FERC-725, Certification of Electric Reliability Organization; Procedures for Electric Reliability Standards

Forms and Documents

Document Name	Status
725 nonsub just.docx Justification for No Material/Nonsubstantive Change	2019-09-18
FERC-725 nonsub change request supporting statement.doc Supporting Statement A	2019-09-18
16 USC 824(o).pdf Supplementary Document	2018-07-20
EPAct 2005 (109 PL 58).pdf Supplementary Document	2018-07-20
18 CFR Part 39.pdf Supplementary Document	2018-07-20

IC Document Collections

IC ID	Document Title	Status
23273	Registered Entities	Unchanged
203074	Regional Entities	Unchanged
203073	Electric Reliability Organization (ERO)	Unchanged

ICR Details

OMB Control No: 1902-0225	ICR Reference No: 201908-1902-003
Status: Active	Previous ICR Reference No: 201810-1902-001
Agency/Subagency: FERC	Agency Tracking No: FERC-725
Title: FERC-725, Certification of Electric Reliability Organization; Procedures for Electric Reliability Standards
Type of Information Collection: No material or nonsubstantive change to a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 10/31/2019
	Date Received in OIRA: 09/18/2019
Terms of Clearance: In accordance with 5 CFR 1320, the information collection is approved. The previous terms of clearance still hold, which are: Any future FERC commission rules that require NERC to develop or modify NERC reliability standards will only be approved as part of this ICR by OMB if they are submitted as an ICR revision request with the required public notice and comment. In addition if such requests are connected to a rule-making that needs to be indicated as part of the ICR revision request.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	02/28/2022	02/28/2022	02/28/2022
Responses	1,730	0	1,730
Time Burden (Hours)	1,117,730	0	1,117,730
Cost Burden (Dollars)	65,000	0	65,000

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Abstract: FERC-725 (nonsubstantive change) This nonsubstantive change request is to incorporate the reporting requirements for the FERC-725(1A) information collection (OMB Control No. 1902-0225) into the FERC-725 information collection (OMB Control No. 1902-0225). The reporting requirements approved under FERC-725(1A) were due to the issuance of an order in Docket No. RD17-4-000 (on 4/17/2017). In that order, the Commission directed NERC to develop a new or modified Reliability Standard for supply chain risk management for industrial control system hardware, software, and computing/networking services associated with bulk electric system operations. Industry burden to develop any new Reliability Standard would normally be contained in the FERC-725 information collection. However, at the time the Order was submitted to OMB for review, the FERC-725 information collection was already under review for an unrelated activity. Commission staff used the FERC-725(1A) as a temporary placeholder collection number under which the required reporting requirements could be submitted to and reviewed by OMB. OMB approved the FERC-725(1A) information collection on 9/22/2016 with the burden estimate of 1 additional response and 1 hour per response annually. (One response and one hour were placeholders.) FERC staff is now administratively moving the reporting requirements of FERC-725(1A) to FERC-725 with no additional ongoing burden (because FERC-725 already accounts for all Reliability Standard development). FERC-725 (General Information) The FERC-725 contains the following information collection elements: -Self Assessment and ERO (Electric Reliability Organization) Application: The Commission requires the ERO to submit to FERC a performance assessment report every five years. The next assessment is due in 2019. Each Regional Entity submits a performance assessment report to the ERO. Submitting an application to become an ERO is also part of this collection. -Reliability Assessments: 18 CFR 39.11 requires the ERO to assess the reliability and adequacy of the Bulk-Power System in North America. Subsequently, the ERO must report to the Commission on its findings. Regional entities perform similar assessments within individual regions. Currently the ERO submits to FERC three assessments each year: long term, winter, and summer. In addition, NERC also submits various other assessments as needed. -Reliability Standards Development: Under Section 215 of the FPA, the ERO is charged with developing Reliability Standards. Regional Entities may also develop regional specific standards. Reliability Standards are one of the three principal mechanisms provided to FERC to ensure reliability on the Bulk-Power System. -Reliability Compliance: Reliability Standards are mandatory and enforceable upon approval by FERC. In addition to the specific information collection requirements contained in each standard (cleared under other information collections), there are general compliance, monitoring and enforcement information collection requirements imposed on applicable entities. Audits, spot checks, self-certifications, exception data submittals, violation reporting, and mitigation plan confirmation are included in this area. -Stakeholder Survey: The ERO uses a stakeholder survey to solicit feedback from registered entities in preparation for its three year and five year self-performance assessment. The Commission assumes that the ERO will perform another survey prior to the 2019 self- assessment. -Other Reporting: This category refers to all other reporting requirements imposed on the ERO or regional entities in order to comply with the Commission’s regulations. For example, FERC may require NERC to submit a special reliability assessment. This category captures these types of one-time filings required of NERC or the Regional Entities. The Commission implements its responsibilities through 18 CFR Part 39.

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Authorizing Statute(s): US Code: 16 USC 824o Name of Law: Energy Policy Act of 2005
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 48813	09/27/2018
30-day Notice:	Federal Register Citation:	Citation Date:
	84 FR 9999	01/09/2019
Did the Agency receive public comments on this ICR? Yes

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Number of Information Collection (IC) in this ICR: 3

IC Title	Form No.	Form Name
Electric Reliability Organization (ERO)
Regional Entities
Registered Entities

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	1,730	1,730	0	0	0	0
Annual Time Burden (Hours)	1,117,730	1,117,730	0	0	0	0
Annual Cost Burden (Dollars)	65,000	65,000	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The adjustments are due to the following reasons. • As shown in Question 12 in the supporting statement, there was a decrease from eight to seven in the number of Regional Entities because the Southwest Power Pool dissolved in 2018. • Other changes from previous estimates come from new data in the proposed NERC 2019 Business Plan and Budget to reflect changes in the number of FTEs working in applicable areas. • Reviewing the NERC Compiance database we determined the number of unique U.S. entities was 1,409. • Lastly, in several instances, the amount of time an FTE devotes to a given function may have been increased or decreased.

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Annual Cost to Federal Government: $4,125,431

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 09/18/2019

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