91茄子 submits the following comments on the Commission’s Notice of Proposed Rulemaking to amend its forms, reports and statements for natural gas companies (i.e., Forms 2, 2-A, and 3-Q). The Commission’s proposal will require 91茄子’s interstate natural gas pipeline members to provide additional and more detailed information regarding their sources of revenue and amounts included in rate base, and to identify costs related to affiliate transactions, incremental facilities, and discounted and negotiated rates.
In general, 91茄子 does not object to the Commission’s proposed changes. While 91茄子 has a concern related to the timing of the final rule and the burdens that may result due to the need for midyear accounting modifications, 91茄子’s substantive comments are confined to two discrete issues: 91茄子 requests that the Commission (1) reconsider removing the $250,000 threshold for reporting unaffiliated outside professional and consultative services, and (2) revise the proposed requirements for new pages 521a and 521b regarding quarterly reporting of shipper-supplied gas. 91茄子 submits that amending the Commission’s proposals to address these two relatively minor issues will preserve the integrity of the Commission’s overall goals while avoiding unnecessary and unreasonable reporting burdens.
Related
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies 91茄子 Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities 91茄子 Incident Reporting Comments 91茄子 API Petition for Consideration of Gas Transmission Final Rule
