Notice2025-11376
Commission Information Collection Activities (FERC Form Nos. 1, 1-F, and 3-Q); Comment Request; Extensions
Primary source
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Published
June 20, 2025
Issuing agencies
Energy DepartmentFederal Energy Regulatory Commission
Abstract
In compliance with the requirements of the Paperwork Reduction Act of 1995 (PRA), the Federal Energy Regulatory Commission (Commission or FERC) is soliciting public comment on the currently approved information collections, FERC Form Nos. 1 (Annual Report of Major Electric Utilities, Licensees, and Others), 1-F (Annual Report for Nonmajor Public Utilities and Licensees), and 3-Q (Quarterly Financial Report of Electric Utilities, Licensees, and Natural Gas Companies). The Commission published a 60-day notice in the Federal Register on February 7, 2025. Twelve parties filed comments.
Full Text
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<title>Federal Register, Volume 90 Issue 117 (Friday, June 20, 2025)</title>
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[Federal Register Volume 90, Number 117 (Friday, June 20, 2025)]
[Notices]
[Pages 26280-26284]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-11376]
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
[Docket No. IC25-7-000]
Commission Information Collection Activities (FERC Form Nos. 1,
1-F, and 3-Q); Comment Request; Extensions
AGENCY: Federal Energy Regulatory Commission.
ACTION: Notice of information collection and request for comments.
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SUMMARY: In compliance with the requirements of the Paperwork Reduction
Act of 1995 (PRA), the Federal Energy Regulatory Commission (Commission
or FERC) is soliciting public comment on the currently approved
information collections, FERC Form Nos. 1 (Annual Report of Major
Electric Utilities, Licensees, and Others), 1-F (Annual Report for
Nonmajor Public Utilities and Licensees), and 3-Q (Quarterly Financial
Report of Electric Utilities, Licensees, and Natural Gas Companies).
The Commission published a 60-day notice in the Federal Register on
February 7, 2025. Twelve parties filed comments.
DATES: Comments on the collections of information are due July 21,
2025.
ADDRESSES: Send written comments on FERC Form Nos. 1, 1-F, and 3-Q to
OMB through:
<bullet> FERC Information Collection Form 1 <a href="https://www.reginfo.gov/public/do/PRA/icrPublicCommentRequest?ref_nbr=202504-1902-003">https://www.reginfo.gov/public/do/PRA/icrPublicCommentRequest?ref_nbr=202504-1902-003</a>
<bullet> FERC Information Collection Form 1-F <a href="https://www.reginfo.gov/public/do/PRA/icrPublicCommentRequest?ref_nbr=202504-1902-004">https://www.reginfo.gov/public/do/PRA/icrPublicCommentRequest?ref_nbr=202504-1902-004</a>
<bullet> FERC Information Collection Form 3-Q <a href="https://www.reginfo.gov/public/do/PRA/icrPublicCommentRequest?ref_nbr=202504-1902-005">https://www.reginfo.gov/public/do/PRA/icrPublicCommentRequest?ref_nbr=202504-1902-005</a>
You can also visit <a href="https://www.reginfo.gov/public/do/PRAMain">https://www.reginfo.gov/public/do/PRAMain</a> and
use the drop-down under ``Currently under Review'' to select the
``Federal Energy Regulatory Commission'' where you can see the open
opportunities to provide comments. Comments should be sent within 30
days of publication of this notice.
Please submit a copy of your comments to the Commission via email
to <a href="/cdn-cgi/l/email-protection#abefcadfcae8c7cecad9cac5c8ceebedeef9e885ccc4dd"><span class="__cf_email__" data-cfemail="c387a2b7a280afa6a2b1a2ada0a68385869180eda4acb5">[email protected]</span></a>. You must specify the Docket No. (IC25-7-000)
and the FERC Information Collection number (FERC Form Nos. 1, 1-F, and
3-Q) in your email. If you are unable to file electronically, comments
may be filed by USPS mail or by hand (including courier) delivery:
<bullet> Mail via U.S. Postal Service Only: Federal Energy
Regulatory Commission, Secretary of the Commission, 888 First Street
NE, Washington, DC 20426.
<bullet> All other delivery methods: Federal Energy Regulatory
Commission, Secretary of the Commission, 12225 Wilkins Avenue,
Rockville, MD 20852.
