60-day Notice in IC16-11

16

Docket No. IC16-11-000

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

[Docket No. IC16-11-000]

COMMISSION INFORMATION COLLECTION ACTIVITIES

(FERC Form Nos. 6, 580, 1, 1-F, and 3-Q);

CONSOLIDATED COMMENT REQUEST; EXTENSION

(June 7, 2016)

AGENCY: Federal Energy Regulatory Commission.

ACTION: Notice of information collections and request for comments.

SUMMARY: In compliance with the requirements of the Paperwork Reduction Act of 1995, 44 USC 3506(c)(2)(A), the Federal Energy Regulatory Commission (Commission or FERC) is soliciting public comment on the requirements and burden¹ of the information collections described below.

DATES: Comments on the collections of information are due [insert date that is 60 days after publication in the Federal Register].

ADDRESSES: You may submit comments (identified by Docket No. IC16-11-000) by either of the following methods:

• eFiling at Commission’s Web Site: http://www.ferc.gov/docs-filing/efiling.asp

• Mail/Hand Delivery/Courier: Federal Energy Regulatory Commission, Secretary of the Commission, 888 First Street, NE, Washington, DC 20426.

Please reference the specific collection number and/or title in your comments.

Instructions: All submissions must be formatted and filed in accordance with submission guidelines at: http://www.ferc.gov/help/submission-guide.asp. For user assistance contact FERC Online Support by e-mail at ferconlinesupport@ferc.gov, or by phone at: (866) 208-3676 (toll-free), or (202) 502-8659 for TTY.

Docket: Users interested in receiving automatic notification of activity in this docket or in viewing/downloading comments and issuances in this docket may do so at http://www.ferc.gov/docs-filing/docs-filing.asp.

FOR FURTHER INFORMATION: Ellen Brown may be reached by e-mail at DataClearance@FERC.gov, telephone at (202) 502-8663, and fax at (202) 273-0873.

SUPPLEMENTARY INFORMATION:

Type of Request: Three-year extension of the information collection requirements for all collections described below with no changes to the current reporting requirements. Please note that each collection is distinct from the next.

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.

FERC Form No. 6, Annual Report of Oil Pipeline Companies ²

OMB Control No.: 1902-0022

Abstract: Under the Interstate Commerce Act (ICA), (Section 20, 54 Stat. 916), the Interstate Commerce Commission (ICC) was authorized and empowered to make investigations and to collect and record data to the extent considered necessary or useful for the purpose of carrying out the provisions of the ICA.

In 1977, the Department of Energy Organization Act transferred to the Commission from the ICC the responsibility to regulate oil pipeline companies. In accordance with the transfer of authority, the Commission was delegated the responsibility to require oil pipelines to file annual reports of information necessary for the Commission to exercise its statutory responsibilities.³ The transfer included the Form P, the predecessor to the FERC Form No. 6, Annual Report of Oil Pipeline Companies (Form 6).⁴

To reduce burden on industry, the FERC Form No. 6 has three tiers of reporting requirements:

1. Each oil pipeline carrier whose annual jurisdictional operating revenues has been $500,000 or more for each of the three previous calendar years must file FERC Form No. 6. Oil pipeline carriers submitting a complete FERC Form No. 6 must submit FERC Form 6-Q.⁵ Newly established entities must use projected data to determine whether FERC Form No. 6 must be filed.

2. Oil pipeline carriers exempt from filing FERC Form No. 6 whose annual jurisdictional operating revenues have been more than $350,000 but less than $500,000 for each of the three previous calendar years must prepare and file page 301, “Operating Revenue Accounts (Account 600), and page 700, “Annual cost of Service Based Analysis Schedule,” of FERC Form No. 6. When submitting pages 301 and 700, each exempt oil pipeline carrier must include page 1 of the FERC Form No. 6, the Identification and Attestation schedules.

3. Oil pipeline carriers exempt from filing FERC Form No. 6 and page 301 and whose annual jurisdictional operating revenues were $350,000 or less for each of the three previous calendar years must prepare and file page 700, “Annual Cost of Service Based Analysis Schedule,” of FERC Form No. 6.

The Commission uses the FERC Form No. 6 information in:

• implementation of its financial audits and programs, the continuous review of the financial condition of regulated companies, and the assessment of energy markets

• various rate proceedings and economic analyses

• background research for use in litigation

• programs relating to the administration of the ICA

• computation of annual charges, which are required by Section 3401 of the Omnibus Budget Reconciliation Act of 1986.

