FR 2024-31432

The document in question, issued by the Federal Energy Regulatory Commission (FERC), is an official notice seeking public input on its current methods for collecting information related to the reliability standards of the bulk-power system. These standards are crucial as they ensure the stability of electrical systems across the United States by setting requirements for how transmission and distribution providers should manage and respond to various power system challenges.

Summary of the Document

The notice announces that FERC is soliciting comments from the public about their already approved information collection activities, which cover a wide range of reliability standards under several categories. These include reliability standards for dealing with misoperations of protection systems, under voltage load shedding, protection system maintenance, and more. An interesting move within this document is the merger of certain information collection activities into a unified framework (FERC-725G), aimed at simplifying and streamlining the reporting process.

The Commission invites comments until March 3, 2025. This initiative arises from statutory requirements, particularly under the Energy Policy Act of 2005, which underlines the need for enforceable reliability standards to safeguard the bulk-power system.

Significant Issues and Concerns

There are several issues and potential areas of concern present in the document:

1. Complex and Technical Language: The text uses specialized jargon and complex legal terminology, making it less accessible to readers without an industry background. Terms such as 'UVLS entities' and 'bulk-power system' might not be immediately clear to all, leading to a potential comprehension hurdle.

2. Justification of Costs: The estimated hourly cost for compliance tasks has been derived using salaries for specific professional roles like Electrical Engineers and Information and Record Clerks. However, the choice of these roles and the calculation methodology lacks clarity and justification, which might raise questions regarding its applicability and accuracy.

3. Merging of Collections: While FERC mentions that merging the data collection activities is an administrative move, details regarding how this affects transparency, accountability, or the actual process for stakeholders are sparse.

4. Estimates and Assumptions: The document estimates annual responses based on assumptions about the frequency of incidents such as misoperations or under-voltage load-shedding programs. These figures are rounded estimates, which might not fully capture the nuances of real-world scenarios.

5. Excessive Repetition: The document has instances of repetitive information, particularly in the summary sections, which can dilute focus and clarity instead of succinctly presenting the core necessity and implications of each collecting task.

Impact on the Public

Broadly, the public stands to benefit from enhanced reliability and robustness of the electrical grid through these regulatory standards. As electricity underpins much of daily life and economic activity, maintaining system reliability is of paramount importance.

However, the complexity of the document may pose a challenge for general public engagement. Members of the public interested in participating in the commentary process may find it difficult to understand and provide input effectively due to the technical nature of the content.

Impact on Specific Stakeholders

For stakeholders like transmission owners, generator owners, and distribution providers, this document outlines critical compliance responsibilities that could impose operational and financial burdens. The estimated costs and administrative activities might affect entities differently based on their size and existing resources.

On the positive side, the merger of information collection activities might reduce redundancy and streamline compliance, potentially leading to more efficient use of resources. Additionally, the opportunity to provide feedback is an avenue for stakeholders to express any concerns or suggestions about the reporting frameworks and their impacts.

Overall, while the initiative aims to strengthen the reliability of the power system, specific enhancements in clarity and justification would be beneficial for comprehending its full impact on various stakeholders.

The Federal Energy Regulatory Commission's (FERC) document discusses various financial estimates related to the collection of information pursuant to several reliability standards for the bulk power system.

One of the key aspects addressed in the document is the annual burden estimates, which includes both time and financial costs associated with compliance for different entities. For the FERC-725G1 standard, the Commission estimates an annual workload of 930 responses, with each response taking 16 hours and costing $1,130.72. The total burden per year for this standard is therefore projected at 14,880 hours, amounting to a total cost of $1,051,570. Similarly, FERC-725G4 involves an estimated 25 responses annually, each demanding 48 hours and having an associated cost of $4,176. This results in ​​1,200 hours of total burden per year, equating to $104,400. Lastly, FERC-725P1 foresees 1,861 responses per year, with each taking 2 hours and costing $141.34, leading to a total estimation of 3,722 hours and costs totaling $263,033.74 annually.

These financial references illustrate the expected expenditures in terms of labor costs and resources required for compliance. Notably, all calculations are based on estimated hourly costs combining salaries of professionals with different expertise – Electrical Engineers and Information and Record Clerks, calculated at $70.67/hour. However, there is a lack of transparency or justification for the choice of these specific roles and their relevance to all activities covered by the various standards, which has been highlighted as a potential issue.

The administrative merging of the information collections (FERC-725G1, FERC-725G4, and FERC-725P1 into FERC-725G) is indicated to be purely for record-keeping purposes. While there is no direct mention of financial impacts associated with this administrative change, questions about transparency and accountability remain pertinent. Since such consolidations might affect the visibility of individual information collections, stakeholders may find it challenging to track exact allocations and ensure that financial resources are appropriately managed.

Additionally, concerns are raised regarding assumptions underlying the financial estimates. For instance, the document uses rounded estimates for annual responses, based on anticipations about the frequency of certain operational events without explicit justification. This method could potentially affect the reliability of the financial estimates provided.

In summary, while the document details thorough financial estimates related to the reporting burdens under several reliability standards, clarity and transparency regarding these estimates and their underlying assumptions could be improved. Furthermore, the merging of various collections into FERC-725G might simplify administration but could raise questions about ongoing financial accountability and transparency in reporting compliance burdens.