# Presentation: 327572

## EEI Views on the EIA Electric Survey Forms

- Presentation by Henri Bartholomot, EEI Director, Regulatory Legal Issues
- at the EIA Energy Outlook, Modeling, and Data Conference in Washington DC
- on March 28, 2007

## Edison Electric Institute (EEI) is the association of U.S. shareholder-owned electric utilities
Our members serve about 67 percent of end-use electricity customers nationwide and generate almost 60 percent of the electricity generated in the U.S.

- Our members serve about 67 percent of end-use electricity customers nationwide and generate almost 60 percent of the electricity generated in the U.S.

## Several other types of entities also provide electricity in the U.S. 
Municipally owned electric utilities
Rural electric cooperatives
Co-generation industrial facilities
Federal power marketing administrations

- Municipally owned electric utilities
- Rural electric cooperatives
- Co-generation industrial facilities
- Federal power marketing administrations

## 4

## Electric Companies Rely on a Complex Array of Generation, Transmission, and Distribution Facilities to Serve Their Customers

- 5

**Electric Companies Rely on a Complex Array of Generation, Transmission, and Distribution Facilities to Serve Their Customers**

## EEI members operate in competitive energy and financial markets 
Wholesale electricity markets
RTOs and ISOs
Bilateral contracts
Hedging
Retail markets competitive in some areas
Stock and bond markets

- Wholesale electricity markets
- RTOs and ISOs
- Bilateral contracts
- Hedging
- Retail markets competitive in some areas
- Stock and bond markets

## EEI members are subject to extensive federal and state regulation
Siting and operating facilities 
Clean air, water, and solid waste permits
Land use authorizations, wetlands permits
Endangered species, historic preservation
Energy and financial markets
Competitive bids for generation
Wholesale and retail rate approval
Financial disclosures to investors

- Siting and operating facilities
- Clean air, water, and solid waste permits
- Land use authorizations, wetlands permits
- Endangered species, historic preservation
- Energy and financial markets
- Competitive bids for generation
- Wholesale and retail rate approval
- Financial disclosures to investors

## Furthermore, EEI members collect and report large volumes of information to a variety of federal and state agencies
Energy Information Administration (EIA)
Federal Energy Regulatory Commission (FERC)
Environmental Protection Agency (EPA)
Securities and Exchange Commission (SEC)
State utility commissions

- Energy Information Administration (EIA)
- Federal Energy Regulatory Commission (FERC)
- Environmental Protection Agency (EPA)
- Securities and Exchange Commission (SEC)
- State utility commissions

## EIA Electric Power Survey Forms Filed by EEI Members

| Form | Description | Estimated Reporting Burden | Confidential Data Elements |
| --- | --- | --- | --- |
| EIA-411
[Annual] Coordinated Bulk Power Supply Program Report  |  Peak demand and energy for the
   preceding year and 5 future years
 Existing and planned generating
   capacity
 Scheduled capacity purchases and
   sales
 Bulk electric transmission system
   maps and power flow cases
 Proposed transmission lines | 1,527 hours per regional response |  Bulk electric
   transmission
   maps
 Bulk transmission
   facility power
   flow cases |
| OE-417
[Per Incident] Electric Emergency Incident and Disturbance Report |  Electric emergency incidents and
   disturbances 
 For DOE’s use in fulfilling its overall
   national security responsibilities | 5 minutes per initial response,
2 hours per explanation |  Utility contact
   information
 Narrative 
   description of
   incident |

**EIA Electric Power Survey Forms Filed by EEI Members**

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## EIA Electric Power Survey Forms Filed by EEI Members

| Form | Description | Estimated Reporting Burden | Confidential Data Elements |
| --- | --- | --- | --- |
| EIA-423
Monthly Cost and Quality of Fuels for Electric Plants Report |  Fuel quantity
 Fuel quality – Btu, sulfur, ash content
 Fuel purchase type, cost, contract
   expiration date, tolling agreements
 Fossil fuel supplier | 1.3 hours per response |  Delivered fuel
   cost – plant
   purchase price |
| EIA-767
[Annual] Steam Electric Plant Operation and Design Report |  Plant design parameters and annual
   operations data for
 boilers
 generators
 cooling systems
 stacks
 flues 
 flue gas particulate collectors
 flue gas desulfurization units | 66.3 hours for plants > 100 MW,  3.4 hours for plants > 10 MW < 100 MW |  Plant latitude and
   longitude |

**EIA Electric Power Survey Forms Filed by EEI Members**

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## EIA Electric Power Survey Forms Filed by EEI Members

| Form | Description | Estimated Reporting Burden | Confidential Data Elements |
| --- | --- | --- | --- |
| EIA-826
Monthly Electric Sales and Revenue with State Distributions Report |  Revenue associated with the sale of
   electricity
 Sales (MWh delivered)
 Number of customers by end-use
   sector and state
 Sample survey of 450 utilities and
   non-utilities selling to end use
   customers | 1.2 hours per response |  Energy only sales
   without delivery
   service
 Bundled service
   by retail energy
   providers
 Power marketers
   that provide
   bundled service |
| EIA-860
Annual Electric Generator Report |  Ownership and NAICS designation
 Energy sources and prime mover
 Nameplate capacity
 Fuel switching capability
 Operational and regulatory status
 On-line dates and actual or planned
   retirement dates | 10.2 hours per electric utility, 
5.1 hours per non-utility |  Plant latitude and
   longitude
 Tested heat rate |

