134 FERC ¶ 61,033 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Part 260 

[Docket No. RM07-9-003; Order No. 710-B] 

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

(Issued January 20, 2011) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Final Rule. 

SUMMARY: In this Final Rule, the Federal Energy Regulatory Commission 

(Commission) is revising its financial forms, statements, and reports for natural gas 

companies, contained in FERC Form Nos. 2, 2-A, and 3-Q, to include functionalized fuel 

data on pages 521a through 521c of those forms, and to include on those forms the 

amount of fuel waived, discounted or reduced as part of a negotiated rate agreement. For 

consistency, the Commission also is revising page 520. The revisions are designed to 

enhance the forms’ usefulness by providing greater transparency as to fuel data. 

EFFECTIVE DATE: This rule will become effective [Insert date that is thirty days after 

publication in the FEDERAL REGISTER]. 

FOR FURTHER INFORMATION CONTACT: 

Brian Holmes (Technical Information) 

Office of Enforcement 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

Telephone: (202) 502-6008, e-mail: brian.holmes@ferc.gov. 
Docket No. RM07-9-003 -iiRobert Sheldon (Technical Information) 

Office of Energy Market Regulation 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

Telephone: (202) 502-8672, e-mail: robert.sheldon@ferc.gov

Gary D. Cohen (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

Telephone: (202) 502-8321, e-mail: gary.cohen@ferc.gov

SUPPLEMENTARY INFORMATION: 
134 FERC ¶ 61,033 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Before Commissioners: Jon Wellinghoff, Chairman; 

 Marc Spitzer, Philip D. Moeller, 

 John R. Norris, and Cheryl A. LaFleur. 

Revisions to Forms, Statements, and Reporting 

Requirements for Natural Gas Pipelines 

Docket No. RM07-9-003 

ORDER NO. 710-B 

FINAL RULE 

(Issued January 20, 2011) 

1. The Federal Energy Regulatory Commission (Commission) is revising its financial 

forms, statements, and reports for natural gas companies, contained in FERC Form Nos. 

2, 2-A, and 3-Q, to include functionalized fuel data on pages 521a through 521c of those 

forms, and to include on those forms the amount of fuel waived, discounted or reduced as 

part of a negotiated rate agreement. In addition, the Commission also is revising page 

520 for consistency. 

I. Background

2. In Order No. 710, the Commission revised its financial forms, statements, and 

reports for natural gas companies, contained in FERC Form Nos. 2, 2-A, and 3-Q, to 

make the information reported in these forms more useful by updating them to reflect 

current market and cost information relevant to interstate natural gas pipelines and their 
Docket No. RM07-9-003 -2- 

 

customers.1

 The information provided in these forms included data on fuel use, but did 

not require these data to be functionally disaggregated. 

3. On rehearing, the American Gas Association (AGA) argued that the fuel data 

would be more useful if such data were broken out by different pipeline functions, 

including transportation, storage, gathering, and exploration/production, and should 

include, by function, the amount of fuel waived, discounted or reduced as part of a 

negotiated rate agreement. This argument originally was rejected in Order No. 710-A, 

and Chairman (then Commissioner) Wellinghoff issued a partial dissent arguing that 

AGA’s proposals should have been adopted.2

4. Subsequently, AGA filed a petition for review in the United States Court of 

Appeals for the District of Columbia Circuit arguing that the Commission erred by not 

addressing the concerns raised by Chairman Wellinghoff in his partial dissent to Order 

No. 710-A. The court agreed and remanded the matter back to the Commission for 

further proceedings.3

 

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

Pipelines, Order No. 710, 73 FR 19389 (Apr. 10, 2008), FERC Stats. & Regs. ¶ 31,267 

(2008), order on reh’g and clarification, Order No. 710-A, 123 FERC ¶ 61,278 (2008), 

remanded sub nom. American Gas Ass’n v. FERC, 593 F.3d 14 (D.C. Cir 2010) (D.C. 

Circuit Remand Order). 

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

Pipelines, Order No. 710-A, 123 FERC at 62,708-9. 

3

 593 F.3d at 21. 
Docket No. RM07-9-003 -3- 

5. On June 17, 2010, the Commission issued a notice of proposed rulemaking 

proposing to revise pages 521a, 521b, and page 520, and proposing to add pages 521c 

and 521d to FERC Form Nos. 2, 2-A, and 3-Q to include functionalized fuel data, 

including the amount of fuel waived, discounted or reduced as part of a negotiated rate 

agreement.4

6. In response to the June 2010 NOPR, comments were filed by eight commenters.5

 

Certain of the comments presented proposals that differed from the Commission’s 

proposals in the June 2010 NOPR. To give all interested persons an opportunity to 

comment on these proposals prior to making a final decision, the Commission issued a 

notice allowing reply comments. Reply comments were filed by two commenters.6

 

II. Discussion

A. Overview

7. After consideration of the comments, the Commission will revise pages 521a, 

521b, and page 520 of FERC Form Nos. 2, 2-A, and 3-Q, and will add page 521c, as 

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

Pipelines, Notice of Proposed Rulemaking, 75 FR 35700 (June 23, 2010), FERC Stats. 

& Regs. ¶ 32,659 (June 17, 2010) (June 2010 NOPR). 

5

 These commenters and the abbreviations used to identify them are provided in 

the attached Appendix. 

6

 INGAA and AGA. 
Docket No. RM07-9-003 -4- 

 

proposed in the June 2010 NOPR.7

 We make this determination because we find that the 

additional information to be reported on pages 521a-521c will allow the user to match the 

revenues generated by the sale of excess fuel with the functionalized costs reported on 

page 520 and will allow a user to better determine if there is a cross-subsidy. The revised 

forms will also now allow the user to determine where on the pipeline system fuel costs 

are being incurred and how they are being allocated. This added transparency will ensure 

that the Commission and pipeline customers have information critical to assessing the 

justness and reasonableness of pipeline rates. The collection and public availability of 

this information is consistent with our goal of having sufficient information reported to 

allow the Commission and pipeline customers to assess the impact on pipeline rates of 

changing fuel costs. The Commission also gave consideration to whether the data 

reported on FERC Form Nos. 2, 2-A, and 3-Q discussed herein should be reported on a 

monthly or quarterly basis. We have determined to require that the page 521 fuel use 

information should be reported on a monthly basis in the quarterly reports,8

 as that 

provides greater transparency. 

7

 As proposed pages 521c and 521d were identical, we no longer see a need for a 

separate page 521d. 

8

 The data reported in FERC Form Nos. 2 and 2-A on page 521 represents fourth 

quarter data and is not a total of data for all four quarters. 
Docket No. RM07-9-003 -5- 

8. These revisions to FERC Form Nos. 2, 2-A, and 3-Q do not require the reporting of 

previously unreported new categories of information.9

 Instead, the new requirements 

merely require greater transparency through a disaggregation of existing data categories. 

Moreover, the Commission has determined that the burden on filers of reporting this 

information is small and is justified by the usefulness of the information. 

B. Support for the June 2010 NOPR Proposal

1. Commenters’ Views

9. Of the eight comments filed in response to the June 2010 NOPR, six support the 

Commission’s proposals.10 One of the six comments offers suggestions for additional 

revisions to the forms.11 In addition, one commenter seeks clarification as to the scope of 

the reporting requirements,12 and another, while expressing support for the goals of the 

June 2010 NOPR, offers a counterproposal to accomplish these goals.13

10. APGA urges the Commission to adopt the proposed revisions to FERC Form 

Nos. 2, 2-A, and 3-Q.14 While AGA also supports the June 2010 NOPR proposals and 

 9

 As explained further below, reporting will be prospective in nature and data for 

previous periods need not be corrected and refiled. 

10 AGA, APGA, Associations, IOGA, Kansas Commission and TVA. 

11 AGA. 

12 MidAmerican. 

13 INGAA. 

14 APGA Comments at 1. 
Docket No. RM07-9-003 -6- 

 

urges prompt action on a final rule,15 AGA requests that the Commission require monthly 

reporting of volume throughput data on page 520 and separate reporting of backhaul 

volumes.16 Associations add that the proposed revised reporting requirements would 

provide useful information.17 TVA likewise supports the Commission’s proposal to 

include additional line items in 521a and 521b to account for fuel information 

disaggregated by function.18 IOGA supports the proposed changes in reporting, 

particularly the inclusion of lost and unaccounted-for gas (“LAUF”) used in 

transportation, storage, gathering, and exploration/production in the fuel data required on 

FERC Form Nos. 2, 2-A, and 3-Q as a separate component of fuel, by function.19 Kansas 

Commission supports the changes proposed in the NOPR.20 

11. MidAmerican requests clarification that the reporting of discounted and negotiated 

fuel should only contain fuel volumes related to agreements that contain discounted or 

negotiated fuel.21

15 AGA Comments at 1, 5-6. 

16 Id. at 6-9. 

17 Associations Comments at 3-4. 

18 TVA Comments at 2. 

19 IOGA Comments at 1-2. 

20 Kansas Commission Comments at 1. 

21 MidAmerican Comments at 3-4. 
Docket No. RM07-9-003 -7- 

12. While INGAA expresses support for the Commission’s goal of enhancing FERC 

Form No. 2 fuel use reporting, it asserts that the Commission’s June 2010 NOPR went 

beyond AGA’s original proposal of reporting fuel by function that has been waived, 

discounted, or reduced as part of a negotiated rate agreement. INGAA offers an 

alternative reporting plan that it asserts will meet the Commission’s stated goals.22 

2. Usefulness of Reporting Additional Details on Fuel Use

13. The Commission’s proposal in the June 2010 NOPR would disaggregate fuel use 

data into Discounted, Negotiated and Recourse categories. By contrast, under INGAA’s 

proposal, companies would report aggregated Dths and Total dollars collected by 

function for Gas Used for Compressor Stations, for Gas Used for Other Deliveries and 

Other Operations, Gas Lost and Unaccounted for, Net Excess or (Deficiency), 

Disposition of Excess Gas, and Gas Acquired to meet Deficiency (eliminating the 

reporting of data in columns b, c, d, f, g, and h, as proposed in the June 2010 NOPR). 

