EIA 1905-0167 COAL Supporting Statement A_Final

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Coal Markets Reporting System

OMB: 1905-0167

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Supporting Statement for Coal Markets Reporting System

  1. Part A: Justification

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Form EIA-3 Quarterly Survey of Industrial, Commercial, & Institutional Coal Users

Form EIA-7A Annual Survey of Coal Production and Preparation

Form EIA-8A Annual Survey of Coal Stocks and Coal Exports

Form EIA-6 Emergency Coal Supply Survey (Standby)

Form EIA-20 Emergency Weekly Coal Monitoring Survey for Coal Burning Power Producers (Standby)



OMB No. 1905-0167

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August 2020

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 is required to publish, and otherwise make available independent, high-quality statistical data to federal government agencies, state and local governments, the coal industry, academic researchers, and the general public.

EIA requests a three-year extension, without changes, to the forms in the Coal Markets Reporting System surveys (OMB Number 1905-0167).

Form EIA-3 Quarterly Survey of Industrial, Commercial, & Institutional Coal Users

This form collects coal consumption data from U.S. manufacturers, transformation and processing plants, and commercial and institutional users. Information collected includes coal consumption, stocks, and receipts.

Form EIA-7A Annual Survey of Coal Production and Preparation

This form collects data on coal production operations, characteristics of coalbeds mined, recoverable reserves, productive capacity, coal preparation and the disposition of the coal mined. For coal preparation, information collected includes operations, locations, productive capacity, disposition, and coal prepared. The information is disseminated in EIA reports and analyses used by public and private analysts.

Form EIA-8A Annual Survey of Coal Stocks and Coal Exports

This form collects coal stocks data for publications, analyses, and statistical reports used by public and private analysts. Data collected include coal stocks by state location, exported coal by origin state, and export revenue of coal sold during the reporting year.

Form EIA-6 Emergency Coal Supply Survey (Standby)

This form collects coal production and stocks data from U.S. coal mining companies and stocks data from distributors that do not produce coal during coal supply disruptions.

Form EIA-20 Emergency Weekly Coal Monitoring Survey for Coal Burning Power Producers (Standby)

This form collects information to monitor coal stocks, receipts, and consumption at electric utilities during coal supply disruptions.



A.1. Legal Justification

The authority for these data collections is provided by the following provisions:

      1. 15 U.S.C. §772(b) establishes the ability for the Secretary of Energy1 to require reports, records and data as deemed necessary or appropriate under the FEAA. The Secretary of Energy delegated certain authorities to the EIA Administrator on October 1, 1977 under DOE Delegation Order 0204-3. This delegation of authority to the EIA Administrator is what gives EIA the lead in energy information collections for DOE. 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) establishes 12 conditions under which the Secretary has the authority to collect relevant information. 15 U.S.C. §764(b) states that to the extent authorized by subsection (a), the Administrator shall:

    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. 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. [Intentionally deleted]

    4. [Intentionally deleted]

    5. [Intentionally deleted]

    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. develop and oversee the implementation of equitable voluntary and mandatory energy conservation programs and promote efficiencies in the use of energy resources;…

    8. [Intentionally deleted]

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

    10. work with business, labor, consumer and other interests and obtain their cooperation;…

    11. [Intentionally deleted]

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



As the authority for invoking subsection (b), above, 15 U.S.C. §764(a) provides the authority for collecting the information under one or more of the conditions listed in 15 U.S.C. §764(b).

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

      2. the Congress;

      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. 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.].

    1. "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. 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. 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. the sensitivity of energy resource reserves, exploration, development, production, transportation, and consumption to economic factors, environmental constraints, technological improvements, and suitability of alternate energy sources;

      4. the comparability of energy information and statistics that are supplied by different sources;

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

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

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



A.2. Needs and Uses of Data

Data reported on Form EIA-3 and mine mouth price data from Form EIA-7A are used as inputs in the National Energy Modeling System (NEMS) Coal Market Module (CMM). The CMM generates projections of U.S. coal production, consumption, exports, imports, distribution, and prices. The CMM consists of three functional areas: coal production, coal distribution, and coal exports. Delivered price data from The EIA National Energy Modeling System (NEMS) uses Form EIA-7A as calibration data for the regional supply curves for the production of the EIA Annual Energy Outlook (AEO). Calibration statistics refers to estimated coefficients used as parameters in the coal supply curve pricing equation.

