EIA-63C Supporting Statement A

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Densified Biomass Fuel Report, EIA-63C

OMB: 1905-0209

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Supporting Statement for Densified Biomass Fuel Report

  1. Part A: Justification

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Form EIA-63C, Densified Biomass Fuel Report

OMB No. 1905-0209

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June 2018

Independent Statistics & Analysis

www.eia.gov

U.S. Department of Energy

Washington, DC 20585





Introduction

The U.S. Energy Information Administration (EIA) is the statistical and analytical agency within the U.S. Department of Energy (DOE). It collects, analyzes, and disseminates independent and impartial energy information to promote sound policymaking, efficient markets, and public understanding regarding energy and its interaction with the economy and the environment.

EIA requests a three-year extension, with changes, from the Office of Management and Budget (OMB) to Form EIA-63C Densified Biomass Fuel Report.

Form EIA-63C Densified Biomass Fuel Report is part of EIA’s comprehensive energy data program. This mandatory survey collects information from facilities that manufacture densified biomass fuel products in the U.S. Data collected include product characteristics, domestic and export sales, and average price of densified biomass fuel products used for energy applications. The information collected is the primary national source on the nation’s production of biomass fuel for heating and electric power generation in domestic and export markets.

Revisions

Consultations with respondents during the first year of data collection identified questions that were either confusing or difficult for respondents to answer. Other questions had too few responses to allow for publication without disclosing identifiable company information. In a Federal Register Notice, 82 FR 48808, published on October 20, 2017, the U.S. Energy Information Administration (EIA) proposed changes to Form EIA-63C.  As a result, EIA is removing six questions:

Part 2. Question 2.2 Operational month

Part 2 Question 2.4 Current horsepower

Part 2. Question 2.6 Planned capacity

Part 2. Question 2.7 Planned horsepower

Part 3. Question 3.2 Feedstock utilization

Part 4. Question 4.2, Delete the column for reporting “Export Port” (not other parts of Q. 4.2)

EIA is also deleting the requirement to report quantity, characteristics, inventory, and revenue data on compressed fuel logs, bricks, and briquettes from Questions 3.3, 3.4 and 4.1. Due to the small size of this sector in the densified biomass industry, it is not feasible to consistently publish quality data.

Finally, EIA is changing the due date for the annual respondents (small facilities producing less than 10,000 tons annually, and planned facilities) from February 1 to June 1 to coincide with the industry’s off-season and ease the burden on small respondents during their busiest time of the year.



A.1. Legal Justification

The authority for this mandatory data collection is provided by the following provisions:

  1. 15 U.S.C. §772(b) states:

    1. "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 Administrator 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 Administrator may prescribe by regulation or order as necessary or appropriate for the proper exercise of functions under this chapter."



  1. 15 U.S.C. §764(b) states that to the extent authorized by subsection (a), the Administrator shall:

    1. (1) advise the President and the Congress with respect to the establishment of a comprehensive national energy policy in relation to the energy matters for which the Administration has responsibility, and, in coordination with the Secretary of State, the integration of domestic and foreign policies relating to energy resource management;

    2. (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;

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

    4. (4) develop plans and programs for dealing with energy production shortages; …

    5. (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. (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;

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

    8. (12) perform such other functions as may be prescribed by law."



  1. As the authority for invoking subsection (b), above, 15 U.S.C. §764(a) states:

    1. ”Subject to the provisions and procedures set forth in this Act, the [Secretary] shall be responsible for such actions as are taken to assure that adequate provision is made to meet the energy needs of the Nation. To that end, he shall make such plans and direct and conduct such programs related to the production, conservation, use, control, distribution, rationing, and allocation of all forms of energy as are appropriate in connection with only those authorities or functions-

      1. (1) specifically transferred to or vested in him by or pursuant to this chapter;

      2. (3) otherwise specifically vested in the Administrator by the Congress."



  1. Additional authority for this information collection is provided by 15 U.S.C. §790(a) which states;

    1. “It shall be the duty of the Director to 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… to meet adequately the needs of…”

      1. (1) the Department of Energy in carrying out its lawful functions;

      2. (2) the Congress;

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

      4. (4) the States to the extent required by the Natural Gas Act [15 U.S.C. §717 et seq.] and the Federal Power Act [16 U.S.C. §791a et seq.].

    2. "At a minimum, the System shall contain such energy information as is necessary to carry out the Administration's statistical and forecasting activities, and shall include… such energy information as is required to define and permit analysis of;

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

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

      3. (5) industrial, labor, and regional impacts of changes in patterns of energy supply and consumption;

      4. (6) international aspects, economic and otherwise, of the evolving energy situation; and

      5. (7) long-term relationships between energy supply and consumption in the United States and world communities.”

