RM22-8 supporting statement for FERC-577 clean

Docket No. RM22-8-000, Final Rule (RIN 1902-AG06), FERC-577 (1902-0128)

Supporting Statement for

RM22-8-000 Final Rule, “Updating Regulations for Engineering and Design Materials for Liquefied Natural Gas Facilities Related to Potential Impacts Caused by Natural Hazards,

FERC-577, Natural Gas Facilities: Environmental Review and Compliance

The Federal Energy Regulatory Commission (FERC or Commission) has issued a Final Rule in Docket No. RM22-8-000 that includes modifications of certain reporting and recordkeeping requirements in the currently approved FERC-537 (OMB Control No. 0060), FERC-539 (OMB Control No. 1902-0062), and FERC-577 (OMB Control No. 1902-0128).¹ All of these information collection activities pertain to liquefied natural gas (LNG). This supporting statement pertains only to FERC-577.

1. CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY

The information collection activities in Docket No. RM22-8-000 will assist the Commission in implementing sections 3 and 7 of the Natural Gas Act (NGA)² and section 102(2)(C) of the National Environmental Policy Act (NEPA).³ Section 3(a) of the NGA authorizes the Commission to approve or deny proposals to import or export natural gas.⁴ Section 3(e) of the NGA authorizes the Commission to approve or deny applications for the siting, construction, expansion, or operation of an LNG terminal. Under section 7(c) of the NGA,⁵ the Commission may issue certificates of public convenience and necessity (PCN certificates) for facilities used for the transportation of natural gas (including LNG) in interstate commerce.

When acting on applications filed pursuant to these provisions of the NGA, the Commission serves as the lead federal agency regarding NEPA.⁶ The Commission’s regulations implementing these authorities are codified in 18 CFR Parts 153, 157, and 380, which require prospective applicants⁷ and applicants to provide information necessary for the Commission to process their applications.⁸

2. HOW, BY WHOM AND FOR WHAT PURPOSE IS THE INFORMATION USED AND THE CONSEQUENCES OF NOT COLLECTING THE INFORMATION

The Commission takes the following actions in the Final Rule in Docket No. RM22-8:

• Removes references to the National Bureau of Standards, which has been renamed the National Institute of Standards and Technology (NIST);

• Removes two outdated technical standards for seismic hazard evaluations and seismic design criteria for LNG facilities;⁹ and

• Replaces the language in 18 CFR 380.12(o)(15) with new regulatory text that requires applicants to provide the engineering and design information that they have typically provided in accordance with the Commission’s “Guidance Manual for Environmental Report Preparation for Applications Filed Under the Natural Gas Act,” which was issued in February of 2017.

The Commission’s “Guidance Manual for Environmental Report Preparation for Applications Filed Under the Natural Gas Act” is divided into two volumes. Volume I (at https://www.ferc.gov/sites/default/files/2020-04/guidance-manual-volume-1.pdf) describes the information that is required or recommended for natural gas projects. Volume II (at https://www.ferc.gov/sites/default/files/2020-04/guidance-manual-volume-2.pdf) specifically addresses additional information required or recommended for LNG facilities.¹⁰

FERC-577, Natural Gas Facilities: Environmental Review and Compliance

The bulk of FERC-577 identifies the Commission’s regulations implementing NEPA. Section 102 (2)(c) of NEPA (42 U.S.C. 4322(2)(C)) requires that all Federal agencies consider the environmental impact of its decisions regarding those activities that are major federal actions significantly affecting the quality of the human environment; produce a detailed statement on the environmental impact of the proposed actions that addresses any adverse environmental effects which cannot be avoided; and consider alternatives to the proposed action. To carry this out, the Commission requires applicants seeking authorization to construct and abandon facilities to provide a detailed environmental report along with their application. The environmental report consists of at least twelve separate reports, each addressing a particular resource area. The report also describes the impact the project is likely to have, and the measures the applicant will implement to mitigate those impacts.