14. The Commission’s proposal would require filers to report Dths not collected under 

waived, discounted, and negotiated for Gas Used for Compressor Stations, for Gas Used 

for Other Deliveries and Other Operations, Gas Lost and Unaccounted for, Net Excess or 

(Deficiency), Disposition of Excess Gas, and Gas Acquired to meet Deficiency. Under 

INGAA’s proposal, this reporting requirement (Dths not collected by function under 

waived and negotiated deals) would apply to shipper supplied gas only, including 

 22 INGAA Comments at 1. 
Docket No. RM07-9-003 -8- 

 

Lines 2-7 on pages 521a and 521b. This change would eliminate the reporting of waived, 

negotiated and total fuel for lines 9 through 64 that was proposed in the June 2010 

NOPR. 

15. Six of the seven commenters that addressed this issue contend that the NOPR 

proposal reports an appropriate level of detail on fuel use.23 INGAA was the sole 

commenter arguing against the NOPR proposal in this regard. 

16. INGAA urges that the Commission limit its revisions to FERC Form No. 2 to 

AGA’s proposal in its response24 to the September 2007 NOPR, arguing that the June 

2010 NOPR went further than necessary to accomplish what AGA proposed, and objects 

to the June 2010 NOPR proposal as providing more information than necessary.25 

INGAA demonstrates its point by referring to AGA’s November 13, 2007 comments 

which referenced pages 4, 5, and 6 of Workpaper 2, and Workpaper 10 of the 

Informational Fuel Report filed by Dominion Transmission, Inc., (DTI) in Docket No. 

RP00-632-023 on June 27, 2007, as an example of what should be included on page 

521.26 INGAA argues that neither the Commission nor AGA has made a case that the 

23 MidAmerican Comments do not take a position on this issue. 

24 AGA Comments filed November 13, 2007 at 4-5 to the September 2007 NOPR.

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

Pipeline, Notice of Proposed Rulemaking, 72 FR 54860 (Sept. 27, 2007), FERC Stats. 

& Regs. ¶ 32,623 (2007) (September 2007 NOPR). 

25 INGAA Comments at 3. 

26 Id. at 4. 
Docket No. RM07-9-003 -9- 

 

additional degree of reporting is required to facilitate monitoring for potential crosssubsidies among services.27

17. By contrast, AGA agrees that the level of detail in the information to be reported 

under the NOPR proposal is needed to adequately assess the justness and reasonableness 

of pipeline fuel charges, addresses the D.C. Circuit Remand Order, and the burden of 

producing such information is small and nonetheless justified. 28 

18. APGA also states that the additional reporting requirements proposed in the NOPR 

will better ensure that pipeline customers and the Commission have sufficient 

information to identify unjust and unreasonable rates and services and to support 

potential complaints.29 APGA states that, under the Commission’s current reporting 

requirements, customers and the Commission currently cannot match the revenues 

generated by the sale of excess gas with the reported functionalized fuel costs.30 

Information regarding both fuel costs and excess gas revenues, broken-down and reported 

by function (including gathering, transmission, distribution, storage and 

production/extraction/processing), will allow customers and the Commission to better 

27 Id. at 11. 

28 AGA Comments at 5-6. 

29 APGA Comments at 2. 

30 Id. at 3. 
Docket No. RM07-9-003 -10- 

 

assess how pipeline fuel costs are incurred and allocated.31 Requiring pipelines to 

disaggregate their excess gas revenue information and report it by function will thus 

provide customers and the Commission with information necessary to better determine 

the reasonableness of pipeline fuel rates.32

19. APGA also supports the Commission’s proposal to require pipelines to report the 

amount of fuel by function that has been waived, discounted or reduced in negotiated rate 

agreements.33 It states that, under the Commission’s policy, existing shippers are 

protected from subsidizing pipeline customers who have negotiated rates.34 It adds that 

the Commission’s proposal to require pipelines to report fuel costs and revenues 

associated with each type of rate structure (i.e., negotiated, discounted, or recourse) by 

function will aid customers and the Commission in identifying inappropriate crosssubsidization.35 

20. Associations assert that the revised reporting requirements will improve the 

reporting of fuel data in FERC Form No. 2.36 Associations maintain that pipeline fuel 

revenues can constitute a substantial percentage of a pipeline’s total system revenues, and 

31 Id. 

32 Id.

33 Id. at 3.

34 Id. 

35 Id. 

36 Associations Comments at 3. 
Docket No. RM07-9-003 -11- 

 

therefore, ensuring that shippers are not paying excessive fuel rates or percentages is 

extremely important.37 

21. Associations comment that shippers will benefit from having functionalized fuel 

data reported on FERC Form No. 2 because this will allow shippers: (1) to ensure that 

rates are just and reasonable, as the greater level of detail will allow them to better assess 

whether pipelines are substantially over recovering fuel from their shippers38 and (2) to 

assess whether they are subsidizing other shippers.39 In this regard, Associations state 

that functionalized reporting will show the sources and uses of a pipeline’s fuel by 

service type on FERC Form No. 2. Associations state that functionalized fuel reporting, 

for example, will show a pipeline’s shippers the amount of fuel that storage users 

provided to the pipeline, as well as how much of that fuel the pipeline actually used for 

storage services.40 If storage users in this example provided less fuel than the pipeline 

used for storage services, shippers using other pipeline services might want to take a 

closer look at the pipeline’s fuel to determine whether they are subsidizing the storage 

shippers’ fuel.41 Thus, Associations assert that functionalized fuel data will allow 

37 Id. at 3. 

38 Id. at 4. 

39 Id.

40 Id.

41 Id.
Docket No. RM07-9-003 -12- 

 

shippers to confirm that they are providing the appropriate amount of fuel to the pipeline 

and are not subsidizing other shippers.42

22. Associations also support breaking out fuel volumes and revenues into rate types—

discounted rates, negotiated rates or recourse rates—and maintain that this level of detail 

will provide shippers and the Commission with information that will be useful in 

assessing fuel rates.43 Associations maintain that reporting fuel volumes and revenues by 

rate type will help shippers ensure: (1) the prevention of inappropriate subsidization; (2) 

the accuracy of pipeline fuel trackers; and (3) the compliance of pipelines with the 

Commission’s fuel discounting policies.44 

23. Associations also state that requiring pipelines to report fuel data by rate type 

would prevent subsidization of some shippers by allowing the Commission and shippers 

to distinguish between those fuel discounts that are eligible for a discount adjustment in a 

rate case and those that are not.45 Associations add that, as the new FERC Form No. 2 

will require pipelines to identify discounted fuel volumes and revenues as either 

“discounted,” “negotiated,” or “recourse,” shippers could use these data to distinguish 

between those fuel discounts that are appropriately included as adjustments in a rate case 

42 Id. at 5. 

43 Id.

44 Id.

45 Id.
Docket No. RM07-9-003 -13- 

 

(e.g., backhauls) and those that are not (e.g., discounts that are part of a negotiated rate).46 

Moreover, Associations assert that this detail gives shippers a better indication of what 

appropriate fuel rates should be, allowing the shippers to determine if fuel rate changes 

are warranted.47 

24. Finally, Associations argue that reporting fuel data by rate type could provide an 

added check on fuel tracker calculations and on pipelines’ compliance with fuel 

discounting policies.48

25. IOGA maintains that it is critical to include and break out LAUF, which it asserts, 

has been far in excess of actual fuel use on certain Appalachian pipelines.49 In this 

regard, IOGA posits that requiring interstate pipelines to break out fuel and LAUF by 

function in FERC Form Nos. 2, 2-A, and 3-Q would be helpful to IOGA’s efforts to limit 

fuel and LAUF assessed to shippers and ultimately netted back to Appalachian 

producers.50 Because the Appalachian pipelines are part of integrated energy companies 

engaged in exploration, production, gathering, storage and transportation of natural gas, 

IOGA asserts that it has long been concerned that unmetered gas flow allocable to 

affiliated exploration and production affiliates or farm tap customers of affiliated LDCs 

46 Id. at 5-6. 

47 Id. at 6. 

48 Id.

49 IOGA Comments at 2. 

50 Id. at 2-3. 
Docket No. RM07-9-003 -14- 

 

becomes LAUF charged to other shippers, instead.51 It states that increasing the 

transparency of FERC Form Nos. 2, 2-A, and 3-Q could help alleviate those concerns.52

26. IOGA also argues that requiring the filing of more transparent fuel and LAUF data 

will allow the Commission and interested market participants to better analyze allegedly 

extraordinary fuel and LAUF experienced by certain interstate pipelines.53 For example, 