A.2. Needs and Uses of Data

The purpose of Form EIA-63C is to collect fundamental statistics on densified biomass production, distribution, trade, consumption, prices, and stocks.

The data collected on Form EIA-63C is used by the US Forest Service. Production and the export of wood pellets has become a contentious issue for forest policy makers at local, national, and international levels. Data from Form EIA-63C supports the US Forest Service’s continued research. The US Forest Service also uses these data to prepare summary documents for the USDA Forest Service assessments, document production and exports for the chief of the Forest Service to present at international hearings and conferences and to address concerns raised by the USDA foreign Agricultural Service officers in London, Brussels and DC. The forest service also uses Form EIA-63C feedstock source data to compare to data they collect in their Forest Inventory and Analysis National Program, to assess the sustainability and productivity of our national and private forest lands.

EIA also uses these data to answer queries from the U.S. Congress, other federal and state agencies, the biomass fuel industry, and the general public; and for other analytical activities. Other users of the data include policy makers, regulators, energy market analysts, academia, and the renewable energy industries. For example, survey respondents use Form EIA-63C data to compare pellet prices to other winter heating fuels. The data are also used in models to forecast and plan for upcoming demand for the winter heating season. Future Metrics, a consulting agency that provides information, market analysis, operations guidance and strategic advice to companies in the wood pellet production sector, recently used Form EIA-63C data in their 2018 North American Pellet Market Quarterly. They specifically cited our inventory, capacity, production, and sales data in their report.

Outside of the data collected from Form EIA-63C, the available quantitative information on the densified biomass industry is minimal, and in particular little data is available at the state level. Form EIA-63C fills this information gap. In the absence of a centralized and public data collection by EIA, each state would have to undertake its own data collection effort, and in many cases request duplicative information from firms with operations that cross state lines. EIA ensures an efficient and consistent data collection with minimum cost to the public and respondents.

The data collected on this survey is used in EIA reports released on EIA’s website, including but not limited to:

A.3. Use of Technology

Form EIA-63C Densified Biomass Fuel Report, uses Internet-based data collection systems as the primary means of data collection. The majority of communications with respondents is by email.

Internet data collection will continue to be the primary collection mode for the survey. The Internet-based system allows respondents to enter their data directly into the EIA survey databases. This reduces the time needed for data collection and processing. The system identifies reported data that fail edit specifications prior to submission allowing respondents to make necessary corrections or explain unusual situations that impact the reported data. This data editing process reduces respondent burden by reducing the number of times a respondent must resubmit forms prior to acceptance by EIA. It also improves the timeliness of reporting the information to the public.

A.4. Efforts to Identify Duplication

The data elements collected on Form EIA-63C are not duplicated in other surveys or sources known to EIA. EIA reviews and evaluates densified biomass industry information available from a variety of sources, including other federal agencies, industry trade associations, state governments, and commercial information services, to identify instances of duplication. Additionally, in the public notices and consultations associated with the triennial re-clearance of Form EIA-63C, EIA encourages respondents and data users to identify alternate sources of the densified biomass information EIA proposes to collect. Instances of potential data duplication identified by EIA are evaluated in terms of data coverage, level of aggregation, frequency of collection, data reliability, and statutory requirements to determine whether alternate data sources represent a suitable substitute for EIA data.

Several other government and private entities conduct biomass energy data collection, estimation, and/or publication programs. These entities include:

  • Pellet Fuels Institute

  • USDA Forest Service

  • State Energy Offices

EIA has evaluated other sources of data relating to the densified biomass industry and has found no other source that can replace Form EIA-63C (see Table 1). This is because of differences in classification, inconsistency, incompleteness, unavailability, or lack of universal coverage.

Table A1. Non-EIA Pellet Fuel Data Collection Programs and Forms

Responsible Group

Form or Collection

No.

Title

Notes

Pellet Fuels Institute

N/A

PFI Pellet Industry Survey

Coverage of approximately 20% of the industry. Last survey was for 2012. Collected data on production, pricing, feedstock, and sales of pellet fuels. The lack of adequate market coverage and unavailability of any current data series prevent this data series from being an appropriate substitute for Form EIA-63C.