The remaining component of FERC-577 identifies the Commission’s regulations which require that a natural gas company must notify affected landowners at least five days prior to coming onto their property for certain activities. The notifications include: (1) a brief description of the activity to be conducted or facilities to be constructed/replaced and the effects that the activities are expected to have on the landowner’s property; (2) the name and phone number of the company representative that is knowledgeable about the project; and (3) a description of the Commission’s Dispute Resolution Service Helpline, as explained in Section 1b.21(g) of the Commission’s regulations, and the Dispute Resolution Service Helpline number. The Commission defines “affected landowners” as owners of property interests, as noted in the most recent tax notice, whose property is directly affected (i.e., crossed or used) by the proposed activity, including all rights-of-way, facility sites, access roads, pipe and contractor yards, and temporary workspaces.

The Commission uses the FERC-577 data to perform its regulatory functions. Natural gas companies file the necessary information with FERC so that the Commission can determine from the data if the requested certificate should be authorized. In addition, natural gas companies submit filing to document compliance with the landowner notification requirements. The information collection cannot be discontinued nor collected less frequently because of statutory requirements. The consequences of not collecting this information are that the Commission would be unable to fulfill its statutory mandate under the NGA and NEPA.

A notable feature of the final rule is the amendment of 18 CFR 380.12(o), which describes
“Resource Report 13—Engineering and design material.” This report is required for construction of new liquefied natural gas (LNG) facilities, or the recommissioning of existing LNG facilities.

Historically, Resource Report 13 has consisted of seismic information specified in a report of the National Bureau of Standards for facilities that would be located in zone 2, 3, or 4 of the Uniform Building Code Seismic Map of the United States. As stated above, the references to the National Bureau of Standards and the Uniform Building Code are both outdated. For that reason, the final rule in Docket No. RM22-8 amends 18 CFR 380.12(o)(15) to codify the following recommendations from the 2017 Guidelines that applicants:

• Demonstrate that the proposed facilities will be sited, designed, constructed, and operated to maintain reliability and will not significantly impact public safety given geotechnical conditions and the occurrence of a natural hazard;

• Provide geotechnical studies and natural hazard studies based on the site location, which must provide impacts and magnitude of historical events and projected impacts and magnitude of events based on projected prescriptive / deterministic events and projected probabilistic events corresponding to mean recurrence intervals;

• Provide the basis of design supported by site information, including design parameters and criteria and preliminary resultant design loads used in the geotechnical and structural design of LNG facilities; and

• Include construction and operation information that discusses quality assurance and quality control plans, monitoring programs, and action programs developed in preparation of and response to geotechnical and natural hazards.

New 18 CFR 380.15(o)(15) also provides that all information provided must, at a minimum, demonstrate compliance with all applicable federal requirements and applicable codes and standards, and identify any applicable state and local requirements for the siting, design, construction, testing, monitoring, operation, and maintenance used to safeguard against significant impacts caused by geotechnical conditions and natural hazards.

2. DESCRIBE ANY CONSIDERATION OF THE USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE BURDEN AND THE TECHNICAL OR LEGAL OBSTACLES TO REDUCING BURDEN

The Commission is continually improving its eFiling capabilities in an effort to reduce the burden to entities needing to file materials. All of the filing material associated with the FERC-577 materials may be eFiled through FERC’s eFiling system, and in the last year, 100 percent of the material was eFiled.

2. DESCRIBE EFFORTS TO IDENTIFY DUPLICATON 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 reviewed for need at least as often as every three years when the information collection expiration dates are due to expire, and typically evaluated more frequently than that. After Commission analysis, it has been confirmed that there is no other source of this information, nor is the material duplicated in another source.

2. METHODS USED TO MINIMIZE BURDEN IN COLLECTION OF INFORMATION INVOLVING SMALL ENTITIES

There are no special provisions or methods for reducing burden on any small entities.

2. CONSEQUENCE TO FEDERAL PROGRAM IF COLLECTION WERE CONDUCTED LESS FREQUENTLY

The Commission reviews and analyses the information filed under the regulations subject to FERC-577 to determine whether to approve or deny the requested authorization, and to ensure landowners are properly notified. If the Commission failed to collect this data, it would lose its ability to review relevant information to determine whether the requested certificate should be authorized, and its ability to ensure compliance related activities were occurring. FERC-577 data collections are required for statutory purposes and cannot be discontinued or collected less frequently.