Docket: To view comments and issuances in this docket, please visit
<a href="https://elibrary.ferc.gov/eLibrary/search">https://elibrary.ferc.gov/eLibrary/search</a>. Once there, you can also
sign-up for automatic notification of activity in this docket.
FOR FURTHER INFORMATION CONTACT: Kayla Williams may be reached by email
at <a href="/cdn-cgi/l/email-protection#5c183d283d1f30393d2e3d323f391c1a190e1f723b332a"><span class="__cf_email__" data-cfemail="8cc8edf8edcfe0e9edfeede2efe9cccac9decfa2ebe3fa">[email protected]</span></a>, and telephone at (202) 502-6468.
SUPPLEMENTARY INFORMATION:
Type of Request: Three-year extensions of FERC Form Nos. 1, 1-F,
and 3-Q, with no changes to the current reporting requirements.
FERC Form No. 1, Annual Report of Major Electric Utilities, Licensees,
and Others
OMB Control Nos. and Titles: 1902-0021 (FERC Form No. 1, Annual
Report of Major Electric Utilities, Licensees, and Others).
Abstract: FERC Form No. 1 is a comprehensive financial and
operating report submitted annually for electric rate regulation,
market oversight analysis, and financial audits by Major electric
utilities, licensees, and others. A Major electric utility, licensee,
or other reporter is defined as having in each of the last three
consecutive calendar years, sales or transmission services that exceed
one of the following: (1) one million megawatt-hours of total sales;
(2) 100 megawatt-hours of sales for resale; (3) 500 megawatt-hours of
power exchanges delivered; or (4) 500 megawatt-hours of wheeling for
others (deliveries plus losses).\1\
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\1\ As detailed in 18 CFR 101 (Uniform System of Accounts
Prescribed for Public Utilities and Licensees Subject to the
Provision of the Federal Power Act, General Instructions) and 18 CFR
141.1.
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FERC Form No. 1 is designed to collect financial and operational
information and is made available to the public. FERC Form No. 1
includes a basic set of financial statements:
<bullet> Comparative Balance Sheet,
<bullet> Statement of Income,
<bullet> Statement of Retained Earnings,
<bullet> Statement of Cash Flows,
<bullet> Statement of Accumulated Comprehensive Income,
Comprehensive Income, and Hedging Activities, and
<bullet> Notes to Financial Statements.
Supporting schedules contain:
<bullet> Supplementary information and outlines of corporate
structure and governance,
<bullet> Information on formula rates, and
<bullet> Description of important changes during the year.
Other schedules provide:
<bullet> Information on revenues and the related quantities of
electric sales and electricity transmitted,
<bullet> Account balances for all electric operation and
maintenance expenses,
<bullet> Selected plant cost data, and
<bullet> Other statistical information.
Type of Respondent: Major electric utilities.
Estimate of Annual Burden: \2\ The Commission estimates the annual
[[Page 26281]]
burden and cost \3\ for FERC Form No. 1 as follows:
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\2\ Burden is defined as the total time, effort, or financial
resources expended by persons to generate, maintain, retain,
disclose, or provide information to or for a Federal agency. For
further explanation of what is included in the information
collection burden, refer to Title 5 Code of Federal Regulations
1320.3. The burden hours and costs are rounded for ease of
presentation.
\3\ The cost is based on FERC's 2025 Commission-wide average
salary cost (salary plus benefits) of $103.00/hour. The Commission
staff believes the FERC FTE (full-time equivalent) average cost for
wages plus benefits is representative of the corresponding cost for
the industry respondents.
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Average Average annual burden Total average annual Cost per
Requirements Number of annual number Total number (hrs.) & cost per burden (hrs.) & total respondent
respondents of responses of responses response ($) annual cost ($) ($)
(1) (2) (1) * (2) = 4....................... (3) * (4) = (5)........ (5) / (1)
(3)
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Form 1............................... 216 1 216 1,168; $120,304......... 252,288; $25,985,664... $120,304
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Total............................ .............. .............. .............. ........................ 252,288; $25,985,664... 120,304
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FERC Form No. 1-F, Annual Report for Nonmajor Public Utilities and
Licensees
OMB Control Nos. and Titles: 1902-0029 (FERC Form No. 1-F, Annual
Report for Nonmajor Public Utilities and Licensees).
