Friday, April 15. 2022
The FERC is requesting three-year extensions of Form Nos. 6, 6T, 6– Q, and 6–QT information collections under the same reporting and recordkeeping requirements for the duration of the extension requested. The FERC initially requested the extensions in November 2021. This renewal of forms integrates the requirements and burden of FERC Form Nos. 6T and 6–QT into FERC Form Nos. 6 and 6Q, respectively. The FERC deems Form Nos. 6T and 6-QT redundant and expects to retire them after its Office of Management and Budget makes determinations.
Form No. 6
Under the Department of Energy Organization Act, the FERC is responsible for regulating oil pipeline companies and requiring them to file annual reports (Form No. 6) that include the information necessary for the FERC to carry out its statutory responsibilities.
Data from Form No. 6 provides FERC with the following:
- figures and details to calculate of the actual rate of return on equity for oil pipelines, which is particularly useful information when evaluating a pipeline’s rates
- information from page 301 to compute annual charges which are then assessed against oil pipeline companies to recover the Commission's annual costs as mandated by Order No. 472. The annual charges are required by Section 3401 of the Omnibus Budget Reconciliation Act of 1986.
FERC Form No. 6 reduces burden on industry by having three levels of reporting requirements:
- Oil pipeline carriers whose annual jurisdictional operating revenues have been $500,000 or more for each of the three previous calendar years must file FERC Form No. 6. Oil pipeline companies subject to the provisions of section 20 of the Interstate Commerce Act must submit FERC Form No. 6-Q. Newly established entities must use projected data to determine if FERC Form No. 6 must be filed.
- Oil pipeline carriers exempt from filing FERC Form No. 6 whose annual jurisdictional operating revenues have been more than $350,000 but less than $500,000 for each of the three previous calendar years must prepare and file the following from FERC Form No. 6: page 301, “Operating Revenue Accounts (Account 600),” and page 700, “Annual cost of Service Based Analysis Schedule”. When submitting from these pages, each exempt oil pipeline carrier must include page 1 of FERC Form No. 6, the Identification and Attestation schedule.
- Oil pipeline carriers exempt from filing FERC Form No. 6 and pages 301 and whose annual jurisdictional operating revenues were $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 must provide page 1 of FERC Form No. 6, the Identification and Attestation schedule.
Form No. 6-Q
Form No. 6-Q includes quarterly financial data that provides the FERC (as well as customers, investors and others) with an essential tool that helps identify developing trends and issues impacting jurisdictional entities throughout the energy industry. The form also renders timely disclosures regarding how new accounting standards (or changes in existing standards) impact jurisdictional entities. Form No. 6-Q also provides the economic effects of major transactions, events, and circumstances. When jurisdictional entities use Form No. 6-Q to report this information, the FERC is better able to both assess profitability, efficiency, risk, and perform overall oversight.
The FERC also uses the data in Form No. 6-Q to:
- perform audits and reviews on the financial condition of oil pipelines
- conduct oil pipeline rate proceedings and economic analysis
- assess energy markets
- conduct research for use in administrative litigation
- administer the requirements of the Interstate Commerce Act
FERC’s Adoption of Structured Data Format
In April 2015, the FERC issued an order announcing its intention to begin using an eXtensible Markup Language-based (XML) filing format for certain FERC forms, including Form Nos. 6 and 6-Q. In June 2019, the FERC issued an order adopting XBRL as the standard for filing FERC Form Nos. 6 and 6-Q and certain other FERC forms.
Interested parties may submit comment on the following matters:
- 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 information collections, including the validity of the methodology and assumptions used
- approaches to enhancing the quality, utility, and clarity of the information collections
- ways to minimize the burden of the collection of information on those who are to respond, including the use of automated collection techniques or other forms of information technology