Overview
Title
Commission Information Collection Activities (FERC-725); Comment Request; Extension
Agencies
ELI5 AI
FERC wants people to tell them what they think about rules that help keep our electricity working safely. They aren't changing the rules now, just asking if they should keep them for another three years.
Summary AI
The Federal Energy Regulatory Commission (FERC) is requesting public comments on the information collection known as FERC-725, which deals with electric reliability standards. This information collection includes requirements for assessing reliability, developing standards, ensuring compliance, and performing assessments. The comments are due by March 10, 2025, and can be submitted via the FERC website or through mail. There are no changes to the existing reporting requirements, and FERC is seeking a three-year extension for these requirements.
Abstract
In compliance with the requirements of the Paperwork Reduction Act of 1995, the Federal Energy Regulatory Commission (Commission or FERC) is soliciting public comment on the currently approved information collection, FERC 725, Certification of Electric Reliability Organization; Procedures for Electric Reliability Standards. There were no changes made to the reporting requirements for this information collection.
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Sources
AnalysisAI
The document from the Federal Energy Regulatory Commission (FERC) presented in the Federal Register is a notice for public comment relating to information collection activities under FERC-725. This information collection involves the Certification of Electric Reliability Organization and the procedures for electric reliability standards. The notice is part of FERC's compliance with the Paperwork Reduction Act of 1995, highlighting the need for feedback from the public by March 10, 2025. While the document provides a detailed explanation of the processes involved, it is marked by technical language and specific regulatory jargon that may pose challenges for those without a background in energy regulation.
General Summary
FERC is seeking a three-year extension for the existing information collection under FERC-725 with no modifications to the current reporting obligations. The information collected includes various elements such as self-assessments, reliability assessments, standards development, compliance requirements, stakeholder surveys, and other related reporting tasks. In essence, these elements are designed to ensure that electric reliability standards are maintained across the United States. Public comments are essential to assessing the necessity, utility, and burden of this collection process.
Significant Issues and Concerns
The document includes highly specialized language typical for regulatory texts, which might be difficult for the general public to comprehend. Terms such as "ERO" (Electric Reliability Organization), "NERC" (North American Electric Reliability Corporation), and "Bulk-Power System" are used without extensive explanations for laypersons. Additionally, the document assumes specific percentages of time spent by different professionals when estimating costs, which may not align with actual scenarios in practice.
Moreover, the notice discusses renewing regulations related to new ERO applications despite not expecting any new applications soon. This might create ambiguity regarding the necessity of the renewal process in this context. There are also numerous footnotes providing detailed explanations, which, while informative, can interrupt the readers' understanding if they are not accustomed to navigating legal or regulatory documents.
Impact on the Public
The request for comments and the extension of information collection requirements highlight the ongoing need for effective public participation in regulatory processes. While the technical language may deter some from engaging, those who can provide insight may influence future regulatory standards and practices. By soliciting public feedback, FERC seeks to ensure that the information collection is practical, necessary, and not overly burdensome.
Impact on Specific Stakeholders
Stakeholders such as electric reliability organizations, regional entities, and registered entities will be directly impacted by this document. These entities will continue to adhere to strict compliance and reporting standards. In general, the maintenance of these standards is likely to promote overall power system reliability, benefiting end-users by ensuring stable electricity supply. However, entities bearing the administrative burden may face ongoing challenges related to compliance costs and requirements.
Overall, while FERC-725 aims to maintain high standards in electric reliability, the complexity of the document underscores the necessity for clear communication and simplification to foster broader public participation and understanding. Important stakeholders need to evaluate whether the potential benefits in system reliability outweigh the administrative burdens imposed.
Financial Assessment
The Federal Energy Regulatory Commission (FERC) document outlines financial considerations connected to the information collection activities related to FERC-725, which involves the Certification of Electric Reliability Organizations and Procedures for Electric Reliability Standards. The document provides detailed information about costs associated with the staffing and workload involved in these activities.
Summary of Financial References
The document mentions financial details related to the hourly costs of different professionals involved in fulfilling these regulatory duties. The cost breakdown is as follows:
- 70% of the time is attributed to Electrical Engineers, with an hourly rate of $79.31.
- 10% of the time involves Legal professionals, with an hourly rate of $162.66.
- 20% of the time is spent by Information and Record Clerks, costing $44.74 per hour.
These amounts are used to derive a weighted average hourly wage of $80.73, which incorporates the percentages of time spent by each role. This calculation serves as a basis for estimating the overall costs involved in the information collection process.
Relation to Identified Issues
Complex Language and Technical Jargon: The financial details are embedded within a very technical narrative that refers to specific job codes and percentage allocations. This complexity might make it difficult for those unfamiliar with regulatory work or energy policy to understand the true costs involved without translated simplifications.
Estimation Methodologies: The methodology used for estimating these financial burdens may not accurately represent real-world conditions. It presumes fixed percentage allocations that could differ substantially in practical settings, raising potential concerns about the precision of these cost evaluations.
No New ERO Applications Expected: Even though the document states that no new applications for Electric Reliability Organization are expected, it mentions a need to renew regulations connected to new applications. This creates a potential misunderstanding regarding financial commitments. The document does not explicitly state what cost implications these renewals may entail, particularly in the context of staffing and labor expenditures noted above.
In conclusion, the document's financial sections detail the monetary costs associated with FERC-725 activities, calculated from specific professional roles and their assigned hourly rates. While these cost estimations provide insight into regulatory spending, they are presented alongside broader issues of complexity and methodology that may impact their understanding and perceived applicability.
Issues
• The document's language is very technical and complex, potentially making it difficult for laypersons to understand without a background in energy regulation or familiarity with FERC proceedings.
• The methodology for estimating the 'burden' and cost, including wages and benefits, assumes specific percentages of time spent by different professionals, which may not be representative of real-world scenarios.
• The document states that no new ERO applications are expected but seeks to renew regulations pertaining to new applications, which could be confusing or unclear to readers about the necessity of this renewal.
• The document references multiple footnotes explaining critical details, which, while thorough, may disrupt the flow for readers not accustomed to navigating such dense legal texts.
• Use of industry-specific jargon such as 'ERO', 'NERC', and 'Bulk-Power System' without sufficient lay explanations may hinder understanding for those not well-versed in these terms.