IOGA notes that one interstate pipeline serving the Appalachian basin recently made a 

filing with the Commission claiming that its actual gathering fuel and LAUF during a 12 

month period was in excess of 11 percent.54 IOGA asserts that pipeline recovery of fuel 

and LAUF should be minimized to the extent possible. If gas is disappearing between the 

wellhead and the interconnection between a pipeline’s gathering and transmission 

facilities, IOGA argues that producers and shippers deserve to know why.55 IOGA 

further argues that, by increasing its ability to compare fuel and LAUF experienced 

among pipelines, the Commission will be better equipped to determine whether a given 

level of fuel and LAUF is unjust and unreasonable and whether the cost should be borne 

by the pipeline rather than by its customers.56

51 Id. at 3. 

52 Id.

53 Id.

54 Id.

55 Id.

56 Id.
Docket No. RM07-9-003 -15- 

 

27. Kansas Commission asserts that the information submitted on the Commission’s 

financial forms is critical to the ability of shippers and other interested parties to assess 

pipeline rates, and as such should be as complete and detailed as practical.57 

28. TVA agrees with the June 2010 NOPR assertion that breaking down fuel costs and 

revenues associated with negotiated, discounted, or recourse rate structures by function 

will provide greater clarity on the justness and reasonableness of rates.58 In addition, 

TVA agrees that reporting the amount of fuel by function that has been waived, 

discounted, or reduced as part of a negotiated rate agreement will allow for the 

determination of whether cross-subsidization is occurring, and thus, is critical to 

assessing the justness and reasonableness of the pipeline’s fuel rates in the absence of 

mandated rate cases.59

29. Further, TVA hopes that the added transparency will encourage support for 

pipelines to develop, and customers to support, incentive fuel initiatives, as tracking 

mechanisms with a true-up process do little to promote capital investment for energy 

efficiency.60 In addition, it states that the proposed changes will add detail and promote 

transparency when considering the unknown impact of cost-recovery resulting from 

57 Kansas Commission Comments at 1. 

58 TVA Comments at 2-3. 

59 Id. at 3. 

60 Id.
Docket No. RM07-9-003 -16- 

 

potential carbon legislation requirements associated with monitoring and/or reporting 

greenhouse gas emissions.61

30. INGAA, by contrast, would have the pipelines aggregate fuel use data by function 

along with the volume of fuel “not collected.”62 INGAA asserts that this approach has 

the benefit of focusing the additional fuel use reporting on the areas that gave rise to 

AGA’s original concerns of fuel waivers and negotiated rate contracts that could present 

cross subsidy concerns.63 

31. Specifically, INGAA suggests the following revisions to page 521a and b: 

(1) Lines 1-7: Total volume and the dollar value of shipper-supplied fuel gas, 

by function, with volumes “not collected” because the otherwise applicable 

fuel rate was waived (column (d)) or because a negotiated fuel rate was less 

than the recourse rate (column (e)), along with the pertinent account(s) 

under the Uniform System of Accounts. 

(2) Lines 8-14: Total volume and dollar value of gas used in compressor 

stations, by function. 

(3) Lines 15-22: Same data for miscellaneous “other deliveries” and “other 

operations.” 

(4) Lines 23-30: Same data for LAUF. 

(5) Lines 31-37: A calculation of the excess or deficiency by function. 

61 Id.

62 INGAA Comments at 2. 

63 Id. at 6. INGAA provides its recommended revisions for a revised page 521a in 

Appendix A to its comments. 
Docket No. RM07-9-003 -17- 

 

(6) Lines 38-51 and 52-65: Disposition of the excess or source of gas acquired 

to meet a deficiency.64

32. INGAA also suggests that the Commission not include a separate reporting 

category for discounted rates because pipelines cannot discount the fuel use component 

of a discounted rate because it is a non-discountable variable cost.65

33. AGA responds that, as recognized in the June 2010 NOPR, the Commission has a 

policy against existing shippers subsidizing the negotiated rate program, and it notes that 

the June 2010 NOPR properly concluded that the information proposed to be required 

could be useful in identifying potential violations of that policy.66 AGA objects to 

INGAA’s counterproposal, arguing that the NOPR proposal would increase the ability of 

the Commission and interested parties to assess whether a pipeline’s existing shippers are 

subsidizing the pipeline’s negotiated rate program, while INGAA’s counterproposal 

would effectively delete much of the information sought in the June 2010 NOPR.67

34. AGA notes that INGAA argued in its comments that reporting fuel use data by 

customer contract would require pipelines to establish mechanisms for allocating fuel use 

among the types of contracts (negotiated, discounted, or recourse).68 AGA believes that 

64 Id. at 7. 

65 Id.

66 AGA Reply Comments at 2. 

67 Id.

68 Id.
Docket No. RM07-9-003 -18- 

it would be appropriate for pipelines to make those allocations transparent through the 

reporting requirements proposed in the NOPR.69 

35. Unless the pipeline itself provides its allocation methods on its financial forms, 

AGA argues that customers cannot adequately assess the costs and revenues associated 

with fuel charges to discounted and negotiated rate customers.70 Commission staff and 

interested parties cannot be expected to estimate or otherwise discern a pipeline’s 

allocation scheme in the absence of information from the pipeline itself. Accordingly, 

AGA urges the Commission to require pipelines to report fuel costs and revenues by rate 

structure (discounted, negotiated, recourse) broken down by function as proposed in the 

June 2010 NOPR.71 Thus, AGA supports the June 2010 NOPR proposal and urges the 

Commission to reject the proposals advanced by INGAA.72

3. Commission Determination

36. In Order No. 710-A, the Commission found that the detail sought by AGA might 

provide additional clarity with respect to fuel costs, but decided not to require the 

reporting of this information based on concerns over the burden associated with 

 69 Id.

70 Id.

71 Id.

72 Id.
Docket No. RM07-9-003 -19- 

 

compliance with such a requirement.73 The Commission also declined to accept AGA’s 

proposal to require natural gas pipelines to report details about the amount of fuel that 

they waived, discounted or reduced as part of a negotiated rate agreement based on 

concerns that this information might not be significant and might not be readily available, 

as many pipelines do not periodically file to adjust fuel rates and may not keep records of 

this type of information.74

37. After consideration of the comments and reply comments to the June 2010 NOPR, 

the Commission finds that the additional information to be reported on pages 521a and 

521b will allow users to match the revenues generated by the sale of excess fuel with the 

functionalized costs reported on page 520 and will allow users to better determine if there 

is a cross-subsidy, which is critical to assessing the justness and reasonableness of the 

pipeline’s fuel rates particularly in the context of pipelines’ negotiated rate program. We 

find that requiring the reporting of fuel costs and revenues by rate structure broken down 

by function will increase the ability of the Commission and interested parties to assess 

whether a pipeline’s existing shippers are subsidizing the pipeline’s negotiated rate 

program. Thus, we find that INGAA’s proposal would effectively delete much of the 

valuable information sought in the June 2010 NOPR. 

73 Revisions to Forms, Statements, and Requirements for Natural Gas Pipelines

Order No. 710-A, 123 FERC ¶ 61,278 at P 10. 

74 Id. P 11. 
Docket No. RM07-9-003 -20- 

38. The revised forms also will now allow the user to better determine where on the 

pipeline system fuel costs are being incurred and how they are being allocated. This 

added transparency, which is supported by the majority of the commenters, will ensure 

that the Commission and pipeline customers have sufficient information to be able to 

assess the justness and reasonableness of pipeline rates. The collection and public 

availability of this information is consistent with our goal of having sufficient 

information to allow the Commission and pipeline customers to assess the impact on 

pipeline rates of changing fuel costs. 

39. By contrast, if we adopted INGAA’s suggestion to limit the revisions to FERC 

Form No. 2 to those originally proposed by AGA, then the benefits of increased 

transparency of rates, particularly within the negotiated rate program, which are 

described in the two preceding paragraphs, would not be fully realized. The 

Commission’s proposal better captures important information about a company’s fuel 

use. The fact that this is not identical to that proposed by AGA to the September 2007 

NOPR in no way refutes the usefulness of these data being reported and made available 

to the Commission and the public. 

40. Moreover, requiring the reporting by function of the amount of fuel waived, 

discounted or reduced as part of a negotiated rate agreement will enable pipeline 

customers to better determine if inappropriate cross-subsidization is occurring. The 

Commission has a policy that existing shippers must not subsidize the negotiated rate 
Docket No. RM07-9-003 -21- 

 

program; this additional information would be useful in identifying potential violations of 

that policy.75 The revised schedules adopted in this Final Rule will functionally 

disaggregate the fuel costs and revenues associated with each type of rate structure (i.e., 

negotiated, discounted, or recourse) to provide users with better information to assess the 

justness and reasonableness of a pipeline’s fuel rates. 

41. In this Final Rule, therefore, the Commission is revising the financial reporting 

forms required to be filed by natural gas companies (FERC Form Nos. 2, 2-A, and 3-Q) 

to include functionalized fuel data on pages 521a, 521b, and 521c of those forms, and to 

include on such forms the amount of fuel waived, discounted or reduced as part of a 

negotiated rate agreement. Specifically, the Commission is revising pages 521a and 521b 

in the following manner: 

(1) expanding line 1 to separately reflect shipper supplied fuel by function (now 

shown on lines 1-7 on page 521a), i.e., production/extraction/processing, 

gathering, transmission, distribution, and storage; 

75 See Alternative to Traditional Cost-of-Service Ratemaking for Natural Gas 

Pipelines; Regulations of Negotiated Transportation Services of Natural Gas Pipeline

(Alternative Rate Policy Statement), 74 FERC ¶ 61,076, at 61,242 (1996), order granting 

clarification, 74 FERC ¶ 61,194 (1996), and NorAm Gas Transmission Company, 

77 FERC ¶ 61,011 (1996). 
Docket No. RM07-9-003 -22- 

 

(2) expanding lines 2, 3, and 4 to separately list the volumes for each of these 

functions (now shown on lines 8-30 on page 521a);76 

(3) expanding the listing of volumes in columns (b), (c), and (d) to include 

discounted, negotiated and recourse rates; 

(4) expanding line 6, net excess or deficiency, to separately list the volumes for 

each of these functions (now shown on lines 31-37 on page 521b); 

(5) expanding the reporting of dollar amounts in columns (f) through (i) to include 

amounts collected under discounted, negotiated and recourse rates; 

(6) requiring the reporting of volumes of gas (in dekatherms) in columns (j) 

through (m) not collected where the request for that gas has been waived or 

reduced under discounted or negotiated rates; and 

(7) directing filers (if the pipeline does not use a particular function) to enter a 

zero for that field. 

