FERC-725B [RM13-5 Final Rule] Mandatory Reliability Standards for Critical Infrastructure Protection

Forms and Documents

Document Name	Status
CIP v5 FR (RM13-5) SuppStmta.docx Supporting Statement A	2014-02-28
Commissioner LaFluer Statement on Reliability Orders (RM13-5).pdf Supplementary Document	2014-02-27
V3-V5 burden and explanation of adjustment 1-24-14.xlsx Supplementary Document	2014-02-27
NERC Petition.pdf Supplementary Document	2014-02-27
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: 201402-1902-005
Status: Historical Active	Previous ICR Reference No: 201311-1902-003
Agency/Subagency: FERC	Agency Tracking No: FERC-725B
Title: FERC-725B [RM13-5 Final Rule] Mandatory Reliability Standards for Critical Infrastructure Protection
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 03/04/2014
	Date Received in OIRA: 02/28/2014
Terms of Clearance: In accordance with 5 CFR 1320, the information collection revisions are approved. The terms of the previous clearance remain in effect including the expiration date for this collection, which is June 30, 2015.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	06/30/2015	36 Months From Approved	06/30/2015
Responses	1,475	0	1,501
Time Burden (Hours)	1,327,231	0	848,730
Cost Burden (Dollars)	0	0	5,444

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Abstract: The information collection requirements in the CIP Version 5 standards apply to the following functional entities: balancing authorities, distribution providers, generator operators, generator owners, interchange coordinators (or interchange authorities), reliability coordinators, transmission operators, and transmission owners. Based on the NERC registry, FERC estimates there are 1,475 entities registered for at least one of the functions listed above. The cyber security policy, process, and procedure documentation required by the CIP standards are the principal components of a cyber-security program. The main use for the information generated is to achieve and maintain a cyber-secure operational state, a process which requires vigilant monitoring of activity against documented policies and procedures. Similarly, the applicable compliance enforcement authority (regional entity or NERC) uses the information to measure an entity's compliance with a given requirement. If the information collection requirements did not exist then it would be difficult to monitor and enforce compliance with the standards, which could lead entities to relax their compliance with the requirements. Also, creating and maintaining documentation is integral to the task of performing cyber security, as reflected in the fact that some of the reliability standards' requirements actually require an entity to create a document (as opposed to documenting compliance with a requirement). Without such information collection an entity may fail to perform actions that may affect the reliability and security of the grid.

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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:
1902-AE66	Final or interim final rulemaking	78 FR 72756	12/03/2013

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Federal Register Notices & Comments

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	1,475	1,501	0	61	-87	0
Annual Time Burden (Hours)	1,327,231	848,730	0	779,595	-301,094	0
Annual Cost Burden (Dollars)	0	5,444	0	0	-5,444	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

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

Burden Reduction Due to:

Short Statement: FERC has issued a final rule which adopts the CIP version 5 Reliability Standards. As discussed previously, these standards are an improvement over the current Version 4 standards. The CIP version 5 standards require new and ongoing paperwork burden. FERC is averaging the estimated burden hours from the proposed rule across the first three years to create an annual figure to provide to OMB. This annual figure is 779,595 hrs [(418,048 hrs + 1,162,788 hrs + 757,948 hrs)/3 = 779,595 hrs]. After the first three years, entities will have completed implementation of CIP version 5 (a total of 383,543 hours) and will continue with ongoing burden unless other changes are made. FERC proposes to add the annual hours from the final rule, 779,595 hours, to an adjusted baseline of burden hours under the existing CIP standards. The current burden inventory shows 848,730 hours. FERC is adjusting the existing hours based upon careful review of the assumptions used to generate the previous estimates. FERC is also adjusting the number entities/responses. Further detail is provided in the supporting statement. FERC does not consider there to be any additional non-labor costs for CIP version 5. The removal of the annual cost burden below is due to a staff review determining that any non-labor hour costs are negligible.

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Annual Cost to Federal Government: $2,250

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: 02/28/2014

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