Type of Respondent: Oil Pipelines

Estimate of Annual Burden: The Commission estimates the annual public reporting burden⁶ and cost⁷ for the FERC Form No. 6 information collection as follows.

FERC Form No. 6, Annual Report of Oil Pipeline Companies
	Number of Respondents (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
FERC-6	198	1	198	161.06 hrs.; $11,998.97	31.889.88 hrs.; $2,375,796.06	$11,998.97

FERC Form No. 580, Interrogatory on Fuel and Energy Purchase Practices

OMB Control No.: 1902-0137

Abstract: FERC Form No. 580 is collected in even numbered years. The Public Utility Regulatory Policies Act (PURPA)⁸ amended the Federal Power Act (FPA) and directed the Commission to make comprehensive biennial reviews of certain matters related to automatic adjustment clauses (AACs) in wholesale rate schedules used by public utilities subject to the Commission’s jurisdiction. Specifically, the Commission is required to examine whether the clauses effectively provide the incentives for efficient use of resources and whether the clauses reflect only those costs that are either ‘‘subject to periodic fluctuations’’ or ‘‘not susceptible to precise determinations’’ in rate cases prior to the time the costs are incurred.

The Commission is also required to review the practices of each public utility under AACs ‘‘to insure efficient use of resources under such clauses.’’⁹ In response to the PURPA directive, the Commission (Docket Number IN79–6-000) established an investigation. Beginning in 1982, the Commission collected ‘‘Interrogatory on Fuel and Energy Purchase Practices’’ data every other year.

Based on filer comments in response to the new electronic form used in the 2014 collections, FERC recommends the following changes to the instructions. FERC is not changing the requirements of the information collection.

Question 2a

-Revise Question 2a columns as follows:

From	To
Docket number under which rate schedule containing AAC through which costs were passed during 2012 and/or 2013 was accepted for filing by FERC	Docket number under which rate schedule containing AAC through which costs were passed during 2014 and/or 2015 was accepted for filing by FERC
Was rate schedule superseded or abandoned during 2012-2013? If so, provide dates	Was rate schedule superseded or abandoned during 2014-2015? If so, provide dates

Question 2b

-Revise the paragraph under Question 2b to read:

From

To

If any of the Utility’s wholesale rate and/or service agreements containing an AAC listed in Question 2a, that was used during 2012 and/or 2013, was filed with the Commission before January 1, 1990, attach an electronic copy of it with this filing. List the documents you are submitting below. Note: once this information is submitted electronically in a text-searchable format it will not be necessary to submit it in future Form 580 filings. See: http://www.ferc.gov/docs-filing/elibrary/accept-file-formats.asp for listing of Commission accepted document types.

If any of the Utility’s wholesale rate and/or service agreements containing an AAC listed in Question 2a, that was used during 2014 and/or 2015, was filed with the Commission before January 1, 1990, attach an electronic copy of it with this filing. List the documents you are submitting below. Note: once this information is submitted electronically in a text-searchable format it will not be necessary to submit it in future Form 580 filings. See: http://www.ferc.gov/docs-filing/elibrary/accept-file-formats.asp for listing of Commission accepted document types.

Question 3

-Revise the paragraph under Question 3 to read:

From

To

If during the 2012-2013 period, the Utility had any contracts or agreements for the purchase of either energy or capacity under which all or any portion of the purchase costs were passed through a fuel adjustment clause (FAC), for each purchase from a PURPA Qualifying Facility (QF) or Independent Power Producer (IPP) provide the information requested in the non-shaded columns of the table below. Provide the information separately for each reporting year 2012 and 2013. Do not report purchased power where none of the costs were recovered through an FAC. For each purchase where costs were flowed through an FAC, fill-in the non-shaded columns and either “Only energy charges” or “The total cost of the purchase of economic power” columns, whichever apply.

If during the 2014-2015 period, the Utility had any contracts or agreements for the purchase of either energy or capacity under which all or any portion of the purchase costs were passed through a fuel adjustment clause (FAC), for each purchase from a PURPA Qualifying Facility (QF) or Independent Power Producer (IPP) provide the information requested in the non-shaded columns of the table below. Provide the information separately for each reporting year 2014 and 2015. Do not report purchased power where none of the costs were recovered through an FAC. For each purchase where costs were flowed through an FAC, fill-in the non-shaded columns and either “Only energy charges” or “The total cost of the purchase of economic power” columns, whichever apply.