U.S. Forest Service

N/A

Forest Inventory

US Forest Service collects data on woody biomass consumption from public and private forests from the USDA Forest Service National Woodland Owner Survey. They don’t track or collect the consumption of the wood. They track how much wood is removed from a forest. There is some overlap with the collection of feedstock data. EIA collects data from the receivers and buyers of feedstocks. US Forest Service collects data from the owners of forests where the trees where originally harvested. The frame file for the US Forest Service is logging companies. These logging companies are different from the biomass suppliers reporting on the EIA-63C frame file.

States

N/A

NA

New Hampshire, Maine, Vermont, Massachusetts, and New York collect data on densified biomass fuel use and appliances in conjunction with incentives for replacing fossil fuel with biomass for space heating. These programs are focused towards the end user of the pellets; people or businesses with wood burning stoves for home heating (which EIA does not collect). The states collect information on who uses these stoves so that the proper incentives can be awarded to lower the cost of installation and maintenance. For example, NY has a program called Renewable Heat NY. This program awards rebates or low interest loans to homeowners who install new pellet stoves for home heating, especially in areas with limited access to natural gas.



A.5. Provisions for Reducing Burden on Small Businesses

EIA recognizes the need to minimize the reporting burden on small businesses and designs data surveys so that small operations are not unduly affected. Additionally, EIA has established reporting thresholds for surveys likely to affect small businesses. These thresholds either eliminate the reporting requirement for small businesses or limit the amount of information they are asked to supply.

Through its Internet data collection system, EIA pre-populates data elements for items that do not frequently change. This allows respondents (both large and small) to verify that the previously reported information has not changed, as opposed to entering the same information for each survey cycle. In addition, the Internet data collection system with its built-in edits has reduced the burden on businesses by reducing call-backs to verify or correct questionable data.

Small biomass fuel manufacturers (manufactures with annual capacity less than 10,000 tons) only need to report Part 1 (Identification) and Part 2 (operational status, capacity, and year of initial operation) annually to minimize their reporting burden. Monthly respondents report the entire form, Parts 1 through 4.

A.6. Consequences of Less-Frequent Reporting

Less frequent reporting would not allow EIA to meet its mandate of providing timely, reliable energy information to the Congress, other federal, state and local governments, industry, and the general public. If this survey went from a monthly to an annual frequency, the users would have a much tougher time forecasting their production needs for the winter. Having more frequent publications of values like inventory numbers allows the respondents to better prepare for a shortage or surplus of product.

The monthly information collected on the Densified Biomass Fuel Report is used to provide data, and in particular price data, that is of greatest value to the industry and analysts when it is timely. Since EIA has begun publication of this information the industry has learned that comparisons of pellet prices and the price of fuel oil for home heating is a valuable indicator of near-term demand. This helps inform decisions on production and inventory levels.

A.7. Compliance with 5 CFR 1320.5

Form EIA-63C is operated in accordance with the guidelines in 5 CFR 1320.5.

A.8. Summary of Consultations Outside of the Agency

EIA staff attended the Pellet Fuel Institute (PFI) Annual Conference in Stowe, VT on July 23-25, 2017. The conference highlighted the various applications of densified biomass, as well as trends and best practices within the densified biomass industry. PFI is a North American trade association consisting of 67 members involved in the diversified biomass fuel industry. A broad range of individuals from the public and private sectors, academia, and local, state and national governments from North America and Europe attended the conference. The conference included two days of educational sessions as well as industry exhibits and extensive networking opportunities which allowed staff to directly engage pellet fuel producers who complete Form EIA-63C.

Staff from EIA also attended and presented densified biomass survey data at the Hearth Patio & Barbeque Association (HPBA) Expo in Atlanta, GA on March 1-4, 2017. The HPBA is an international trade association that promotes the interests HPBA members that manufacture, distribute, sell, and service products that include, among other things, wood, pellet, coal, gas and electric stoves and the hearth products industry in North America. EIA’s presentation explained the history, purpose, and use of Form EIA-63C data collection. The presentation recounted that in 2013, Senator Shaheen and Senator Collins wrote a letter asking EIA to expand the collection and reporting of biomass data. In their letter, the senators stated how important the biomass industry is to their states and how this collection would “provide a clearer picture of the nation’s home heating fuel portfolio”. The presentation also covered who is required to report for Form EIA-63C and what data elements are collected. Aggregate sales and production data were presented as well as the different publications where the data are published.

Conversations were conducted with several respondents, including Energex, Pacific Coast Pellets, and American Wood Fibers. These conversations occurred after the presentation and involved discussions on how EIA-63C data are useful to them.