42. FERC Form Nos. 2, 2-A, and 3-Q involve estimates and allocations and the 

methods for making these allocations are to be documented in FERC Form Nos. 2, 2-A, 

and 3-Q. Thus, we will add an instruction to page 521a to require that companies 

disclose their fuel use allocation method(s) in a note to these financial forms. 

76 Lines 2-4 previously consisted of: (2) Less gas used in compressors; (3) Less 

gas used for other operational purposes (footnote); and (4) Less gas lost and unaccounted 

for. 
Docket No. RM07-9-003 -23- 

C. Separate Reporting of Forwardhaul and Backhaul Throughput 

Volumes 

1. Comments

43. AGA favors further revisions to the forms to require interstate pipelines to 

separately report forwardhaul and backhaul throughput volumes associated with detailed 

fuel use, LAUF, and fuel collections data reported on the revised FERC Form No. 2.77 

AGA cites a recent case involving the calculation of retention percentages for fuel use 

and LAUF where, it asserts, the Commission determined that additional data were 

required regarding forwardhaul and backhaul deliveries in order to properly determine a 

pipeline’s level of fuel use.78 

44. AGA argues that in Columbia Gulf the Commission stated that it was unable to 

determine whether the throughput figures set forth on page 305 of the pipeline’s FERC 

Form No. 2 filings included or excluded backhaul volumes and that the Commission 

accordingly directed the pipeline to provide “[f]orward haul and backhaul deliveries 

stated separately for the mainline, onshore, and offshore zones for each month” for a 

specified period of time.79 AGA asserts that the Commission recognized in that case that 

accurate forwardhaul and backhaul throughput data are important for the Commission 

 77 AGA Comments at 1, 7-9. 

78 (Citing Columbia Gulf Transmission Co., 132 FERC ¶ 61,009, at P 38 (2010) 

(Columbia Gulf)). 

79 AGA Comments at 8. 
Docket No. RM07-9-003 -24- 

 

and shippers to properly assess fuel use and LAUF, and that the current FERC Form No. 

2 is not adequate to collect the separate forwardhaul and backhaul throughput data 

needed to conduct a proper analysis of fuel use and lost and unaccounted for fuel costs.80

45. AGA maintains that the current rulemaking is the proper proceeding in which to 

consider this revision, even though it was not raised earlier, because the purpose of this 

proceeding is to revise the financial forms for interstate pipelines “to provide, in greater 

detail, the information the Commission needs to carry out its responsibilities under the 

NGA to ensure that rates are just and reasonable, and to provide pipeline customers and 

the public the information they need to assess the justness and reasonableness of pipeline 

rates.”81

46. In its reply comments INGAA disagrees with AGA’s proposal for an additional 

breakout of forwardhaul and backhaul data, arguing that this is neither practical nor 

necessary to achieve the Commission’s FERC Form No. 2 reporting goals.82 In 

INGAA’s view, the fact that this information was deemed important by the Commission 

in Columbia Gulf does not warrant a general requirement that it be reported across the 

industry on an ongoing basis.83 INGAA also notes that “typically no fuel is used for 

80 Id.

81 Id. Revisions to Forms, Statements, and Reporting Requirements for Natural 

Gas Pipelines, citing Order No. 710, FERC Stats. & Regs. ¶ 31,267 at P 1. 

82 INGAA Reply Comments at 2. 

83 Id.
Docket No. RM07-9-003 -25- 

o. 637.86 

 

backhaul volumes, although the Commission requires an allocation of LAUF gas [to] be 

attributed to backhauls.”84 

47. INGAA cautions that if the proposal involves the reporting of fuel retained and fuel 

used on backhaul volumes, this would present practical difficulties with respect to 

backhauls that use no compressor fuel (citing Mississippi River Transmission Corp., 

98 FERC ¶ 61,119 at 61,353 (2002) in this regard). However, INGAA agrees that these 

problems would not be present if the proposal only requires the reporting of forwardhaul 

and backhaul throughput volumes, which is all that is being required in this Final Rule. 

48. INGAA comments that, particularly on a reticulated pipeline, gas flows in each 

direction, depending on demand and storage operations, and there may be no specific or 

designated transportation path for many services, which makes reporting problematic or 

impossible.85 INGAA argues that the current gas system does not provide shippers with 

a set capacity path and that gas flows in each direction, depending on demand and 

storage, and this is why the Commission declined to adopt a generic requirement to 

establish a path priority system in Order N

84 Id. at n.1. 

85 Id. at 3. 

86 Id. at 4. 
Docket No. RM07-9-003 -26- 

49. In addition, INGAA argues that a single transportation service can involve a 

combination of forwardhauls or backhauls; thus, classifying each dekatherm of 

transportation as forwardhaul or backhaul is impossible.87

2. Commission Determination

50. Currently FERC Form No. 2 does not require a distinction between forwardhaul 

and backhaul volumes. Since compressor fuel use is not assessed to backhaul volumes, it 

is inaccurate to include backhaul volumes for throughput. 

51. After consideration of all the arguments on this issue, we find that it would be 

informative and useful for pipelines to separately report their forwardhaul and backhaul 

volumes, because this would allow the Commission and customers to determine whether 

the fuel use being assigned to customers in their bills contain any cross-subsidies, based 

on the inclusion of backhaul volumes in their gas purchases, and thus help ensure that 

rates are just and reasonable. We also find that the benefits arising from this reporting, 

providing the opportunity to track fuel costs and examine cross-subsidies, outweigh the 

burden of reporting such data. 

52. As to INGAA’s argument that it would not be possible, even for the services that 

are pathed, to classify each dekatherm of transportation as either forwardhaul or 

backhaul, we conclude that, for a majority of pipelines, this is not a significant problem. 

Many pipelines offer clearly defined backhaul services that are defined in their tariffs. In 

 87 Id. at 4-5. 
Docket No. RM07-9-003 -27- 

order to offer and, ultimately, provide that service, those pipelines must be able to 

determine the volumes for which the service is provided. However, some pipelines do 

not offer backhaul service, and for these pipelines it is reasonable to expect that backhaul 

volumes may not be able to be tracked. Therefore, the Commission will require reporting 

on this matter depending on the service identified in the tariff. If backhaul service is not 

offered under the tariff, the reporting pipeline may report as if the service it offers is 

entirely forwardhaul. The reporting pipeline must separately identify backhaul volumes 

only if it offers backhaul service in its tariff and provides this service to customers. 

D. Clarification of Whether Additional Details on Fuel Use Only 

Apply in Instances Where Contract Provides for Discounted or 

Negotiated Fuel Rates

1. Comments

53. MidAmerican comments that, to its knowledge, very few discounted and 

negotiated rate agreements include a provision for discounted or negotiated fuel.88 Thus, 

MidAmerican suggests that the Commission clarify that columns (b) and (c) of pages 

521a and 521b and columns (f) and (g) of pages 521c and 521d include only contracts 

with discounted or negotiated fuel rates, and the column headings be revised to read 

“Discounted Fuel Rate” and “Negotiated Fuel Rate.”89

 88 MidAmerican Comments at 3. 

89 Id.
Docket No. RM07-9-003 -28- 

54. MidAmerican further argues that the columns should only contain volumes 

related to agreements with discounted or negotiated fuel, not fuel volumes related to all 

discounted or negotiated agreements, if the purpose of the information is to determine if 

there is a cross subsidy.90

2. Commission Determination

55. In this Final Rule, we are requiring pipelines to report fuel use by function for all 

contracts involving discounted rates, negotiated rates, or recourse rates. We reject 

MidAmerican’s proposal to only require the reporting of fuel costs in contracts where the 

fuel rate is discounted. Under MidAmerican’s proposal, how a contract is structured 

would dictate whether it would be within the scope of the reporting requirements of this 

Final Rule and MidAmerican states that very few discounted and negotiated rate 

agreements include a provision for discounted or negotiated fuel. If this is so, or if future 

contracts are specifically written to make it so, then, under MidAmerican’s proposal, 

many contracts that otherwise would be included in the reporting requirements would not 

be reported. This would have the consequence of diminishing the benefits of enhanced 

transparency that we hope to achieve with this Final Rule and thus we reject 

MidAmerican’s suggestion. 

56. As to MidAmerican’s suggestion that columns (b) and (c) on pages 521a and 521b, 

and columns (f) and (g) on pages 521c and 521d ,should only contain volumes and 

 90 Id.
Docket No. RM07-9-003 -29- 

dollars related to agreements with discounted or negotiated fuel, not fuel volumes or 

dollars related to discounted or negotiated agreements, for the reasons stated, we clarify 

that the amounts reported on pages 521a and 521b in columns (b) and (c) and on page 

521c at columns (f) and (g) reflect shipper supplied gas collected under all discounted or 

negotiated rate agreements.91

E. Monthly v. Quarterly Reporting

57. As mentioned above, FERC Form Nos. 2 and 2-A are annual reports and FERC 

Form 3-Q is a quarterly report. In the June 2010 NOPR, the Commission invited 

comments on whether the data reported on FERC Form Nos. 2, 2-A, and 3-Q should be 

reported on a monthly or quarterly basis (i.e., whether the data should provide separate 

entries for each month, or one entry covering the entire quarter). 

