

2017

Reporting Company* is:
(1)
Same as Respondent*
(2)
An affiliate* of Respondent* (other Affiliates reported separately)

Purchase and Sales Information
If the Respondent* is reporting collectively for multiple Affiliates, the Respondent* should complete this
schedule for all of its affiliates* companies collectively. Volumes should be reported to the nearest tenth
TBtu.
* An asterisk means that the previous term is explained in more detail in the definitions.
Purchases
(TBtu)
(b)

Sales
(TBtu)
(c)

2

Item
(a)
What was the total volume of Physical Natural Gas
Transactions* (reportable sales and purchases) engaged in by
the Respondent in the prior calendar year?
Of the amounts reported on line 1, what quantities were
contracted at Fixed Prices* for Next-Day Delivery*?

3

Of the amounts reported on line 1, what quantities were
contracted at prices that refer to* published daily indices?

0.0

0.0

4

Of the amounts reported on line 1, what quantities were
contracted at Fixed Prices for Next-Month Delivery*?

0.0

0.0

5

Of the amounts reported on line 1, what quantities were
contracted at prices that refer to* published monthly indices?

0.0

0.0

0.0

0.0

0.0

0.0

Line
No.
1

Of the amounts reported on line 1, what quantities were
contracted under trigger agreements*, such as NYMEX Plus*
contracts.
Of the amounts reported on line 1, what quantities were
contracted as physical basis transactions*?

6

7

8

9

0.0

0.0

0.0

0.0

If there is a difference between Respondent’s* purchases reported on line 1 and the sum of its purchases on
lines 2, 3, 4, 5, 6 and 7, please explain the difference in the space below and provide the relevant volumes.
If you used a basket of indices that included a gas price index in lines 3 and 5, please list the names of the
non-gas indices used.

If there is a difference between Respondent’s* sales reported on line 1 and the sum of its sales on lines 2, 3,
4, 5, 6 and 7, please explain the difference in the space below and provide the relevant volumes. If you
used a basket of indices that included a gas price index in lines 3 and 5, please list the names of the nongas indices used.

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FERC FORM NO. 552 (R2.3) 

Page 4 

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