Supporting Statement for
FERC-567, Gas Pipeline Certificates: Annual Reports of System Flow Diagrams
The Federal Energy Regulatory Commission (Commission or FERC) requests that the Office of Management and Budget (OMB) review and extend its approval to information collection requirements in FERC-567 (Gas Pipeline Certificates: Annual Reports of System Flow Diagrams and System Capacity, OMB Control No. 1902-0005) for three years.
CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY
Under the Natural Gas Act (NGA)1, a natural gas company must obtain FERC authorization to engage in the transportation of natural gas in interstate commerce, to undertake the construction or extension of any facilities, or to acquire or operate any such facility. The Commission is authorized to make investigations and to collect and record data, to the extent the Commission may deem necessary or useful for the purpose of carrying out the provisions of the NGA.
Section 7 authorizes the Commission to process certificate applications and to analyze impacts of market expansions of new facilities.
Section 10(a) authorizes the Commission to collect special reports from natural gas companies.
Section 16 provides the Commission administrative power to establish rules, regulations, and orders.
HOW, BY WHOM, AND FOR WHAT PURPOSE THE INFORMATION IS TO BE USED AND THE CONSEQUENCES OF NOT COLLECTING THE INFORMATION
The Commission uses the information collected under the requirements of the FERC-567 to obtain accurate data on pipeline facilities. More specifically, the Commission utilizes the FERC-567 data to review a pipeline system as a whole and to inform analyses for new facilities proposed by pipelines in certificate applications. By reviewing a pipeline applicant’s system, as provided in FERC-567, Commission staff utilizes the data to determine configuration/location of installed pipeline facilities, and verify and determine the receipt and delivery points between shippers, producers and pipeline companies.
Additionally, the Commissions uses the FERC-567 to determine the location of receipt and delivery points and emergency interconnections on a pipeline system, determine the location of pipeline segments, laterals and compressor stations on a pipeline system, verify pipeline segment lengths and pipeline diameters, justify the maximum allowable operating pressures and suction and discharge pressures at compressor stations, verify the installed horsepower and volumes compressed at each compressor station, determine the existing shippers and producers currently using each pipeline company, and develop and evaluate alternatives to proposed facilities as a means to mitigate environmental impact of new pipeline construction.
18 CFR 260.8 requires each major natural gas2 pipeline to file five (5) copies of a diagram or diagrams reflecting operating conditions on the pipeline’s main transmission system3 with the Commission by June 1st of each year. However, these reports may be submitted by eFiling. If that option is selected by the respondent, there is no requirement for any paper copies.
These data are physical/engineering data not included as part of any other data collection requirements. The data is collected so that it’s available in the event the Commission needs to confirm pipeline facility data.
DESCRIBE ANY CONSIDERATION OF THE USE OF IMPROVED TECHNOLOGY TO REDUCE BURDEN AND TECHNICAL OR LEGAL OBSTACLES TO REDUCING BURDEN.
FERC-567 (usually with a security level of Critical Energy Infrastructure Information [CEII]) may be submitted electronically through the FERC’s eFiling system.
The Commission continues to expand the list of filing types that may be submitted electronically to reduce burden on entities. To see a full list of submission guidelines click here: https://www.ferc.gov/sites/default/files/2020-05/filing.pdf.
DESCRIBE EFFORTS TO IDENTIFY DUPLICATION AND SHOW SPECIFICALLY WHY ANY SIMILAR INFORMATION ALREADY AVAILABLE CANNOT BE USED OR MODIFIED FOR USE FOR THE PURPOSE(S) DESCRIBED IN INSTRUCTION NO. 2
Filing requirements are periodically reviewed as information collection expiration dates arise or as the Commission may deem necessary in carrying out its regulatory responsibilities under the NGA in an effort to alleviate duplication. All Commission information collections are subject to analysis by Commission staff and are examined for redundancy. The Commission is unaware of any other source of information similar to the additional requirements.
