IC14-16 60-day notice

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be damaged by mail screening
processes.]
• Hand Delivery/Courier: Mr. Joseph
Hagerman, U.S. Department of Energy,
Building Technologies Program, 950
L’Enfant Plaza SW., Suite 600,
Washington, DC 20024. If possible,
please submit all items on CD, in which
case it is not necessary to include
printed copies.
Docket: The docket is available for
review at www.regulations.gov,
including Federal Register notices,
framework documents, summary notes,
comments, and other supporting
documents/materials. All documents in
the docket are listed in the
www.regulations.gov index.
FOR FURTHER INFORMATION CONTACT: Mr.
Joseph Hagerman, U.S. Department of
Energy, Office of Building Technologies
(EE–5B), 950 L’Enfant Plaza SW.,
Washington, DC 20024. Phone: (202)
586–4549. Email: joseph.hagerman@
ee.doe.gov.
SUPPLEMENTARY INFORMATION: This
notice announces the availability for
public comment of the draft document
‘‘Transaction-Based Building Controls
Framework, Volume 1: Reference
Guide’’. A new building diagnostic and
controls revolution is underway within
the buildings sector, primarily in the
commercial buildings sector. In it,
application-based systems are
presenting an opportunity to implement
strategies in which highly ‘‘optimized’’
control capable of constantly increasing
efficiency levels while improving
resource allocation is an inherent
attribute of the strategy rather than an
explicitly programmed feature. These
building controls and algorithms can
also be part of deep retrofits in existing
buildings that result in energy savings
not just today, but also ensure persistent
energy savings over the life of the
buildings. At the same time, the
introduction of sensors and controls, as
well as information technology and
communication protocols between the
buildings and the electric grid, has led
to digitized sensing, metering,
communication and controls.
Using these technological advances
and careful coordination, buildings
could provide valuable comfort and
productivity services to building owners
and occupants, such as automatically
and continuously improving building
operations and maintenance, while at
the same time reducing energy costs.
The above-mentioned document
proposes a framework concept to
achieve the objectives of raising
buildings’ efficiency and energy savings
potential benefiting building owners
and operators. We call it a transaction-

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based building controls’ framework,
wherein mutually-beneficial and costeffective market-based transactions can
be enabled between multiple players
across different domains.
DOE is particularly interested in
public comment on the following list of
questions embedded within the
document.
1. What do you think of the
Transactive Energy future state
described here?
2. Are there other or better ways to
make buildings smarter?
3. How smart do buildings need to be
and why?
4. Are there other examples of
Transactive Energy implementation that
should be included? Please provide
details, reports and studies that you
might be aware of documenting the
results of such implementations.
5. Are these four categories of
exchangeable services comprehensive
enough? If not, should they be expanded
in scope? Or, should additional
categories be defined?
6. What are some other reports/
studies that cover/support/illustrate
these topics of services and service
categories?
7. Are there other important networks
that need to be illustrated?
8. Are there other (project)
demonstration examples to be included?
Are there other important categories of
transactions?
9. What are some additional use cases
for this end-user service category?
Please see the use-case template in
section 8.0 to provide your inputs.
10. Are there additional or better use
cases for this energy market service
category? Please see the use-case
template in section 8.0 to provide your
inputs.
11. Can you describe additional use
cases for this grid service category?
Please see the use-case template in
section 8.0 to provide your inputs.
12. What are some additional use
cases for this societal service category?
Please see the use-case template in
section 8.0 to provide your inputs.
The public comment period ends
November 10, 2014 to provide
interested parties adequate time to
prepare and submit comments and DOE
will consider any comments received by
that date. The report is available at
http://www.regulations.gov/
#!docketDetail;D=EERE-2014-BT-NOA0016.

