On March 28, 91茄子 filed comments in response to FERC’s Notice of Inquiry regarding proposals to revise its financial reporting forms (2, 2-A, 3-Q). 91茄子 stated that the information currently in the forms, along with other publicly available information, is sufficient to provide FERC and the public with the data necessary to evaluate whether or not further investigation under section 5 is warranted. In support, 91茄子 pointed to the recent National Fuel and Southwest Gas proceedings. 91茄子 took the position that the forms serve to provide FERC and the industry with a snapshot of pipelines’ financial position during the reporting period and currently are not designed to facilitate projections or judgment calls based on the data “or to provide all of the information that may be useful to other agencies, the public, or to a litigant in challenging pipeline rates.” In evaluating proposals to increase reporting requirements, 91茄子 urged FERC to balance the amount and type of information it needs against the burden on the industry. 91茄子 reserved comments on specific proposals until they are fleshed out in comments by others.
