FERC-725B, Mandatory Reliability Standards for Critical Infrastructure Protection

Forms and Documents

Document Name	Status
IC11-725B Extension of time notice.pdf Supplementary Document	2011-06-14
725B_Revised Just_2011 v3.doc Supporting Statement A	2011-09-15
Statutes and Regs for Reliability.doc Supplementary Document	2011-04-08

IC Document Collections

IC ID	Document Title	Status
181478	FERC-725B, Mandatory Reliability Standards for Critical Infrastructure Protection	Modified

ICR Details

OMB Control No: 1902-0248	ICR Reference No: 201104-1902-001
Status: Historical Active	Previous ICR Reference No: 200802-1902-001
Agency/Subagency: FERC	Agency Tracking No: FERC-725B
Title: FERC-725B, Mandatory Reliability Standards for Critical Infrastructure Protection
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved with change	Conclusion Date: 09/15/2011
	Date Received in OIRA: 04/13/2011
Terms of Clearance: In accordance with 5 CFR 1320, the information collection is approved for three years. The agency is reminded that for information collections submitted as an "Extension without change of a currently approved collection," changes to the annual number of responses, time burden, and cost burden should only be attributable to a change in agency estimate as opposed to a substantative change to the collection.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	09/30/2014	36 Months From Approved	09/30/2011
Responses	1,501	0	1,000
Time Burden (Hours)	819,840	0	1,125,400
Cost Burden (Dollars)	5,261	0	0

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Abstract: How is the information used? Under the Critical Infrastructure Protection (CIP) Reliability Standards, a responsible entity is not required to report to the Commission, ERO or Regional Entities, the various policies, plans, programs and procedures. However, a showing of the documented policies, plans, programs and procedures is required to demonstrate compliance with the CIP Reliability Standards. Who uses the information? The responsible entity uses the information in a periodic audit in order to show compliance with the Reliability Standards. Why is the information collected? The purpose in documenting policies, plans, programs and procedures is to be able to show how the standard is being followed. What are the consequences of not collecting the information? Without this information, the compliance enforcement authority would have difficulty in verifying compliance to the CIP Reliability Standards. Without verification, serious breaches in cyber security could perpetuate indefinitely before being corrected. Who must comply? Entities registered with NERC that have at least one CIP-related function.

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Authorizing Statute(s): US Code: 18 USC 824o Name of Law: Federal Power Act
   PL: Pub.L. 109 - 58 1211, Title XII, Subtitle A 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:
	75 FR 65618	12/27/2010
30-day Notice:	Federal Register Citation:	Citation Date:
	76 FR 31320	05/31/2011
Did the Agency receive public comments on this ICR? Yes

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
FERC-725B, Mandatory Reliability Standards for Critical Infrastructure Protection

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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	1,501	1,000	0	0	501	0
Annual Time Burden (Hours)	819,840	1,125,400	0	0	-305,560	0
Annual Cost Burden (Dollars)	5,261	0	0	0	5,261	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 adjustment decrease of 305,560 hours is due to two factors. The first is that the multi-year implementation period for these initial CIP standards was completed in 2010 (a reduction of 579,204 hours). It is now assumed that most entities (all but an average of 6 new entities per year) are incurring the much reduced burden requisite with demonstrating ongoing compliance as opposed to initial implementation. The second factor is an increase in the number of applicable entities which is due to a more accurate estimate of the effected industry (an increase of 273,644 hours). The net burden change is a reduction of 305,560 hours.

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Annual Cost to Federal Government: $1,575

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

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? 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: 04/13/2011

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