133 FERC ¶ 61,236 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Part 284 

[Docket No. RM11-4-000] 

Storage Reporting Requirements of Interstate and Intrastate Natural Gas Companies 

(December 16, 2010) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Notice of Inquiry. 

SUMMARY: The Federal Energy Regulatory Commission is considering whether to 

revise regulations requiring interstate and intrastate natural gas pipelines to report semiannually on their storage activities. This Notice of Inquiry will assist the Commission in 

determining what changes, if any, should be made to its regulations. 

COMMENT DATE: Comments are due [Insert_Date that is 60 days after publication in 

the FEDERAL REGISTER]

ADDRESSES: You may submit comments on the Notice of Inquiry, identified by 

Docket No. RM11-4-000, by one of the following methods: 

 Agency Web Site: Documents created electronically using word processing 

software should be filed in native applications or print-to-PDF format, and not in a 

scanned format, at http://www.ferc.gov/docs-filing/efiling.asp. 

 Mail/Hand Delivery: Commenters unable to file comments electronically must 

mail or hand deliver an original copy of their comments to: Federal Energy 

Regulatory Commission, Secretary of the Commission, 888 First Street, NE, 
Docket No. RM11-4-000 - 2 - 

Washington, DC 20426. These requirements can be found on the Commission’s 

website; see, e.g., the “Quick Reference Guide for Paper Submissions,” available 

at http://www.ferc.gov/docs-filing/efiling.asp or via phone from FERC Online 

Support at 202-502-6652 or toll-free at 1-866-208-3676. 

FOR FURTHER INFORMATION CONTACT: 

Vince Mareino (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street NE 

Washington, DC 20426 

(202) 502-6167 

Vince.Mareino@ferc.gov

Kenneth Kohut (Technical Information) 

Office of Enforcement 

Federal Energy Regulatory Commission 

888 First Street NE 

Washington, DC 20426 

(202) 502-6342 

Kenneth.Kohut@ferc.gov

Thomas Russo (Technical Information) 

Office of Enforcement 

Federal Energy Regulatory Commission 

888 First Street NE 

Washington, DC 20426 

(202) 502-8792 

Thomas.Russo@ferc.gov

SUPPLEMENTARY INFORMATION:
133 FERC ¶ 61,236 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Storage Reporting Requirements of Interstate and 

Intrastate Natural Gas Companies 

Docket No. RM11-4-000 

NOTICE OF INQUIRY 

(December 16, 2010) 

1. In this Notice of Inquiry, the Federal Energy Regulatory Commission 

(Commission) seeks comments on whether the Commission should modify the semiannual storage reports required of interstate and intrastate natural gas companies pursuant 

to 18 CFR 284.13(e) and 284.126(c) of the Commission’s regulations.1

 In particular, the 

Commission is interested in exploring whether it should modify the information currently 

collected in the semi-annual storage reports, whether there should be a standardized 

electronic format for the reports, and whether the storage reports must be public. 

I. Background

2. Section 284.13(e) of the Commission’s regulations requires interstate pipelines to 

file semi-annual storage reports at the end of each complete storage injection and 

withdrawal season. Section 284.126(c) requires similar reports by (1) intrastate natural 

 1

 The FERC Form No. 549B reporting requirements in 18 CFR 284.13(e) are 

approved by the Office of Management and Budget (OMB) under OMB Control 

No. 1902-0169. The Form No. 549 reporting requirements in 18 CFR 284.126(c) are 

approved under OMB Control No. 1902-0089. 
Docket No. RM11-4-000 - 2 - 

gas pipelines providing interstate transportation service pursuant to section 311 of the 

Natural Gas Policy Act of 1978 (NGPA)2

 and (2) Hinshaw pipelines providing interstate 

service subject to the Commission’s Natural Gas Act (NGA) section 1(c) jurisdiction 

pursuant to blanket certificates issued under 18 CFR 284.224.3

 The reports by both sets 

of pipelines must include: 

(1) the identity of each customer injecting gas into storage 

and/or withdrawing gas from storage (including, for interstate 

pipelines, any affiliate relationship), 

(2) the rate schedule (for interstate pipelines) or docket 

number (for intrastate pipelines) authorizing the storage 

injection or withdrawal service, 

(3) the maximum storage quantity and maximum daily 

withdrawal quantity applicable to each storage customer, 

(4) for each storage customer, the volume of gas (in 

dekatherms) injected into and/or withdrawn from storage 

during the period, 

(5) the unit charge and total revenues received during the 

injection/withdrawal period from each storage customer 

(including, for interstate pipelines, any discounts), and 

(6) for intrastate pipelines, any related docket numbers under 

which the intrastate pipeline reported storage related 

injection/withdrawal transportation services. 