EIA collects sales revenues, coal, type, mine type, at the mine level annually in EIA-7A.  Data are used to calculate coal prices, and measure productivity.  The number of mines reporting on Form EIA-7A is less than the number of mines reporting to MSHA because mines producing below the EIA’s production thresholds do not have to report to EIA. For the AEO projections, EIA reconciles the EIA-7A sales data with the MSHA production data for adjusting the calibration statistics.  A database for each calibration year uses data on coal deliveries from Forms EIA-923M and EIA-3Q and modified exports data from Census.  These data show delivered volumes by end use and mine source. The average heat and sulfur content values are estimated from data reported on Form EIA-923 for coal consumed at electric power plants and from Form EIA-3 for coal consumed at industrial facilities and coke plants, respective. This database is used to construct base year calibration data for the Coal Production Submodule (CPS) and the Domestic Coal Distribution Submodule (DCDS) transport rates.   The AEO projections on coal exports are then benchmarked to the projections generated from the monthly Short Term Energy Outlook projections. Coal deliveries reported on Form EIA-3Q also used extensively for generating consumption estimates by end use category for residential, commercial, institutional, industrial including the Coking Sector. 

The CMM requires base year inputs for the most current year of actual data as a starting point for the model projection. EIA aggregates Form EIA-7A mine level data into the 41 supply curve regions, and uses the data as inputs to the model. Calibration data includes calculated values for total coal production, average mine mouth price, average Btu or sulfur content of the coal, and labor productivity. This data forms parameter inputs into the CMM by supply curve, coal supply region, coal grade, or mine type. The delivered coal prices are not direct coal model inputs but they are used to compute the base transport rates from coal supply to coal demand regions. Form EIA-3 and Form EIA-923 survey data are similarly used to compute delivered coal prices by coal demand region. Form EIA-3 collects data on coal consumption from non-electric power in the industrial sector, while Form EIA-923 collects information on coal used solely from electric power producers.

Form EIA-7A requires mines with production above a certain production threshold to report a variety of survey parameters. This data is not collected by MSHA. This data are used to compile calibration statistics by coal geographic region (14 regions), mine type (underground vs. surface), coal grade (bituminous, subbituminous, lignite, and premium coking coal), and sulfur content (low-compliance, medium, and high). EIA uses calibration data to estimate the coefficients of the coal pricing equation. These calibration statistics do not need to be updated each year, but are critical input parameters to the CMM. Other calibration statistics could be assumptions or statistics compiled from multiple years of calibration data. Parameters like fuel splits in coal mining, or historical coal capacity utilization rates, are other calibration statistics. They are derived from EIA’s historical data collection on the coal sector. Among the data that are exclusively reported to EIA are mine revenues by coal type, which EIA uses to compile mine mouth prices for 41 identified coal supply curves.

The data are published in many EIA products, including:

In addition, EIA uses the data in short-term and long-term models, including the Short-Term Integrated Forecasting System and the National Energy Modeling System (NEMS) Coal Market Module. The forecasts are reported in the Short-Term Energy Outlook, http://www.eia.gov/forecasts/steo/, and the Annual Energy Outlook, http://www.eia.gov/forecasts/aeo/ publications.

Some Federal agencies rely on EIA coal data to meet their information needs:

      1. Environmental Protection Agency (EPA) accessed company level data reported on Form EIA-3 data from 2011 – 2016. EPA used the data to compare with and validate greenhouse gas information that EPA collected under 40 CFR Part 98 through the Greenhouse Gas Reporting Program (GGRP) from approximately 10,000 facilities starting in 2011. EPA identified refineries, facilities in the manufacturing sector, and natural gas local distribution companies as three sectors that report comparable data to both EIA and EPA. EPA accessed company level data reported on Form EIA-7A during 2003 – 2006 to analyze how different mine types utilize degasification and coal mine methane recovery systems