Abstract: FERC Form No. 1-F is a financial and operating report
submitted annually for electric rate regulation, market oversight
analysis, and financial audits by Nonmajor electric utilities and
licensees. Nonmajor is defined as utilities and licensees that are not
classified as Major, and having total sales in each of the last three
consecutive years of 10,000 megawatt-hours or more.\4\
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\4\ See 18 CFR part 101 (Uniform System of Accounts Prescribed
For Public Utilities And Licensees Subject To The Provisions Of The
Federal Power Act).
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FERC Form No. 1-F is designed to collect financial and operational
information and is made available to the public. FERC Form No. 1-F
includes a basic set of financial statements:
<bullet> Comparative Balance Sheet,
<bullet> Statement of Retained Earnings,
<bullet> Statement of Cash Flows,
<bullet> Statement of Accumulated Other Comprehensive Income and
Hedging Activities, and
<bullet> Notes to Financial Statements.
Supporting schedules contain:
<bullet> Supplementary information and include revenues and the
related quantities of electric sales and electricity transmitted,
<bullet> Account balances for all electric operation and
maintenance expenses,
<bullet> Selected plant cost data, and
<bullet> Other statistical information.
Type of Respondent: Nonmajor electric utilities.
Estimate of Annual Burden: The estimated annual burden and cost
follow. (The estimated hourly cost used for FERC Form No. 1-F is $103/
hour (for wages plus benefits) and is described above, under FERC Form
No. 1.) The burden hours and costs are rounded for ease of
presentation.
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Average Average annual burden Total average annual Cost per
Requirements Number of annual number Total number (hrs.) & cost per burden (hrs.) & total respondent
respondents of responses of responses response ($) annual cost ($) ($)
(1) (2) (1) * (2) = 4....................... (3) * (4) = (5)........ (5) / (1)
(3)
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Form 1-F............................. 2 1 2 122; $12,566............ 244; $25,132........... $12,566
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Total............................ .............. .............. .............. 244; $25,132............ 12,566................. ..............
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FERC Form No. 3-Q, Quarterly Financial Report of Electric Utilities,
Licensees, and Natural Gas Companies
OMB Control Nos. and Titles: 1902-0205 (FERC Form No. 3-Q,
Quarterly Financial Report of Electric Utilities, Licensees, and
Natural Gas Companies).
Abstract: FERC Form No. 3-Q is a quarterly financial and operating
report for rate regulation, market oversight analysis, and financial
audits which supplements (a) FERC Form Nos. 1 and 1-F, for the electric
industry, or (b) FERC Form No. 2 (Annual Report for Major Natural Gas
Companies; OMB Control No. 1902-0028) and FERC Form No. 2-A (Annual
Report for Nonmajor Natural Gas Companies; OMB Control No. 1902-0030),
for the natural gas industry. FERC Form No. 3-Q is submitted for all
Major and Nonmajor electric utilities, licensees, and natural gas
companies.\5\
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\5\ 18 CFR 260.1(b) states that for natural gas companies as
defined by the Natural Gas Act, Major pertains to a company whose
combined gas transported or stored for a fee exceed 50 million Dth
in each of the three previous calendar years. 18 CFR 260.2(b) states
that for natural gas companies as defined by the Natural Gas Act,
Non-Major pertains to a company not meeting the filing threshold for
FERC Form No. 2, but having total gas sales or volume transactions
exceeding 200,000 Dth in each of the three previous calendar years.
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FERC Form No. 3-Q includes a basic set of financial statements:
<bullet> Comparative Balance Sheet,
<bullet> Statement of Income and Statement of Retained Earnings,
<bullet> Statement of Cash Flows,
<bullet> Statement of Accumulated Comprehensive Income,
Comprehensive Income and Hedging Activities, and
<bullet> Supporting schedules containing supplementary information.
Electric respondents report:
<bullet> Revenues and the related quantities of electric sales and
electricity transmitted,
<bullet> Account balances for all electric operation and
maintenance expenses,
<bullet> Selected plant cost data, and
<bullet> Other statistical information.
Natural gas respondents report:
<bullet> Monthly and quarterly quantities of gas transported and
associated revenues,
<bullet> Storage, terminalling, and processing services,
<bullet> Natural gas customer accounts and details of service, and
<bullet> Operational expenses, depreciation, depletion, and
amortization of gas plant.