1. Comments

58. AGA favors continuation of the requirement for monthly reporting of fuel use on 

page 521, asserting that important seasonal changes would be obscured by quarterly 

reporting.92 AGA states that the consumption of natural gas in the United States varies 

significantly from one month to the next and, while demand in the industrial sector is 

largely constant, demand in the residential and commercial sector is weather-driven and 

 91 As discussed above, the revised forms we are adopting in this Final Rule do not 

include page 521d. 

92 AGA Comments at 1, 6-7. 
Docket No. RM07-9-003 -30- 

 

has a dramatic seasonal shape with a winter peak.93 AGA also notes that demand in the 

power generation sector is weather sensitive with a summer peak, or in some cases bimodal with both winter and summer peaks.94 AGA states that, because fuel is a variable 

cost and varies with consumption, the amount of fuel costs and revenues experienced by 

interstate pipelines varies by month and the fuel cost and revenue data of interstate 

pipelines does not fit neatly into calendar quarters. Consequently, significant variations 

in fuel data would be masked by fuel reporting only on a quarterly basis.95 

59. AGA further recommends that the fuel information on page 520 be reported on a 

monthly basis.

96 AGA argues that, as the Commission noted in the June 2010 NOPR, the 

fuel information reported on page 520 works in tandem with the information reported on 

page 521 and should allow a shipper to match the functionalized costs on page 520 with 

the functionalized revenues on page 521.97 Having only quarterly information reported 

on page 520 would impede the ability of shippers and the Commission to match costs and 

revenues with the monthly information reported on page 521.98 Therefore, AGA requests 

93 Id. at 6. 

94 Id.

95 Id.

96 Id. at 7, AGA Reply Comments at 5, and AGA Further Reply Comments at 4. 

97 AGA Comments at 7. 

98 Id.
Docket No. RM07-9-003 -31- 

 

that page 520 of the financial reports be revised to add the appropriate columns to reflect 

the reporting of the information on that page on a monthly basis. 99 

60. Associations also argue that providing shippers with access to detailed fuel 

information on a monthly basis, such as functionalized fuel data by rate type on FERC 

Form No. 2, would allow the Commission and shippers to ensure that fuel rates remain 

just and reasonable.100 Associations state that better information would also help the 

Commission and shippers to develop a Natural Gas Act (NGA), section 5 complaint 

proceeding case and, further, would allow parties to confirm fuel tracker reports.101

61. IOGA urges the Commission to retain the requirement for the monthly filing of 

fuel data.102 In IOGA’s experience, fuel and LAUF can vary significantly from month to 

month. Monthly breakdowns in FERC Form Nos. 2, 2-A, and 3-Q could provide 

valuable data that might be masked by aggregated quarterly data.103 IOGA notes that 

pipelines already report transportation and gathering quantities by month, and contends 

that quarterly reporting of fuel and LAUF as proposed by INGAA will foreclose accurate 

99 Id.

100 Associations Comments at 4. 

101 Id.

102 IOGA Comments at 3. 

103 Id.
Docket No. RM07-9-003 -32- 

 

comparative analysis of the relationship between quantities shipped and fuel and LAUF 

on a monthly basis.104

62. IOGA further argues that, as pipelines track throughput, fuel and LAUF data 

monthly for invoicing and other purposes, a requirement to report fuel and LAUF by 

month will not pose additional administrative burden or expense.105

63. Kansas Commission believes that monthly reporting of this information is not 

necessary to provide the information required to effectively evaluate a pipeline’s rates. 

Therefore, Kansas Commission supports INGAA’s suggestion to change the reporting 

requirements to quarterly.106

64. INGAA argues that the reporting requirements should be quarterly.107 INGAA 

comments that, because of weather events and anomalous events in the data, monthly 

data cannot provide an accurate picture or trend.108 INGAA also asserts that pipelines 

with storage assets or significant line pack do not need to dispose of excess fuel, so 

monthly data would not provide an accurate picture of fuel use.109 

104 Id. at 4. 

105 Id.

106 Kansas Commission Comments at 2. 

107 INGAA Comments at 3. 

108 Id.

109 Id. at 11. 
Docket No. RM07-9-003 -33- 

65. In response to INGAA, AGA argues that monthly reporting is preferable, because 

significant variations in fuel data can be masked by fuel reporting on a quarterly basis,110

and quarterly data cannot be disaggregated to obtain monthly information to determine 

what costs or revenues were experienced and by what functions. Only monthly fuel 

information will provide sufficient transparency to allow the Commission and interested 

parties to assess the justness and reasonableness of interstate pipeline fuel charges.111 

AGA also notes that INGAA did not contradict AGA’s observation that weather 

variations and the location of shipper-scheduled volumes on the pipeline from month to 

month have a substantial effect on fuel consumption.112

2. Commission Determination

66. In Order No. 710, the Commission eliminated FERC Form No. 11, the Natural Gas 

Pipeline Company Quarterly Statement of Monthly Data, and shifted the reporting of that 

information to FERC Form Nos. 2 and 3-Q.113 We found that this fuel use information 

provides critical data for detecting trends, determining seasonal variation of fuel use, and 

testing the reasonableness of a pipeline’s fuel costs. Upon further consideration of this 

issue in the instant docket, the Commission finds that monthly reporting provides greater 

 110 AGA Reply Comments at 3. 

111 Id.

112 Id.

113 Revisions to Forms, Statements, and Reporting Requirements for Natural 

Gas Pipelines, Order No. 710, FERC Stats. & Regs. ¶ 31,267 at P 51, Order No. 710-A, 

123 FERC ¶ 61,278 at P 3. 
Docket No. RM07-9-003 -34- 

transparency and provides more representative information about a pipeline’s fuel use 

than quarterly reporting and we will retain this requirement. 

67. Reporting data on a monthly basis provides more accurate accounting of fuel use, 

allowing for a better understanding of pipeline operations, and provides critical detail to 

understand how the pipeline treats its fuel. It would not be unexpected that a pipeline’s 

operating parameters would change from January to March, from April to June, from July 

to September, or from October to December. It would seem counter to the interest of 

increased transparency to reduce the granularity of fuel use data over these periods. The 

monthly data are more representative of the pipeline’s varying operations, enabling the 

transparency required by Order No. 710 to more fully evaluate a pipeline’s fuel use and 

address the concerns of the remand. We conclude that moving to quarterly reporting 

would gloss over natural gas monthly fluctuations, thus distorting what actually occurred 

during the reporting period. Thus, we find that fuel use data should continue to be 

reported on a monthly basis, and not on a quarterly basis. 

68. As to AGA’s proposal to modify page 520 to have respondent companies report 

transmission throughput volumes on a monthly basis, we note that AGA did not provide 

specific reasons supporting the imposition of this requirement. Currently, page 520 only 

requires that transmission volumes be reported on a quarter and year to date basis and we 

see no need to revise this requirement. The reporting of transmission volume throughput 

and the reporting of fuel data are separate matters and the additional information to be 
Docket No. RM07-9-003 -35- 

provided on fuel use does not provide a reason to further break down transportation 

volume throughput. Thus, we find that the quarterly separation of that data is sufficient 

and we will not impose the additional burden on filers to break down these data in the 

absence of demonstrated benefits. 

F. Burden

1. Comments

69. AGA, APGA, and Kansas Commission comment that the burden of producing and 

reporting the additional details on fuel use proposed in the June 2010 NOPR is both small 

and justified.114 By contrast, INGAA finds the June 2010 NOPR proposal unduly 

burdensome.115 

70. Specifically, APGA comments that pipelines should have this information readily 

available because they maintain it for their own purposes.116 Given the potential benefit 

of the information and the relatively low compliance burden on pipelines, APGA 

supports the Commission’s proposal to require pipelines to report the amount of fuel 

waived, discounted or reduced as part of negotiated rate agreements.117 

 114 See, e.g., AGA Comments at 5. 

115 INGAA Comments at 3. 

116 APGA Comments at 3. 

117 Id. at 4. 
Docket No. RM07-9-003 -36- 

 

71. Kansas Commission states that the benefits of the additional reporting outweigh 

any burden that might be placed on the reporting pipelines.118 Given that pipelines 

already functionalize this data for ratemaking purposes, Kansas Commission concludes 

that the burden on pipelines will be minimal.119 

72. Kansas Commission further argues that, in the absence of a mandatory requirement 

for pipelines to periodically restate their base tariff rates, the Commission must rely on 

section 5 of the NGA to police pipeline rates. Under these circumstances, the need for 

functionalized data is heightened.120 Without functionalized data, shippers and other 

interested parties cannot determine whether a pipeline is cross-subsidizing service, and 

the efficacy of the NGA section 5 complaint process is undermined.121 Accordingly, the 

Kansas Commission supports the Commission’s proposal to require functionalized fuel 

data to be included on pages 521a and 521b of FERC Form No. 2.122 Kansas 

Commission also supports the Commission’s proposal to require pipelines to report the 

amount of fuel waived, discounted or reduced as part of a negotiated rate agreement.123