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Issued in Washington, DC, on September
30, 2014.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy
Efficiency, Energy Efficiency and Renewable
Energy.
[FR Doc. 2014–24134 Filed 10–8–14; 8:45 am]
BILLING CODE 6450–01–P

DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
[Docket No. IC14–16–000]

Commission Information Collection
Activities (FERC–537, FERC–725F,
FERC–725I); Consolidated Comment
Request; Extension
Federal Energy Regulatory
Commission, DOE.
ACTION: Notice of information
collections and request for comments.
AGENCY:

In compliance with the
requirements of the Paperwork
Reduction Act of 1995, 44 USC
3506(c)(2)(A), the Federal Energy
Regulatory Commission (Commission or
FERC) is soliciting public comment on
the requirements and burden 1 of the
information collections described
below.
DATES: Comments on the collections of
information are due December 8, 2014.
ADDRESSES: You may submit comments
(identified by Docket No. IC14–16–000)
by either of the following methods:
• eFiling at Commission’s Web site:
http://www.ferc.gov/docs-filing/
efiling.asp
• Mail/Hand Delivery/Courier:
Federal Energy Regulatory Commission,
Secretary of the Commission, 888 First
Street NE., Washington, DC 20426.
Please reference the specific
collection number and/or title in your
comments.
Instructions: All submissions must be
formatted and filed in accordance with
submission guidelines at: http://
www.ferc.gov/help/submissionguide.asp. For user assistance contact
FERC Online Support by email at
[email protected], or by phone
at: (866) 208–3676 (toll-free), or (202)
502–8659 for TTY.
Docket: Users interested in receiving
automatic notification of activity in this
docket or in viewing/downloading
SUMMARY:

1 The Commission defines burden as the total
time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or
provide information to or for a Federal agency. For
further explanation of what is included in the
information collection burden, reference 5 Code of
Federal Regulations 1320.3.

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comments and issuances in this docket
may do so at http://www.ferc.gov/docsfiling/docs-filing.asp.
FOR FURTHER INFORMATION CONTACT:
Ellen Brown may be reached by email
at [email protected], telephone
at (202) 502–8663, and fax at (202) 273–
0873.
SUPPLEMENTARY INFORMATION:
Type of Request: Three-year extension
of the information collection
requirements for all collections
described below with no changes to the
current reporting requirements. Please
note that each collection is distinct from
the next.
Comments: Comments are invited on:
(1) Whether the collections of
information are necessary for the proper
performance of the functions of the
Commission, including whether the
information will have practical utility;
(2) the accuracy of the agency’s
estimates of the burden and cost of the
collections of information, including the
validity of the methodology and
assumptions used; (3) ways to enhance
the quality, utility and clarity of the
information collections; and (4) ways to
minimize the burden of the collections
of information on those who are to
respond, including the use of automated
collection techniques or other forms of
information technology.
FERC–537, Gas Pipeline Certificates:
Construction, Acquisition and
Abandonment
OMB Control No.: 1902–0060.

Abstract: The information collected
under the requirements of FERC–537 is
used by the Commission to implement
the statutory provisions of the Natural
Gas Policy Act of 1978 (NGPA) 2 and the
Natural Gas Act (NGA). 3 Under Section
7(c) of the NGA, natural gas pipeline
companies must obtain Commission
authorization to undertake the
construction or extension of any
facilities, or to acquire or operate any
such facilities or extensions. A natural
gas company must also obtain
Commission approval under Section
7(b) of the NGA prior to abandoning any
jurisdictional facility or service. Under
the NGA and the NGPA, interstate and
intrastate pipelines must also obtain
authorization for certain transportation
and storage services and arrangements,
particularly a Part 284, Subpart G—
Blanket Certificate.4
The information collected is
necessary to certificate interstate
pipelines engaged in the transportation
and sale of natural gas, and the
construction, acquisition, and operation
of facilities to be used in those
activities, to authorize the abandonment
of facilities and services, and to
authorize certain NGPA transactions. If
a certificate is granted, the natural gas
company can construct, acquire, or
operate facilities, plus engage in
interstate transportation or sale of
natural gas. Conversely, approval of an
abandonment application permits the
pipeline to cease service and/or
discontinue the operation of such

facilities. Authorization under NGPA
Section 311(a) allows the interstate or
intrastate pipeline applicants to render
certain transportation services.
The data required to be submitted
consists of identification of the
company and responsible officials,
factors considered in the location of the
facilities and the detailed impact on the
project area for environmental
considerations. Also to be submitted are
the following:
• Flow diagrams showing proposed
design capacity for engineering design
verification and safety determination;
• Commercial and economic data
presenting the basis for the proposed
action; and
• Cost of the proposed facilities,
plans for financing, and estimated
revenues and expenses related to the
proposed facility for accounting and
financial evaluation.
The Commission implements these
filing requirements in the Code of
Federal Regulations (CFR) under 18 CFR
Parts 157.5–.11; 157.13–.20; 157.53;
157.201–.209; 157.211; 157.214–.218;
284.8; 284.11; 284.126; 284.221;
284.224.
Type of Respondent: Natural Gas
Pipelines.
Estimate of Annual Burden: The
Commission estimates the annual public
reporting burden for the information
collection as:

FERC–537—GAS PIPELINE CERTIFICATES: CONSTRUCTION, ACQUISITION, AND ABANDONMENT
Number of
respondents

Annual number of
responses per
respondent

Total number of
responses

Average burden hours
& cost per response 5

Total annual burden
hours & total annual
cost

Cost per respondent
($)

(1)

(2)

(1)*(2) = (3)

(4)

(3)*(4) = (5)

(5) ÷ (1)

389

1.2

467

133
$9,377

62,111
$4,379,059

$11,257

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A more granular breakdown of the
average burden hour figure (i.e. 133
hours per response) follows:
Number of
respondents

Number of
responses

Avg. hours per
response

Regulation section 18 CFR . . .

Regulation topic

157.5–.11; & 157.13–.20 .................
157.53 ..............................................
157.201–.209; 157.211; 157.214–
.218.
157.201–.209; 157.211; 157.214–
.218.
284.11 ..............................................

Interstate certificate and abandonment applications ....
Exemptions ....................................................................
Blanket Certificates prior notice filings ..........................

149
149
149

82
0.5
46

500
100
200

Blanket Certificates—annual reports .............................

198

294

50

NGPA Sec. 311 Construction—annual reports .............

198

294

50

2 15

U.S.C. 3301–3432.
U.S.C. 717–717w.
4 18 CFR 284.8.

5 The estimates for cost per response are derived
using the following formula: Average Burden Hours
per Response * $70.50 per Hour = Average Cost per
Response. The cost per hour figure is the FERC

3 15

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average salary. Subject matter experts found that
industry employment costs closely resemble FERC’s
regarding the FERC–537 information collection.

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Federal Register / Vol. 79, No. 196 / Thursday, October 9, 2014 / Notices
Number of
respondents

Regulation section 18 CFR . . .

Regulation topic

284.8 ................................................
284.126(a)&(c) .................................

284.224 ............................................
157.5–.11; & 157.13–.20 .................

Capacity Release—record keeping ...............................
Intrastate bypass, semi-annual transportation & storage—reports.
Blanket Certificates—one time filing, inc. new tariff and
rate design proposal.
Hinshaw Blanket Certificates ........................................
Non-facility certificate or abandonment applications ....

TOTALS ....................................

........................................................................................

284.221 ............................................

1 Distinct

1 389

Number of
responses

Avg. hours per
response

0
37

N/A
48

75
30

60

N/A

100

5
0

5
N/A

75
75

distinct
entities.

467

2 133

average,
weighted.

entities.
weighted.

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2 Average

FERC–725F, Mandatory Reliability
Standards for Nuclear Plant Interface
Coordination
OMB Control No.: 1902–0249.
Abstract: The Commission requires
the information collected by the FERC–
725F to implement the statutory
provisions of section 215 of the Federal
Power Act (FPA) (16 U.S.C. 824o). On
August 8, 2005, the Electricity
Modernization Act of 2005, which is
Title XII, Subtitle A, of the Energy
Policy Act of 2005 (EPAct 2005), was
enacted into law.7 EPAct 2005 added a
new section 215 to the FPA, which
required a Commission-certified Electric
Reliability Organization (ERO) to
develop mandatory and enforceable
Reliability Standards, which are subject
to Commission review and approval.
Once approved, the Reliability
Standards may be enforced by the ERO
subject to Commission oversight, or the
Commission can independently enforce
Reliability Standards.8
On February 3, 2006, the Commission
issued Order No. 672, implementing
section 215 of the FPA.9 Pursuant to
Order No. 672, the Commission certified
one organization, North American