**EIA Electric Power Survey Forms Filed by EEI Members**

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## EIA Electric Power Survey Forms Filed by EEI Members

| Form | Description | Estimated Reporting Burden | Confidential Data Elements |
| --- | --- | --- | --- |
| EIA-861
Annual Electric Power Industry Report |  Revenues associated with the sale of
   electricity
 MWh sales delivered
 Number of customers
 Energy sources and disposition
 Customer service programs
 Electric operating revenue
 DSM information
 Distribution system information  | 8.1 hours per response | None |
| EIA-906
[Monthly for Large Plants/ Annual for Others] Power Plant Report |  Electric power generation
 Fuel consumption and heat content
 Fossil fuel stocks | 1.3 hours monthly, 
1.9 hours annually |  Stocks at end of
   reporting period |

**EIA Electric Power Survey Forms Filed by EEI Members**

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## EEI encourages all agencies to
Minimize the reporting burden
Apply reporting provisions equitably across ownership type and energy sector
Treat key commercial and security related information as confidential

- Minimize the reporting burden
- Apply reporting provisions equitably across ownership type and energy sector
- Treat key commercial and security related information as confidential

## Burden issues
Reporting involves significant costs
Collecting, verifying, and analyzing data take substantial staff time, funds, and other resources
Multiple reports are often due at the same time
Paperwork Reduction Act aims to reduce these costs
Requires agencies to minimize the reporting burden and to avoid duplication
Requires triennial review by each agency and the Office of Management and Budget (OMB)

- Reporting involves significant costs
- Collecting, verifying, and analyzing data take substantial staff time, funds, and other resources
- Multiple reports are often due at the same time
- Paperwork Reduction Act aims to reduce these costs
- Requires agencies to minimize the reporting burden and to avoid duplication
- Requires triennial review by each agency and the Office of Management and Budget (OMB)

## Burden recommendations
Collect only information each agency truly needs
Collect the information only in the detail needed
Avoid duplication
Allow information to be filed in original or .pdf formats without re-entry of data
Provide reasonable reporting deadlines

- Collect only information each agency truly needs
- Collect the information only in the detail needed
- Avoid duplication
- Allow information to be filed in original or .pdf formats without re-entry of data
- Provide reasonable reporting deadlines

## Equitability issues
Requiring only shareholder-owned electric companies and not others to report information can harm companies and undermine fair competition by
imposing higher costs on those companies
giving their competitors strategic advantage

- Requiring only shareholder-owned electric companies and not others to report information can harm companies and undermine fair competition by
- imposing higher costs on those companies
- giving their competitors strategic advantage

## Equitability recommendations
Treat shareholder- and non-shareholder owned entities comparably
Treat energy sectors comparably
Collect less rather than more data when possible in search for common ground

- Treat shareholder- and non-shareholder owned entities comparably
- Treat energy sectors comparably
- Collect less rather than more data when possible in search for common ground

## Confidentiality issues
Disclosing commercially sensitive information such as cost and operating data can harm companies
FOIA “b(4)” exemption applies
CIPSEA can apply
Disclosing information such as facility location, design, importance, and safeguards can increase security risks
Department of Homeland Security umbrella
DOE confidentiality efforts
FERC confidentiality efforts

- Disclosing commercially sensitive information such as cost and operating data can harm companies
- FOIA “b(4)” exemption applies
- CIPSEA can apply
- Disclosing information such as facility location, design, importance, and safeguards can increase security risks
- Department of Homeland Security umbrella
- DOE confidentiality efforts
- FERC confidentiality efforts

## Confidentiality recommendations
Aggregate commercially sensitive information; do not disclose it at a plant or company level
Avoid disclosing security-related information such as facility location, design, importance, and safeguards 
Ensure that information remains confidential when shared with others
Maintain protection across agencies
Disclose only to those who need the information
Use non-disclosure agreements

- Aggregate commercially sensitive information; do not disclose it at a plant or company level
- Avoid disclosing security-related information such as facility location, design, importance, and safeguards
- Ensure that information remains confidential when shared with others
- Maintain protection across agencies
- Disclose only to those who need the information
- Use non-disclosure agreements

## Initial suggestions for EIA Electricity 2008 triennial review
Streamline the electric survey forms
Eliminate unnecessary detail 
Consolidate EIA forms if that makes sense
Provide reasonable reporting deadlines
Protect sensitive information
Do not release latitude and longitude or other security sensitive information
Consolidate information about competitive operations and costs to avoid disclosing at a plant or company level

- Streamline the electric survey forms
- Eliminate unnecessary detail
- Consolidate EIA forms if that makes sense
- Provide reasonable reporting deadlines
- Protect sensitive information
- Do not release latitude and longitude or other security sensitive information
- Consolidate information about competitive operations and costs to avoid disclosing at a plant or company level