Overview
Title
Commission Information Collection Activities (FERC-549B); Comment Request; Extension
Agencies
ELI5 AI
The Federal Energy Regulatory Commission (FERC) wants to know what people think about how they collect information on natural gas pipes and their customers. People can share their thoughts on whether the information is helpful and if it's too much work to gather that information.
Summary AI
The Federal Energy Regulatory Commission (FERC) is asking the public for comments on the information collection known as FERC-549B, related to natural gas pipeline rates and customer information. This request is part of complying with the Paperwork Reduction Act of 1995 and involves collecting key data about gas pipeline capacities and services. People can submit comments to the Office of Management and Budget (OMB) and FERC until February 4, 2021. The comments should address the usefulness, accuracy, and burden of this information collection.
Abstract
In compliance with the requirements of the Paperwork Reduction Act of 1995, the Federal Energy Regulatory Commission (Commission or FERC) is soliciting public comment on the currently approved information collection FERC-549B (Gas Pipeline Rates: Annual Capacity Reports and Index of Customers), and is submitting the information collection to the Office of Management and Budget (OMB) for review. Any interested person may file comments directly with OMB and should address a copy of those comments to the Commission as explained below.
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AnalysisAI
The document titled "Commission Information Collection Activities (FERC-549B); Comment Request; Extension" is a notice issued by the Federal Energy Regulatory Commission (FERC). It seeks public input on the information collection related to gas pipeline rates and customer indexes, under the guidelines of the Paperwork Reduction Act of 1995. The deadline for comments is February 4, 2021, and feedback is directed towards assessing the utility, accuracy, and burden of this data collection.
Summary of the Document
The notice is primarily a request for public comments on the currently approved information collection associated with gas pipeline capacities and customer information. It details FERC's intended submission of this information collection to the Office of Management and Budget (OMB) for review. The document outlines methods for submitting comments and details the regulatory background that governs these data collections.
Significant Issues and Concerns
Several issues arise in analyzing the document. Firstly, it uses technical jargon and references numerous regulatory orders and codes—like Order No. 636 and 18 CFR 284.13—without providing explanations. This could be confusing for individuals not well-versed in regulatory terminologies or the natural gas industry.
Secondly, the procedure for submitting comments is somewhat elaborate, involving multiple portals and steps. This complexity might deter potential commenters who lack technical prowess or access to specific online resources.
Additionally, the document specifies certain data formats for submission, such as tab-delimited files on diskette, which are outdated. This highlights a potential need for updating submission methods to align with current technology practices.
Further, there is ambiguity in how the document estimates the annual public reporting burden and the average cost of $83 per hour for a FERC full-time equivalent. Details on these calculations and cost justifications are not provided, questioning the reliability and relevance of these figures.
Impact on the Public
The general public, especially those unfamiliar with regulatory processes or the natural gas industry, may find this document challenging to interpret. Its complexity may limit public engagement and diminish the potential for broad, meaningful input on natural gas pipeline regulations.
Impact on Specific Stakeholders
For industry stakeholders like interstate pipeline companies and entities regulated under the Natural Gas Act, the document outlines important compliance requirements. However, a lack of clarity and modernity in data submission formats may impose additional burdens or complications for these stakeholders.
Conversely, the notice offers an opportunity for stakeholders who can navigate the complexities to influence regulations potentially. Comments could shape how information is collected and used, thereby impacting operational efficiency and customer relations.
In conclusion, while the document seeks necessary feedback to enhance regulatory processes, various barriers to participation and understanding must be addressed to maximize public and stakeholder engagement effectively.
Financial Assessment
The document mentions a specific financial reference related to the costs associated with the Federal Energy Regulatory Commission (FERC) and its information collection activities. The key financial reference found in the document states that the current average cost for one FERC full-time equivalent is $83.00 per hour, including wages and benefits. This amount is used as a proxy to represent the industry's hourly cost. However, the document does not provide a detailed breakdown or justification for why this particular figure was chosen as the standard for industry costs.
In relation to the identified issues:
Estimation of Costs Without Breakdown: One of the principal financial observations revolves around the lack of clarity regarding how the $83.00 per hour cost estimate was determined. This absence of detail can lead to questioning the accuracy and relevance of the figure used as a reference. Stakeholders might find it challenging to assess the financial implications of the document's directives without understanding the derivation of this cost.
Cost Justification and Proxy Use: The use of a specific cost figure to represent industry-wide hourly costs as a proxy could misrepresent or oversimplify varied industry conditions and roles. There is no justification provided in the document for the decision to use FERC’s internal cost as a representative figure for broader industry costs, which could prompt queries or criticisms from those affected by this financial characterization.
Practical Implications for Stakeholders: For stakeholders required to adhere to or comment on the proposed measures, understanding the financial implications is vital. The financial reference does not fully convey the potential burden or cost-effectiveness from an industry perspective, which could cause pushback or submission of contradictory comments focusing on the cost assessment's validity.
This limited financial insight highlights the need for documents such as this to offer transparent and well-supported financial rationales. Clarity in financial details helps ensure that stakeholders can engage meaningfully with the content and assess its impact comprehensively. By providing a more detailed context and rationale for financial figures, the Commission could enhance the document's informational value and facilitate more informed and constructive public feedback.
Issues
• The document refers to statistical terms and regulatory codes (e.g., Order No. 636, 18 CFR 284.13) without providing definitions or context for readers unfamiliar with these references.
• The process for submitting comments to both the OMB and the Commission might be confusing to some, as it involves multiple steps and online portals, which may not be user-friendly for all potential respondents.
• The document outlines requirements for submitting data in specific formats (e.g., tab delimited format on diskette) that may be outdated, suggesting a need for modernized submission methods.
• There is a lack of clarity around the specific metrics used for estimating the annual public reporting burden and how these were calculated, including any assumptions inherent in this estimate.
• The document calls for comments on the necessity and utility of the information collection but provides no clear criteria for how these comments will be assessed or utilized.
• The estimated average cost for FERC full-time equivalent is set at $83.00 per hour; however, there is no breakdown of how this figure was derived or justification for its use as a proxy for the industry's hourly cost.
• Complex legislative and regulatory references may hinder understanding for readers not specialized in this field, potentially limiting effective public comment.