Electric Reliability Corporation (NERC),
as the ERO. The Reliability Standards
developed by the ERO and approved by
the Commission apply to users, owners
and operators of the Bulk-Power System
as set forth in each Reliability Standard.
On November 19, 2007, NERC filed its
petition for Commission approval of the
Nuclear Plant Interface Coordination
Reliability Standard, designated NUC–
001–1. In Order No. 716, issued October
16, 2008, the Commission approved the
standard while also directing certain
revisions.10 Revised Reliability
Standard, NUC–001–2, was filed with
the Commission by NERC in August
2009 and subsequently approved by the
Commission January 21, 2010.11
The purpose of Reliability Standard
NUC–001–2 is to require ‘‘coordination
between nuclear plant generator
operators and transmission entities for
the purpose of ensuring nuclear plant
safe operation and shutdown.’’ 12 The
Nuclear Reliability Standard applies to
nuclear plant generator operators
(generally nuclear power plant owners
and operators, including licensees) and
‘‘transmission entities,’’ defined in the
Reliability Standard as including a

nuclear plant’s suppliers of off-site
power and related transmission and
distribution services. To account for the
variations in nuclear plant design and
grid interconnection characteristics, the
Reliability Standard defines
transmission entities as ‘‘all entities that
are responsible for providing services
related to Nuclear Plant Interface
Requirements (NPIRs),’’ and lists eleven
types of functional entities (heretofore
described as ‘‘transmission entities’’)
that could provide services related to
NPIRs.13
FERC–725F information collection
requirements include establishing and
maintaining interface agreements,
including record retention
requirements. These agreements are not
filed with FERC but with the
appropriate entities as established by
the Reliability Standard.
Type of Respondent: Nuclear
operators, nuclear plants, transmission
entities.
Estimate of Annual Burden: The
Commission estimates the average
annual burden for this information
collection as:

6 The number for these filings is accounted for in
other regulatory categories in FERC–537.
7 Energy Policy Act of 2005, Public Law 109–58,
Title XII, Subtitle A, 119 Stat. 594, 941 (2005), 16
U.S.C. 824o.
8 16 U.S.C. 824o(e)(3).
9 Rules Concerning Certification of the Electric
Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of
Electric Reliability Standards, Order No. 672, FERC
Stats. & Regs. ¶ 31,204, order on reh’g, Order No.
672–A, FERC Stats. & Regs. ¶ 31,212 (2006).
10 Mandatory Reliability Standard for Nuclear
Plant Interface Coordination, Order No. 716, 125
FERC ¶ 61,065, at P 189 & n.90 (2008), order on
reh’g, Order No. 716–A, 126 FERC ¶ 61,122 (2009).
11 North American Electric Reliability
Corporation, 130 FERC ¶ 61,051 (2010). When the
revised Reliability Standard was approved the

Commission did not go to OMB for approval. It is
assumed that the changes made did not
substantively affect the information collection and
therefore a formal submission to OMB was not
needed.
12 See Reliability Standard NUC–001–2 at http://
www.nerc.com/files/NUC-001-2.pdf.
13 The list of functional entities consists of
transmission operators, transmission owners,
transmission planners, transmission service
providers, balancing authorities, reliability
coordinators, planning authorities, distribution
providers, load-serving entities, generator owners
and generator operators.
14 The cost for reporting requirements is $73.83/
hour and is based on a composite loaded (wage plus
benefits) average wage for an electrical engineer,
attorney, and administrative staff. The cost for
record keeping is $29.01 and is based on the loaded

wage for a file clerk. The wages are generated from
Burueau of Labor Statistics data retrieved
September, 2014 from http://www.bls.gov/oes/
current/naics2_22.htm. The loaded wage is
calculated using BLS data indicating, as of Sept 1,
2014, that wages make up 69.9% of total salary
(http://www.bls.gov/news.release/ecec.nr0.htm).
15 This figure of 130 transmission entities is based
on the assumption that each agreement will be
between 1 nuclear plant and 2 transmission entities
(65 times 2 = 130). However, there is some double
counting in this figure because some transmission
entities may be party to multiple agreements with
multiple nuclear plants. The double counting does
not affect the burden estimate and the correct
number of unique respondents will be reported to
OMB. The actual number of unique entities subject
to this collection is 143.

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FERC–725F

New agreements (Reporting).
New Agreements (Record
Keeping).
Modifications to agreements
(Reporting).
Modifications to Agreements
(Record Keeping).
Total .............................