 2

 15 U.S.C. 3372. 

3

 Section 1(c) of the NGA exempts from the Commission’s NGA jurisdiction 

those pipelines which transport gas in interstate commerce if (1) they receive natural gas 

at or within the boundary of a state, (2) all the gas is consumed within that state, and 

(3) the pipeline is regulated by a state Commission. This exemption is referred to as the 

Hinshaw exemption after the Congressman who introduced the bill amending the NGA to 

include section 1(c). See ANR Pipeline Co. v. Federal Energy Regulatory Comm’n, 

71 F.3d 897, 898 (1995) (briefly summarizing the history of the Hinshaw exemption). 
Docket No. RM11-4-000 - 3 - 

The pipelines must file these reports within 30 days of the end of each complete storage 

injection and withdrawal season, and the reports must be signed under oath by a senior 

official. The Commission has not adopted any standardized electronic form for pipelines 

to submit the semi-annual storage reports. Nor has the Commission expressly required 

that the reports be public. 

3. The Commission adopted the existing semi-annual storage reporting requirements 

for both interstate and intrastate pipelines in their current form in 1992 as part of Order 

No. 636,4

 and there have been only minor modifications in the semi-annual storage 

reporting requirements since that date.5

 In Order No. 637,6 the Commission revised the 

 4 Pipeline Service Obligations and Revisions to Regulations Governing SelfImplementing Transportation; and Regulation of Natural Gas Pipelines After Partial 

Wellhead Decontrol, Order No. 636, FERC Stats. & Regs. ¶ 30,939, order on reh’g, 

Order No. 636-A, FERC Stats. & Regs. ¶ 30,950, order on reh’g, Order No. 636-B, 

61 FERC ¶ 61,272 (1992), order on reh’g, 62 FERC ¶ 61,007 (1993), aff’d in part and 

remanded in part sub nom. United Distribution Cos. v. FERC, 88 F.3d 1105 (D.C. Cir. 

1996), order on remand, Order No. 636-C, 78 FERC ¶ 61,186 (1997). 

5

 In 1995 in Order No. 581, the Commission held that it would “retain the semiannual storage reports,” and “not exempt intrastate storage companies charging marketbased rates from the requirement to file semi-annual storage reports,” and made minor 

changes to the regulatory text. Revisions to Uniform System of Accounts, Forms, 

Statements, and Reporting Requirements for Natural Gas Companies, Order No. 581, 

60 FR 53019, 53049-51, FERC Stats. & Regs. ¶ 31,026 (1995), order on reh’g, Order 

No. 581-A, FERC Stats. & Regs. ¶ 31,032 (1996). 

6 Regulation of Short-Term Natural Gas Transportation Services and Regulation 

of Interstate Natural Gas Transportation Services, Order No. 637, FERC Stats. & Regs. 

¶ 31,091, clarified, Order No. 637-A, FERC Stats. & Regs. ¶ 31,099, reh’g denied, Order 

No. 637-B, 92 FERC ¶ 61,062 (2000), aff’d in part and remanded in part sub nom. 

Interstate Natural Gas Ass’n of America v. FERC, 285 F.3d 18 (D.C. Cir. 2002), order on 

remand, 101 FERC ¶ 61,127 (2002), order on reh’g, 106 FERC ¶ 61,088 (2004), aff’d 

sub nom. American Gas Ass’n v. FERC, 428 F.3d 255 (D.C. Cir. 2005). 
Docket No. RM11-4-000 - 4 - 

reporting requirements for interstate pipelines in order to require them to post on their 

internet websites basic information on the terms of each transportation and storage 

contract with individual shippers, no later than the first nomination under a transaction.7

 

These posting requirements are set forth in section 284.13(b) of the Commission’s 

regulations.8

 However, Order No. 637 did not modify the semi-annual storage reporting 

requirement for either interstate pipelines or section 311 and Hinshaw pipelines. 

4. In recent years, the Commission has updated almost all of its other reporting 

requirements to clarify their public status, standardize the filing format, and streamline 

the process of publishing the reported data to the general public. For example, in Order 

No. 2001,9

 the Commission amended its filing requirements for public utilities under the 

Federal Power Act (FPA) to require them to file Electric Quarterly Reports (EQR) 

summarizing the contractual terms and conditions in their contracts for all jurisdictional 

 7

 The information to be posted includes the name of the shipper, the contract 

number (for firm service), the rate charged, the maximum rate, the duration (for firm 

service), the receipt and delivery points and zones covered, the quantity of natural gas 

covered, any special terms or details (such as any deviations from the tariff), and whether 

any affiliate relationship exists. 