Type of Respondent: Major and nonmajor electric utilities,
licensees, and major and non-major natural gas companies.
Estimate of Annual Burden: The estimated annual burden and cost (as
rounded) follow. (The estimated hourly cost used for FERC Form No. 3-Q
is $103/hour (for wages plus benefits) and is described above, under
FERC Form No. 1.) The burden hours and costs are
[[Page 26282]]
rounded for ease of presentation. The quarterly filings are generally a
subset of the annual filings.
Burden Table--Form 3-Q--Electric and Gas
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Average Average annual burden Total average annual Cost per
Requirements Number of annual number Total number (hrs.) & cost per burden (hrs.) & total respondent
respondents of responses of responses response ($) annual cost ($) ($)
(1) (2) (1) * (2) = (4)..................... (3) * (4) = (5)........ (5) / (1)
(3)
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Form 3-Q (Electric).................. 218 3 654 168; $17,304............ 109,872; $11,316,816... $51,912
Form 3-Q (Gas)....................... 148 3 444 168; $17,304............ 74,592; $7,682,976..... 51,912
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Total............................ .............. .............. .............. ........................ 184,464; $18,999,792... 51,912
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For FERC Form No. 3-Q (electric and natural gas), the total average
annual burden hours is 184,464, and the total annual cost is
$18,999,792.
60-Day Notice Comments
The Commission published a 60-day Notice \6\ in the Federal
Register on February 7, 2025, providing the public with an opportunity
to comment on the information collections. In the public notice, the
Commission noted that it would be requesting a three-year extension of
the public reporting burden with no change to the existing requirements
concerning the collection of data. The Bureau of Economic Analysis
(BEA), Energy and Policy Institute (EPI), Edison Electric Institute
(EEI), and nine electric utility companies \7\ filed comments.\8\
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\6\ 90 FR 9151 (February 7, 2025).
\7\ The nine electric utilities companies are: American Electric
Power Service Corporation (AEP); Duke Energy Corporation (Duke
Energy); Entergy Services, LLC (Entergy); Exelon Corporation
(Exelon); Evergy, Inc. (Evergy); FirstEnergy Service Company
(FirstEnergy); Portland General Electric Company (PGE); PPL Services
Corporation (PPL); and Southern California Edison Company (SCE)
(collectively, Electric Utility Companies).
\8\ The submittals are posted at <a href="https://elibrary.ferc.gov">https://elibrary.ferc.gov</a> under
Docket No. IC25-07-000.
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Comments Regarding the Necessity, Quality, Utility, and Clarity of the
Information Collected, as Well as Ways To Minimize the Burden on
Respondents
BEA explains that it uses data from FERC Form Nos. 1 and 1-F
indirectly in estimating the United States Census Bureau's Construction
Value Put-In Place (VPIP) for electric utilities. BEA further explains
that census VPIP serves as a major source data input to the national
income and product account (NIPA) structures investment estimates. BEA
states that while it uses the information indirectly through the VPIP
program, it is considered an indispensable data source to the NIPA
estimates.
BEA states that it relies heavily on the data collected in the FERC
Form No. 3-Q for the accurate calculation of many key components of
both the industry and national economic accounts. BEA argues that data
collected in FERC Form No. 3-Q are indispensable to estimates of gross
output, intermediate input, and value added in the U.S. economy for the
utilities industry (NAICS 22). BEA explains that it uses data from the
Energy Information Administration's (EIA) Form 861M for electricity and
EIA's natural gas monthly programs as source data for the utilities
industry, and that these programs integrate utility and natural gas
company financial and operational information from FERC Form No. 3-Q.
BEA further explains that it also uses FERC tabulations indirectly to
estimate the Census Bureau's construction VPIP for electric, gas, and
pipeline utilities. Census' VPIP estimates serve as a major source data
input to the national income and product account's NIPA fixed
investment in structures estimates. BEA further explains that its fixed
asset accounts (FAA) estimates of private fixed investment in
structures by the utilities industry rely upon selected FERC data sets
published by the EIA.