  • The Federal Reserve Board (FRB) in its monthly Industrial Production and Capacity Utilization statistical release uses Form EIA-7A coal data to produce estimates of capacity and capacity utilization for industries in mining. For a given industry, the capacity utilization rate is equal to an output index (seasonally adjusted) divided by a capacity index. The Federal Reserve Board's capacity indexes attempt to capture the concept of sustainable maximum output—the greatest level of output a plant can maintain within the framework of a realistic work schedule, after factoring in normal downtime and assuming sufficient availability of inputs to operate the capital in place. The FRB monthly reports are available from this url: https://www.federalreserve.gov/releases/g17/Current/ (G.17 (419))

  • Government Accountability Office: In 2018, the Government Accountability Office (GAO) reviewed the Department of Interior’s Office of Surface Mining Reclamation and Enforcement oversight activities. As part of their review, GAO evaluated the management of financial assurances for coalmine reclamation made by the Department of Interior. GAO used Form EIA-7A coal data to determine the states that produced the most coal. Based on this information GAO selected a nonprobability sample of 7 states—Illinois, Kentucky, Montana, Pennsylvania, Tennessee, West Virginia, and Wyoming. EIA’s coal data were used as background information on coal supply conditions, specifically energy production from coal and tonnage mined in the US to produce energy. The report is available at: https://www.gao.gov/products/gao-18-305

  • The Bureau of Economic Analysis (BEA) uses EIA’s Quarterly Coal Report (QCR) to get quarterly coal production data to inform GDP-by-industry analysis.

  • U.S. Geological Survey: USGS assess the U.S. Coal Resources and reserves to determine if the Nation’s coal resources and reserves are sufficient to meet projected future demands. They conduct periodic objective and scientific assessments of these coal resources and reserves using data from Form EIA-7A.

Additionally, the entire Coal Markets Reporting System and analyses are used by Congress, federal agencies, and state and local governments, and private entities to support policy and business decisions related to the coal industry. EPA currently relies on coal production data from EIA – specifically annual Coal Report Table 1 – to estimate emissions from surface mines and post-mining operations, however, this is MSHA data that EIA aggregates and publishes.



Some university institutions use EIA coal data in their work include:

  • Currently there is an active data sharing agreement with Carnegie Mellon University to obtain data from Form EIA-3A and Form EIA-923. In 2019, Akshaya Jha, a researcher from Carnegie Mellon University, used data from Form EIA-3A to estimate a dynamic plant-level model of coal procurement. The researcher did this by comparing model-based costs across price-regulated versus market-based plants using matched difference-in-differences. The main finding of this paper suggest that the largest efficiency benefits from introducing market mechanisms to price-regulated industries stem from steady-state differences in capital levels rather than changes in the timing of capital investments. This paper provides empirical estimates of the regulated rate of return on capital received by utilities. Furthermore, it illustrates that the artificially high rate of return on capital provided to utilities can distort both the long-run aggregate level of electricity generating capacity as well as the mix of generating technologies in operation.



  • On June 10 2014, Stanford Law School requested an extension for continued access to data reported on Form EIA-7A until December 2016. Stanford used the data to develop a statistically-based mine targeting protocol to identify mines that have high safety risks and to estimate the potential improvement in mine safety by targeting MSHA inspection activity towards mines that are identified as a high risk of workers incurring serious injuries and fatalities. Furthermore, Stanford used Form EIA-7A data to research inspector and district level variations in injury inspection quality, types of mine injuries that will most likely be underreported, and identify new mine safety technologies. The research explored union safety effect by comparing frequency and severity across union and nonunion companies, examining cross-sectional differences, and by examining changes over time.



A.3. Use of Technology

All EIA coal surveys use Internet-based data collection systems as the primary means of data collection. The majority of routine contact with respondents is by email.

Internet data collection will continue to be the primary collection mode for the Coal Markets Reporting System surveys. The Internet-based system allows respondents to enter their data directly into EIA survey databases, which reduces the time needed for data collection and processing. The system also identifies data that fail edits prior to submission, allowing respondents to make necessary corrections or explain unusual events impacting the reported data prior to submission. This data editing process reduces respondent burden by reducing the number of resubmissions respondents may have to complete before a form accepted by EIA. It also improves the timeliness of reporting the information to the public. The respondent only requires an internet connection.



