Overview
Title
Commission Information Collection Activities (FERC Form Nos. 1,1-F, and 3-Q); Comment Request; Extentions
Agencies
ELI5 AI
FERC, a group that looks at energy details, wants people to say what they think about forms it uses to get numbers from big and small electric and gas companies by April 8, 2025. They want to know if these forms help and how to make them better or easier to fill out.
Summary AI
The Federal Energy Regulatory Commission (FERC), part of the Department of Energy, is asking for public comments on its information collections, specifically FERC Form Nos. 1, 1-F, and 3-Q. These forms are used to collect financial and operational data from major and nonmajor electric utilities, licensees, and natural gas companies. Comments are due by April 8, 2025, and FERC seeks input on the necessity, accuracy, and potential improvements for the data collection processes. The request aims to understand if the information is useful for FERC's functions and how the collections can be enhanced or made less burdensome.
Abstract
In compliance with the requirements of the Paperwork Reduction Act of 1995 (PRA), the Federal Energy Regulatory Commission (Commission or FERC) is soliciting public comment on the currently approved information collections, FERC Form Nos. 1 (Annual Report of Major Electric Utilities, Licensees, and Others), 1-F (Annual Report for Nonmajor Public Utilities and Licensees), and 3-Q (Quarterly Financial Report of Electric Utilities, Licensees, and Natural Gas Companies).
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AnalysisAI
The document from the Federal Energy Regulatory Commission (FERC), part of the Department of Energy, is a formal request for public comments regarding three specific forms used in collecting financial and operational data. These are FERC Form Nos. 1, 1-F, and 3-Q, targeting major and nonmajor electric utilities, licensees, and natural gas companies. The request stems from the need to comply with the Paperwork Reduction Act of 1995 and examines the burden of information collection on these industries. Comments from the public are due by April 8, 2025.
Summary
This notice revolves around the collection of essential data by FERC, which helps in managing and overseeing the utilities and natural gas sectors. FERC seeks public input on whether the data collected are necessary, the accuracy of its burden estimates, and if there are any improvements to their processes. Essentially, they want to know if the information they gather serves a pragmatic function and if their approach can be refined or streamlined.
Issues and Concerns
Several concerns arise from reviewing the document. Firstly, it lacks specific data or examples to substantiate its cost and burden estimates regarding the forms mentioned. Transparency could be improved with a detailed breakdown or calculation explanation.
Furthermore, the mention of the hourly cost for data collection, set at $103 for wages and benefits, would benefit from additional clarification. This would help readers understand how this figure was determined and ensure its relevance to current market conditions.
The language used in the comment request section is quite complex, combining several inquiries into one lengthy paragraph. This could potentially confuse respondents who may find it challenging to address multiple issues simultaneously.
Another notable issue is the absence of clarity concerning the impact on stakeholders if they miss submission deadlines. The document provides detailed guidance on submitting comments but does not explain the consequences of non-compliance.
The document also fails to articulate how FERC plans to utilize the data beyond generic explanations like rate regulation and market oversight analysis. Providing clearer insights into how this data influences policy or decision-making could enrich the understanding of stakeholders.
Finally, while inviting comments, the document lacks context about how previous feedback has been integrated into the process or how it shapes future changes. Understanding this feedback loop would provide stakeholders with reassurance that their contributions have tangible impacts.
Public Impact
For the general public, the collection of this data ensures that regulatory oversight remains robust and that utilities operate efficiently, which could indirectly influence service pricing and reliability. However, the complexity of the document and potential impositions on utilities might raise questions about transparency and burden distribution.
Impact on Stakeholders
For electric utilities and natural gas companies, especially major and non-major categories defined by sales and operations volume, these forms represent a routine yet potentially burdensome task. This process can be resource-intensive, incurring costs and requiring significant administrative efforts. Such entities will be most interested in how efficiently they can fulfill these obligations and whether their operations could benefit from any streamlined processes arising from this feedback cycle.
On a positive note, the opportunity to comment allows these companies to suggest improvements that might reduce their reporting burdens. However, without clear feedback loops, stakeholders may remain skeptical about the impact of their input.
In conclusion, while the FERC's solicitation for comments is an essential regulatory practice aiming to enhance data collection processes, the lack of specificity and transparency in some areas calls for focused improvements to address stakeholder concerns effectively.
Financial Assessment
The document under consideration from the Federal Energy Regulatory Commission (FERC) invites public comments on the information collection processes associated with FERC Form Nos. 1, 1-F, and 3-Q. Throughout the document, there are several references to the financial burden and costs associated with these forms.
Financial References and Context
The estimated costs associated with these forms are a central focus. The document reports that the estimated hourly cost for fulfilling the requirements of FERC Form No. 1-F and FERC Form No. 3-Q is $103, which accounts for wages and benefits. Interestingly, this figure is based on FERC's 2025 Commission-wide average salary cost. This universal cost estimation is intended to represent the industry respondents' expenses.
Moreover, for FERC Form No. 3-Q, which involves reporting by both electric and natural gas companies, the document specifies a total average annual burden of 184,464 hours. This corresponds to a substantial total annual cost of $18,999,792. Such a significant financial figure underlines the extensive nature of the reporting requirements and the resource investment required by respondent companies.
Related Issues and Observations
One issue with these financial references is the lack of a detailed breakdown or justification for the $103 hourly rate. Readers may benefit from a clearer explanation of how this figure was derived and whether it adequately reflects the current industry costs and financial realities. Without a detailed calculation or rationale, stakeholders might question the accuracy or relevance of this cost estimation.
Additionally, while the document discusses the financial burden imposed by these requirements, it does not delve into the potential consequences for stakeholders who might fail to meet the obligations, such as missing submission deadlines. Such clarity could inform stakeholders about the financial risks associated with non-compliance.
Another observation is that the document solicits feedback on various aspects, like the accuracy of the burden and cost estimations, suggesting that there might be room for improvement or perhaps historical inaccuracies. Engaging stakeholders on whether these figures truly represent their experiences could enhance the document's credibility and transparency.
In conclusion, while significant financial allocations are apparent, providing greater transparency and clarity about how these figures are determined could assist stakeholders in understanding and responding to the document's requests for public comment. Accurate financial representations are crucial for maintaining trust and ensuring that the data collection processes remain efficient and equitable.
Issues
• The document does not provide specific data or examples to back up the cost and burden estimations for FERC Form Nos. 1, 1-F, and 3-Q. Providing specific calculations or breakdowns would enhance transparency.
• The hourly cost of $103 (for wages plus benefits) is mentioned, but the basis of this figure could be further clarified to assess its current relevance and accuracy.
• The language in the comment request section could be simplified, as it combines multiple complex queries into a single point, potentially causing confusion for respondents.
• The document mentions deadlines and addresses for submission, but it lacks clarity on the potential consequences of missing these deadlines for stakeholders.
• There is insufficient detail about how the FERC plans to use the data collected from these forms, beyond general purposes of rate regulation, market oversight analysis, and financial audits.
• While the document invites comments on specific points, it does not provide much context on how previous comments have been utilized or how this feedback loop influences future processes.
• Some technical jargon and references to regulatory provisions (e.g., 18 CFR part 101, 18 CFR 260.1(b)) are cited without additional explanation, which might be difficult for laypersons or those unfamiliar with regulatory texts to understand.