METHODS USED TO MINIMIZE BURDEN IN COLLECTION OF INFORMATION INVOLVING SMALL ENTITIES
For FERC-567, small entities have the option of filing electronically through the eFiling interface as a means of reducing their incurred burden. This is how the Commission attempts to minimize the burden of FERC-567 upon small entities. However, eFiling is a means of submission available to all respondents with no regard to size. The burden will vary among applicants since the information should be specific for each applicant and site.
CONSEQUENCE TO FEDERAL PROGRAM IF COLLECTION WERE CONDUCTED LESS FREQUENTLY
The consequence of not collecting or collecting the information of FERC-567 less frequently would be the Commission’s inability to fulfill its statutory mandates under the NGA and its Rules of Practice and Procedure. The Commission uses system flow diagrams of FERC-567 for regulatory purposes in connection with processing applications filed by interstate pipelines under Sections 7(a), 7(b), and 7(c) of the NGA. Various investigations and pipeline operations use this information in order to show interconnections with other pipelines, locations of gas supply sources, and the flow of gas and interconnections with customers’ facilities.
If the Commission failed to collect these data under FERC-567, it would lose the ability to monitor and evaluate transactions, operations, and reliability of interstate pipelines and perform its regulatory functions. Finally, the Commission cannot collect these data less frequently due to statutory and/or regulatory requirements to monitor emergency situations. The information collection cannot be discontinued due to statutory requirements. The Commission must review reports concerning any disruptions in service of the transportation of natural gas in wholesale markets.
EXPLAIN ANY SPECIAL CIRCUMSTANCES RELATING TO THE INFORMATION COLLECTION
If a FERC-567 respondent opts to respond electronically, the requirements of 5 CFR 1320.5 are met. However, if an applicant opts not to file electronically, they would have to submit five (5) copies per 18 CFR 260.8. While the Commission encourages applicants to submit their filings electronically, this is the applicant’s option.
DESCRIBE EFFORTS TO CONSULT OUTSIDE THE AGENCY: SUMMARIZE PUBLIC COMMENTS AND THE AGENCY'S RESPONSE TO THESE COMMENTS
In accordance with OMB requirements4, each FERC activity that results in the revision of an information collection is published in the Federal Register thereby providing the public, state commissions, Federal agencies, and other interested parties an opportunity to submit data, views, comments, and/or suggestions concerning the approved collections of data. The Commission published a consolidated 60-day notice for FERC-567 and FERC-576 (86 FR 25852) and a 30-day notice (86 FR 38335) to the public regarding this information collection on 5/11/2021 and 7/20/2021 respectively. Within the public notices, the Commission noted that it would be requesting a three-year extension of the public reporting burden.
The Commission received no comments from the public in response to the 60-day notice regarding FERC-567.
EXPLAIN ANY PAYMENT OR GIFTS TO RESPONDENTS
The Commission makes no payments or gifts to respondents associated with FERC-567.
DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS
The Commission classified the FERC-567 data (filed under 18 CFR 260.8) within the definition of CEII and, thus, public access to this data is limited. Additional information on FERC’s CEII program and related landmark orders is available at https://www.ferc.gov/enforcement-legal/legal/major-orders-regulations/critical-energyelectric-infrastructure-information.
PROVIDE ADDITIONAL JUSTIFICATION FOR ANY QUESTIONS OF A SENSITIVE NATURE, SUCH AS SEXUAL BEHAVIOR AND ATTITUDES, RELIGIOUS BELIEFS, AND OTHER MATTERS THAT ARE COMMONLY CONSIDERED PRIVATE
The Commission does not consider any of the questions within the FERC-567 of a sensitive nature, as described above. However, the Commission considers the FERC-567 information as sensitive to the nation’s energy infrastructure because the data contains location and operational data on the nation’s natural gas pipelines. Therefore, the FERC-567 information is classified as CEII (described in greater depth within Question #10).
ESTIMATED BURDEN OF COLLECTION OF INFORMATION
The following table provides the estimated annual burden5 and cost related to information collection requirements for FERC-567.