Number of respondents

Annual
number of
responses per
respondent

Total number
of responses

Average
burden
hours & cost
per
response 14

Total annual
burden hours
& total annual
cost

Cost per
respondent
($)

(1)

(2)

(1)*(2) = (3)

(4)

(3)*(4) = (5)

(5) ÷ (1)

10 nuclear operators + 20
transmission entities.
10 nuclear operators + 20
transmission entities.
65 nuclear plants + 130
transmission entities 15.
65 nuclear plants + 130
transmission entities.
.............................................

FERC–725I, Mandatory Reliability
Standards for the Northeast Power
Coordinating Council
OMB Control No.: 1902–0258.
Abstract: This information collection
relates to two FERC approved Protection
and Control (PRC) regional Reliability
Standards: PRC–002–NPCC–01—
Disturbance Monitoring, and PRC–006–
NPCC–1—Automatic Underfrequency
Load-Shedding. These Northeast Power
Coordinating Council (NPCC) regional
Reliability Standards require
respondents to provide recording
capability necessary to monitor the
response of the Bulk-Power System to
system disturbances, including
scheduled and unscheduled outages;
requires each reliability coordinator to
establish requirements for its area’s
dynamic disturbance recording needs;
establishes disturbance data reporting
requirements; and requires planning
coordinators to incrementally gather
data, run studies, and analyze study
results to design or update the UFLS
programs that are required in the
regional Reliability Standard in addition

Information collection requirements

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Jkt 235001

1

30

2

390

2

390

16 420

........................

1,080
$79,736
108
$3,133
66.67
$4,922
6.67
$193
64,240
$4,481,091

32,400
$2,392,092
3,240
$93,992
26,000
$1,919,581
2,600
$75,426
........................

$79,736
3,133
9,844
387
........................

Information collection burden for
Reliability Standard PRC–006–NPCC–01
is based on the time needed for
planning coordinators and generator
owners to incrementally gather data, run
studies, and analyze study results to
design or update the UFLS programs
that are required in the regional
Reliability Standard in addition to the
requirements of the NERC Reliability
Standard PRC–006–1.21 There is also
burden on the generator owners to
maintain data.
Type of Respondent: Entities
registered with the North American
Electric Reliability Corporation (NERC)
as Generator Owners, Transmission
Owners, Reliability Coordinators and
Planning Coordinators
Estimate of Annual Burden: The
number of respondents is based on
NERC’s registry as of August 27, 2014.
Entities registered for more than one
applicable function type have been
accounted for in the figures below. The
Commission estimates the annual public
reporting burden for the information
collection as:

Number of
respondents

Annual
number of
responses per
respondent

Total number
of responses

Average
burden hours
& cost per
response 22

Total annual
burden hours
& total annual
cost

Cost per
Respondent
($)

(1)

(2)

(1)*(2) = (3)

(4)

(3)*(4) = (5)

(5) ÷ (1)

1

16 The recordkeeping ‘‘responses’’ are considered
to be part of (i.e. to be contained within the same
quantity as) the Reporting responses leading to a
total number of unique responses of 420 (390 + 30
= 420).
17 The burden estimates for Reliability Standard
PRC–006–1 are included in Order No. 763 (Final
Rule in RM11–20) and covered in FERC–725A
(OMB Control No. 1902–0244). OMB approved

17:56 Oct 08, 2014

30

to the requirements of the NERC
Reliability Standard PRC–006–1.17
Reliability Standard PRC–002–NPCC–
01 introduced several new mandatory
and enforceable requirements for the
applicable entities. However, when
FERC approved this standard NPCC had
(and continues to have) criteria 18 and
published guidance 19 addressing
similar requirements that the Reliability
Standard made mandatory. Thus, it is
usual and customary for affected entities
within NPCC to create, maintain and
store some of the same or equivalent
information identified in Reliability
Standard PRC–002–NPCC–01.
Therefore, many of the requirements
contained in PRC–002–NPCC–01 do not
impose new burdens on the affected
entities.20
Several requirements contained in
regional Reliability Standard PRC–002–
NPCC–01 were entirely new
responsibilities for the applicable
entities when the Commission approved
the standard and each of these is listed
in the estimated annual burden section
below.

R13: GO 23 and TO to have evidence it
acquired and installed dynamic disturbance recorders and a mutually agreed
upon implementation schedule with the
RC (record retention) ...........................