A.4. Efforts to Identify Duplication

EIA reviews and evaluates coal industry information available from a variety of sources, including other federal agencies, state governments, industry trade associations, and commercial information services to identify instances of duplication. Additionally, in the public notices and consultations associated with the triennial re-clearance of the Coal Markets Reporting System, EIA specifically encourages respondents and data users to identify alternate sources of the coal 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.

The U.S. Census Bureau collects quantity and value of coal exports and imports, country of destination or origin, and port of import/export. EIA collects similar information about coal exports on Form EIA-8A, but requires additional information such as state of origin and qualities of the coal by each export transaction. Census data is collected by transaction. EIA data is collected by broker/trader. Therefore, there is only an overlap in aggregate. The data that overlaps is necessary to separate the new information (state of origin). For example, we still need the amount of coal exported to gather the state of origin, yet Census also collects the amount of coal exported. Although census data are used as the official statistics on coal exports, census data cannot be used to trace the shipment from a specific mine.  Census data shows where the export is going and the port of departure, however, the source where the coal was produced is not available since they have no mine source field.  Form EIA-7A collects the share of production by mine that is exported, however the volumes rarely match the volumes reported as exports from census data. 

There is one area of overlap between EIA’s coal and electric power surveys. Form EIA-923 Power Plant Operations Report collects data on coal consumed to produce electric power. Form EIA-3 collects coal consumption data from U.S. manufacturers, transformation and processing plants, and commercial and institutional users. In cases where a facility consumes coal and has onsite electric power production equipment with a nameplate capacity equal to or greater than 1MW, that facility will report on Form EIA-3 survey as a coal user and report on Form EIA-923 Power Plant Operations Report as an electric power producer. This occurs in a small number of cases because Form EIA-3 respondents are coal end-users and generally do not have the capacity to generate electricity.

MSHA collects coal labor data as well as production data. MSHA sends this data to EIA, ahead of their publication data, and EIA uses coal production value to ask coal respondents on how coal production is distributed. This process aids in quality and assurance checks to MSHA and results in several iterations of communication before publication. EIA and MSHA are not collecting the same data. EIA supplements its data collection with MSHA data. EIA uses MSHA data to avoid duplication of data collection.

MSHA data are updated every quarter, which includes production data from all mines and employment data (labor hours). There are some additional MSHA data, such as ownership and location (state, county, longitude and latitude) that are used peripherally, such as for quality assurance on coal production data (QA) or to inform EIA on mine ownership as EIA collects 7A data. These data are published on MSHA’s web site. As part of EIA’s data agreement with MSHA, EIA helps validate monthly coal production data. EIA also uses MSHA data to maintain Form EIA-7A frame file. The frame for Form EIA-7A is a threshold survey, based on how much coal a mine produced during the year, or labor hours for prep plants. The MSHA production data are used to determine who meets that threshold. The MSHA data are also used in EIA’s Weekly Coal Production estimation model. These data are a primary variable used to determine the weekly coal production estimates. Once EIA receives the most current MSHA data, EIA updates its weekly coal production estimates.

From these production estimates and subsequent revisions after receiving MSHA data, the Short-Term Energy Outlook (STEO) pulls in the weekly coal estimates for its model. EIA aggregates the information, then publishes and revises the production estimates monthly in the Monthly Energy Review. EIA also publishes production data from MSHA in the Quarterly Coal Report each quarter. EIA uses the MSHA production data to provide estimates to International Energy Agency (IEA), with a quarterly production estimate and then the annual IEA mini (preliminary data) before EIA finalizes MSHA data in conjunction with Form EIA-7A data later in the year. MSHA production and employment data are also published in the Annual Coal Report (ACR) and on EIA’s web site under the detailed Form EIA-7A data files.

In the ACR, some tables include all mines, using the MSHA production and employment data, whereas other tables only use the subset of Form EIA-7A respondents – the footnotes make this distinction. On Form EIA-7A, coal disposition is collected rather than production to reduce the duplication of data efforts – EIA already has the production data from MSHA, therefore there is no need to collect this data. Disposition is the sales data – who did they sell it to (open market, captive market, export, etc.), and at what price. It primarily supports the price piece of the industry.

