Quarterly Transportation and Storage Report for Intrastate Natural Gas and Hinshaw Pipelines Updated: 08/19/2011
The Commission issued Orders 735 and 735-A in 2010, and held a Technical Workshop on the Form 549D on April 12, 2011. Given the large number of questions directed at Staff via the firstname.lastname@example.org mail box and at the workshop, Staff agreed to prepare a list of Frequently Asked Questions (FAQ).
The Commission extended the deadline for the first and second quarters of 2011 to September 9, 2011 and September 30, 2011, respectively. All future filing deadlines are as listed in 18 CFR §284.126(b)(2): 3Q on December 1, 4Q on March 1, 1Q on June 1, 2Q on September 1, etc.
Respondents should not eFile their data until August 15, 2011.
Each intrastate pipeline company providing interstate services pursuant to section 311 of the NGPA or Hinshaw pipeline company that provides interstate services pursuant to a blanket certificate issued under § 284.224 of the Commission's regulations must file a quarterly report with the Commission and the appropriate state regulatory agency.
Yes, your company must still eFile a Form 549D. Only fill out fields 1- 18 and make sure to check "No" in field 5.
When FERC replaced paper tariffs with eTariff, every company, including NGPA and Hinshaw companies, was required to register (https://www.ferc.gov/docs-filing/company-reg.asp). The exact name and identification number from that eTariff registration is what your company should be using for all filings with the Commission, including Fields 1 and 2 of Form 549D.
The company official who signs the form should be a manager who has responsibility for the accuracy of the submission, and is also responsible for the day-to-day maintenance of Commission-jurisdictional data and forms. Our understanding is that at most large corporations, this would not be an executive officer.
No electronic signature is required. Just type in the name of the company official and eFile the document when completed. See 18 CFR §385.205(c) for how FERC views an electronic signature.
The eFiling signatory is the person actually going through the eFiling process on ferc.gov (for instance, a paralegal at the law firm that represents your company). The person actually doing the eFiling is not usually the company official signing the Form 549D.
How to File
The most important document to look at is the Corrected Appendix to Order 735-A (Data Dictionary and Instructions) and filing tips that were made available on the FERC website. The corrected Appendix contains the data dictionary and detailed instructions. The Form 549D web page also contains other files and other information that you will need to prepare the form and eFile it to the Commission.
No. Email and paper filings are not permitted. You must eFile the form at https://ferconline.ferc.gov/LogIn.aspx. From the menu, select Gas › Report /Form- No Docket Number > Form 549D.
Filers can request FERC staff to test their filing by sending the file to the Form549D email box (email@example.com). Please title the email "Request to Test Form 549D filing." Testing is very limited and subject to staff availability. If you want to test your filing, do so very early. Staff will only honor requests more than two weeks before the filing deadline.
If your eFiling is accepted for filing, your data will be parsed and go into our Form 549D database which will be made public on the FERC website within one to two weeks after the filing deadline. A copy of your filing will also be available in FERC's eLibrary within 24 hours after filing. Staff will review your filing and contact you by email or telephone if they find obvious errors or data that looks unusual.
If you made errors of the type that ferc.gov can catch automatically, you will receive an error message. Correct the errors and try to eFile the Form 549D PDF again (contact FERC staff if you have attempted to correct the errors and still cannot file). If your eFiling was successful, you will receive two emails. The first just acknowledges that we have your filing. The second email informs you that your filing has been accepted.
Failure to select the proper filing type when you eFile your Form 549D will result in your filing being rejected and not being in compliance. You will have to eFile your filing again and select the correct filing type.
Select the correct filing type: Gas>>Non-Docketed Report / Form>>Form 549D This allows our system to process your data and place it into the Form 549D database and ultimately place it on the FERC website for public access.
As long as your company continues to have a Statement of Operating Conditions on file with the Commission, it should file a Form 549D for the quarter - just as it was obligated to file the old Form 549 even if it did no jurisdictional business for the reporting year. If your company did not conduct any FERC- jurisdictional business this quarter, just fill in Fields 1 through 18 (the contact information fields) making sure to check "No" in field 5 , and the rest of the form can stay blank.
Fields 1 through 18 must be completed. The eFiling system will not allow any Form 549D that has blank data in fields 1-18. All other fields are not required in order to get past the eFiling system (but of course might be legally required in order for your filing to be complete and accurate).
Receipt and Delivery Points
The term refers to the standard endorsed by the North American Energy Standards Board (NAESB) Wholesale Gas Quadrant (WGQ). If a receipt or delivery point already has an Industry Common Code, then report this code. For points that do not yet have a code, respondents may obtain an Industry Common Code, but the Commission is not requiring respondents do to so (unless NAESB requires the respondent to do so for other reasons).
If respondents do not have or obtain an Industry Common Code, then they should report using the same point identification system that they use for scheduling with shippers. In addition, respondents who do not use Industry Common Codes must publish a list of all the jurisdictional receipt and delivery point codes they use for scheduling, along with the county and state of each point, and the name of the pipeline (if any) that interconnects at each point. This list should be filed as a separate document alongside the respondent's initial report; if the list should change at any time, the respondent should include a document alongside its next quarterly report updating the list. See Order No. 735, 131 FERC ¶ 61,150, at P 59-60. This document should use the same field names and numbers as the Form 549D; eFiling will accept MS Word, text, XLS, or PDF formats.