8

 18 CFR 284.13(b). 

9 Revised Public Utility Filing Requirements, Order No. 2001, FERC Stats. 

& Regs. ¶ 31,127, reh’g denied, Order No. 2001-A, 100 FERC ¶ 61,074, reh’g denied, 

Order No. 2001-B, 100 FERC ¶ 61,342, order directing filing, Order No. 2001-C, 

101 FERC ¶ 61,314 (2002), order directing filing, Order No. 2001-D, 102 FERC 

¶ 61,334, order refining filing requirements, Order No. 2001-E, 105 FERC ¶ 61,352 

(2003), order on clarification, Order No. 2001-F, 106 FERC ¶ 61,060 (2004), order 

revising filing requirements, Order No. 2001-G, 120 FERC ¶ 61,270, order on reh’g and 

clarification, Order No. 2001-H, 121 FERC ¶ 61,289 (2007), order revising filing 

requirements, Order No. 2001-I, 125 FERC ¶ 61,103 (2008). 
Docket No. RM11-4-000 - 5 - 

services during the most recent calendar quarter. The EQRs include information similar 

to that required by the semi-annual storage reports, including the quantities of service 

provided and the rates charged for all sales under the reported contracts. Order No. 2001 

required that the EQRs be filed in a standardized electronic format and that they be 

public.10 In Order No. 710,11 the Commission revised the Commission’s financial 

reporting requirements for natural gas pipelines, FERC Form Nos. 2, 2-A, and 3-Q, also 

adopting standardized electronic forms for the filing of these reports and requiring them 

to be public. Similarly, new forms, such as Form No. 552 issued pursuant to the 

transparency provisions of section 23 of the Natural Gas Act, have likewise emphasized 

standardization and transparency.12

5. Most relevant to this proceeding, on May 20, 2010, the Commission issued Order 

No. 735 to bring the less stringent transactional reporting requirements for NGPA section 

311 intrastate pipelines and Hinshaw pipelines closer in line with the 18 CFR 284.13(b) 

 10 Order No. 2001, FERC Stats. & Regs. ¶ 31,127 at P 44-46, 74-85, 104-117, 

reh’g denied, Order No. 2001-A, 100 FERC ¶ 61,074 at P 13-17, 30-35.

11 Revisions to Forms, Statements, and Reporting Requirements for Natural Gas 

Pipelines, Order No. 710, 73 FR 19389, FERC Stats. & Regs. ¶ 31,267 (2008), reh’g and 

clarification, Order No. 710-A, 123 FERC ¶ 61,278 (2008). 

12 See Transparency Provisions of Section 23 of the Natural Gas Act, Order 

No. 704, 73 FR 1014, FERC Stats. & Regs. ¶ 31,260 (2007), order on reh’g, Order 

No. 704-A, 73 FR 55726, FERC Stats. & Regs. ¶ 31,275 (2008), order on reh’g, Order 

No. 704-B, 125 FERC ¶ 61,302 (2008), order on reh’g, Order No. 704-C, 75 FR 35632, 

131 FERC ¶ 61,246 (2010). 
Docket No. RM11-4-000 - 6 - 

posting requirements for interstate pipelines.13 As part of that proceeding, the 

Commission revised the former annual transportation report at 18 CFR 284.126(b) to 

cover storage as well. Order No. 735 requires that section 311 and Hinshaw pipelines file 

quarterly reports in a standardized electronic format, and requires that those reports be 

public. As revised in a contemporaneous order on rehearing, the new quarterly reports 

must contain the following information on each transportation and storage transaction, 

aggregated by contract: 

i. The full legal name, and identification number, of the shipper 

receiving the service, including whether there is an affiliate 

relationship between the pipeline and the shipper; 

ii. The type of service performed (i.e., firm or interruptible 

transportation, storage, or other service); 

iii. The rate charged under each contract, specifying the rate 

schedule/name of service and docket where the rates were approved. 

The report should separately state each rate component set forth in 

the contract (i.e., reservation, usage, and any other charges); 

iv. The primary receipt and delivery points covered by the contract, 

identified by the list of points that the pipeline has published with 

the Commission, which shall include the industry common code for 

each point where one has already been established; 

v. The quantity of natural gas the shipper is entitled to transport, store, 

or deliver under each contract; 

vi. The duration of the contract, specifying the beginning and (for firm 

contracts only) ending month and year of the current agreement; 

vii. Total volumes transported, stored, injected, or withdrawn for the 

shipper; and 

viii. Annual revenues received for each shipper, excluding revenues from 

storage services. The report should separately state revenues 

received under each component, and need only be reported every 

fourth quarter. 