EEI, AEP, Duke Energy, Entergy, Exelon, FirstEnergy, PGE, and PPL
state they are supportive of the Commission's overall objective to
achieve vigilant oversight of reporting entities. They believe that the
Commission meets this objective through the data presently collected in
the annual FERC Form No. 1. They note that FERC Form No. 1 is used,
among other things, by the Commission in calculating rates for
jurisdictional customers, by state commissions in calculating retail
rates, and by various other parties in making investment decisions.
EEI and the Electric Utility Companies filed comments that propose
eliminating FERC Form No. 3-Q. They claim that FERC Form No. 3-Q has
little to no value to the Commission's objective to achieve vigilant
oversight of reporting, argue that FERC Form No. 3-Q does not lend
itself to identification of emerging trends or the economic effects of
significant transactions and events, and assert that FERC Form No. 3-Q
has no bearing on formula rate determinations.
EEI, AEP, Duke Energy, Exelon, PGE, and PPL argue that it is
unclear exactly how and to what extent FERC uses the 3-Q quarterly data
in its oversight capacity. EEI states that its members have never been
contacted about a FERC Form No. 3-Q filing. Similarly, of the Electric
Utility Companies filing comments in this proceeding, only Duke Energy
and AEP stated that they received requests about the information
reported in their FERC Form No. 3-Qs in recent years. In addition,
FirstEnergy argues that it could not identify any reference in an audit
report or FERC enforcement action to FERC Form No. 3-Q.
EEI and Entergy comment that President Trump's Executive Order,
Unleashing Prosperity Through Deregulation, states it is the ``policy
of the executive branch to be prudent and financially responsible in
the expenditure of funds, from both public and private sources, and to
alleviate unnecessary regulatory burdens placed on the American
people.'' \9\ EEI argues that the clear spirit of the Executive Order
is for federal agencies to seek opportunities to reduce or eliminate
regulations wherever feasible. As a result, EEI explains that is
requesting that the Commission strongly consider what EEI sees as the
limited value that FERC Form No. 3-Q has in accomplishing the
Commission's oversight mission.
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\9\ Exec. Order No. 14,154, 90 FR 8353 (Jan. 20, 2025).
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AEP, Duke Energy, PGE, and PPL argue that Order No. 646's \10\ goal
to identify and evaluate emerging trends, business conditions, and
financial issues, and to identify the economic effects of significant
transactions and
[[Page 26283]]
events cannot be accomplished by FERC Form No. 3-Q. They assert that
electric utilities are subject to large seasonal variations, and given
that FERC Form No. 3-Q covers only three months of data, it provides an
incomplete glimpse into a company's expected annual results. They argue
that the administrative burden associated with preparing and filing
FERC Form No. 3-Q unnecessarily increases costs to customers.
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\10\ See Quarterly Financial Reports and Revisions to the Annual
Reports, Order No. 646, 106 FERC ] 61,113, at PP 11, 16 and 35
(2004).
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EEI, AEP, Duke Energy, and FirstEnergy state they, or in the case
of EEI, its members, file large quantities of financial, operational,
facility, and other information with the Commission and other federal
and state agencies. They assert that these filings give a detailed
picture of company finances and operations. They note that often FERC
Form No. 3-Q filings are due in short and overlapping time frames and
while the companies are closing their accounting books and preparing
financial reports for other agencies.
EEI, AEP, PGE, and PPL state that the Commission has commented in
prior Notice of Information Collections that FERC Form No. 3-Q is used
to validate the debt and equity information of filings under Part 34 of
the Commission's regulations when the most recent 12-month filing
occurred more than four months prior to the application under Part 34.
However, they argue that this use of FERC Form No. 3-Q does not justify
requiring all jurisdictional utilities to file FERC Form No. 3-Q each
quarter. Instead, they suggest that the Commission consider amending
the Part 34 filing requirements so that the relevant information is
only provided when a Part 34 filing is made. Alternatively, they
suggest that Commission staff could use data requests to obtain
information needed to validate debt and equity balances.
While their preference is to eliminate FERC Form No. 3-Q entirely,
AEP, Duke Energy, Exelon, PGE, and PPL propose two alternative
approaches for the Commission to consider. The first suggestion is to
require the filing of a single mid-year FERC Form No. 3-Q filed for the
six months ended June 30 of each respective year. They argue that this
approach would be a reasonable compromise that could provide FERC with
the insight needed for oversight and transparency if it deems an
interim report is necessary, but would also provide significant and
immediate relief to respondents from the tangible and measurable burden
of preparing multiple quarterly filings. PPL and AEP argue that
reducing the reporting requirements of FERC Form No. 3-Q will reduce
the burden and costs ultimately passed to customers.