EIA uses the MSHA production data to quality assure the disposition data – for example, EIA flags the information if the disposition data reported by a mine is not within 10% of the production data from MSHA. MSHA data is used to quality assure the county/state data on Form EIA-7A, particularly for augers (machinery with an MSHA ID like a mine but that can move around the country from mine to mine, so its location data can change). Furthermore, as Form EIA-7A collects sales data and MSHA collects production data, EIA can quality assure MSHA data by comparing both data sources (annual coal sales plus adjustments to ending coal stocks should equal annual production, within a reasonable deviation). EIA also uses MSHA data to quality assure Form EIA-3, where EIA collects MSHA ID of the mine from which a respondent purchases coal to verify that Form EIA-3 reported MSHA ID and the state the coal originated from are valid. Finally, MSHA data is used to quality assure the longitude and latitude data reported on Form EIA-7A, which is subsequently used in the US Energy Mapping System.



A.5. Provisions for Reducing Burden on Small Businesses

Minimizing burden to small businesses is a primary concern to EIA. 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.

Reporting on Form EIA-3 Quarterly Survey of Industrial, Commercial, & Institutional Coal Users is limited to non-electric sector sites (i.e. manufacturers, hospitals, universities, and correctional facilities) that consume more than 1,000 short tons of coal annually. However, all companies operating coke plants within the United States must submit Form EIA-3.

Reporting on Form EIA-7A Annual Survey of Coal Production and Preparation is limited to U.S. coal mining companies that produce 25,000 or more short tons of coal during the reporting year, except for anthracite mines. All anthracite mines that produced 10,000 or more short tons during the reporting year must submit Form EIA-7A. Standalone facilities (e.g., preparation plant/tipple/loading dock/train load-out) that worked 5,000 or more hours must submit Form EIA-7A.

Reporting on Form EIA-8A Annual Survey of Coal Stocks and Coal Exports is limited to coal brokers, coal traders, and coal terminals in the 50 United States and the District of Columbia that own stocks of 10,000 or more short tons of coal originating in the United States on December 31st of the reporting year or exported coal originating in the United States during the reporting year. Companies that take custody (physical possession) of the coal and transport, but never own the coal do need to report. Companies that report coal stocks on Form EIA-923 Power Plant Operations Report do not need to report. EIA does not require a company to report the same data twice.



A.6. Consequences of Less-Frequent Reporting

Form EIA-3 collects coal data on a quarterly basis from consumers of coal and on Forms EIA-7A and EIA-8A collect information on an annual basis from coal suppliers. The quarterly and annual collection of coal data meets data user needs. There is seasonality in the coal consumption data reported on Form EIA-3. Respondents who produce concrete show an increase in fuel consumption during the 2nd and 3rd quarters and a decline in the 1st and 4th quarters. Some academic institutions use coal for space heating and their coal consumption increases in the 4th and 1st quarters of the calendar year and then decreases in the 2nd and 3rd quarter. Some manufacturing plants show up and down trends on a quarterly basis. This occurs when they purchase coal near the end of the one calendar quarter but consume the coal in the following calendar quarter.



A.7. Compliance with 5 CFR 1320.5

All EIA coal surveys are operated in accordance with the guidelines in 5 CFR 1320.5. In the event of a coal supply disruption, EIA will collect weekly information on Forms EIA-6 and EIA-20. This weekly frequency is justified by the need to provide rapid response during such a supply disruption to prevent adverse national economic impacts or to alleviate potential human suffering from a lack of access to electricity. However, this information collection would only be triggered during highly unusual circumstances, and the conditions that would necessitate such a frequent collection have never yet arisen.



A.8. Summary of Consultations Outside of the Agency

On December 2, 2019, EIA published a 60-day Federal Register Notice at 84 FR 65977, outlining proposed changes to the Coal Program Package and inviting interested parties to comment. EIA responded to all comments it received. EIA received one comment expressing support for the extension of data collection of the Coal Markets Report System. The commenter also recommended that EIA revisit the reporting threshold to reduce paperwork burdens. EIA evaluated the recommendation and decided to proceed with a no-change clearance. EIA will conduct research on how much market coverage is lost, if any, by raising the thresholds above 25,000 tons for bituminous and 10,000 short tons for anthracite.