118 Kansas Commission Comments at 1. 

119 Id.

120 Id. at 2. 

121 Id.

122 Id.

123 Id.
Docket No. RM07-9-003 -37- 

73. INGAA maintains that the Commission’s proposal is unnecessarily burdensome.124 

First, INGAA maintains that it is difficult for pipelines to track fuel use by individual 

contract or contract type because pipelines operate on an integrated basis.125 Second, 

INGAA asserts that it would require substantially more information than would be 

provided under this proposal to enable FERC Form No. 2 users to monitor potential 

cross-subsidy concerns.126 Third, INGAA comments that pipelines will have to establish 

a mechanism for allocating fuel use between or among services and contracts.127 

2. Commission Determination

74. The Commission finds that fuel use data on a functionalized basis is needed to 

obtain the transparency necessary to ensure just and reasonable rates. Additionally, we 

find that this reporting requirement is not unnecessarily burdensome. Currently, 

pipelines that file annual fuel use trackers assign fuel to their individual shippers. In this 

Final Rule, the Commission is not imposing any additional reporting requirements that 

change how those pipelines track fuel. Pipeline billings are provided on an integrated 

basis, accounting for sales based on whether the volumes are negotiated, recourse, or 

discounted. Moreover, contrary to INGAA’s assertions, the Commission is not requiring 

pipelines to track fuel by individual contracts, but merely continuing the current practice 

 124 INGAA Comments at 2. 

125 Id. at 2. 

126 Id.

127 Id.
Docket No. RM07-9-003 -38- 

 

of requiring the assignment of fuel based on an allocation of throughput or stated fuel 

rate. The revisions to page 521a through 521c require the same accounting mechanism 

for fuel, enabling parties to better understand how fuel use costs are assigned. 

75. The Commission in the June 2010 NOPR estimated the annual burden to comply 

with the requirements established in Docket No. RM07-9-003 while inviting comments 

on the cost to comply with the proposed requirements. We estimated that the additional 

collection costs would not be overly burdensome.128 The Commission provided its best 

estimate of the time required to complete page 521a through 521d. No party presented 

data contradicting the Commission’s estimate. While INGAA contends that the proposal 

is burdensome, INGAA did not identify any inaccuracies in the Commission’s estimate, 

did not quantify its own estimate of the impact of reporting fuel on a functionalized basis, 

and did not provide any support for its contention that functionalizing fuel would be 

burdensome to the pipelines. In this Final Rule, as discussed above, we are adding a 

requirement to report information on forwardhauls and backhauls and we are revising our 

burden estimate to account for this requirement. The Commission finds that, even with 

this minor additional reporting requirement, the benefits of enhanced transparency 

provided by the additional reporting proposed in the June 2010 NOPR outweigh the 

burden placed on the pipelines. Further, we find that our estimated burden hours (as 

128 June 2010 NOPR, FERC Stats. & Regs. ¶ 32,659 at P 19. 
Docket No. RM07-9-003 -39- 

adjusted) are small and reasonable, and we will continue to require fuel to be reported on 

a functionalized basis. 

G. Implementation Date

1. Comments

76. AGA contends that the new rules should apply to the financial forms that are 

required to be filed beginning in calendar year 2011.129 AGA states that the annual 

financial reports (FERC Form Nos. 2 and 2-A) showing data for calendar year 2010 

would be required to be filed on April 18, 2011. Quarterly financial reports (FERC Form 

No. 3-Q) would be required to be filed 60 days (for major pipelines) or 70 days (for nonmajor pipelines) after the end of the reporting quarter. Thus, the first quarterly financial 

reports in 2011 would be due March 1, 2011 (for majors) and March 10, 2011 (for nonmajors), based on fourth quarter 2010 data.130

77. INGAA comments that changes to FERC Form No. 2 should be prospective.131 It 

states that this approach will provide pipelines adequate time to put data collection 

software in place.132 In addition, it states that implementing the changes prospectively 

will allow time for pipelines to complete any engineering or other operational studies that 

might be needed for pipelines that do not already have accounting systems in place to 

 129 AGA Comments at 5-6. 

130 Id. at 6. 

131 INGAA Comments at 3. 

132 Id. at 12. 
Docket No. RM07-9-003 -40- 

make reasonably accurate estimates.133 INGAA urges that pipelines be permitted to 

collect any additional data the Commission may require in 2011, with reporting to begin 

in 2012.134 

2. Commission Determination

78. We conclude that the information to be reported under this Final Rule may require 

some companies to revise accounting systems to accurately allocate fuel use. While this 

is already reflected in the burden estimate, we nonetheless will revise the implementation 

schedule that we proposed in the June 2010 NOPR to address this concern. Additionally, 

we are not requiring companies subject to this Final Rule to refile the FERC Form Nos. 2, 

2-A, and 3-Q that they have already filed. 

79. Companies subject to these new requirements must begin collecting the more 

detailed data starting on July 1, 2011, and must use that data in completing their FERC 

Form Nos. 2, 2-A, and 3-Q thereafter. The revised data requirements would first be 

reflected in the FERC Form No. 3-Q filings for the period July 1 through September 30, 

2011, which must be filed within 60 days of the end of the reporting quarter for majors 

and within 70 days of the end of the reporting quarter for non-majors (i.e., by November 

 133 Id.

134 INGAA Reply Comments at 2. 
Docket No. RM07-9-003 -41- 

29, 2011 for majors and December 9, 2011 for non-majors) and in the FERC Form Nos. 2 

and 2-A filings for 2011, which must be filed by April 18, 2012.135

80. As noted above,136 page 521 only reports fourth quarter data and not yearly data. 

By contrast, page 520 gives yearly totals. However, while page 520 currently breaks 

down LAUF into several subcategories, the revised page 520 adopted in this Final Rule 

combines these subcategories into a single total that is reported on line 32 of the revised 

page 520. Thus, the FERC Form Nos. 2 and 2-A, filings for 2011, which must be filed 

by April 18, 2012, should report LAUF as a single line item on line 32, and should not 

report the breakdowns of these data for the first six months of the reporting year. 

III. Information Collection Statement

81. The Office of Management and Budget’s (OMB) regulations require approval of 

certain information collection requirements imposed by agency rules.137 Previously, the 

Commission submitted to OMB the information collection requirements arising from 

Order No. 710 and OMB approved those requirements.138 The revisions to FERC Form 

Nos. 2, 2-A, and 3-Q adopted in this Final Rule consist of giving additional details about 

 135 See 18 CFR 260.300(b)(2)(vii), 18 CFR 260.1(b)(2), and 18 CFR 260.2(b)(2). 

136 See n.8, supra. 

137 5 CFR 1320.11. 

138 OMB approved the information collections prescribed in Order No. 710 on 

June 27, 2008 for FERC Form No. 2 (OMB Control No. 1902-0028, ICR# 200804-1902-

005) and FERC Form No. 2-A (OMB Control No. 1902-0030, ICR# 200804-1902-007) 

and on Oct. 8, 2008 for FERC Form No. 3-Q (OMB Control No. 1902-0205, ICR# 

200804-1902-008). 
Docket No. RM07-9-003 -42- 

certain fuel cost data that the Commission already required to be reported in less detail in 

Order No. 710.

82. The Commission is submitting the information collection requirements imposed in 

this Final Rule to OMB for review and approval under section 3507(d) of the Paperwork 

Reduction Act of 1995.139 Comments are solicited on the Commission’s need for this 

information, whether the information will have practical utility, the accuracy of the 

burden estimates, ways to enhance the quality, utility, and clarity of the information to be 

collected, and any suggested methods of minimizing respondent’s burden, including the 

use of automated information techniques. 

83. This Final Rule affects the following existing data collections: 

Title: FERC Form No. 2, “Annual Report for Major Natural Gas Companies”; 

FERC Form No. 2-A, “Annual Report for Nonmajor Natural Gas Companies”; FERC 

Form No. 3-Q, “Quarterly Financial Report of Electric Utilities, Licensees, and Natural 

Gas Companies.” 

Action: Proposed information collection. 

OMB Control Nos. 1902-0028 (FERC Form No. 2); 1902-0030 (FERC Form No. 

2-A); and 1902-0205 (FERC Form No. 3-Q). 

Respondents: Businesses or other for profit. 

Frequency of responses: Annually (FERC Form Nos. 2 and 2-A) and quarterly 

(FERC Form No. 3-Q). 

 139 44 U.S.C. § 3507(d). 
Docket No. RM07-9-003 -43- 

Necessity of the information: The information maintained and collected under the 

requirements of 18 CFR 260.1, 18 CFR 260.2, and 18 CFR 260.300 is essential to the 

Commission’s oversight duties. The data now reported in the forms does not provide 

sufficient information to the Commission and the public to permit an evaluation of the 

filers’ jurisdictional rates. Since the triennial restatement of rates requirement was 

abolished and pipelines are no longer required to submit this information, the need for 

current and relevant data is greater than in the past. The information collection required 

by this Final Rule will increase the forms’ usefulness to both the public and the 

Commission. 

84. Without this information, it is difficult for the Commission and the public to 

perform an assessment of pipeline costs, and thereby help to ensure that rates are just and 

reasonable. The pipelines should already have this information readily available for their 

own use in developing separately stated fuel rates in their tariffs. In any event, we 

believe this additional information will allow the Commission and form users to better 

analyze pipeline fuel costs, an important component in assessing the justness and 

reasonableness of pipelines’ rates. 

