FR 2021-03804

The document titled "Commission Information Collection Activities (FERC-516G); Comment Request; Revision and Extension" is a notice issued by the Federal Energy Regulatory Commission (FERC) seeking public comments on the information collection related to Electric Rate Schedules and Tariff Filings (FERC-516G). This information collection is crucial for maintaining the operations of organized wholesale electric power markets, which are primarily managed by Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs).

General Summary

The notice invites stakeholders to provide feedback on several aspects of this information collection. Specifically, it addresses the renewal of a requirement that RTOs and ISOs maintain websites and modify tariffs to communicate transmission constraint penalty factors, which can affect locational marginal prices. The information collection involves mandatory reporting on monthly uplift payments and operational commitments.

Significant Issues and Concerns

One significant concern is the lack of detailed financial impact analysis provided in the document. While it outlines hourly cost estimates for certain positions involved in the process, these may not translate into clear financial impact assessments for the organizations involved. This could hinder stakeholders' ability to understand the full cost implications of compliance.

Moreover, the document utilizes technical terminology—such as "transmission constraint penalty factors" and "uplift payments"—without providing adequate explanation. This could alienate members of the public who are not specialized in energy regulation, potentially limiting the breadth and effectiveness of public engagement.

There is also the issue of redundancy in the requirements. The document mandates the establishment and potential modification of websites and tariffs even though current RTO and ISO entities might have already complied. Such redundancy seems inefficient unless anticipating new organizations entering the market.

Finally, while the notice calls for comments on various aspects, it does not clarify what specific actions might result from the input received, which could diminish public perception of the process's transparency and significance.

Public and Stakeholder Impact

Broad Public Impact

For the general public, this document is mainly procedural. It demonstrates an ongoing regulatory accountability effort to monitor and manage the nation's electricity markets. However, the complexity and technical nature may be inaccessible for those unacquainted with regulatory jargon or the functioning of electric markets.

Impact on Specific Stakeholders

For RTOs and ISOs, the documentation requirements present both a compliance burden and an operational accountability measure. While the effort ensures transparency and efficiency in energy markets, it could also divert resources toward administrative tasks—resources that might be otherwise allocated to technological advancements or market improvements.

Additionally, new entities considering entering the market might view these requirements as initially burdensome, potentially acting as a barrier to entry and stifling competition or innovation.

Overall, while the notice reflects necessary regulatory oversight, there are elements that could benefit from clearer communication, reduced redundancy, and a more transparent explanation of how public comments might influence regulatory action.

In reviewing the financial references within this Federal Register document, several key points stand out regarding how monetary allocations and costs are articulated.

Financial References and Costs

The document provides specific hourly wage data for personnel involved in reporting and recordkeeping activities associated with the information collection FERC-516G. The hourly rates are given as follows:

• Manager (Occupation Code 11-0000): $94.84/hour
• Engineer (Occupation Code 17-2071): $85.71/hour
• File Clerk (Occupation Code 43-4071): $52.60/hour

These figures are derived from data available on the Bureau of Labor Statistics website, indicating both salary and benefits.

Additionally, the document notes that the hourly cost for the reporting requirements is $77.72, which represents an average calculated from the costs of employing a manager, an engineer, and a file clerk.

Issue Analysis

While these cost figures provide some insight into the financial considerations tied to the FERC-516G information collection, they only account for hourly expenses related to human resources required for the compliance process. The document does not, however, delve into broader financial implications for Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs). This omission is notable given the potential financial burden an organization might face in fulfilling the requirements specified by FERC, such as modifying tariffs and establishing a website.

Clarity and Comprehensiveness

The absence of a comprehensive breakdown of potential total costs for an RTO or ISO to comply with these directives could result in underestimating financial impact. Stakeholders may benefit from more exhaustive cost analyses that consider the scale of operations, diversity of tasks, and technological investments needed to achieve compliance.

Moreover, the requirement for existing entities to potentially alter tariffs and infrastructure raises concerns of unnecessary redundancy and financial inefficiency, particularly if no new organizations are formed. This could amplify the importance of defining and understanding the true financial implications for stakeholders when commenting on or updating these standards.

In conclusion, while the document provides hourly labor rates, the overall financial assessment lacks depth, leaving room for interpretation and prompting potential concerns regarding transparency and anticipated costs for compliance.