Question 4a

-Revise Question 4a columns as follows:

From	To
If emission allowance costs were incurred by the Utility in 2012 and/or 2013 and were recovered through a FAC, provide the following information.	If emission allowance costs were incurred by the Utility in 2014 and/or 2015 and were recovered through a FAC, provide the following information.
Dollar value of emission allowance cost passed through a FAC: 2012|2013	Dollar value of emission allowance cost passed through a FAC: 2014|2015

Question 5

-Revise the paragraph under Question 5 as follows:

From

To

Provide the information requested below regarding the Utility's fuel procurement policies and practices in place during 2012 and/or 2013 for fuels whose costs were subject to 18 CFR 35.14. Note: Responses to this question may be filed as Privileged. To do so, skip this question now and answer it via the Fuel Procurement Policies and Practices Privileged Addendum provided. Otherwise, answer it here and your responses will be made public.

Provide the information requested below regarding the Utility's fuel procurement policies and practices in place during 2014 and/or 2015 for fuels whose costs were subject to 18 CFR 35.14. Note: Responses to this question may be filed as Privileged. To do so, skip this question now and answer it via the Fuel Procurement Policies and Practices Privileged Addendum provided. Otherwise, answer it here and your responses will be made public.

Question 6

-Revise the paragraph under Question 6 as follows:

From

To

For each fuel supply contract, of longer than one year in duration, in force at any time during 2012 and/or 2013, where costs were subject to 18 CFR 35.14, (including informal agreements with associated companies), provide the requested information. Report the information individually for each contract, for each calendar year. [No response to any part of Question 6 for fuel oil no. 2 is necessary.] Report all fuels consumed for electric power generation and thermal energy associated with the production of electricity. Information for only coal, natural gas, and oil should be reported.

For each fuel supply contract, of longer than one year in duration, in force at any time during 2014 and/or 2015, where costs were subject to 18 CFR 35.14, (including informal agreements with associated companies), provide the requested information. Report the information individually for each contract, for each calendar year. [No response to any part of Question 6 for fuel oil no. 2 is necessary.] Report all fuels consumed for electric power generation and thermal energy associated with the production of electricity. Information for only coal, natural gas, and oil should be reported.

Question 7

-Revise the paragraph under Question 6 as follows:

From

To

For each fuel supply contract, including informal agreements with associated or affiliated companies in force at any time during 2012 or 2013 WHERE CONTRACT SHORTFALL COSTS WERE PASSED THROUGH an FAC subject to 18 CFR 35.14, provide for each contract separately the information requested below. Only report the information requested for shortfalls that occurred under your contracts during reporting years 2012 or 2013 and that are not under dispute i.e. parties agree there was indeed a shortfall.

For each fuel supply contract, including informal agreements with associated or affiliated companies in force at any time during 2014 or 2015 WHERE CONTRACT SHORTFALL COSTS WERE PASSED THROUGH an FAC subject to 18 CFR 35.14, provide for each contract separately the information requested below. Only report the information requested for shortfalls that occurred under your contracts during reporting years 2014 or 2015 and that are not under dispute i.e. parties agree there was indeed a shortfall.

Question 8

-Revise the paragraph under Question 8 as follows:

From

To

For each fuel supply contract that was bought-out or bought-down, including informal agreements with associated or affiliated companies in force at any time during 2012 or 2013 WHERE CONTRACT BUY-OUT AND/OR BUY-DOWN COSTS WERE PASSED THROUGH an FAC subject to 18 CFR 35.14, provide for each contract separately the information requested below. Only report the information requested for contract buy-downs and buy-outs that occurred under your contracts during reporting years 2012 or 2013 and that are not under dispute i.e. parties agree there was indeed a shortfall.

For each fuel supply contract that was bought-out or bought-down, including informal agreements with associated or affiliated companies in force at any time during 2014 or 2015 WHERE CONTRACT BUY-OUT AND/OR BUY-DOWN COSTS WERE PASSED THROUGH an FAC subject to 18 CFR 35.14, provide for each contract separately the information requested below. Only report the information requested for contract buy-downs and buy-outs that occurred under your contracts during reporting years 2014 or 2015 and that are not under dispute i.e. parties agree there was indeed a shortfall.

Access to the Revised Materials: A copy of the form, desk reference, and glossary are attached to this Notice, but they will not be published in the Federal Register.¹⁰ Interested parties can see the form electronically as part of this notice in FERC’s eLibrary (http://www.ferc.gov/docs-filing/elibrary.asp) by searching Docket No. IC16-11-000.

Type of Respondent: Large electric public utilities within FERC jurisdiction.

