On November 24th, the FERC published a Notice of Information Collection in the Federal Register. Consistent with the requirements of the Paperwork Reduction Act of 1995 (PRA), the FERC is requesting public feedback pertaining to currently approved information collections, FERC Form Nos. 6 and 6T (Annual Report of Oil Pipeline Companies) and 6-Q and 6-QT (Quarterly Report of Oil Pipeline Companies). Pursuant to the Interstate Commerce Act (ICA), the FERC is authorized and empowered to make investigations and to collect and record data to the extent FERC deems necessary or useful in order to carry out the provisions of the ICA.
FERC Form No. 6 - Annual Report of Oil Pipeline Companies
The FERC requires oil pipelines to file annual reports with information (which includes Form No. 6) needed for the FERC to exercise its regulatory responsibility. Form 6 consists of the following three tiers of reporting requirements:
- Oil pipeline carriers exempt from filing FERC Form No. 6 and pages 301 and whose annual jurisdictional operating revenues totaled $350,000 or less for each of the three previous calendar years must prepare and file page 700, “Annual Cost of Service Based Analysis Schedule,” of FERC Form No. 6. When submitting page 700, each exempt oil pipeline carrier is required to include page 1 of FERC Form No. 6, the Identification and Attestation schedule (18 CFR 357.2 (a)(3)).
- Oil pipeline carriers exempt from filing FERC Form No. 6 whose annual jurisdictional operating revenues have totaled more than $350,000 but less than $500,000 for each of the three previous calendar years must prepare and file page 301, “Operating Revenue Accounts (Account 600),” and page 700, “Annual cost of Service Based Analysis Schedule,” of FERC Form No. 6. When submitting pages 301 and 700, each exempt oil pipeline carrier must include page 1 of FERC Form No. 6, the Identification and Attestation schedule (18 CFR 357.2 (a)(2)).
- Each oil pipeline carrier whose annual jurisdictional operating revenues has totaled $500,000 or more for each of the three previous calendar years must file FERC Form No. 6 (18 CFR 357.2 (a)). Oil pipeline companies subject to the provisions of section 20 of the ICA must submit FERC Form No. 6-Q. (18 CFR 357.4(b)). Newly established entities must use projected data to determine whether FERC Form No. 6 must be filed.
The FERC uses Form Nos. 6 and 6-Q the perform the following operations:
- Perform audits and reviews on the financial condition of oil pipelines
- Conduct oil pipeline rate proceedings and economic analysis
- Assess energy markets
- Administer the requirements of the ICA
- Conduct research for use in administrative litigation
- Compute annual charges which are then assessed against oil pipeline companies to recover the FERC’s annual costs as mandated by Order No. 472
The majority of state regulatory commissions use FERC Form Nos. 6 and 6-Q and the FERC’s Uniform System of Accounts (USofA) to comply with reporting requirements for those entities under their jurisdiction. Also, the public uses the information in FERC Form Nos. 6 and 6-Q to assist in monitoring rates, the financial condition of the oil pipeline industry, and assessing energy markets.
FERC Form No. 6-Q - Quarterly Financial Report of Oil Pipeline Companies
The FERC uses the information collected in Form No. 6-Q to prescribe rules and regulations pertaining to accounts, records, and memoranda, as necessary or appropriate. Financial accounting and reporting provides critical information concerning an entity’s past performance and its future prospects. With reliable financial statements prepared in compliance with FERC’s USofA and related regulations, the FERC can more easily and accurately determine the costs that relate to a particular time period, service, or line of business.
The FERC uses data from Form No. 6-Q to assist in:
- Continuous review of the financial condition of regulated companies
- Implementation of its financial audits and programs
- Assessment of energy markets
- Rate proceedings and economic analyses
Financial data reported on the quarterly Form No. 6-Q provides the FERC, customers, investors and others with an essential tool to help recognize developing trends and matters impacting jurisdictional entities within the energy industry. In addition, Form No. 6-Q provides timely disclosures of the impacts on jurisdictional entities, including new accounting standards (or revisions in existing standards), economic effects of significant transactions, events, and circumstances. Jurisdictional entities reporting this information assists the FERC in its analysis of profitability, efficiency, risk, and in its overall monitoring.
The FERC also requested three-year extensions of Form Nos. 6 and 6T (Annual Report of Oil Pipeline Companies), 6-Q and 6-QT (Quarterly Report of Oil Pipeline Companies) information collections with no changes to the current reporting and recordkeeping requirements.
Interested parties may submit comments on the FERC Information Collection Activities until January 24, 2022. More specifically, responses to the following matters are requested:
- Whether the collections of information are necessary for the proper performance of the functions of the FERC, including whether the information will have practical utility
- The accuracy of the agency’s estimates of the burden and cost of the collections of information, including the validity of the methodology and assumptions used
- Methods to enhance the quality, utility, and clarity of the information collections
- Ways to minimize the burden of the collections of information on those who are to respond, including the use of automated collection techniques or other forms of information technology
Methods for submitting feedback are detailed in the FERC Notice published in the Federal Register.
For more information, contact Ellen Brown via email at dataclearance@ferc.gov, or by phone at (202) 502-8663.
Sources:
Commission Information Collection Activities (FERC Form Nos. 6, 6T, 6-Q, and 6-QT); Comment Request; Extension (federalregister.gov)