 13 Contract Reporting Requirements of Intrastate Natural Gas Companies, Order 

No. 735, 75 FR 29404, FERC Stats. & Regs. ¶ 31,310, 131 FERC ¶ 61,150 (2010), order 

on reh’g, Order No. 735-A, Docket No. RM09-2-001 (Dec. 16, 2010). 
Docket No. RM11-4-000 - 7 - 

6. Order No. 735 did not modify the existing semi-annual storage reporting 

requirement for section 311 and Hinshaw pipelines in section 284.126(c) of the 

Commission’s regulations in any way. That semi-annual storage report collects certain 

information that the new quarterly reports do not. This includes (1) the volumes actually 

injected and withdrawn from storage during the injection and withdrawal seasons and 

(2) revenues collected from each customer. Moreover, because the semi-annual reporting 

periods are tied to the injection and withdrawal season, the time periods covered by each 

report do not correspond precisely. Similarly, the 18 CFR 284.13(b) posting 

requirements for interstate pipelines do not collect this information. 

II. Discussion

7. The Commission is issuing this Notice of Inquiry to consider whether and how the 

semi-annual storage reports required of both interstate and intrastate pipelines should be 

modified in light of (1) changes in the natural gas market since the Commission 

originally adopted the semi-annual storage reporting requirements and (2) recent 

improvements in the Commission’s other reporting requirements. 

8. Both the evolution of natural gas markets, and the Commission’s experience in 

improving the usefulness and accessibility of other informational reports filed by natural 

gas pipelines and public utilities, warrant a review of the continued usefulness of the 

semi-annual storage reports in their current format. The semi-annual storage reports are 

now the only significant report required of regulated entities for which the Commission 

has not established a standardized electronic format and required to be public. As a 
Docket No. RM11-4-000 - 8 - 

result, many respondents file these reports subject to requests for confidential treatment, 

and/or file the data in a format that is not conducive to automated data review and posting 

on the Commission’s website for public review. The Commission has often had to rely 

on exhaustive data requests in individual rate filings in order to fulfill its oversight duty, a 

method that is administratively burdensome to the pipelines and the Commission. 

Perhaps more importantly, significant information in the reports is either not available to 

the public at all or, if available, is difficult to analyze because of the different reporting 

formats. 

9. Further, improved storage technology and the increased use of natural gas in 

industry and electric generation have helped transform the storage market since 1992. 

There has been a sharp increase in demand for natural gas outside of the traditional 

winter months. Withdrawals and injections, instead of occurring on a uniform annual 

schedule based on heating needs, now occur dynamically year-round in response to 

market forces. 

10. Also, on rehearing of Order No. 735, several parties argued that, because the new 

quarterly transportation reports for section 311 and Hinshaw pipelines will include 

storage transactions, Order No. 735 has made the existing 18 CFR 284.126(c) semiannual storage reporting requirement for those pipelines duplicative and therefore the 

semi-annual storage report should be eliminated. However, while there is significant 

overlap between the two reports, as described above the semi-annual storage reports for 

section 311 and Hinshaw pipelines still require the reporting of certain information not 

included in the new quarterly transportation report, including volumes injected and 
Docket No. RM11-4-000 - 9 - 

withdrawn from storage during each injection and withdrawal season and per-customer 

storage revenues. The 18 CFR 284.13(e) semi-annual storage reports by interstate 

pipelines are also the only place where interstate pipelines report this information. 

11. Accordingly, the Commission requests comment on the following questions 

concerning the semi-annual storage reports by both interstate pipelines and by section 

311 and Hinshaw pipelines. 

1) Should the Commission require that the semi-annual storage reports be 

public? In recent years, the Commission has clarified that Form Nos. 2, 2a, 

3Q, 552, and other similar reports must be filed publicly with no provision for 

redacting data. The EQR, which Order No. 2001 requires to be public, contain 

reporting requirements quite similar to the semi-annual storage reports. In the 

contemporaneous order on rehearing of Order No. 735, the Commission 

affirmed that the new quarterly transportation reports by section 311 and 

Hinshaw pipelines will be public as well. Is there any reason why the natural 

gas storage reports by interstate and intrastate pipelines should not be made 

public? 

2) Should the natural gas storage reporting requirements be standardized into 

an electronic form with standard fields and definitions? 

