Commissioner James Danly Statement
November 17, 2022
RM21-18-000
I concur with today’s final rule as I believe it complies with the Natural Gas Act and the Administrative Procedure Act.[1] I write separately to express my apprehension that the Commission does not fully appreciate the burden that will be incurred, or how long it will take, for jurisdictional entities to come into compliance.[2] It is my understanding that some pipeline companies currently create each statement and its supporting schedules using different software that do not, by themselves, link. Requiring links may require a pipeline company to upgrade existing, or implement entirely new, software systems—tasks which oftentimes are neither simple nor inexpensive. And while “pipelines are allowed to recover those costs through their rates,”[3] I would have preferred to have solicited additional comment on the cost and timing of the software upgrades that this rule might require in order to better inform our decision on whether and when to impose these changes.
For these reasons, I respectfully concur.
[1] Revised Filing & Reporting Requirements for Interstate Nat. Gas Co. Rate Schedules & Tariffs, 181 FERC ¶ 61,121 (2022).