As additional outreach, EIA sent an email notification about the 60-day Federal Register Notice to all active respondents on Form EIA-3, Form EIA-7A, Form EIA-8A, and email lists for the users of the Weekly Coal Report, Quarterly Coal Report, and Coal Distribution Report.



EIA Cognitive Study

The Office of Energy Production, Conversion and Delivery sought to determine if operators of surface coal mines were able to report the annual stripping ratio of a mine on Form EIA-7A Annual Survey of Coal Production and Preparation. The stripping ratio is one measure of the productivity of a mining operation. Furthermore, EIA was interested in validating the reporting burden per response for Form EIA-7A. EIA interviewed 16 participants that filed a total of 108 Form EIA-7A reports in 2018 from Pennsylvania, Texas, West Virginia, Virginia, Alabama, Kentucky, Wyoming, Montana, Maryland, Alaska, and New Mexico. The findings showed that participants were able to report the annual stripping ratio of a mine. Participants stated that they track the ratio of the amount of soil and rock removed to the amount of coal recovered. The term stripping ratio did not have a common meaning among participants when describing this productivity measure. Participants were familiar with the term stripping ratio but also used other terms such as, mining ratio, overburden ratio, and strip ratio in their regular course of business. Even though the cognitive study provided useful and insightful information, EIA is not proposing a change to Form EIA-7A at this time.


A.9. Payments or Gifts to Respondents

Respondents to this information collection will not receive any payments or gifts from EIA to participate in this information collection.



A.10. Provisions for Protection of Information

Form EIA-3

The information reported on Form EIA-3 are protected and are 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.


Data protection methods are applied to the cost data reported on Form EIA-3 in Parts 3 and 4 to ensure that the risk of disclosure of identifiable information is very small. Data protection methods are not applied to the other aggregate statistical and quantity data published from this survey.


Form EIA-7A

The name and address of the responding company, the mine type or plant type, and location reported on Form EIA-7A is considered public information and may be released in company identifiable form. All other information reported on this form 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.


Data protection methods are applied to the “Total Revenue” from “Open Market Sales,” “Captive Market Sales,” and “Export Coal Sales” reported in Part 5 to ensure that the risk of disclosure of identifiable information is very small. Data protection methods are not applied to the other aggregate statistical data published from this survey.


Form EIA-8A

The information reported on Form EIA-8A 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.


Data protection methods are applied to the total revenue of coal exported from each origin state, reported in Part 3, to ensure that the risk of disclosure of identifiable information is very small. Data protection methods are not applied to the other aggregate statistical data published from this survey.


Form EIA-6

The name and address of the responding company, the mine type or plant type, and location reported on Form EIA-6 is considered public information and may be released in company identifiable form. All other information reported on this form 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.


Form EIA-20

The information reported on Form EIA-20 on Part 1, Question 1 and Part 2, Questions 1 and 4 is considered public information and may be released in company identifiable form. All other information reported on this form 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.


For both standby Forms EIA-6 and EIA-20 the following statement is included:


Data protection methods are applied to the statistical data published from survey information to ensure that the risk of disclosure of identifiable information is very small.


The following paragraph is included in Forms EIA-3, EIA-6, EIA-7A, EIA-8A, and EIA-20:


The Federal Energy Administration Act requires the U.S. 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 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 non-statistical purposes such as administrative, regulatory, law enforcement, or adjudicatory purposes.

A.11. Justification for Sensitive Questions

This information collection does not include any questions of a sensitive nature.



A.12. Estimate of Respondent Burden Hours and Cost

The overall annual burden for this package is estimated to be 4,417 hours (see Table 1 below). The burden has decreased from the previous clearance from 5,515 total burden hours to 4,417 hours. This decrease is primarily the result of an overall industry decline.

The annual labor cost of burden hours to the respondents is estimated to be $353,978 (4,417 hours, burden hours times $80.14 per hour). The $80.14 per hour is a fully-burdened wage hour.