Estimate of Annual Burden¹¹: The Commission estimates the annual¹² public reporting burden for the information collection as:

FERC Form 580 (Interrogatory on Fuel and Energy Purchase Practices)
	Number of Respondents (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden & Cost Per Response13 (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Annual Cost per Respondent ($) (5)÷(1)
Respondents with FACs	37	0.5	18.5	103 hrs.; $7,673.50	1,905.5 hrs.; $141,959.75	$3,836.75
Respondents with AACs, but no FACs	10	0.5	5	20 hrs.; $1,490	100 hrs.; $7,450	$745
Respondents with no AACs nor FACs	35	0.5	17.5	2 hrs.; $149	35 hrs.; $2,607.50	$74.50
TOTAL			41		2,040.5 hrs.; $152,017.25

FERC Form No. 1, Annual Report of Major Electric Utilities, Licensees, and Others

OMB Control No.: 1902-0021

Abstract: The FERC Form No. 1 (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. Major is defined as having in each of the three previous calendar years, sales or transmission services that exceed one of the following: (1) one million megawatt hours of total annual sales; (2) 100 megawatt hours of annual sales for resale; (3) 500 megawatt hours of annual power exchanges delivered; or (4) 500 megawatt hours of annual wheeling for others (deliveries plus losses).¹⁴

The Form No.1 is designed to collect financial and operational information and is considered to be a non-confidential public use form. The Form No.1 includes a basic set of financial statements: Comparative Balance Sheet, Statement of Income, Statement of Retained Earnings, Statement of Cash Flows, Statements of Accumulated Comprehensive Income, Comprehensive Income, and Hedging Activities; and Notes to Financial Statements. Supporting schedules contain supplementary information and outlines of corporate structure and governance; information on formula rates; and description of important changes during the year. Other schedules provide information on revenues and the related quantities of electric sales and electricity transmitted; account balances for all electric operation and maintenance expenses; selected plant cost data; and other statistical information.

Type of Respondent: Major electric utilities

Estimate of Annual Burden: The estimated annual burden and cost¹⁵ follow:

Form No. 1
Number of Respondents (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden Hours & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
210	1	210	1,169 hrs.; $91,953.54	245,490 hrs.; $19,310,243.40	$91,953.54

FERC Form No. 1-F, Annual Report for Nonmajor Public Utilities and Licensees

OMB Control No.: 1902-0029

Abstract: The FERC Form No. 1-F (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 having total annual sales of 10,000 megawatt-hours or more in the previous calendar year and not classified as Major.¹⁶

The Form No.1-F is designed to collect financial and operational information and is considered to be a non-confidential public use form. The Form No.1-F includes a basic set of financial statements: Comparative Balance Sheet, Statement of Retained Earnings, Statement of Cash Flows, Statement of Comprehensive Income and Hedging Activities, and Notes to Financial Statements. Supporting schedules contain supplementary information and include revenues and the related quantities of electric sales and electricity transmitted; account balances for all electric operation and maintenance expenses; selected plant cost data; and 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 the Form No. 1-F is $78.66 (wages plus benefits) and is described above, under the Form No. 1.):

Form No. 1-F
Number of Respondents (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden Hours & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
5	1	5	123 hrs.; $9,675.18	615 hrs.; $48,375.90	$9,675.18

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

OMB Control No.: 1902-0205

Abstract: The FERC Form No. 3-Q (Form No. 3-Q) is a quarterly financial and operating report for rate regulation, market oversight analysis, and financial audits which supplements the (a) Form Nos. 1 and 1-F for the electric industry, or the (b) Form No. 2 (Major Natural Gas Pipeline Annual Report; OMB Control No. 1902-0028) and Form No. 2-A (Nonmajor Natural Gas Pipeline Annual Report; OMB Control No. 1902-0030) (for the natural gas industry). The Form No. 3-Q is submitted for all Major and Nonmajor electric utilities and licensees; and natural gas companies¹⁷.

Form No. 3-Q includes a basic set of financial statements: Comparative Balance Sheet, Statement of Income and Statement of Retained Earnings, Statement of Cash Flows, Statement of Comprehensive Income and Hedging Activities and supporting schedules containing supplementary information. Electric respondents report revenues and the related quantities of electric sales and electricity transmitted; account balances for all electric operation and maintenance expenses; selected plant cost data; and other statistical information. Natural gas respondents include monthly and quarterly quantities of gas transported and associated revenues; storage, terminaling and processing services; natural gas customer accounts and details of service; and operational expenses, depreciation, depletion and amortization of gas plant.

Type of Respondent: Major and nonmajor electric utilities and natural gas pipelines.