Burden Statement: The Commission estimates that on average it will take each 

respondent six additional hours per collection to comply with the proposed 
Docket No. RM07-9-003 -44- 

requirements.140 Most of the additional information required to be reported is already 

compiled and maintained by the pipelines. This proposal will increase the burden hours 

as follows: 

Data Collection 

Form 

Number of 

Respondents 

Change in the 

Number of Hours 

per Respondent 

Filings 

Per Year 

Change in the Total 

Annual Hours for 

this Form 

FERC Form No. 

2 

 84 6 1 504 

FERC Form No. 

2-A 

 44 6 1 264 

FERC Form No. 

3-Q 

 128 6 3 2304 

Totals 3072 

Information Collection Costs: 3072 hours at $120/hour= $368,640. 

85. Given that none of the commenters identified any errors or inaccuracies in the 

estimates we used in the June 2010 NOPR, we will adopt these same estimates in this 

Final Rule, with the exception that we are adjusting our estimate to account for our 

requirement to report on forwardhauls and backhauls. At paragraphs 73-74 above, we 

address and reject INGAA’s contention that certain parts of our proposal would be 

burdensome. 

86 Internal Review: The Commission has reviewed the proposed changes and has 

determined that the changes are necessary. These requirements conform to the 

 140 We revised this number from five hours to six hours to reflect our additional 

requirement to report information on forwardhauls and backhauls. 
Docket No. RM07-9-003 -45- 

Commission’s need for efficient information collection, communication, and 

management within the energy industry. The Commission has assured itself, by means of 

internal review, that there is specific, objective support associated with the information 

requirements. 

87. Interested persons may obtain information on the reporting requirements by 

contacting: Federal Energy Regulatory Commission, 888 First Street, NE, Washington, 

DC 20426 [Attention: Ellen Brown, Office of the Executive Director, phone (202) 502-

8663, fax: (202) 273-0873, email: DataClearance@ferc.gov. For submitting comments 

concerning the collections of information and the associated burden estimates, please 

send your comments to the contact listed above and to the Office of Information and 

Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503 [Attention: Desk Officer for the Federal Energy Regulatory 

Commission, phone: (202) 395-4638, fax: (202) 395-7285]. Due to security concerns, 

comments should be sent electronically to the following e-mail address: 

oira_submission@omb.eop.gov. Please refer to OMB Control Nos. 1902-0028 (FERC 

Form No. 2), 1902-0030 (FERC Form No. 2-A), and 1902-0205 (FERC Form No. 3-Q), 

and the docket number of this Final Rule in your submission. 

IV. Environmental Analysis

88. The Commission is required to prepare an environmental assessment or an 

environmental impact statement for any action that may have a significant adverse effect 
Docket No. RM07-9-003 -46- 

on the human environment.141 However, in 18 CFR 380.4(a)(5), we categorically 

excluded the type of information gathering required in this Final Rule from the 

requirement to prepare an environmental impact statement. Thus, we affirm the finding 

we made in the June 2010 NOPR that this Final Rule does not impose any requirements 

that might have a significant effect on the human environment and find that no 

environmental impact statement concerning this rule is required. 

V. Regulatory Flexibility Act

89. The Regulatory Flexibility Act of 1980 (RFA)142 generally requires a description 

and analysis of final rules that will have significant economic impact on a substantial 

number of small entities.143 However, the RFA does not define “significant” or 

“substantial.” Instead, the RFA leaves it up to an agency to determine the effect of its 

regulations on small entities. Most filing companies regulated by the Commission do not 

fall within the RFA’s definition of small entity. 

 141 Regulations Implementing the National Environmental Policy Act, Order 

No. 486, FERC Stats. & Regs., Regulations Preambles 1986-1990 ¶ 30,783 (1987). 

142 5 U.S.C. §§ 601-612. 

143 The RFA definition of “small entity” refers to the definition provided in the 

Small Business Act, which defines a “small business concern” as a business that is 

independently owned and operated and that is not dominant in its field of operation. 

15 U.S.C. 632. The Small Business Size Standards component of the North American 

Industry Classification System defines a small natural gas pipeline company as one 

whose total annual revenues, including its affiliates, are $6.5 million or less. 13 CFR 

121, 201. 
Docket No. RM07-9-003 -47- 

90. The Commission estimates that there are 84 Major natural gas pipeline companies 

and 44 Non-major companies that will be affected by the Final Rule.144 As we stated in 

the June 2010 NOPR, this Final Rule will apply to all interstate natural gas companies 

subject to the Commission’s jurisdiction. While we do not foresee that this Final Rule 

will have a significant impact on a substantial number of small entities within the 

meaning of the Regulatory Flexibility Act, we will consider granting waivers in 

appropriate circumstances. Moreover, our most recent information shows that only six 

natural gas companies not affiliated with a large natural gas company fall within the 

definition of a small entity and these six entities constitute only 4.7 percent of the 128 

total companies. 

91. Accordingly, the Commission certifies that this Final Rule will not have a 

significant impact on a substantial number of small entities. As a result, no regulatory 

flexibility analysis is required. 

VI. Document Availability

92. 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 FERC's Home Page 

(http://www.ferc.gov) and in FERC's Public Reference Room during normal business 

 144 These numbers are based on the most recent filings. 
Docket No. RM07-9-003 -48- 

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

Washington DC 20426. 

93. From FERC's Home Page on the Internet, this information is available on 

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 of this document in the 

docket number field. 

94. User assistance is available for eLibrary and the FERC’s website during normal 

business hours from FERC Online Support at 202-502-6652 (toll free at 1-866-208-3676) 

or email at ferconlinesupport@ferc.gov, or the Public Reference Room at (202) 502-

8371, TTY (202) 502-8659. E-mail the Public Reference Room at 

public.referenceroom@ferc.gov. 

VII. Effective Date and Congressional Notification

95. These regulations are effective [insert date that is thirty days from publication in 

the FEDERAL REGISTER]. Companies subject to the requirements of this Final Rule 

must comply with the requirements of this rule in accordance with the implementation 

timeline prescribed in this preamble. The Commission has determined (with the 
Docket No. RM07-9-003 -49- 

concurrence of the Administrator of the Office of Information and Regulatory Affairs of 

OMB) that this rule is not a “major rule” as defined in section 351 of the Small Business 

Regulatory Enforcement Fairness Act of 1996. 

List of subjects in 18 CFR Part 260

Natural gas, Reporting and recordkeeping requirements 

By the Commission. 

( S E A L ) 

Nathaniel J. Davis, Sr., 

Deputy Secretary. 
Docket No. RM07-9-003 -50- 

Appendix 

List of Commenters on June 2010 NOPR 

(and abbreviations used to identify them) 

Comments

American Gas Association (AGA) 

American Public Gas Association (APGA) 

Independent Oil & Gas Association of West Virginia (IOGA) 

Interstate Natural Gas Association of America (INGAA) 

Kansas Corporation Commission (Kansas Commission) 

Natural Gas Supply Association, Independent Petroleum Association of America, 

Electric Power Supply Association and Process Gas Consumers Group 

(collectively, Associations) 

Northern Natural Gas Company and Kern Gas Transmission Company 

(collectively, MidAmerican) 

Tennessee Valley Authority (TVA) 

Reply Comments

AGA 

INGAA
Docket No. RM07-9-003 -51- 

Note: The following revised schedules will not be published in the Code of Federal 

Regulations. 

Revised Schedules for FERC Form Nos. 2, 2-A and 3-Q

FERC FORM NO. 2 (REVISED 12-10) Page 520 

Name of Respondent This Report is: 

(1)  An Original 

(2)  A Resubmission 

Date of Report 

(Mo, Da, Yr) 

 / / 

Year/Period of Report 

End of Year/Qtr

Gas Account – Natural Gas 

1. The purpose of this schedule is to account for the quantity of natural gas received and delivered by the respondent. 

2. Natural gas means either natural gas unmixed or any mixture of natural and manufactured gas. 

3. Enter in column (c) the year to date Dth as reported in the schedules indicated for the items of receipts and deliveries. 

4. Enter in column (d) the respective quarter’s Dth as reported in the schedules indicated for the items of receipts and deliveries. 

5. Indicate in a footnote the quantities of bundled sales and transportation gas and specify the line on which such quantities are listed. 

6. If the respondent operates two or more systems which are not interconnected, submit separate pages for this purpose. 

7. Indicate by footnote the quantities of gas not subject to Commission regulation which did not incur FERC regulatory costs by showing: (1) the local distribution volumes another 

jurisdictional pipeline delivered to the local distribution company portion of the reporting pipeline; (2) the quantities that the reporting pipeline transported or sold through its local 

distribution facilities or intrastate facilities and which the reporting pipeline received through gathering facilities or intrastate facilities, but not through any of the interstate portion of the 

reporting pipeline; and (3) the gathering line quantities that were not destined for interstate market or that were not transported through any interstate portion of the reporting pipeline. 

8. Indicate in a footnote the specific gas purchase expense account(s) and related to which the aggregate volumes reported on line No. 3 relate. 

9. Indicate in a footnote: (1) the system supply quantities of gas that are stored by the reporting pipeline, during the reporting year and also reported as sales, transportation and 

compression volumes by the reporting pipeline during the same reporting year; (2) the system supply quantities of gas that are stored by the reporting pipeline during the reporting year 

which the reporting pipeline intends to sell or transport in a future reporting year,; and (3) contract storage quantities. 

10. Also indicate the volumes of pipeline production field sales that are included in both the company's total sales figure and the company's total transportation figure. Add additional 

information as necessary to the footnotes.

Line 

No. 