2. EXPLAIN ANY SPECIAL CIRCUMSTANCES RELATING TO THE INFORMATION

There are no special circumstances (as described in 5 CFR 1320.5(d)(2)) related to the FERC-577 information collection.

2. DESCRIBE EFFORTS TO CONSULT OUTSIDE THE AGENCY: SUMMARIZE PUBLIC COMMENTS AND THE AGENCY’S RESPONSE TO THESE COMMENTS

The NOPR was published in the Federal Register on November 27, 2022 (87 FR 72906). In accordance with OMB requirements, the NOPR invited public comments for a period of 60 days on the collection of information FERC-577 and the other information collections associated with Docket No. RM22-8-000. The public comment period ended on January 27, 2023.

One set of timely comments was filed jointly by the Center for LNG and the American Petroleum Institute (collectively, Associations). The Commission considered the comments in preparing the Final Rule.

Comments on Informational Requirements Applicable to LNG Applications

The Associations endorsed the Commission’s efforts to prevent confusion about the informational requirements that the Commission applies to its review of applications for the construction and operation of LNG facilities. However, the Associations recommended that the Commission include in the Final Rule additional clarifications in keeping with the National Technology Transfer and Advancement Act of 1995 (NTTAA)¹¹ and OMB Revised Circular A119.¹²

The Commission responded in the preamble of the Final Rule, noting that the NTTAA requires all federal agencies and departments to use technical standards that are developed or adopted by voluntary consensus standard bodies¹³ to carry out policy objectives or activities determined by the agencies and departments unless using such a standard is inconsistent with applicable law or otherwise impractical.¹⁴

The Commission determined that voluntary consensus standards related to natural hazard evaluation and design criteria for LNG structures, systems, and components would be impractical. The Commission’s evaluation and analysis of LNG applications, which propose technically diverse types of facilities, must consider the unique locations that the LNG facilities will be sited, constructed, and operated. Over 2,500 standards exist that could be applicable to an LNG structure, system, or component. No one standard would apply to every application that the Commission reviews. Likewise, no individual application would be subject to every standard. To ensure that all types of proposals are covered by a standard would require that the Commission codify every potential consensus standard that could apply in its various LNG proceedings. Such an effort would be infeasible and would confuse applicants about which standards the Commission expects them to apply to their proposal.

Moreover, although some standards set criteria for the siting, design, construction, operation, and maintenance of LNG facilities, they often do not sufficiently detail the engineering information needed in an application to allow the Commission to fully assess the reliability and safety of the LNG facilities. As a result, the lack of detail has led to applicants applying these standards inconsistently.

The Commission’s practice, informed by the 2017 Guidance, has been to clarify that, when applicants prepare Resource Report 13, they should provide certain specific information regarding the engineering of the proposed LNG facilities. This information includes identifying applicable federal regulations, proposed codes and standards, as well as additional information on the proposed siting, design, construction, and operation. By having the applicants identify all federal regulations, codes, and standards that apply to their project-specific and site-specific proposal, the Commission is then able to evaluate applications for LNG facilities on a case-by-case basis, determine and evaluate the federal regulations, codes, and standards that apply (including any voluntary consensus standards that are adopted into those regulations). Based on the information, the Commission could more effectively coordinate with other federal agencies with jurisdiction over the proposal, evaluate whether the identified regulations, codes, and standards contain informational gaps, and recommend modifications or conditions that should be included in the Commission’s authorization based on the proposed LNG facilities and layers of protection that would reduce the risk of adverse effects to the public and the environment and reliability.

For these reasons, the Commission codified its practice of obtaining information necessary for it to fulfill its regulatory mission in lieu of using a voluntary consensus standard, as permitted by the NTTAA.

Comments Requesting Additional Definitions

The commenters requested clarification about the following terms undefined in the NOPR: (i) “structures, systems, and components;” (ii) “associated safety related structures, systems, and components;” (iii) “applicable codes and standards;” and (iv) “generally accepted codes, standards, and specifications.” To prevent confusion, they recommend that the Final Rule define these terms and identify which codes and standards should be incorporated by reference into the Commission’s regulations.

