FR 2025-06220

General Summary

The Federal Energy Regulatory Commission (FERC) has issued a notice requesting public comments on proposed revisions to two information collection activities: FERC-725R and FERC-725A. These collections pertain to mandatory reliability standards for energy systems specifically focusing on short-term energy reliability assessments (BAL-007-1) and data collection for transmission operators (TOP-003-7). The changes target 97 balancing authorities, emphasizing the need for robust planning and data gathering to mitigate potential energy emergencies. Public comments are invited until June 10, 2025.

Significant Issues or Concerns

Several issues arise from the notice that may impact public perception and stakeholder engagement:

• Cost Transparency: The document lists estimated cost burdens for the proposed reliability standards but does not provide detailed calculations. This lack of transparency can raise concerns about how these costs were determined and whether they are reasonable.

• Complexity in Justification: The language used to justify the necessity of these information requirements is technical. Terms like "balancing authorities" and "Near-Term ERAs" may obscure understanding for those not versed in energy regulations. Simplifying this language could foster better public comprehension.

• Calculation of Costs: The estimated hourly cost for compliance activities is calculated using a specific allocation between Electrical Engineers and Information and Record Clerks. However, the rationale behind these proportions is unclear, potentially questioning the accuracy of these estimates.

• Practical Utility Clarity: The document lacks specific examples or evidence to demonstrate how the proposed energy reliability assessments and data collection standards will directly reduce energy emergencies. Such justification is critical to garner public and stakeholder support.

• Dynamic Nature of Respondents: The estimated number of balancing authorities is based on data from a specific date. How these numbers might fluctuate over time, or how emergent changes would be managed, isn’t addressed, leading to uncertainties about the burden estimate's relevance.

Impact on the Public and Stakeholders

The notice’s implications are broad and affect various groups differently:

• General Public: For the larger public, the revisions aim to enhance energy reliability, potentially reducing the risk of power outages or energy shortages. Such benefits could lead to stable energy prices and enhanced quality of life.

• Balancing Authorities: These entities face increased responsibilities and possibly higher costs due to the new standards. While the goal is to ensure reliable energy supply, the financial and operational impacts on these authorities could be significant, requiring them to re-evaluate current processes and resource allocations.

• Policymakers and Regulators: This notice underscores the ongoing effort to bolster energy reliability through regulatory adjustments. It could guide future policymaking by highlighting areas where further alignment or clarification might be necessary.

In conclusion, while the FERC’s proposed revisions aim to enhance the resilience and stability of energy systems, ensuring clarity, transparency, and practical utility in its mandates is crucial. Stakeholder engagement and public input could be instrumental in addressing these issues, fostering widespread support and effective implementation of the standards.

The document under review outlines financial allocations related to the proposed revisions of information collection requirements for FERC-725R and FERC-725A, which are standards connected to energy reliability and assessment.

The annual cost burden for the proposed Reliability Standard BAL-007-1 is set at $164,519.76, whereas the burden for the proposed Reliability Standard TOP-003-7 is $27,419.96. These figures suggest a significant financial investment in refining energy reliability standards and indicate the level of resources being committed to ensuring more accurate and predictive analyses of energy emergencies.

However, there is a notable issue concerning the transparency and calculation of these costs. The document does not provide a detailed explanation of how these amounts—$164,519.76 for BAL-007-1 and $27,419.96 for TOP-003-7—were precisely derived. Consequently, stakeholders may find it challenging to understand what specific activities, personnel, or resources these allocations are intended to cover, raising concerns about the spending's transparency.

The document also provides an estimated hourly cost of $70.67/hour, combining salaries and benefits, derived from a weighted mix (75% for an Electrical Engineer at $79.31/hour and 25% for an Information and Record Clerk at $44.74/hour). This rate implicitly supports the cost burden calculation. Nevertheless, the choice of these specific proportions (75% engineer, 25% clerk) might not accurately reflect the real-world distribution of tasks between engineering and clerical work, potentially leading to questions about the accuracy of these financial estimates.

Without clear justification for these specific allocations and calculations, stakeholders may have difficulty appreciating the practical utility and necessity of these funds. Additionally, the complexity of the language used in the document can further obscure understanding, particularly for those not deeply versed in energy regulation terms or financial estimation processes. This complexity could hinder stakeholder engagement and dialogue about the efficacy and efficiency of the proposed spending.

Overall, while the document presents specific financial figures tied to regulatory standards improvements, it would benefit from greater transparency and clarity in explaining the origins and justifications for the identified costs. This clarity would help reassure stakeholders of the prudence of the expenditure and its alignment with regulatory goals.