On December 5, 2017, EIA conducted an Outreach Session via both WebEx and In-Person attendance options. Invitations were extended to respondents, known relevant trade associations, and other stakeholders known to EIA. Representatives from University of British Columbia/Oak Ridge National Lab and Fiber By-Products attended via WebEx. A representative from Enviva Biomass attended in person. EIA’s presentation covered the uses and purposes of the Form EIA-63C and reviewed the proposed changes from the 60 Day Federal Register Notice (FRN).

EIA received one written comment in response to the 60 Day FRN from the Pellet Fuels Institute (PFI), a trade association. PFI agreed with EIA’s proposal to eliminate Questions 2.2, 2.4, 2.7, and 3.2. They recommended keeping Questions 2.5, 2.6, and 4.2. EIA carefully considered their comment and agreed that Question 2.5 provides useful information, knowing why pellet extrusion equipment is not fully utilized, and should be retained. EIA stated that finding a way to publish the data that was both useful and did not compromise data protection was an issue, but agreed that going forward EIA would provide the information in a narrative format rather than tabular summary of the data. This will be done using the monthly “highlights” section that gets published alongside the data tables.

EIA is still removing Question 2.6, Planned Maximum Annual Production, and Question 4.2, Ports for Pellet Export. Respondents have been unable to consistently provide accurate planned capacity data. Problems have included reports of planned capacity less than existing capacity and reported capacity expansions that never occurred. Further, only a small number of respondents provide the export port, so the data cannot be published without violating data protection rules designed to maintain the confidentiality of company-specific information.

A.9. Payments or Gifts to Respondents

There will not be any payments made or gifts given to respondents as an incentive to complete the densified biomass survey.

A.10. Provisions for Protection of Information

Information reported for the following three data elements: Part 1. Name of Facility; Question 1.2. Physical Location of Facility; and Question 2.2. Maximum Annual Production Capacity; are considered public information and may be publicly released in company identifiable form.

All other information reported on this survey 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 Department of Energy (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 also requires EIA 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 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 by other federal agencies for non-statistical purposes such as administrative, regulatory, law enforcement, or adjudicatory purposes.

A.11. Justification for Sensitive Questions

There are no questions of a sensitive nature.

A.12. Estimate of Respondent Burden Hours and Cost

The total annual burden is estimated to be 1,467 hours (see Table 2, below). During May and June of 2017, EIA conducted a cognitive research project on the form (including the six questions) to verify the reporting burden estimate of 1.5 hours and found it to be accurate based on responses received from the participants. The burden hours per response of 1.4 hours is based on the removal of the six questions from the burden in the previous clearance of 1.5 hours.

Based on the estimated rate of $75.69 per hour for employees who would complete these forms, the total annual respondent cost for all forms is estimated to be:

$75.69/hour x 1,467 hours/year = $111,026.

An average cost per hour of $75.69 is used because that is the average loaded (salary plus benefits) cost for an EIA employee assigned to data survey work. EIA assumes that the survey respondent workforce completing surveys for EIA is comparable with EIA workforce.



A.13. Annual Cost to the Federal Government

The estimated annual cost to the government for Form EIA-63C, including personnel, maintenance, data collection, and processing by EIA is approximately $158,949. The data requested will be captured via an internet data collection system and website for which EIA already has technology in place. The estimate of $158,949 is based on one full-time equivalent (FTE) employee. (The current estimate of the hourly rate for an EIA employee is $75.69/hour. Assuming 2,100 hours per year the annual cost is $158,949.) The estimate of one FTE is based on experience with other EIA electricity surveys, the frame size of 108 respondents and the frequency of data collection.

A.14. Changes in Burden

The estimated change in annual burden is a reduction of 1,233 hours as shown in Table 3 below.




A.15. Reasons for Changes in Burden

The reduction of 1,233 annual burden hours is comprised of three factors. One factor for the reduction is due to a frame adjustment following the initial cycle of data collection. When creating the frame in 2015, EIA used two main sources to target respondents. The first of these sources came from discussions with the Pellet Fuel Institute, trade groups, and biomass manufacturers. The second source was a list of biomass manufactures published by Biomass Magazine. This periodically updated list included more than 100 manufacturing establishments. Utilizing these sources, EIA identified 150 establishments as the initial reporting population for Form EIA-63C. Since the initial survey collection, the survey frame has been regularly updated to remove duplicate reporting entities, establishments that ceased operations, and establishments that were improperly included in the survey frame.