3) Storage injections and withdrawals are no longer done exclusively on a 

seasonal basis, but occur dynamically year-round. Should any reporting on 

storage be filed on a quarterly schedule, instead of semi-annually by injection 

and withdrawal season? 
Docket No. RM11-4-000 - 10 - 

4) If a standardized electronic form is developed for storage reports by 

interstate pipelines, what data elements from the Data Dictionary for the new 

quarterly transportation reports for section 311 and Hinshaw pipelines should 

be used in the revised interstate pipeline storage reports? What additional data 

elements should be included? 

5) Should the Commission require that interstate and section 311 and Hinshaw 

pipelines must report the different rate components in each storage customer’s 

contracts separately? What data elements should be included? 

6) In Order No. 735-A, the Commission removed from the new quarterly 

transportation report the requirement that section 311 and Hinshaw pipelines 

report revenues received from each storage customer, partly on the grounds 

that the semi-annual storage reports require reporting such information. 

Should this reporting requirement be retained for interstate and intrastate 

storage companies? Is the revenue information primarily of use in the rate 

cases of cost-based rate storage providers, so that revenues need not be 

reported by market-based storage providers? 

7) Given the extensive overlap between the new quarterly Form No. 549D 

reports14 and the current requirements of the intrastate semi-annual storage 

 14 The information collection requirements included in Commission Order No. 735 

for Form No. 549D were approved under OMB Control No. 1902-0253. The proposed 

revisions in the order on rehearing in Docket No. RM09-2-001 are being submitted to 

OMB for review and approval under the Paperwork Reduction Act. 
Docket No. RM11-4-000 - 11 - 

reports, should the intrastate storage reporting requirements be folded into 

Form No. 549D, or kept as a separate form? 

III. Comment Procedures

12. The Commission invites interested persons to submit comments and other 

information on the matters, issues, and specific questions identified in this notice. 

Comments are due [insert date that is 60 days from the date of publication in the

FEDERAL REGISTER]. Comments must refer to Docket No. RM11-4-000, and must 

include the commenter’s name, the organization it represents, if applicable, and its 

address. 

13. To facilitate the Commission’s review of the comments, commenters are requested 

to provide an executive summary of their position. Commenters are requested to identify 

each specific question posed by the Notice of Inquiry that their discussion addresses and 

to use appropriate headings. Additional issues the commenters wish to raise should be 

identified separately. The commenters should double-space their comments. 

14. Comments may be filed electronically via the eFiling link on the Commission’s 

web site at http://www.ferc.gov or on paper. The Commission accepts most standard 

word processing formats and commenters may attach additional files with supporting 

information in certain other file formats (as detailed at 

http://www.ferc.gov/help/submission-guide.asp). Commenters filing electronically do 

not need to make a paper filing. 
Docket No. RM11-4-000 - 12 - 

15. Commenters unable to file comments electronically must mail or hand deliver an 

original copy of their comments to: Federal Energy Regulatory Commission, Secretary 

of the Commission, 888 First Street NE, Washington, DC 20426. 

16. All comments will be placed in the Commission’s public files and may be viewed, 

printed, or downloaded remotely as described in the Document Availability section 

below. Commenters are not required to serve copies of their comments on other 

commenters. 

IV. Document Availability

17. In addition to publishing the full text of this document in the Federal Register, the 

Commission provides all interested persons an opportunity to view and/or print the 

contents of this document via the Internet through the Commission’s Home Page 

(http://www.ferc.gov) and in the Commission’s Public Reference Room during normal 

business hours (8:30 a.m. to 5:00 p.m. Eastern time) at 888 First Street, NE, Room 2A, 

Washington, DC 20426. 

18. From the Commission’s Home Page on the Internet, this information is available 

in the Commission’s document management system, eLibrary. The full text of this 

document is available on eLibrary in PDF and Microsoft Word format for viewing, 

printing, and/or downloading. To access this document in eLibrary, type the docket 

number (excluding the last three digits) in the docket number field. 

19. User assistance is available for eLibrary and the Commission’s website during 

normal business hours. For assistance, please contact the Commission’s Online Support 

at 1-866-208-3676 (toll free) or (202) 502-6652 (e-mail at 
Docket No. RM11-4-000 - 13 - 

FERCOnlineSupport@ferc.gov or the Public Reference Room at (202) 502-8371, TTY 

(202) 502-8659 (e-mail at public.referenceroom@ferc.gov). 

By direction of the Commission. 

Nathaniel J. Davis, Sr., 

Deputy Secretary.