FR 2025-04135

The document under discussion is a notice from the Federal Energy Regulatory Commission (FERC) regarding the information collection known as FERC-725. This process involves the certification of Electric Reliability Organizations (EROs) and the procedures related to setting electric reliability standards. The agency is currently soliciting public feedback as it seeks to extend the collection process for an additional three years without changing existing reporting requirements. The deadline for submitting comments is April 16, 2025.

General Summary

FERC-725 collects necessary data to maintain electric reliability standards, which ensure the efficient functioning and reliability of the electric grid across North America. The document notifies the public of the request for comment process as part of complying with the Paperwork Reduction Act of 1995, which requires federal agencies to minimize the paperwork burden for individuals, small businesses, and other entities.

Significant Issues and Concerns

This notice raises several points of concern:

1. Lack of Quantitative Data: Although the document mentions estimated annual burdens and costs, it fails to specify exact figures. This omission could leave stakeholders unclear about the anticipated financial and temporal costs associated with complying with FERC-725 requirements.

2. ERO Application Assumptions: The notice assumes no new applications for ERO status will be filed in the next five years but still seeks to renew application regulations. This approach may lead to ambiguity regarding the necessity of such regulatory renewal.

3. Complex Language: The document adopts technical language and provides complex instructions for submission guidelines. This complexity might pose challenges for stakeholders unfamiliar with FERC processes, potentially discouraging public participation.

4. External Links Dependency: The reliance on external links for additional details can be inconvenient for those seeking comprehensive information within the document itself, and the user experience might suffer as a result.

5. Technical Jargon: Terms such as "Docket" and "OMB Control Number" are used without explanation, possibly alienating readers who do not have specialized knowledge of the subject matter.

Broad Public Impact

The notice is part of FERC's broader initiative to ensure ongoing monitoring and reliability of the electric grid, a topic of significant importance as reliance on electric power continues to grow. By seeking public comments, the document encourages transparency and public engagement, potentially fostering trust and cooperation between the agency and its stakeholders.

Impact on Specific Stakeholders

Positive Impacts:

• For professionals and major players in the energy sector, such as Electrical Engineers and Legal Advisors, there is an opportunity to engage with FERC and contribute opinions that could influence regulatory practices and standards.

• Registered entities required to comply with electric reliability standards stand to benefit from a foreseeable continuation of existing requirements without any substantive changes, allowing them to maintain business operations without the need for adaptation to new standards.

Negative Impacts:

• Entities unfamiliar with FERC procedures could find the process of comment submission daunting due to the formal language and procedural complexity involved. This may discourage smaller entities or members of the general public from participating.

• There might also be concerns from stakeholders who feel that the regulations' renewal lacks justification, especially regarding new ERO applications.

In conclusion, while the document outlines a systematic approach for regulatory compliance and invites public discourse, it also opens avenues for clarity and simplification, which could enhance engagement and ensure that all affected entities have an equal opportunity to contribute to the standards that govern electric reliability.

In the document, financial references are primarily related to the estimation of hourly costs associated with different labor categories involved in the information collection activities for the Federal Energy Regulatory Commission (FERC). These categories include Electrical Engineers, Legal experts, and Information and Record Clerks.

The specified rates are as follows: Electrical Engineers are attributed a rate of $79.31 per hour, Legal personnel at $162.66 per hour, and Information and Record Clerks at $44.74 per hour. To provide a comprehensive overview of the financial burden—and thereby ensure proper budgeting and resource allocation—the document calculates a weighted average hourly cost of $80.73. This calculation is designed to reflect how these different roles contribute to the overall labor costs effectively.

This weighted cost represents a blend of these roles, conjecturing that 70% of the time spent on this activity involves Electrical Engineers, 10% involves Legal services, and 20% involves Information and Record Clerks. The weighted average is calculated using these percentages applied to their respective hourly rates, yet there appears to be a typo in one of the figures ($79.13/hr.) used for the calculation. It likely meant to reflect the same hourly wage listed for Electrical Engineers ($79.31/hr).

The financial framework established here does not directly provide an estimate for the total annual cost associated with these activities, leaving readers without a clear picture of how significant these financial burdens might be on the involved entities. This lack of a clear financial total may cause ambiguity, as noted in one of the issues identified in the document. Readers might wonder about the overall fiscal impact on the Electric Reliability Organization (ERO) or other stakeholders involved.

Furthermore, while there is an assumption that no new ERO applications will be submitted in the next five years, the regulations are still being renewed to allow for such submissions. The document indicates that there is no expected burden for such applications, which aligns with another issue identified in the document regarding potential ambiguity in renewing regulations despite no anticipated activity.

Lastly, the document's complexity and reliance on technical terms and external links may further obscure a comprehensive understanding, potentially complicating attempts to relate the financial implications directly with compliance and procedural activities mentioned. For a general audience, clearer breakdowns and direct links between financial estimations and procedural requirements would enhance understanding and engagement.