*For the standby surveys to be used only in the case of a coal supply or transportation emergency, the standby surveys would be operated on a weekly frequency over a ten week period. The number of respondents was calculated as follows:

(Total number of coal mining companies [EIA-6] or coal-fired power plants [Form EIA-20]) multiplied by

(Percentage of facilities affected [assumed to be 25%]) multiplied by

(Probability of a disruption occurring in a year [assumed to be 10%]) equals

(Probability-weighted number of respondents, rounded to a whole number)


For the Form EIA-6 calculation is (610 coal mining companies x 25%) x 10% = 15 respondents

For the Form EIA-20 calculation is (491 coal mining companies x 25%) x 10% = 12 respondents

The assumed duration of the emergency was 10 weeks for both surveys.

A.13. Annual Cost to the Federal Government

The annual cost of operating these surveys is estimated at $539,000 and includes contractor costs and federal staff time for survey related activities. The estimated annualized cost to the government, includes personnel, forms development, maintenance, data collection, and processing.

The Federal Government coal forms cost estimate for FY 2019 is shown in Table 2 below:

A.14. Changes in Burden

The estimated decrease in annual burden is 642 burden hours shown in Table A2 below.

For the standby surveys to be used only in the case of a coal supply or transportation emergency, the standby surveys would be operated on a weekly frequency over a ten week period. The number of respondents was calculated by assuming 25% of facilities would be required to report, with a 10% chance of a disruption.



A.15. Reasons for Changes in Burden

The number of respondents decreased overall due to fewer companies meeting the reporting thresholds for Form EIA-3 and Form EIA-7A. Form EIA-7A is a threshold survey. MSHA tracks the entire universe of mines while EIA has a subset. On a given year a mine may meet the threshold of production, while the next year the mine may not meet the threshold, thus constantly dropping off or being added back on. This frame is re-defined twice each reporting year. This includes coal mine closures and decreases in production which caused some mines to no longer be eligible to file a report because their production level was below the reporting threshold.

The estimated changes to respondent burden for the individual forms contained in this package are listed in Table A2.

Table A3. ICR Summary of Burden

 

Requested

Program Change Due to Agency Discretion

Change Due to Adjustment in Agency Estimate

Previously Approved

Total Number of Responses

2,598

0

 -216

 2,814

Total Time Burden (Hr)

 4,417

 0

 -642

 5,059



A.16. Collection, Tabulation, and Publication Plans

Plans to tabulate and publish data collected by the coal data collection forms are described below.

a. Weekly Standby Forms

The weekly standby Forms EIA-6 (coal production) and EIA-20 (coal consumption and stocks at power plants) are used to collect data during coal supply disruptions. The number of mining companies or generators representatives who will be asked to respond will depend on the nature and extent of the emergency. Form EIA-6 and Form EIA-20, if and when activated, will cover mines and power producers, respectively. Form EIA-6 is a readily available frame of parent mining companies.

During supply disruptions, the forms must be submitted no later than 5pm eastern time each Monday after the seven-day reporting period. The reporting period is Saturday midnight to Saturday midnight.

b. Quarterly Form

Quarterly Form EIA-3 is due one month after the close of each calendar quarter.

Form EIA-3 data are published in the following reports:

  • Monthly Energy Review

  • Quarterly Coal Report

  • Quarterly Distribution Report

  • Annual Coal Report

  • Annual Distribution Report

c. Annual Forms

Form EIA-7A collects information on coal production and related information from U.S. coal mining operations. Form EIA-8A collects coal stocks and export data from U.S. coal brokers, coal traders, and coal terminals.

Data collected are published in the following reports:

  • Monthly Energy Review

  • Annual Coal Report

  • Annual Coal Distribution Report

  • State Energy Profiles



A.17. OMB Number and Expiration Date

The OMB Number (1905-0167) and expiration date are displayed on each form.



A.18. Certification Statement

This submission meets all certification requirements of the "Certification for Paperwork Reduction Act Submissions."



1 At the time the FEAA was passed, this referred to the Administrator of the Federal Energy Administration, which is why “Secretary” is shown in parentheses in the citations from the law (i.e., because it replaces the word “Administrator” that was in the law).

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleSupporting Statement for Coal Markets Reporting System
AuthorStroud, Lawrence
File Modified0000-00-00
File Created2021-01-14
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