FR 2021-03802

The document from the Federal Energy Regulatory Commission (FERC) announces a request for public comments on the renewal of an information collection titled FERC-725U, which deals with Reliability Standard CIP-014-2. This standard requires the protection of critical transmission infrastructure, ensuring that vital facilities remain secure from physical attacks that could disrupt electrical stability. Stakeholders have been invited to offer input on the necessity and utility of this information collection process by March 26, 2021.

General Summary

The purpose of the notice is to meet the requirements of the Paperwork Reduction Act of 1995, which necessitates that FERC solicits public comment on any renewal of data collection activities. This particular collection renewal involves standards that aim to protect vital parts of the nation's electrical grid infrastructure. Comments can be submitted online via a government website or through the mail. The feedback is expected to focus on not only the practicality of these regulations but also the burden they place on entities required to comply.

Significant Issues and Concerns

One notable concern with the document is its call for comments without providing sufficient data or analysis supporting the unaltered continuation of these reporting requirements. While stakeholders are encouraged to weigh in on the burden of compliance, the document lacks transparency regarding the current costs or how this burden is assessed. This absence of clear data makes it challenging to provide informed feedback.

The instructions for submitting comments are multiple and potentially confusing, which could deter public engagement. The procedural language is detailed to the point of complexity, discouraging those who might otherwise contribute valuable input. There is also no clarity on how submitted feedback will impact FERC’s decision-making or whether it will be considered at all, which might reduce stakeholder willingness to participate.

Public Impact

For the general public, the documentation reviewed hints at ensuring reliable energy services by protecting electrical infrastructure. However, it lacks a direct connection to specific public benefits or risks posed by changes (or a lack of changes) to FERC-725U. Public interest may thus be limited due to the technical nature of the information and the complexity of the submission process.

Impact on Stakeholders

For entities like transmission owners and operators, the renewal could mean continued compliance obligations without modifications to the existing standards. While protecting infrastructure is undoubtedly vital, these stakeholders might argue that clarity and further analysis on compliance costs are necessary for effective planning and resource allocation.

The document indicates that FERC estimates the skills and costs associated with the reporting to align with their internal costs. Yet, without detailed methodological breakdowns, these calculations could be disputed by stakeholders. Concerns about fairness and accuracy might arise, especially if actual costs differ significantly from FERC's averages.

Conclusion

Overall, while the document performs a routine regulatory function, it lacks a user-friendly approach that might encourage broader public participation. Without more accessible information and clearer guidance on the impact of feedback, there is a significant risk that important perspectives could be lost. This could potentially result in standards that do not fully consider the burdens on the entities expected to comply, ultimately impacting the robustness and effectiveness of the regulations in question.

In the Federal Register document, there is a notable reference to financial details concerning the average salary and benefits for employees at the Federal Energy Regulatory Commission (FERC). The document specifies that the 2020 average salary plus benefits for one FERC full-time equivalent (FTE) is $172,329 per year, which translates to an hourly rate of $83.00. This figure highlights the cost associated with staffing and suggests a benchmark for the industry's wage and benefits structure related to the FERC-725U information collection activities.

The mention of financial allocations provides context for understanding the cost implications of the reporting requirements under the FERC-725U information collection. However, there are areas where the financial references intersect with issues in the document that could be further clarified:

1. Lack of Justification for Unchanged Requirements: The document indicates that the information collection requirements remain unchanged, but it does not offer detailed financial or cost-benefit analysis to justify this decision. While the average salary is provided, there is no clear breakdown or explanation of how financial efficiencies or benefits are achieved or whether maintaining the current status quo is cost-effective compared to making potential updates or revisions to the process.

2. Request for Comments on Financial Impact: The document invites public comment on the burden and cost of information collection. Yet, it lacks a thorough presentation of the current financial burden or a comprehensive cost analysis. By providing the FERC average salary, the document gives a glimpse into the potential financial outlay but does not address the broader financial implications or costs faced by the industry or those entities required to comply with the standard.

3. Instruction Complexity vs. Financial Considerations: The complexity of the procedural requirements for submitting comments, as noted in the document, could also have financial implications. Detailed and potentially confusing instructions may result in increased administrative costs, both for FERC in processing submissions and for stakeholders attempting to comply, especially if professional assistance is required to navigate these procedures. Simplifying these instructions could reduce the administrative financial burden on all parties involved.

Overall, while the document provides a relevant piece of financial information regarding staff costs, it falls short of connecting this data to the broader financial impacts, justifications, or considerations that may influence or result from the FERC-725U information collection process. Providing a more detailed financial analysis and its relation to the issues identified could enhance transparency and inform more meaningful public commentary.