Item 

(a) 

Ref. Page No. 

of 

 (FERC Form 

Nos. 2/2-A) 

(b) 

Total 

Amount of 

Dth 

Year to Date 

(c) 

Current Three Months 

Ended Amount of Dth 

Quarterly Only 

 (d) 

1 Name of System: 

2 GAS RECEIVED 

3 Gas Purchases (Accounts 800-805) 

4 Gas of Others Received for Gathering (Account 489.1) 303 

5 Gas of Others Received for Transmission (Account 489.2) 305 

6 Gas of Others Received for Distribution (Account 489.3) 301 

7 Gas of Others Received for Contract Storage (Account 489.4) 307 

8 Gas of Others Received for Production/Extraction/Processing (Accounts 490 and 491) 

9 Exchange Gas Received from Others (Account 806) 328 

10 Gas Received as Imbalances (Account 806) 328 

11 Receipts of Respondent’s Gas Transported by Others (Account 858) 332 

12 Other Gas Withdrawn from Storage (Explain) 

13 Gas Received from Shippers as Compressor Station Fuel 

14 Gas Received from Shippers as Lost and Unaccounted for 

15 Other Receipts (Specify) (footnote details) 

16 Total Receipts (Total of lines 3 thru 15) 

17 GAS DELIVERED 

18 Gas Sales (Accounts 480-484) 

19 Deliveries of Gas Gathered for Others (Account 489.1) 303 

20 Deliveries of Gas Transported for Others (Account 489.2) 305 

21 Deliveries of Gas Distributed for Others (Account 489.3) 301 

22 Deliveries of Contract Storage Gas (Account 489.4) 307 

23 Gas of Others Delivered for Production/Extraction/Processing (Accounts 490 and 491) 

24 Exchange Gas Delivered to Others (Account 806) 328 

25 Gas Delivered as Imbalances (Account 806) 328 

26 Deliveries of Gas to Others for Transportation (Account 858) 332 

27 Other Gas Delivered to Storage (Explain) 

28 Gas Used for Compressor Station Fuel 509 

29 Other Deliveries and Gas Used for Other Operations 

30 Total Deliveries (Total of lines 18 thru 29) 

31 GAS LOSSES AND GAS UNACCOUNTED FOR 

32 Gas Losses and Gas Unaccounted For 

33 TOTALS 

34 Total Deliveries, Gas Losses & Unaccounted For (Total of lines 30 and 32) 

FERC FORM NO. 2-A (REVISED 12-10) 
Docket No. RM07-9-003 -52- 

FERC FORM NO. 3-Q (REVISED 12-10) 
Docket No. RM07-9-003 -53- 

Name of Respondent 

This Report is: 

(1)  An Original 

(2)  A Resubmission 

Date of Report 

(Mo, Da, Yr) 

 / / 

Year/Period of Report 

End of Year/Qtr

Shipper Supplied Gas for the Current Quarter 

1. Report monthly (1) shipper supplied gas for the current quarter and gas consumed in pipeline operations, (2) the disposition of any excess, the accounting recognition given to such disposition and the specific 

account(s) charged or credited, and (3) the source of gas used to meet any deficiency, the accounting recognition given to the gas used to meet the deficiency, including the accounting basis of the gas and the specific 

account(s) charged or credited. 

2. On lines 7, 14, 22 and 30 report only the dekatherms of gas provided by shippers under tariff terms and conditions for gathering , production/ extraction/processing, transmission, distribution and storage service and 

the use of that gas for compressor fuel, other operational purposes and lost and unaccounted for. The dekatherms must be broken out by functional categories on Lines 2-6, 9-13, 16-21 and 24-29. The 

dekatherms must be reported in column (d) unless the company has discounted or negotiated rates which should be reported in columns (b) and (c). 

3. On lines 7, 14, 22 and 30 report only the dollar amounts of gas provided by shippers under tariff terms and conditions for gathering, production/ extraction/processing, transmission, distribution and storage service 

and the use of that gas for compressor fuel, other operational purposes and lost and unaccounted for. The dollar amounts must be broken out by functional categories on Lines 2-6, 9-13, 16-21 and 23-29. The 

dollar amounts must be reported in column (h) unless the company has discounted or negotiated rates which should be reported in columns (f) and (g). The accounting should disclose the account(s) debited and 

credited in columns (m) and (n). 

4. Indicate in a footnote the basis for valuing the gas reported in Columns (f), (g) and (h). 

5. Report in columns (j), (k) and (l) the amount of fuel waived, discounted or reduced as part of a negotiated rate agreement. 

6. On lines 32-37 report the dekatherms and dollar value of the excess or deficiency in shipper supplied gas broken out by functional category and whether recourse rate, discounted or negotiated rate. 

7. On lines 39 through 51 report the dekatherms, the dollar amount and the account(s) credited in Column (o) for the dispositions of gas listed in column (a). 

8. On lines 53 through 65 report the dekatherms, the dollar amount and the account(s) debited in Column (n) for the sources of gas reported in column (a). 

9. On lines 66 and 67, report forwardhaul and backhaul volume in Dths of throughput. 

10. Where appropriate, provide a full explanation of the allocation process used in reported numbers in a footnote.

Line 

No. 

Item 

(a) 

Month 1 

Discounted Rate 

Dth 

(b) 

Month 1 

Negotiated Rate 

Dth 

(c) 

Month 1 

Recourse Rate 

Dth 

(d) 

Month 1 

Total 

Dth 

(e) 

1 Shipper Supplied Gas (Lines 13 and 14 , Page 520) 

2 Gathering 

3 Production/Extraction/Processing 

4 Transmission 

5 Distribution 

6 Storage 

7 Total Shipper Supplied Gas 

8 

 Less Gas Used For Compressor Station Fuel (Line 28, 

Page 520) 

9 Gathering 

10 Production/Extraction/Processing 

11 Transmission 

12 Distribution 

13 Storage 

14 Total gas used in compressors

15 

 Less Gas Used For Other Deliveries And Gas Used For 

Other Operations (Line 29, Page 520) (footnote) 

16 Gathering 

17 Production/Extraction/Processing 

18 Transmission 

19 Distribution 

20 Storage 

21 Other Deliveries (specify) (footnote details) 

22 

Total Gas Used For Other Deliveries And Gas Used For 

Other Operations

23 

 Less Gas Lost And Unaccounted For (Line 32, Page 

520) 

24 Gathering 

25 Production/Extraction/Processing 

26 Transmission 

27 Distribution 

28 Storage 

29 Other Losses (specify) (footnote details) 

30 Total Gas Lost And Unaccounted For
Docket No. RM07-9-003 -54- 

FERC FORM NO. 2 (REVISED 12-10) Page 521a 

FERC FORM NO. 2-A (REVISED 12-10) 

FERC FORM NO. 3-Q (REVISED 12-10) 
Docket No. RM07-9-003 -55- 

Name of Respondent This Report is: 

(1)  An Original 

(2)  A Resubmission 

Date of Report 

(Mo, Da, Yr) 

 / / 

Year/Period of Report 

End of Year/Qtr

Shipper Supplied Gas for the Current Quarter (Continued) 

Line 

No. 

Item 

(a)

Month 1 

Discounted 

Rate 

Dth 

(b) 

Month 1 

Negotiated Rate 

Dth 

(c) 

Month 1 

Recourse Rate 

Dth 

(d) 

Month 1 

Total 

Dth 

(e) 

31 Net Excess Or (Deficiency) 

32 Gathering 

33 Production/Extraction 

34 Transmission 

35 Distribution 

36 Storage 

37 Total Net Excess Or (Deficiency)

38 Disposition Of Excess Gas: 

39 Gas sold to others 

40 Gas used to meet imbalances 

41 Gas added to system gas 

42 Gas returned to shippers 

43 Other (list) 

44 

45 

46 

47 

48 

49 

50 

51 Total Disposition Of Excess Gas 

52 Gas Acquired To Meet Deficiency: 

53 System gas 

54 Purchased gas 

55 Other (list) 

56 

57 

58 

59 

60 

61 

62 

63 

64 

65 Total Gas Acquired To Meet Deficiency 

SEPARATION OF FORWARDHAUL AND BACKHAUL THROUGHPUT 

66 Forwardhaul Volume in Dths for the Quarter 

67 Backhaul Volume in Dths for the Quarter 

68 TOTAL 

FERC FORM NO. 2 (REVISED 12-10) Page 521b 

FERC FORM NO. 2-A (REVISED 12-10) 

FERC FORM NO. 3-Q (REVISED 12-10) 
Docket No. RM07-9-003 -56- 

Name of Respondent This Report is: 

(1)  An Original 

(2)  A Resubmission 

Date of Report 

(Mo, Da, Yr) 

 / / 

Year/Period of Report 

End of Year/Qtr

Shipper Supplied Gas for the Current Quarter (continued) 

Amount Collected (Dollars) Volume (in Dth) Not Collected 

Month 1 

Discounted 

Rate 

Amount 

(f) 

Month 1 

Negotiated Rate 

Amount 

(g) 

Month 1 

Recourse Rate 

Amount 

(h) 

Month 1 

Total 

Amount 

(i) 

Month 1 

Waived 

Dth 

(j) 

Month 1 

Discounted 

Dth 

(k) 

Month 1 

Negotiated 

Dth 

(l) 

Month 1 

Total 

Dth 

(m) 

Month 1 

Account(s) 

Debited 

(n) 

Month 1 

Account(s) 

Credited 

(o) 

FERC FORM NO. 2 (REVISED 12-10) Page 521c 

FERC FORM NO. 2-A (REVISED 12-10) 

FERC FORM NO. 3-Q (REVISED 12-10)