Overview
Title
Commission Information Collection Activities (FERC-725G); Comment Request; Extension
Agencies
ELI5 AI
The Federal Energy Regulatory Commission wants to make sure the big electrical system works well, so they're asking people for ideas on how to check and fix any problems with it. They are looking for suggestions until April 2025 on how to make this task easier and better.
Summary AI
The Federal Energy Regulatory Commission (FERC) is asking for public comments on its approved information collections, including FERC-725G, which deals with reliability standards for the bulk-power system. These collections focus on maintaining and ensuring the reliability of the electrical grid, such as identifying and correcting system mis-operations, under voltage load shedding, and maintenance of protection systems. The agency aims to gather comments on aspects such as the necessity and utility of the information, how the collection could be improved, and ways to reduce the burden on respondents. Comments are due by April 16, 2025, and the procedures for submission are clearly laid out.
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 725G, Mandatory Reliability Standards for the Bulk-Power System: Reliability Standard PRC standards; FERC-725G1, Mandatory Reliability Standards for the Bulk-Power System: Reliability Standard PRC-004-6 (Protection System Mis-operation Identification and Correction), FERC-725G4, Mandatory Reliability Standards: Reliability Standard PRC-010-2 (Under Voltage Load Shedding) and 725P1, PRC-005-6 (Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance). There are no changes made to the reporting requirements for this information collection. The comment period ended on March 3, 2025, with no comments received.
Keywords AI
Sources
AnalysisAI
The Federal Energy Regulatory Commission (FERC) is requesting public feedback on various information collections that aim to ensure the reliability of the bulk-power system. These collections cover standards such as identifying and resolving system mis-operations and maintaining protection systems. Feedback is sought on the necessity, utility, and potential improvements of these collections, with submissions due by April 16, 2025.
General Summary
The document is an official notice from the Federal Energy Regulatory Commission announcing a request for public comments on several approved information collection activities related to the reliability standards of the bulk-power system. The FERC is specifically focused on maintaining the stability and reliability of the electric grid through activities like mis-operation identification, under voltage load shedding, and protection system maintenance. Although the comment period ended with no responses, the agency is continuing to seek input on improving these processes.
Significant Issues or Concerns
There are several concerns regarding the complexity and accessibility of the document. The legal and technical jargon, including references to specific reliability standards and statutory language, may be difficult for the average reader to understand. Additionally, the document uses a combination of job roles for estimating hourly costs, which may not accurately reflect the costs or variations different entities might experience.
The merging of multiple FERC standards into a single collection, FERC-725G, is described as an administrative task, yet the details on how it might affect data tracking and accountability remain unclear. Despite these mergers and proposed extensions, there is no outlined process narrative or clear timeline specifying how these tasks will be managed or concluded.
Furthermore, the absence of comments by the earlier deadline raises questions about the effectiveness of public engagement strategies, as this lack of feedback could indicate problems in communications between FERC and the public or stakeholders.
Impact on the Public
Broadly, this document and its implications may not directly affect the everyday life of the general public but may indirectly impact electricity reliability and safety. An efficient bulk-power system influences stable power delivery, potentially reducing blackouts or disturbances, which are critical for maintaining both public safety and the economic well-being of communities reliant on consistent energy supplies.
Impact on Specific Stakeholders
For specific stakeholders like transmission owners, generator owners, and distribution providers, this document outlines regulatory compliance obligations that can be costly and time-consuming. While ensuring reliability and safety, these responsibilities require significant labor and financial investment, underscored by the detailed burden estimates presented.
Stakeholders are also offered an opportunity to voice feedback on the processes and improve them, which could minimize cost burdens and operational complexities. Nevertheless, the lack of public response indicates that these avenues for feedback may not be fully utilized or effectively communicated.
Overall, the document reflects FERC's commitment to upholding stringent standards to ensure grid reliability, although it encounters issues related to connectivity with stakeholders and potential inefficiencies in standard and cost assessments.
Financial Assessment
The document in question outlines the Federal Energy Regulatory Commission's (FERC) request for public comments on existing information collections related to Mandatory Reliability Standards for the Bulk-Power System, under the Paperwork Reduction Act requirements. It includes specific financial references that help elucidate the financial implications of these standards.
The commission breaks down the annual burden estimates for various reliability standards, listing 930 responses annually with a per-response burden of 16 hours and a cost of $1,130.72. This results in total yearly burdens amounting to 14,880 hours and $1,051,570. For another standard, the annual burden was estimated at 25 responses, with each response requiring 48 hours and costing $4,176, accumulating to a yearly total of 1,200 hours and $104,400.
For a third standard, the document estimates 1,861 responses annually, with each response taking 2 hours and costing $141.34, bringing the total annual burden to 3,722 hours and $263,033.74.
These figures rely on assumptions about hourly costs based on job classifications, including a combination of an Electrical Engineer and an Information and Record Clerk. The cost per hour is calculated to be $70.67, combining 75% of an Electrical Engineer's hourly rate of $79.31 and 25% of an Information and Record Clerk's rate of $44.74.
Several issues arise from these financial references. First, calculations use a static combination of job roles to estimate an average hourly cost. While this approach provides a baseline, it may not fully capture the real-world cost variations across different entities involved in the reliability standards. Variations in labor costs across regions and organizations may lead to discrepancies between estimated and actual costs.
Additionally, while FERC has merged various standards into FERC-725G for administrative purposes, the document does not address the potential financial implications of such a merger on data tracking and reporting. The merging process might affect how entities allocate resources to meet the enforced regulations without fully transparent and detailed guidelines.
Furthermore, although the document mentions no comments were received by the deadline, it does not explore the potential reasons behind the lack of public engagement. This absence of feedback could imply potential issues with communication or public understanding of the complex financial elements within the document, further emphasizing the need for clearer dissemination of information to stakeholders.
Overall, the financial references in the document highlight the complexity and significant resource implications for entities involved in adhering to FERC's mandatory reliability standards. However, there appears to be a need for clearer guidance and possibly a review of estimation methods to ensure accuracy and transparency.
Issues
• The document contains complex legal and regulatory language that may be difficult for non-experts to understand, such as the detailed descriptions of reliability standards and statutory references.
• The estimated hourly cost calculations use a combination of job roles and a rounded value that may not precisely reflect the real-world cost variations across entities involved.
• The document involves multiple approvals and merges of data collection but does not provide a process narrative or timeframe outlining how exactly these will be managed or concluded.
• The burden estimates and methodology, such as those presented for the number of responses and the estimated costs, are based on assumptions and previous data but might require further explanation for clarity and verification.
• Despite no comments being received by the comment period deadline, the reasons for this are not addressed, which could suggest issues with public engagement or communication.
• The merging of different FERC standards into FERC-725G is described as 'administrative only,' but the implications for data tracking, reporting, and accountability are not fully detailed.