The second alternative they propose is to limit the quarterly
report to the basic set of financial statements discussed in Order No.
646: the Comparative Balance Sheet, Statement of Income, Statement of
Retained Earnings, Statement of Cash Flows, Statement of Other
Comprehensive Income, and accompanying Notes to the Financial
Statements. PGE states that the creation of the basic financial
statements is not overly burdensome, and while the development of the
notes to the financial statements requires more extensive effort, the
overall burden would be greatly reduced by not having to prepare the
supplemental schedules. Duke Energy argues that if there is value in
identifying trends and reviewing debt and equity balances, the basic
set of financial statements would provide sufficient information to do
so. FirstEnergy, SCE, and Evergy also generally support limiting the
filing to the basic set of financial statements, although they
recommend excluding the notes to the financial statements, and Evergy
further recommends excluding the Statement of Cash Flows and Statement
of Other Comprehensive Income, which, it argues, are burdensome to
prepare and not used in ratemaking.
FirstEnergy recommends that the Commission perform a review of each
FERC Form No. 3-Q schedule and request comments from stakeholders on
the utility of data provided to determine the necessity and usefulness
of information and specific pages currently required in FERC Form No.
3-Q. Evergy states that if the Commission is utilizing FERC Form No. 3-
Q supplemental page data, the Commission should evaluate whether any of
these pages can be eliminated based on relevance and applicability of
the pages.
Entergy suggests that the Commission could collect the information
in FERC Form No. 3-Q semi-annually, and supplement the information with
filings made at the SEC or with direct data requests. EEI and Exelon
argue that Commission staff can utilize reports filed with the SEC.
They comment that the quarterly report on the SEC Form No. 10-Q
includes a full set of financial statements along with Management's
Discussion and Analysis, as well as other information. Additionally,
EEI and Exelon state that the SEC Form No. 8-K is required to disclose
material events typically within four days of the event.
EPI states that it is interested in the Commission requiring more
disclosure of expenses charged to certain accounts within the USofA,
including an itemized list of expenses in Account 909, Informational
and Instructional Expenses; Account 913, Advertising Expenses; Account
923, Outside Services Employed; Account 928, Regulatory Commission
Expenses; Account 930.1, General Advertising Expenses; 930.2,
Miscellaneous General Expenses; Account 426.1, Donations; Account
426.4; Expenditures for Certain Civic, Political and Related
Activities; and Account 426.5, Other Deductions. EPI also recommends
revisions to clarify instructions and include additional disclosures on
Page 350, Regulatory Commission Expenses, of FERC Form No. 1. EPI
recommends additional disclosures and itemization for transactions with
associated (affiliated) companies and recommends modifications to
enhance reporting of these transactions on page 429, Transactions with
Associated (Affiliated) Companies, of FERC Form No. 1. EPI explains
that many parties, especially individual ratepayers, lack the
resources, access to information, or both that are necessary to
challenge the categorization of a cost. EPI argues that through
itemization of certain USofA accounts that have been prone to abuse,
the Commission can enhance transparency, ensuring just and reasonable
rates.
Evergy requests additional instructions on FERC Form Nos. 1 and 3-
Q, to explicitly state how information should be reported and what type
of details are required for pages 232, Other Regulatory Assets, and
278, Other Regulatory Liabilities. Evergy also states that multiple
pages including pages 320-323 and 324-325 are reported differently
between FERC Form Nos. 1 and 3-Q. Evergy argues that while some FERC
pages contain detail, the detail is not consistent across pages, which
results in inconsistent data collection and reporting across the
industry. Therefore, Evergy requests additional instructions and
clarifications of certain column headings.
FERC Response: The Commission appreciates the comments submitted
regarding the necessity, usefulness and ways to minimize burden
associated with filing of FERC Form Nos. 1, 1-F, and 3-Q. As previously
noted, the Commission uses the information provided on these forms to
develop and monitor cost-based rates, conduct market analysis, and
perform financial audits, thereby fulfilling its responsibility under
the FPA and NGA to ensure that customers pay just and reasonable rates
for energy. Additionally, state commissions and other parties use the
information provided on these forms for rate
[[Page 26284]]
development and evaluation and in making investment decisions. In
particular, as recognized by EEI and the Electric Utility Companies,
FERC Form Nos. 1 and 1-F are critical inputs in the development and
updating of formula rates. Regarding FERC Form No. 3-Q, in addition to
using the information provided on this form for oversight analysis and
the timely evaluation of current financial information, FERC Form No.
