FR 2021-01756

The notice from the Federal Energy Regulatory Commission (FERC) invites the public to comment on the FERC-725S information collection, which focuses on Emergency Preparedness and Operations Reliability Standards. This request is part of the compliance requirements under the Paperwork Reduction Act of 1995. The collection's purpose is to safeguard the reliability of the electric system, even during emergencies or outages. Feedback from the public is sought to enhance the efficiency and effectiveness of this information-gathering process. Comments were due by February 26, 2021.

Issues and Concerns

One of the primary issues with the document is its complexity. It contains numerous technical and legal references, such as specific Reliability Standards and sections of the Federal Power Act (FPA), which might be challenging for readers without a legal or technical background. Simplifying the text or providing explanations of these terms could make the document more accessible to the general public. Clear explanations would help individuals understand the relevance and practical implications, facilitating more informed public comments.

Additionally, while the document mentions an estimated burden and costs, it fails to provide a detailed breakdown or explanation of how these estimates affect respondents in practical terms. This lack of clarity may hinder stakeholders' ability to understand or contest these figures effectively. Moreover, the document notes that no comments were received during a previous 60-day notice period, suggesting inadequate public engagement or outreach. Improving strategies to boost public participation could lead to more comprehensive feedback.

Public Impact

Broadly speaking, the document influences how FERC gathers crucial data that is instrumental in maintaining the reliability of the national electric grid. This system affects everyone who relies on electricity, which includes essentially the entire population. Ensuring the process is as effective and efficient as possible is in the public interest. However, without adequate public participation, the opportunity for enhancing this process could be lost.

Impact on Stakeholders

For stakeholders such as utility companies and electric grid operators, the document outlines mandatory compliance with the standards set by FERC. While these requirements are designed to enhance reliability, they also represent a regulatory burden. Stakeholders might incur costs associated with meeting these standards and providing the necessary information. Ensuring that this burden is fairly estimated and justified is crucial for these entities. Conversely, well-implemented standards and efficient information collection can lead to improved reliability, benefitting both service providers and consumers by reducing outages and associated costs.

In summary, while the document serves a vital role in maintaining electrical reliability, improvements in clarity, public engagement, and transparency could enhance its impact and effectiveness.

In the document provided, there is a single explicit reference to financial information, specifically relating to personnel costs. The Federal Energy Regulatory Commission (FERC) states that the average salary plus benefits for one full-time equivalent (FTE) at FERC was $172,329 per year, which equates to approximately $83.00 per hour. This figure serves as a baseline for estimating the cost of compliance for the parties involved in fulfilling the requirements of the Emergency Preparedness and Operations (EOP) Reliability Standards as outlined in the document.

In terms of financial allocations, the document does not detail any specific budget appropriations or expenditures related directly to the information collection activity FERC-725S. The cited average salary figure can be seen as an indication of the typical financial resources required by a regulatory body like FERC to employ personnel skilled in managing and analyzing regulatory compliance. This financial reference is helpful but limited, as it gives insight into the average cost of staff resources at FERC but does not provide a complete picture of the total cost or budget implications for the stakeholders involved in complying with the regulations.

This isolated financial reference does not directly address or resolve the identified issues in the document. For instance, the document notes that there were no comments received on the 60-day notice, potentially reflecting insufficient public engagement. This absence of public commentary could be, in part, due to stakeholders lacking a clear understanding of the financial implications of compliance with these standards, as the document does not provide a detailed breakdown of the potential financial burden on respondents. Moreover, without a clear presentation of financial data, it is challenging to assess whether the resources devoted to this regulatory activity are adequate or excessive.

Furthermore, without additional context or information on the financial resources allocated to public outreach or stakeholder engagement, it is difficult to evaluate if the absence of received comments was a result of budgetary constraints or other factors. This lack of clarity suggests there might be opportunities to improve transparency regarding financial spending, as well as to enhance engagement strategies, potentially requiring financial investment in communication and public involvement initiatives.