As of January 2018, the respondent frame for reporting on Form EIA-63C is 108 respondents. 87 respondents report monthly and 21 respondents report annually. The decrease in the number of monthly respondents from 150 (previous clearance) to 87 lowered the annual number of responses by 756 (63 * 12). Several factors caused the decrease of 63 monthly respondents from the last clearance. 21 of the 63 monthly respondent are active and in-scope but only need to report their production capacity on an annual basis. The reporting burden for these 21 small annual respondents was incorrectly combined with the larger size respondents that report monthly during the last clearance. These 21 small companies are shown as annual respondents in a second row in Table A3 and result in an increase of 21 responses and 5 hours annually shown under Change due to Agency Discretion. Separating the annual respondents from the monthly respondents and showing the reporting burden for annual respondents as a separate row also resulted in a decrease of 252 responses and is included in the -600 value shown under Change due to Agency discretion in the first row for the respondents that report monthly. It also resulted in a decrease of 378 hours and is included in the -900 value shown under Change Due to Agency Discretion in the first row for the respondents that report monthly.

The second reason relates to frame maintenance issues. EIA found that 13 entities that were obtained from the Biomass Magazine list were duplicates. This change represents a decrease of 156 responses annually (13 * 12) and is shown under Change Due to Agency Estimate. EIA also found that there were 29 companies who produced bio-densified pellets for use other than energy, or were planned facilities that had made little or no progress since announcing an intention to build. This change represents a decrease of 348 responses annually (29 * 12) and is included in the -600 value shown under Change Due to Agency Discretion because these 29 companies were not in scope to report on this survey. It also resulted in a decrease of 522 hours and is included in the -900 value shown under Change due to Agency Discretion in the first row for the respondents that report monthly.

The third reason for the decline in total burden hours is the decrease in the estimate for the burden per response for the respondents reporting monthly from 1.5 hours to 1.4 hours. This reduction is due to the removal of the six questions from the form and the removal of the requirement to report quantity, characteristics, inventory, and revenue data on compressed fuel logs, bricks, and briquettes from Questions 3.3, 3.4 and 4.1. The change in the estimate for the Burden Hours Per Response for respondents that report monthly results in a decrease of 104 hours and is included in the -378 value shown under Change due to Agency Estimate in the first row for the respondents that report monthly. Another 234 hours is included in the -378 value shown under Change due to Agency Estimate for the 12 companies listed in the frame that were duplicates.



A.16. Collection, Tabulation, and Publication Plans

The data collected in this package are released in EIA reports available on the EIA website at https://www.eia.gov/biofuels/biomass/ and is listed at the end of Section A.2. Detailed information on the data elements collected on the form tabulation, and publication time schedules are contained in Tables 5 and 6, respectively.


Table A5. Data Elements Collected on Form EIA-63C

Elements Collected

Publication Level of Detail

Name and Location of Facility

Facility Level

Status of Operation

Aggregate by Production Capacity and State/Region

Year of Commercial Operation

Aggregate by Production Capacity and State/Region

Annual Production Capacity

Facility Level

Number of Direct Employees

Aggregate by Production Capacity and State/Region

Feedstock Types/ Cost

Aggregate by Production Capacity and State/Region

Product Type, Volume and Characteristics (heat, ash, moisture)

Aggregate by Production Capacity and State/Region

Inventory Type and Volumes

Aggregate by Production Capacity and State/Region

Domestic Sales by Product Type, Retail/Wholesale and Associated Revenues

Aggregate by Production Capacity and State/Region

Export Sales by Product Type, Retail/Wholesale, Associated Revenues, Destination Countries

Aggregate by Production Capacity and State/Region


Table A6. Collection, Tabulation, and Publication, Form EIA-63C

Survey Form

Data Collection Frequency

Survey Opening Date

Response Due Date

Date Final Data are Ready

EIA-63C - Densified Biomass Fuel Report

Monthly

First of the month

The last day of the month following the reporting period

45 days after the Response Due Date

Small facilities producing less than 10,000 tons annually

Annually

First business day of May.

Annual responses are due the first business day of June.

45 days after response due date.



Respondents can also link to the data series in EIA's Application Programming Interface (API). An API makes EIA data machine-readable and more accessible to users. Links to analytic reports such as the Monthly Energy Review and pertinent Today in Energy articles are also available from the page. For more information see the EIA website at: http://www.eia.gov/beta/api/.

A.17. OMB Number and Expiration Date

The OMB number (OMB Number 1905-0209) and expiration date will be displayed on the data collection form and instructions.

A.18. Certification Statement

There are no exceptions to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I. This information collection request complies with 5 CFR 1320.9.

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleSupporting Statement for Densified Biomass Fuel Report
SubjectImproving the Quality and Scope of EIA Data
AuthorBournazian, Jacob
File Modified0000-00-00
File Created2021-01-20

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