FR 2025-02357

Overview

Title

Commission Information Collection Activities (FERC Form No. 60, FERC-61, and FERC-555A); Consolidated Comment Request; Extension

Agencies

ELI5 AI

The Federal Energy Regulatory Commission (FERC) wants people to give their thoughts about some important paperwork that helps keep energy companies honest and fair. They are asking if these papers are useful and if they could be better or easier to fill out.

Summary AI

The Federal Energy Regulatory Commission (FERC) is inviting the public to comment on the ongoing information collection requirements associated with FERC Forms No. 60, 61, and 555A. These forms are necessary for monitoring centralized service companies and ensuring they adhere to the standards set by the Energy Policy Act and the Public Utility Holding Company Act. The comment period is open until April 8, 2025, and submission guidelines are detailed on the FERC website. The request seeks input on the usefulness of these information collections, the accuracy of FERC's burden estimates, and suggestions for improving data quality and minimizing reporting burdens.

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 collections, FERC Form No. 60 (Annual Report of Centralized Service Companies), FERC-61 (Narrative Description of Service Company Functions), and FERC-555A (Preservation of Records Companies and Service Companies Subject to PUHCA).

Type: Notice
Citation: 90 FR 9144
Document #: 2025-02357
Date:
Volume: 90
Pages: 9144-9146

AnalysisAI

Summary of the Document

The document is a notice from the Federal Energy Regulatory Commission (FERC) concerning the request for public comments on the information collection requirements associated with FERC Forms No. 60, 61, and 555A. These forms are used to monitor centralized service companies and ensure compliance with the regulations outlined in the Energy Policy Act and the Public Utility Holding Company Act. The public comment period is open until April 8, 2025. The notice also provides details about how comments can be submitted, including guidelines available on the FERC website.

Significant Issues and Concerns

One notable issue with the document is the complexity of the terminology and references to specific regulations, such as the Energy Policy Act of 1992 and the Public Utility Holding Company Act of 2005. These references may not be immediately clear to readers without prior knowledge, potentially limiting the accessibility of the document to the general public.

Another concern is the explanation of cost breakdowns for the various forms. The document provides labor and storage costs but lacks detail on how these figures were specifically derived, particularly for the significant expense differences across the forms. For instance, the cost associated with FERC-61 is relatively low compared to others, which might require further clarification.

The document mentions expected downward trends in storage and labor costs as companies shift towards electronic records. However, it lacks specific evidence or timelines to support these predictions, leaving readers to question the accuracy of these statements.

Impact on the Public

Broadly, this document is essential for maintaining the transparency and accountability of service companies in the energy sector. Its impact on the public is mainly indirect; however, it could help protect ratepayers by preventing improper service company costs from being passed on to consumers. Ensuring accurate and efficient data collection may improve oversight functions, potentially leading to fairer pricing and market practices.

Impact on Specific Stakeholders

For centralized service companies, this information collection and compliance requirement could represent a significant administrative burden, both in terms of time and cost. However, if companies can streamline these processes through increased electronic record-keeping, they might experience reduced costs over time.

From the perspective of regulatory bodies like FERC, these forms provide crucial data to fulfill their oversight roles effectively. The availability of this information allows FERC to closely monitor compliance and market practices, ensuring that companies adhere to legislative requirements and do not engage in cost manipulations that could harm ratepayers.

In conclusion, while the intent of the document is clear in calling for public commentary to refine and potentially improve the information collection process, its complexity and the lack of clarity on certain points may hinder full engagement by all stakeholders. Nonetheless, for those directly involved, such as service companies and regulatory bodies, the notice outlines crucial steps towards maintaining industry accountability.

Financial Assessment

The document outlines financial aspects concerning the information collections required by the Federal Energy Regulatory Commission (FERC). This involves three specific forms: FERC Form No. 60, FERC-61, and FERC-555A. The estimated total annual cost associated with these forms and their associated record-keeping requirements amounts to $2,468,472.40. This figure includes the labor cost and the storage cost for maintaining records.

Breakdown of Financial Costs

The document provides a detailed breakdown of the labor costs, which account for $2,466,612.40 of the total estimate. Each form has specific expenses associated with it:

  • FERC Form No. 60: The labor cost for the 37 respondents required to submit this form totals $288,600, with each respondent incurring a cost of $7,800.

  • FERC-61: With 14 respondents, the labor cost is substantially lower at $700 in total, equating to $50 per respondent. This amount is notably lower in comparison to the other forms, potentially raising questions about its sufficiency to cover the labor involved, which may require further clarification.

  • FERC-555A: The most significant labor cost is associated with this form, amounting to $2,177,312.40 for 51 respondents. Each respondent incurs a cost of $42,692.40.

Additionally, there is a minor storage cost projected at $510 annually, stemming from electronic storage requirements.

Issues Relating to Financial Allocations

Several issues arise in the financial allocations detailed in the document. Firstly, the cost distribution across the different forms, particularly the low cost per respondent for the FERC-61 at $50, may prompt inquiries into the robustness of these calculations given the disparity when compared to FERC-555A.

The methodology behind these expense estimates could be further elucidated to aid understanding. Simplifying or expanding on technical references, such as the rationale for estimating the number of FERC-61 filers, would enhance the transparency of how costs are determined.

Moreover, the projected decrease in storage and labor costs with the transition to digital platforms is mentioned. However, there are no detailed timelines or data-backed predictions to support these claims of cost reduction, which may benefit from further elaboration.

In conclusion, while the document provides a comprehensive financial overview of the FERC forms in question, certain areas, particularly the cost assumptions and potential savings, would benefit from further detail to provide clearer insight into their justification and potential impacts.

Issues

  • • The breakdown of costs, particularly the labor costs for each FERC form, could be more detailed to better understand how these estimates were derived.

  • • The document uses technical terms and references specific regulations and acts (e.g., EPAct 1992, PUHCA 2005) which may not be easily understood without prior knowledge or context.

  • • The document could clarify why the number of FERC-61 respondents was updated, as the explanation is somewhat complex and may be difficult for laypersons to follow.

  • • The mention of expected downward trends in storage costs and labor costs could benefit from more specific timelines or evidence-based predictions to support this assertion.

  • • The cost savings on storage transition from paper to electronic is not fully quantified in terms of past and expected future savings.

  • • It's unclear how the FERC-61 $50 per respondent cost was determined, given it seems significantly lower than other costs, which could warrant a more detailed explanation.

Statistics

Size

Pages: 3
Words: 2,030
Sentences: 69
Entities: 158

Language

Nouns: 678
Verbs: 146
Adjectives: 108
Adverbs: 31
Numbers: 111

Complexity

Average Token Length:
5.21
Average Sentence Length:
29.42
Token Entropy:
5.48
Readability (ARI):
21.35

Reading Time

about 7 minutes