A point is "primary" if the shipper has unrestricted access to that point, within the terms and conditions of the shipper's contract. If there is more than one primary point, it is completely within the respondents' discretion as to which primary receipt point gets listed first. The only requirement is that respondents be internally consistent (for instance, list points alphabetically, or in the order written on the contract, or in the order of which points received the largest quantity of gas flow that quarter).
Some intrastate pipelines grant shippers equal access to all points, or define a zone in their SOC and grant shippers equal access to all points in that zone. This is especially common for gas received from dedicated wells or gathering lines. In this case, respondents may instead note as the receipt point the common point where the gathered gas is considered to enter the pipeline's transmission system. Respondents who use this method in their reports must develop their list of jurisdictional receipt and delivery points so that a potential new shipper could "decode" the list - that is, use the list to figure out all of the individual points that belong to a certain group.
There are two acceptable ways to report: (1) list all primary points, whether they were used that quarter or not; or (2) list only those primary points used by the shipper in that quarter. Whichever method respondents use, they must use it consistently from quarter to quarter.
Rates and Services
For contracts that provide for multiple services, each under a separate rate schedule, the respondent will only need to fill out fields 19- 25 once. Then, using the "add service" button in the upper-right, the respondent can fill out a separate set of fields 26-53 for each of the services offered under the contract. (XML users can fill in multiple-service contracts automatically through their XML database).
The various rate components to be reported for each individual service will be determined by the respondent's rate schedules as defined in its Statement of Operating Conditions (SOC). For example, some storage operators provide authorized overrun service as a separate rate schedule listed in their SOC; others consider authorized overrun service to be an individual rate component within their firm or interruptible transportation rate schedule. If the SOC lists it as a separate rate schedule, then it must be reported as separate service. If the SOC lists it as a rate component, then the authorized overrun service must be reported as a separate component of a firm or interruptible transaction.
The weighted average rate is simply (1) the sum of all the revenues from a given rate component as defined in the respondent's SOC, divided by (2) the sum of all the billing units (see fields 54–67) recorded for that particular transaction.
Form 549D is meant to collect "transaction" data by contract by rate schedule or service. Since the Commission does not mandate the tariff structure for 311 / Hinshaw companies in the way it does for NGA companies, the "other" field is a catch-all to make sure that no part of a rate gets ignored or left off of the form.
Filers who use XML should eFile only the verified fillable Form 549D PDF file.
We require the fillable Form 549D PDF for several reasons. First, we expect the filer to actually review the information in the fillable PDF to ensure that it has no errors. The fact that a filer has imported the data into the fillable Form 549D PDF provides some assurance that this has been done. We also require this for purposes of non-repudiation. Providing the actual fillable Form 549D PDF ensures that the data file is actually what the filer intended to eFile to the Commission and not the result of a conversion error at FERC.
Converting Old Data
The Commission posted the latest version of Form 549D on ferc.gov on June 23, 2011. If you attempt to use a version of the form that the Commission distributed in January 2011 with Order No. 735A), our eFiling system will reject the file. This is because of a programming error in the earlier file version. If you are using XML, it is best to just populate the form using the corrected version of the XML Schema. If you have already manually typed a large amount of data into an old version of the fillable PDF form, the easiest and safest way may be to reenter the information in the form. However, there is a workaround that should allow you to recover at least 90% of your typed data. We only recommend this for filers who have IT Support staff to assist them.
Step 1 Open the old form in Adobe Pro and export the data to a XML File.
Step 2 Open the above XML file in the Notepad or in any other XML editor and rename the xml element Row3 to Row3a in the <
Respondent> section of the XML file. See below:
If, after completing the submission of a prior quarter's data, you discover that the Form 549D data was in error or otherwise misleading, a resubmission is usually the most effective way to cure the error and get back into compliance.
Form 549D reports should reflect the data on the billing statements to customers. If a pipeline's billing policy for prior period adjustments is to revise the prior bill, then that pipeline should resubmit its Form 549D for that prior quarterly time period. If, however, a pipeline's billing policy for prior period adjustments is to bill for the quarter when the discrepancy is discovered, then that pipeline should submit the adjusted data as part of its upcoming report rather than revising prior reports. Either way, the Form 549D data should match the data in the pipeline's own billing systems.
Simply check field 3, provide an explanation in field 3a, and save the file on your own computer. Then eFile and upload the corrected fillable Form 549D PDF. Describe your filing as a Corrected file, (for example, Corrected Form 549D for Quarter 1 2011 for Acme Pipeline). Please resubmit your entire filing, so that Staff and shippers can read it without referring back to obsolete filings.
The Form 549D database will contain only the most recent filing and be made available on the FERC website a week or two after the filing deadline. Both the new filing and any previous filings, however, are stored on eLibrary.
If the field size is not sufficient to accommodate the primary receipt/delivery points or groups, please eFile a separate narrative alongside the respondent's initial report. The narrative should contain a list of points along with the county and state of each point, and the name of the jurisdictional pipeline (if any) that interconnects at each point. The narrative can be in a Word, Text, XLS or PDF file.
Use of Third Party Tools
Respondents may use the services of a third party vendor to prepare their Form 549D reports. The Commission released to the public the XML Schema (XML XSD file) which should facilitate development of software applications to comply with Orders 735 and 735-A. Respondents who use third party vendors are still solely responsible for their filings and should ensure that the vendor is working with the latest versions of the XML XSD file and fillable Form 549D PDF file.