FR 2021-00262

The document under examination is a notice from the Federal Energy Regulatory Commission (FERC), part of the U.S. Department of Energy, which invites public comments on the renewal of the information collection process designated as FERC-512. This collection pertains to the issuance of Preliminary Permits for hydropower projects. These permits provide entities the priority in applying for a project license but do not confer construction rights. Instead, they allow for comprehensive site studies and planning over a maximum period of four years. The deadline for public comments is March 12, 2021.

General Summary

At its core, the notice outlines FERC's compliance with the Paperwork Reduction Act of 1995, seeking a continuation of the existing FERC-512 collection procedure. It details how the permits maintain the priority of potential applicants while they conduct necessary evaluations, such as engineering and environmental feasibility studies. These permits are crucial as they ensure the firm organization of information before a license is granted for energy project expansions or developments.

Significant Issues and Concerns

Several issues arise from this document that may warrant closer inspection:

• Lack of Clarity on the Permit’s Advantages and Impacts: While the notice describes the function of the Preliminary Permit, it could benefit from clearly articulating the specific advantages and potential impacts on the parties involved. Providing examples or case studies could help illuminate past experiences that may anticipate future outcomes.

• Cost and Burden Estimation: There is limited information on the assumptions and methodologies used to calculate the burden and costs associated with the information collection, making it difficult to evaluate the appropriacy of these estimates fully.

• Absence of Changes to Reporting Requirements: The document states there are no changes to current reporting requirements but fails to explain the reasoning behind this decision, which might be vital information for stakeholders involved.

• Automation Opportunities: The notice does not address potential utilization of automation or technology to ease information collection, a notable absence considering the goal is to minimize the burden on respondents.

Impact on the Public

The general public stands to benefit from a well-regulated system of preliminary permits, as they ensure a level of due diligence and preparedness in hydropower developments that can lead to more efficient and environmentally friendly energy solutions. However, the implications of this information collection on the permeability of cutting-edge technology and financial expenditures remain opaque, which might hinder public understanding and confidence.

Impact on Specific Stakeholders

For stakeholders directly involved in the energy sector, including businesses and both for-profit and not-for-profit organizations, the renewal could provide continued assurance and structured processes to guide their project licensing. However, they may face challenges due to the unspecified burden of compliance costs, as well as operating without any change in reporting requirements for the next three years.

In conclusion, while the document provides a regulatory backbone enabling stakeholders to pursue hydropower advancements responsibly, a clearer exposition of its parameters and impacts could enhance stakeholder engagement and informed decision-making.

The document under review addresses the renewal of the information collection for the Preliminary Permit (FERC-512) by the Federal Energy Regulatory Commission (FERC). Among its detailed content, financial elements are noted concerning the cost and burden estimation related to the collection requirements.

Financial Overview

The document provides a single explicit financial reference: the FERC 2020 average salary plus benefits for one full-time equivalent (FTE) is $172,329 per year, or $83.00 per hour**. This figure is used as a standard to estimate the burden and cost of the information collection requirements associated with FERC-512.

Relation to Identified Issues

One of the noted issues in the document is the lack of detailed cost and burden estimation, making it challenging to assess the appropriateness of these financial figures. The provided salary reference, although specific, does not offer a comprehensive breakdown of the total cost implications for conducting or undergoing the FERC-512 information collection process. This missing context can lead to questions among stakeholders regarding the assumptions made by FERC when determining these financial allocations.

Analysis of Financial References

The financial reference implies that FERC considers the industry's skill set and cost on par with its internal averages. However, stakeholders might find it beneficial to understand how this translates into the total expected financial burden for businesses and institutions involved with FERC-512. It does not detail how many hours or full-time equivalents would be required, thus leaving gaps in projection for potential financial planning by interested parties.

Methodological Concerns

The document does not explain the methodologies or assumptions underlying this cost estimation, an issue identified in the metadata. Stakeholders would benefit from a more thorough examination or rationale behind how the standard $83.00 per hour figure impacts the overall calculation of cost and time investment necessary for satisfying FERC-512 requirements.

In summary, while the provided financial reference offers a foundational salary benchmark, it lacks contextual elaboration necessary for stakeholders to fully grasp its implications on their financial planning regarding FERC-512 activities. This could both obscure the perceived transparency of FERC's decision-making and impede the ability of respondents to accurately foresee the financial commitments necessary for compliance.