The Commission found no need to codify definitions for these terms but provided additional clarification in the preamble to the Final Rule.

Comments Opposing Retroactive Application of Final Rule

The commenters requested clarification that the requirements in the final rule will not be retroactively applied to existing jurisdictional LNG facilities. They are concerned that existing operators who file an application or request Commission approval to modify operations, expand, or add equipment to their LNG facilities would be required to upgrade or retrofit the existing facility to comply with the new requirements. To help avoid confusion, they recommend that the Commission amend Parts 153, 157, and 380 by adding a new applicability section that states the new requirements do not apply to existing LNG facilities authorized before the effective date of the final rule.

The Commission declined to adopt commenters’ recommendation because 18 CFR 380.12(o) already specifies the applicability of the content and formatting requirements for Resource Report 13. Therefore, the requirements in new § 380.12(o)(14) would apply only to applicants who file an application to construct new LNG facilities or recommission existing LNG facilities once the final rule is effective. Adding a new applicability section would be redundant and unnecessary.

Comments on Estimated Regulatory Burden

The commenters identified one new requirement that they asserted could introduce a new burden. The NOPR proposed in new § 380.12(o)(15)(iii)(A)(22) that applicants are required to describe the proposed LNG facility’s seismic monitoring system, which includes a minimum of one triaxial ground motion recorder installed to register the free-field ground motion and additional triaxial ground motion recorders on each LNG tank system foundation, LNG tank roof, and associated safety related structures, systems, and components. They argued that the term “associated safety related structure, systems, and components” is vague and that it is unclear how many ground motion recorders would be required. The commenters add that applicable codes and standards, such as American Concrete Institute Code 376-11, Code Requirements for Design and Construction of Concrete Structures for Containment of Refrigerated Liquefied Gases,¹⁵ do not require accelerometers for LNG tanks with Safe Shutdown Earthquake (SSE) peak ground accelerations less than 0.1 gravity. If the final rule requires accelerometers for such LNG tanks and associated systems, structures, and components, it will constitute a new regulatory burden, which the commenters oppose.

The Commission does not anticipate that compliance with this rule will alter current practice. With respect to new § 380.12(o)(15)(iii)(A)(22), contrary to the commenters’ argument, the new regulation does not require that LNG facilities have a certain number of seismic monitoring systems or accelerometers. The new requirement, which implements the seismic monitoring system recommendations in the 2017 Guidance, requires only that Resource Report 13 describe how the proposed seismic monitoring system would be designed in accordance with all applicable federal requirements and applicable codes and standards. Nevertheless, the final rule replaces “a minimum of one” with “any” in new § 380.12(o)(15)(iii)(A)(22) to avoid unnecessary confusion about whether the final rule establishes a specific number of triaxial ground motion recorders. In terms of where the seismic monitoring equipment are required to be located, the new section does not require anything other than a description of what the applicant proposes, which should follow the requirements under federal requirements and applicable codes and standards. If the Commission determines that the specifics of the proposal require additional seismic monitors to ensure safety and reliability, the order authorizing the application would include such a condition.

The commenters contend that the Final Rule will eliminate the flexibility that is purportedly in the 2017 Guidance, which allows applicants to exercise alternative approaches to prepare seismic information. They quote NBSIR 84-2833 for support.

The commenters are mistaken. The flexibilities in the 2017 Guidance are preserved by its codification in this rulemaking. The Final Rule does not enumerate specific federal regulations or codes or standards that applicants must apply to the safe and reliable design, construction, operation, and maintenance of jurisdictional LNG facilities. Instead, consistent with the 2017 Guidance and the Commission’s practice, the Final Rule instructs applicants to identify all applicable federal regulations, including codes and standards when preparing their application, and to explain how their proposal would comply with these regulations and requirements. To the extent that applicants currently identify information that is not necessary in a geotechnical report based on the seismology and geology of the proposed site, applicants are free to continue to identify the unnecessary information and provide an explanation or rationale for their decision. The Commission would review the information that is provided in Resource Report 13 and coordinate with other federal agencies with jurisdiction over the proposed LNG facility to ensure that there is sufficient information to assist in the public safety and reliability review of the proposals. Further, if the Commission finds the application contains insufficient information based on applicable regulations, codes and standards, or is unable to demonstrate that their proposed facilities would be sited, designed, constructed, and operated safely and reliably, the Commission may issue data requests for further information or clarification.