3-Q is used to validate the debt and equity information included in
filings under Part 34 of the Commission's regulations when the most
recent 12-month filing occurred more than 4 months prior to the
application. The Commission receives approximately 130 such Part 34
filings in each two-year cycle.
Regarding relying on reports filed with the SEC or other federal
and state agencies, as mentioned above, the information included in
these reports is not structured in a manner that would meet the
Commission's needs under the FPA and NGA. For example, the financial
statements filed with the SEC are provided on a consolidated, or parent
company, basis and therefore do not provide information at the level of
granularity required by the Commission to develop and monitor cost-
based rates, conduct market analysis, and perform financial audits.
However, the Commission recognizes that there may be opportunities to
limit the information required by FERC Form No. 3-Q, reducing the
burden on filing parties, while still providing the Commission with the
information required to fulfill its responsibilities. While the
Commission is not considering modifications to the collection or
frequency of collection of FERC Form Nos. 1, 1-F, and 3-Q in this
renewal, it may consider doing so in the future, at which time EEI, the
Electric Utility Companies, BEA, and other interested parties will be
able to submit comments.
With respect to EPI and Evergy's interest in modifying the forms,
the Commission recognizes that certain instructions may benefit from
updated or clarified language. However, as noted above, the Commission
is not considering in this renewal modifications to FERC Form Nos. 1,
1-F, and 3-Q, but may consider doing so in the future, at which time
EPI, Evergy, and other interested parties will be able to submit
comments on this issue.
Comments Regarding the Commission's Burden Estimate
AEP, Duke Energy, Evergy, Entergy, FirstEnergy, PGE, PPL, and SCE
state that, while the time for each respondent to complete FERC Form
No. 3-Q varies significantly, as each respondent has different systems
and processes, they generally support FERC's estimate of approximately
168 hours of annual effort to prepare FERC Form No. 3-Q. They note
that, in addition to the cost of preparing FERC Form No. 3-Q, companies
incur additional costs to maintain a software package to support the
filing requirements including XBRL tagging and/or to utilize a third-
party vendor's software to prepare FERC Form No. 3-Q filings in XBRL.
FirstEnergy states that, with the implementation of XBRL requirements,
both the software costs and labor burden have increased, and it
estimates that each report takes nearly 70 hours per respondent each
quarter to complete, or 210 hours annually. Entergy comments that
because each of its reports are individually prepared by Entergy
Services' accounting employees, there are no economies of scale or
efficiencies to be had in their preparation. Entergy Services estimates
that the yearly hourly expenditure to prepare and file FERC Form No. 3-
Qs is 1,050 hours at a total cost of about $84,000, in addition to the
cost of software licenses and other related costs incurred. SCE
estimates that it takes their staff approximately 900 hours annually
for three quarterly filings. SCE asserts that the required XBRL format
has added additional burden without a clear linkage to any benefit by
users.
FERC Response: The Commission appreciates the comments providing
each company's individual estimate of the total burden, time, and/or
costs associated with the quarterly filings. The Commission
acknowledges that the burden presented is meant to represent an
industry average and that the time for each respondent to complete the
forms varies as each respondent has different employee compensation,
systems, and processes.
30-Day Notice Comments
Comments: Comments are invited on: (1) whether the collections of
information are necessary for the proper performance of the functions
of the Commission, including whether the information will have
practical utility; (2) the accuracy of the agency's estimates of the
burden and cost of the collections of information, including the
validity of the methodology and assumptions used; (3) ways to enhance
the quality, utility, and clarity of the information collections; and
(4) ways to minimize the burden of the collections of information on
those who are to respond, including the use of automated collection
techniques or other forms of information technology.
Dated: June 16, 2025.
Debbie-Anne A. Reese,
Secretary.
[FR Doc. 2025-11376 Filed 6-18-25; 8:45 am]
BILLING CODE 6717-01-P
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