FR 2021-00513

The document issued by the Federal Energy Regulatory Commission (FERC), a segment of the Department of Energy, serves as a formal request for public input on the renewal of the information collection requirements under the FERC-725D framework. These guidelines are instrumental in ensuring the reliability and sound operation of the nation's electrical infrastructure. The document outlines various standards related to how transmission and electrical generation facilities are designed, connected, and maintained.

General Overview

This notice surrounds the call for public comment regarding the continuation of certain standards, identified by specific codes like FAC-001-3 and FAC-002-3, that dictate how different parts of the electrical system interact. Such standards are crucial in maintaining the secure and efficient operation of the power grid. The emphasis is on maintaining existing reporting and recordkeeping requirements rather than introducing new obligations. The public is encouraged to submit their feedback by February 12, 2021.

Significant Issues and Concerns

A predominant issue within the document arises from its complex and technical language. Many readers, especially those without a background in energy regulation, might find it challenging to grasp the nuances of the standards described. This barrier to understanding could dissuade public engagement, which is vital for the feedback process. Furthermore, while the document has a stated goal of reducing paperwork, it does not clearly articulate these benefits in accessible language. Additionally, numerous references are made to other documents and regulatory framework sections, which might be unfamiliar or inaccessible to the general public.

Broad Public Impact

For the general public, the renewal of these standards implies continuity in how electrical systems are reviewed and monitored for safety and reliability. While most individuals may not understand the technical specifics, they benefit from a more stable electrical grid, which can prevent outages and other disruptions. However, if the language and presentation deter engagement, valuable public insights might be lost.

Stakeholder Impact

Specific stakeholders, such as transmission owners, generator owners, and reliability coordinators, will find these standards particularly relevant. For these groups, the document's detailed requirements underscore ongoing compliance responsibilities, which might necessitate dedicated resources to ensure adherence. While continuing with existing frameworks may provide operational consistency, the realigning of responsibilities, as noted in certain sections, could either alleviate or augment the administrative burden on some stakeholders.

Overall, while technical documents like this one are essential for regulatory functioning, there is room for improvements in clarity and accessibility to facilitate broader public understanding and engagement.

In this Federal Register document, financial considerations are primarily reflected through estimated costs per hour associated with the administrative and reporting tasks mandated by the Federal Energy Regulatory Commission (FERC). These estimates are pivotal for understanding the economic impact of compliance with the FERC-725D information collection requirements.

The document outlines two key hourly cost rates:

• $83.67/hour, which is described as the average of the salary plus benefits for both a manager ($97.15/hour) and an electrical engineer ($70.19/hour). This is derived from data available through the Bureau of Labor and Statistics as of June 2020.

• For Record and Information Clerks, the hourly rate is estimated at $41.03/hour. This figure is based on a Commission staff study concerning the costs associated with record retention.

These figures are crucial as they draw a direct connection to the resource allocation, both human and financial, required for entities to comply with the reliability standards stipulated by FERC. Each of the roles mentioned—managers, electrical engineers, and clerks—plays a part in ensuring these compliance measures are met, reflecting the significant investment in manpower that such regulatory processes demand.

While the document focuses significantly on compliance and regulatory processes, it implies a recognition of the economic burden these requirements might place on affected entities. However, there isn't a detailed breakdown of how these costs might affect smaller entities differently than larger ones, or how these costs compare to potential economic benefits derived from increased reliability in facilities design and maintenance.

One of the issues identified in the document is the complexity and density of the text. The use of specific hourly rates illustrates transparency about the economic burden, yet the extensive technical language could still obscure this information for non-expert readers. Providing clearer explanations or visual aids might help bridge the gap for the general public to comprehend how these costs fit into broader regulatory frameworks and whether they are justified given the expected outcomes in system reliability and safety.

Additionally, while the document addresses the administrative effort in terms of cost, it doesn't explicitly focus on potential savings or efficiencies that might result from the proposed extension of the FERC-725D requirements. Highlighting potential savings or efficiencies could enhance the narrative around the value of these financial commitments, aligning with the supposed goal of the Paperwork Reduction Act to decrease the administrative overhead.

Overall, the financial references within the document add a layer of depth to the conversation about regulatory compliance, yet further simplification and transparency are needed to convey the information's significance to those without specialized knowledge in the field.