2. EXPLAIN ANY PAYMENT OR GIFTS TO RESPONDENTS

There are no payments or gifts to respondents of this collection.

2. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS

The Commission does not guarantee the information provided by applicants to be confidential. In fact, most of it is understood to be public. However, the Commission has encouraged applicants to indicate information which may be Critical Energy/Electric Infrastructure Information (CEII), or privileged, and thus initially confidential. CEII as stated in Section 18 CFR 157.10 includes information about proposed or existing natural gas facilities that could be useful to a person planning an attack on critical energy infrastructure. Privileged material most often includes proprietary business information, specific cultural resource details and locations, and personal identification information of affected landowners.  More information about CEII and privileged security levels of information are posted at http://www.ferc.gov/legal/ceii-foia/ceii.asp and http://www.ferc.gov/legal/ceii-foia/ceii/classes.asp. The Commission’s procedures in Part 388 are designed to ensure that CEII and privileged material are not placed in the Commission’s public records.

2. 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

There are no questions of a sensitive nature associated with the reporting requirements.

2. ESTIMATED BURDEN COLLECTION OF INFORMATION

The Commission estimates the annual public reporting burden¹⁶ and cost¹⁷ for the information collection as shown in Table 12.

The estimated burdens for FERC-577, because of the Final Rule in RM22-8-000, are as follows:

Table 12

Estimated Annual Burdens for FERC-577 Due to Docket No. RM22-8-000

Number of Respondents (1)	Number of Responses Per Respondent (2)	Total Number of Responses (1) * (2) = (3)	Average Burden Hours & Average Cost per Response ($) (rounded) (4)	Total Annual Burden Hours & Total Annual Cost ($) (rounded) (3) * (4) = (5)	Cost per Respondent ($) (rounded) (5) ÷ (1) = (6)
6	16	96	193.52 hours; $17,610.32	18,578 hours; $1,690,591	$281,765

These estimated burdens are in addition to those previously approved for FERC-577

2. ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS

There are no non-labor start-up costs. All costs are related to burden hours and are addressed in Questions #12 and #15.

2. ESTIMATED ANNUALIZED COST TO FEDERAL GOVERNMENT

The estimate of the cost for ‘analysis and processing of filings’ is based on salaries and benefits for professional and clerical support. This estimated cost represents staff analysis, decision-making, and review of any actual filings submitted in response to the information collections for the information collections in FERC-577.

The Paperwork Reduction Act (PRA) Administrative Cost is the average annual FERC cost associated with preparing, issuing, and submitting materials necessary to comply with the PRA for rulemakings, orders, or any other vehicle used to create, modify, extend, or discontinue an information collection. It also includes the cost of publishing the necessary notices in the Federal Register.

Table 14

Estimated Annualized Federal Cost Due to Docket No. RM22-8-000

	Number of Employees (FTE)	Estimated Annual Federal Cost
Analysis and Processing of Filings18	4	$799,468
PRA19 Administrative Cost		$8,286
FERC Total		$807,754

2. REASONS FOR CHANGES IN BURDEN INCLUDING THE NEED FOR ANY INCREASE

The Final Rule adds to the previously approved burdens for FERC-577 only with respect to LNG facilities. These additions are program changes: an additional 96 responses and an additional 4,788 hours. The previously approved burdens for FERC-577 apply to all natural gas facilities. Table 15 shows those changes.

Table 15

Changes in Burden Due to Docket No. RM22-8-000

FERC-577	Total Request	Previously Approved	Program Change	Net Burden
Annual Number of Responses	96	25,232	+ 96	25,328
Annual Time Burden (Hours)	4,788 hours	359,957	+4,778 hours	364,745 hours
Annual Cost Burden ($)	$0	$0	$0	$0

2. TIME SCHEDULE FOR PUBLICATION OF DATA

There are no publication plans for the collection of information. The data are used for regulatory purposes only.