Estimate of Annual Burden: The estimated annual burden and cost (as rounded) follow. (The estimated hourly cost used for the Form No. 3-Q is $78.66 (wages plus benefits) and is described above, under the Form No. 1.):

Form No. 3-Q
	Number of Respondents (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden Hours & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Annual Cost per Respondent ($) (5)÷(1)
FERC 3-Q (electric)	21318	3	639	168 hrs.; $13,214.88	107,352 hrs.; $8,444,308	$39,644.64
FERC 3-Q (gas)	167	3	501	167 hrs.; $13,136.22	83,667 hrs.; $6,581,246	$39,408.66
Total for FERC 3-Q			1,140		191,019 hrs.; $15,025,554

Kimberly D. Bose,

Secretary.

1 The Commission defines burden as the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. For further explanation of what is included in the information collection burden, reference 5 Code of Federal Regulations 1320.3.

2 The renewal request for the FERC Form No. 6 in this IC docket is for the current form, with no change to the reporting requirements.

The FERC Form No. 6 is also part of the Forms Refresh effort (started in Docket No. AD15-11), which is a separate activity and not addressed in this Notice.

In addition, there is a pending Docket No. RM15-19 which is a separate activity and is not addressed in this Notice.

3 Section 402(b) of the Department of Energy Organization Act (DOE Act), 42 U.S.C. 7172 provides that; "[t]here are hereby transferred to, and vested in, the Commission all functions and authority of the Interstate Commerce Commission or any officer or component of such Commission where the regulatory function establishes rates or charges for the transportation of oil by pipeline or established the valuation of any such pipeline."

4 The ICC developed the Form P to collect information on an annual basis to enable it to carry out its regulation of oil pipeline companies under the Interstate Commerce Act. A comprehensive review of the reporting requirements for oil pipeline companies was performed on September 21, 1982, when the Commission issued Order 260 revising the former ICC Form P, "Annual Report of Carriers by Pipeline" and redesignating it as FERC Form No. 6, "Annual Report of Oil Pipeline Companies”.

5 FERC Form 6-Q is covered separately and is approved by OMB under OMB Control No. 1902-0206. It is not a subject of this Notice; FERC Form 6-Q is being addressed separately in Docket No. IC16-7-000.

6 The burden associated with the one-time re-filing of Page 700 data for Years 2009-2011 has been completed and is not included.

7 The cost is based on FERC’s 2016 average cost (salary plus benefits) of $74.50/hour. The Commission staff believes that the industry’s level and skill set is comparable to FERC.

8 Enacted November 8, 1978

9 The review requirement is set forth in two paragraphs of Section 208 of PURPA, 49 Stat.851; 16 U.S.C. 824d.

10 The attached form is for illustrative purposes only and does not include all the interactive features of the actual form.

11 The Commission defines burden as the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. For further explanation of what is included in the information collection burden, reference 5 Code of Federal Regulations 1320.3.

12 The FERC Form 580 data is collected on a biennial basis. In order to represent the burden appropriately, the “Annual Number of Responses per Respondent” is assigned a figure of 0.5. This figure means that one response per respondent is received on average for each two year period. The “Total Annual Burden Hours & Total Annual Cost” figures are all annual figures based on the biennial frequency assumption.

13 The estimates for cost per response are derived using the 2016 FERC average salary plus benefits of $154,647/year (or $74.50/hour). Commission staff finds that the work done for this information collection is typically done by wage categories similar to those at FERC.

14 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.

15 The cost estimate (wages plus benefits) is $78.66/hour and is used for the Form Nos. 1, 1-F, and 3-Q. The $78.66/hour (wages plus benefits) is based on figures from the Bureau of Labor Statistics National Industry-Specific Occupational and Employment Wage Estimates (May 2015 estimates at http://www.bls.gov/oes/current/naics2_22.htm, and benefits information for December 2015 at http://www.bls.gov/news.release/ecec.nr0.htm) and is an average of the following:

• management (code 11-0000) of $88.94/hour

• business and financial operations occupations (code 13-0000) of $56.86/hour

• legal (code 23-0000) of $128.94/hour

• office and administrative support (code 43-0000) of $39.91/hour.

16 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 141.2.

17 18 CFR § 260.1(b) states that for natural gas companies, Major, as defined by the Natural Gas Act, 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, Nonmajor as defined by the Natural Gas Act, pertains to a company not meeting the filing threshold for Major, but having total gas sales or volume transactions exceeding 200,000 Dth in each of the three previous calendar years.

18 The estimated number of electric filers of the Form No. 3-Q is 213 (rather than the 215 total for the number of filers of the Form Nos. 1 and 1-F) due to standing waivers for two coops who do not file the Form No. 3-Q.