FERC-567, Gas Pipeline Certificates: Annual Reports of System Flow Diagrams |
||||||
Respondents |
Number
of Respondents6 |
Annual Number of Responses per Respondent (2) |
Total Number of Responses (1)*(2)=(3) |
Average Annual Burden & Cost Per Response7 (4) |
Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5) |
Average Annual Cost per Respondent ($) (5)÷(1) |
Natural Gas Pipelines |
124 |
1 |
124 |
4 hrs.; $332 |
496 hrs.; $41,168 |
$332 |
ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS
There are no non-labor costs currently associated with FERC-567.
All costs are associated with burden hours (labor) for both information collections and are addressed in Question #12 and Question #15.
ESTIMATED ANNUALIZED COST TO FEDERAL GOVERNMENT
The estimated annualized cost to the Federal Government for FERC-567 follows:
|
Number of FTE’s |
Estimated Annual Federal Cost ($) |
PRA8 Administration Cost |
1 |
$6,475.00 |
Data Processing and Analysis for FERC-5679 |
0.06 |
$10,339.74 |
FERC Total |
|
$16,814.74 |
The Commission bases its estimate of the ‘Analysis and Processing of filings’ cost to the Federal Government on salaries and benefits for professional and clerical support. This estimated cost represents staff analysis, decision making, and review of any actual filings made in response to the information collection.
The PRA Administrative Cost is a Federal Cost associated with preparing, issuing, and submit-ting materials necessary to comply with the Paperwork Reduction Act (PRA) for rulemakings, orders, or any other vehicle used to create, modify, extend, or discontinue an information collection. This average annual cost includes requests for extensions, all associated rulemakings, other changes to the collection, and publications in the Federal Register.
REASONS FOR CHANGES IN BURDEN INCLUDING THE NEED FOR ANY INCREASE
For FERC-567, there is a decrease from 197 respondents to 124 respondents and a decrease from 591 burden hours to 496 annual burden hours in this renewal. The change in burden hours and number responses for FERC-567 is based on the average number of respondents over the past three years which provides a more accurate estimate based on agency adjustment. As this is based on historical data, the agency could revise these burdens up or down in subsequent reporting.
The Commission estimates the annual public reporting burden for FERC-567 is:
FERC-567 |
Total Request |
Previously Approved |
Change due to Adjustment in Estimate |
Change Due to Agency Discretion |
Annual Number of Responses |
124 |
197 |
-73 |
0 |
Annual Time Burden (Hr) |
496 |
591 |
-95 |
0 |
Annual Cost Burden ($) |
$0 |
$0 |
$0 |
$0 |
TIME SCHEDULE FOR THE PUBLICATION OF DATA
There is no publication of data associated with FERC-567 information collections.
DISPLAY OF THE EXPIRATION DATE
The OMB expiration dates are displayed at https://www.ferc.gov/enforcement-legal/legal/information-collections
EXCEPTIONS TO THE CERTIFICATION STATEMENT
1 Public Law 75-688
2 A pipeline having a system delivery capacity exceeding 100,000 Mcf per day.
3 For the prior 12 months ending December 31.
4 5 CFR 1320.8(d)
5 Burden is defined as the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a federal agency. Refer to 5 CFR 1320.3 for additional information.
6 The number of respondents in the currently approved OMB inventory for FERC-567 is 197. Changes to the estimate were based on average number of respondents over the past three years.
7 The Commission staff estimates that the average respondent for FERC-567 is similarly situated to the Commission, in terms of salary plus benefits. Based on FERC’s 2020 annual average of $172,329 (for salary plus benefits), the average hourly cost is $83/hour.
8 Paperwork Reduction Act of 1995 (PRA).
9 Based on 2020 cost (salary plus benefits) per FTE of $172,329 (for salary plus benefits), the average hourly cost is $83/hour.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Michele Chambers |
| File Modified | 0000-00-00 |
| File Created | 2021-07-23 |