2. DISPLAY OF EXPIRATION DATE

The expiration date is displayed in a table posted on ferc.gov at https://www.ferc.gov/information-collections.

2. EXCEPTIONS TO THE CERTIFICATION STATEMENT

There are no exceptions.

1 In the Notice of Proposed Rule (NOPR) in Docket No. RM22-8-000, FERC-539A and FERC-577A were temporary placeholder designations for the permanently designated collections of FERC-539 and FERC-577, which at the time were pending renewal at OMB. The temporary placeholder designations were necessary because only one request is allowed for any information collection.

OMB issued “comment and continue” types of decisions for all three of the information collection requests associated with the NOPR at Docket No. RM22-8-000. As part of those decisions, OMB assigned new control numbers for FERC-539A and FERC-577A (i.e., 1902-0326 and 1902-0327).

The previously pending requests for FERC-539 and FERC-577 have been approved and are now available for use in connection with the Final Rule.

In the metadata in ROCIS for FERC-577, we are listing the NOPR as a 60-day notice and the Final Rule as a 30-day notice (as well as a Final Rule) so that we may characterize our request as a “regular” type of request. We were allowed to characterize our request as “regular” in the metadata for ROCIS for FERC-539 without taking those measures.

2 15 U.S.C. 717b and 717f, respectively.

3 42 U.S.C. 4332(2)(C).

4 The 1977 Department of Energy (DOE) Organization Act (42 U.S.C. 7151(b)) placed all section 3 jurisdiction under DOE. The Secretary of Energy subsequently delegated authority to the Commission to “[a]pprove or disapprove the construction and operation of particular facilities, the site at which such facilities shall be located, and with respect to natural gas that involves the construction of new domestic facilities, the place of entry for imports or exit for exports.” DOE Delegation Order No. S1-DEL-FERC-2006, section 1.21A (May 16, 2006).

5 15 U.S.C. 717f(c).

6 See 15 U.S.C. 717n(b)(1).

7 Applicants to construct LNG terminals are required to comply with the Commission’s pre-filing process prior to filing an application with the Commission. 15 U.S.C. 717b-1(a); 18 CFR 157.21.

8 See 18 CFR 153.8(a)(5), 153.8(a)(6), 153.8(a)(7)(i), 157.14(a)(7), 157.21, 380.3, and 380.12. 18 CFR 153.8(a)(7) contains an errant subparagraph (i), which the NOPR would remove.

9 The outdated standards are (1) the National Bureau of Standards Information Report (NBSIR) 84-2833 and (2) the Uniform Building Code’s Seismic Risk Map (UBC Map).

10 See also Notice of Availability of the Final Guidance Manual for Environmental Preparation, 82 FR 12088 (Feb. 28, 2017).

11 The NTTAA (Pub. L. No. 104-113) directs Federal agencies to adopt voluntary consensus standards wherever possible (avoiding development of unique government standards) and establishes reporting requirements.

12 OMB Revised Circular A119 spells out the government strategy for standards development. It promotes agency participation on standards bodies, specifies reporting requirements on conformity assessment activities, and informs agencies of their statutory obligations related to standards setting.

13 A voluntary consensus standard body is a type of association, organization, or technical society that plans, develops, establishes, or coordinates voluntary consensus standards using a voluntary consensus standards development process that includes following attributes or elements: openness, balance, due process, appeals process, and consensus. Revised OMB Circular A-119, 2(e).

14 15 U.S.C. 272 note.

15 The code provides minimum design and construction requirements for reinforced concrete and prestressed structures for the storage and containment of refrigerated liquefied gases.

16 “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. For further explanation of what is included in the information collection burden, reference 5 Code of Federal Regulations 1320.3.

17 The Commission staff estimates that industry is similarly situated in terms of hourly cost (for wages plus benefits). Based on the Commission’s current average cost (for wages plus benefits), $96.00/hour is used.

18 Based upon the current FERC FTE average annual salary plus benefits ($199,867).

19 Paperwork Reduction Act of 1995 (PRA).

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