Why Is FERC Asking Agencies to Keep Filing the Same Two Forms for Another Three Years?

The forms that track who says yes or no

FERC-606 and FERC-607 sound like tax forms. They are not. They are the paperwork that federal and state agencies fill out when a company asks for permission to build a natural gas pipeline. The first form tells the commission that an agency has received a request and whether it needs more information. The second form sends the commission a copy of the final decision plus an index of every document the agency relied on.

The law makes them mandatory

The Energy Policy Act of 2005 requires the commission to set deadlines for those agency decisions and to keep a consolidated record for appeals. Section 313 of that act and the commission's own rule at 18 CFR 385.2013 make the collections mandatory. Without them the commission could not build the schedule or the record the statute demands.

One respondent each, five hours total

The commission estimates the burden in a table that fits on half a page. For FERC-606 it lists one respondent, one response per year, four hours of work, and a cost of $408. For FERC-607 the same single respondent files once a year, spends one hour, and costs $102. The totals: two respondents, two responses, five hours, $510.

The dollar figures come from a salary model

The commission's FY 2026 average salary plus benefits is $213,003 per year, which works out to $102 an hour. The notice does not say how many agencies actually hold authorization authority today. It only says the model assumes one for each form.

The comment window is open

Anyone can send comments to the Office of Management and Budget through the RegInfo.gov portal using reference number 202607-1902-005. A copy should also go to the commission at DataClearance@FERC.gov with the docket number IC26-34-000 and the collection numbers FERC-606 and FERC-607. The deadline is September 24, 2026.

Four topics the commission wants input on

Comments can address whether the collections are necessary. They can question whether the burden estimates are accurate. They can suggest ways to improve clarity or to reduce the load through automation. The commission specifically invites input on all four points.

What the notice does not say

It does not name the agencies that currently respond. It does not explain why the respondent count stays at one per form when multiple agencies often share authority over a single project. It does not describe any change in how the commission uses the data once it arrives. The renewal is presented as a continuation, not an adjustment. It does not say how many natural gas projects are currently in the pipeline. It does not say whether the commission has ever missed a deadline because an agency failed to file. It does not say whether the $510 annual cost has ever been audited. Those questions are left for the comment period to surface.