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1

1

1

those requirements on 7/9/2012 (ICR Reference No.
201204–1902–001).
18 Disturbance Monitoring Equipment Criteria
(Aug. 2007), available at https://www.npcc.org/
Standards/Criteria/A-15.pdf (Disturbance
Monitoring Criteria).
19 Guide for Application of Disturbance
Recording Equipment (Sept. 2006), available at

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10
$290

10
$290

$290

https://www.npcc.org/Standards/Guides/B-26.pdf
(Application Guide).
20 5 CFR 1320.3(b)(2) (2011).
21 The burden estimates for Reliability Standard
PRC–006–1 are included in Order No. 763 (Final
Rule in RM11–20) and currently covered in FERC–
725A (OMB Control No. 1902–0244). OMB
approved those requirements on 7/9/2012 (ICR
Reference No. 201204–1902–001).

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Information collection requirements

Number of
respondents

Annual
number of
responses per
respondent

Total number
of responses

Average
burden hours
& cost per
response 22

Total annual
burden hours
& total annual
cost

Cost per
Respondent
($)

(1)

(2)

(1)*(2) = (3)

(4)

(3)*(4) = (5)

(5) ÷ (1)

R14.5: GO and TO to have evidence of
a maintenance and testing program for
stand-alone disturbance monitoring
equipment
including
monthly
verification of active analog quantities

166

12

1,992

5
$305

9,960
$607,560

3,660

R14.7: GO and TO to record efforts to
return failed units to service if it takes
longer than 90 days 24 ..........................

33

1

33

33

1

33

330
$20,130
330
$9,570

610

R14.7: GO and TO record retention ........

10
$610
10
$290

R17: RC provide certain disturbance
monitoring equipment data to the Regional Entity upon request ...................

5

1

5

R17: RC record retention .........................

5

1

5

5
$305
10
$290

25
$1,525
50
$1,450

Total ..................................................

........................

25 2,031

........................

10,705
$640,525

........................

........................

290

305
290

RELIABILITY STANDARD PRC–006–NPCC–01
Information collection requirements

Number of
respondents

Annual
number of
responses per
respondent

Total number
of responses

Average
burden hours
& cost per
response

Total annual
burden hours
& total annual
cost

Cost per
respondent
($)

(1)

(2)

(1)*(2) = (3)

(4)

(3)*(4) = (5)

(5) ÷ (1)

PCs Design and document automatic
UFLS program ......................................

6

1

6

8
$488

48
$2,928

$488

PCs update and maintain UFLS program
database ...............................................

6

1

6

16
$976

96
$5,856

976

GOs provide documentation and data to
the planning coordinator .......................

145

1

145

145

1

145

2,320
$141,520
580
$16,820

976

GOs: record retention ..............................

16
$976
4
$116

Total ..................................................

........................

........................

302

........................

3,044
$167,124

........................

116

Dated: September 30, 2014.
Kimberly D. Bose,
Secretary.
[FR Doc. 2014–24057 Filed 10–8–14; 8:45 am]

mstockstill on DSK4VPTVN1PROD with NOTICES

BILLING CODE 6717–01–P

22 The estimates for cost per response are derived
using the following formula: Average Burden Hours
per Response * XX per Hour = Average Cost per
Response. The hourly cost figure comes from the
Bureau of Labor Statistics (http://www.bls.gov/oes/
current/naics2_22.htm and http://www.bls.gov/
news.release/ecec.nr0.htm). Record retention at a
wage plus benefits cost of $29/hour and the

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17:56 Oct 08, 2014

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remaining costs are based on the wage plus benefits
for an electrical engineer at $61/hour.
23 For purposes of these charts, generation owner
is abbreviated to GO, transmission owner is
abbreviated to TO, reliability coordinator is
abbreviated to RC, and planning coordinator is
abbreviated to PC.
24 We estimate that an entity will experience a
unit failure greater than 90 days once every five

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years. Therefore, 20 percent of NPCC’s 166
generator owners and transmission owners will
experience a unit failure of this duration each year.
25 The recordkeeping ‘‘responses’’ for R14.7 and
R17 are considered to be part of (i.e. to be contained
within the same quantity as) the Reporting
responses leading to a total number of unique
responses of 420 (390 + 30 = 420).

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