FR 2025-01736

In a recent notice, the Federal Energy Regulatory Commission (FERC) is seeking public commentary on the renewal of information collection designated as FERC-725D. This collection concerns reliability standards related to the design, connections, and maintenance of facilities. Central to this update is the incorporation of standards FAC-003-5 and FAC-008-5, which are aimed at improving the management of vegetation around transmission lines and ensuring that facility ratings are conducted using technically sound principles. These steps are crucial for maintaining the reliability of the electricity transmission system.

Summary of the Document

The notice issued by the Federal Energy Regulatory Commission invites public comments on whether the ongoing collection of information under FERC-725D is necessary and effective. The stated goal is to manage vegetation more effectively near transmission lines to prevent outages and ensure that facilities are reliably rated. Additionally, the document outlines how the transfer of specified standards into FERC-725D intends to streamline processes and improve oversight. Comments from the public are solicited by March 28, 2025, and the input is expected to address various aspects, including the necessity and accuracy of the information collection, and how its burden can be minimized.

Significant Issues and Concerns

One notable issue with the document is the lack of detailed information on the potential costs that organizations might incur to comply with these requirements. This omission could mean stakeholders are unaware of the financial implications, which is a significant concern for smaller organizations with limited resources.

The language throughout the document is intricate and may be too technical for those without a background in regulatory or electrical transmission fields. Terms like "Cascading" and "Bulk Electric System (BES)" are used without definitions, which could lead to misunderstandings among the general public or smaller stakeholders who may not have the requisite technical knowledge.

Additionally, the rationale for transferring the standards FAC-003-5 and FAC-008-5 into FERC-725D is not clearly articulated. A lack of transparency in this explanation could raise questions about why these changes are being made and who will ultimately benefit. These concerns could be compounded by the absence of clarity on how public comments will affect any decisions moving forward, which may discourage stakeholder participation.

Impact on the Public and Stakeholders

For the general public, the information collection renewal and associated changes could have widespread implications on electric service reliability. When effectively executed, these standards are designed to prevent outages and improve system reliability, thereby enhancing the overall electric service for all consumers.

Specific stakeholders, such as transmission and generation owners (referred to as TOs and GOs), may experience changes to the reporting burdens. If implemented effectively, the burdensome aspects of information collection could be reduced through streamlined processes. However, there remains a risk that the adjustments may benefit some entities more than others, which could lead to a perceived or actual bias in the policy's impact.

Overall, the notice aims to uphold energy reliability and ensure that the frameworks used in designing and maintaining facilities are current and effective. However, without clearer communication and consideration of stakeholder input, the proposed changes face potential obstacles in gaining wide acceptance and understanding.

In the Federal Register document concerning the Commission Information Collection Activities related to FERC-725D, several financial aspects and estimates are presented. These financial references primarily focus on the estimated hourly cost of burden for entities required to comply with the information collection requirements.

The document outlines an estimated hourly cost (salary plus benefits) of $70.67. This cost is derived from a calculation of labor expenses associated with compliance. It incorporates 75% of the average hourly wage of an Electrical Engineer at $79.31, equating to $59.48, and 25% from an Information and Record Clerk earning $44.74, amounting to $11.19. The figures are based on data from the Bureau of Labor Statistics as of 2024, providing an hourly rate that combines these roles' salaries to estimate the financial impact of the reporting requirements.

While the cost estimate offers a clear calculation, it ties directly to some identified issues. For instance, the document does not specify how these financial estimates translate into the broader costs for organizations required to comply with the information collection. The lack of specificity may leave stakeholders uncertain about the exact financial obligations they might incur. Additionally, the cost calculation assumes a specific combination of labor roles, which might not reflect the operational realities and staffing configurations of all impacted entities.

Moreover, the absence of clear details regarding how public comments on the information collection may influence financial allocations or adjustments is a notable concern. Participants in the regulatory process might find it challenging to understand the financial implications of their feedback or how it might lead to cost adjustments or reallocation.

Overall, while the financial estimates provide a basis for understanding the potential economic burden of compliance, the document could benefit from greater transparency and elaboration on how these costs are contextualized within the regulatory framework and how they might affect the diverse entities involved.