RM15-7_ 15-12_ 15-13_725G4_725S NOPR supporting statement

FERC-725G4 (OMB Control No.: 1902-TBD) and

FERC-725S (OMB Control No.: 1902-0270),

as implemented by the NOPR (issued 6/18/2015) in Docket Nos. RM15-7-000, RM15-12-000, and RM15-13-000

RIN: 1902-AF06

Supporting Statement for

FERC-725G4, Mandatory Reliability Standards: Reliability Standard

PRC-010-1 (Undervoltage Load Shedding)¹ and

FERC-725S, Mandatory Reliability Standards: Emergency Preparedness

and Operations (EOP) Reliability Standards

The Federal Energy Regulatory Commission (FERC or Commission) requests that the Office of Management and Budget (OMB) review the information collection requirements in the Notice of Proposed Rulemaking (NOPR) under Dockets RM15-7-000, RM15-12-000, RM15-13-000 under OMB Control Numbers 1902-TBD (FERC-725G4) and 1902-0270 (FERC-725S). This supporting statement is a consolidated document that covers the requirements of both information collections (FERC-725G4 and FERC-725S).

1. CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY

On August 8, 2005, The Electricity Modernization Act of 2005, which is Title XII of the Energy Policy Act of 2005 (EPAct 2005), was enacted into law. EPAct 2005 added a new Section 215 to the Federal Power Act (FPA), which requires 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. In 2006, the Commission certified the North American Electric Reliability Corporation (NERC) as the ERO pursuant to FPA section 215.²

On March 16, 2007, the Commission issued Order No. 693, approving 83 of the 107 Reliability Standards filed by NERC, including initial versions of EOP-001, EOP-002, and EOP-003. In addition, the Commission directed NERC to develop certain modifications to the EOP standards. In Order No. 693, the Commission also approved several Undervoltage Load Shedding (UVLS)-related Reliability Standards, including PRC-010-0, PRC-021-1 and PRC-022-1. Also, the Commission directed NERC to modify Reliability Standard PRC-010-0 to develop an “integrated and coordinated” approach to all protection systems. In Order No. 693, the Commission approved the NERC Glossary, including NERC’s currently-effective Special Protection System and Remedial Action Scheme definitions.

2. HOW, BY WHOM, AND FOR WHAT PURPOSE THE INFORMATION IS TO BE USED AND THE CONSEQUENCES OF NOT COLLECTING THE INFORMATION

The NOPR in Docket Nos. RM15-7, RM15-12, and RM15-13 proposes the following changes to Reliability Standards EOP-011-1 and PRC-010-1, and the Remedial Action Scheme (RAS).

Reliability Standard EOP-011-1, to be included in FERC-725S:

Proposed Reliability Standard EOP-011-1 includes six requirements, associated measures and evidence retention requirements and is applicable to balancing authorities, reliability coordinators and transmission operators. Requirements R1 and R2 require transmission operators and balancing authorities to develop, maintain and implement reliability coordinator-reviewed operating plans to mitigate operating, capacity and energy emergencies. Requirement R1 specifies elements for the plans “as applicable,” which is intended to provide flexibility to account for regional differences and pre-existing emergency mitigation methods. NERC states that the requirement for transmission operators and balancing authorities to maintain operating plans includes the expectation that the plans are current and up-to-date.

Requirement R3 requires reliability coordinators to review the operating plans submitted by transmission operators and balancing authorities and is designed to ensure that there is appropriate coordination of reliability risks identified in the operating plans. In reviewing operating plans, reliability coordinators shall consider compatibility, coordination and inter-dependency with other entity operating plans and notify transmission operators and balancing authorities if revisions to their operating plans are necessary.

Requirement R4 requires transmission operators and balancing authorities to resolve any issues identified by the reliability coordinator and resubmit their revised operating plans within a time period specified by the reliability coordinator. Requirement R5 requires each reliability coordinator to notify balancing authorities and transmission operators in its area, and neighboring reliability coordinators, within thirty minutes of receiving an emergency notification. Requirement R6 requires a reliability coordinator with a balancing authority experiencing a potential or actual energy emergency to declare an energy emergency alert in accordance with Attachment 1.

The Measures describe the evidence which entities have to be able to produce to demonstrate compliance with the Requirements. The Evidence Retention (Section 1.2) explains how long the records must be retained and says in part:

• Each Responsible Entity shall retain the current Operating Plan plus each

version issued since the last audit for Requirements R1, and Measure M1.

• Each Responsible Entity shall retain evidence of compliance since the last audit for Requirements R2, R3 and Measure M2, M3.

If a Responsible Entity is found non-compliant, it shall keep information related to the non-compliance until mitigation is complete and approved or for the duration specified above, whichever is longer.

The Compliance Enforcement Authority shall keep the last audit records and all requested and submitted subsequent audit records.

Proposed Reliability Standard EOP-011-1 also includes the following revised definition of Energy Emergency:

Energy Emergency—A condition when a Load-Serving Entity or Balancing Authority has exhausted all other resource options and can no longer meet its expected Load obligations.

NERC explains that the proposed revised definition is intended to clarify that an energy emergency is not limited to a load-serving entity and, based on a review of the impact on the body of NERC Reliability Standards, “does not change the reliability intent of other requirements of Definitions.”

Reliability Standard PRC-010-1, to be included in FERC-725G4:

NERC states that proposed Reliability Standard PRC-010-1 is a single, comprehensive standard that addresses the same reliability principles outlined in the four currently-effective UVLS-related Reliability Standards. NERC explains that the purpose of proposed Reliability Standard PRC-010-1 is to “establish an integrated and coordinated approach to the design, evaluation, and reliable operation of Undervoltage Load Shedding Programs” as directed by the Commission in Order No. 693. Also, according to NERC, proposed Reliability Standard PRC-010-1 replaces the applicability to and involvement of “Regional Reliability Organization” in Reliability Standards PRC-020-1 and PRC-021-1 and consolidates the four currently-effective UVLS-Related Standards into one comprehensive standard. NERC states that proposed Reliability Standard PRC-010-1 “reflects consideration of the 2003 Blackout Report recommendations,” particularly, Recommendation 21 for NERC to “make more effective and wider use of system protection measures” and Recommendation 21C that “NERC determine the goals and principles needed to establish an integrated approach to relay protection for generators and transmission lines, as well as of UFLS and UVLS programs.”

Proposed Reliability Standard PRC-010-1 incorporates a proposed definition of UVLS Program, which reads:

Undervoltage Load Shedding Program (UVLS Program): An automatic load shedding program, consisting of distributed relays and controls, used to mitigate undervoltage conditions impacting the Bulk Electric System (BES), leading to voltage instability, voltage collapse, or Cascading. Centrally controlled undervoltage-based load shedding is not included.

NERC explains that “to ensure that the applicability of the proposed Reliability Standard covers undervoltage‐based load shedding systems whose performance has an impact on system reliability, a UVLS Program must mitigate risk of one or more of the following: voltage instability, voltage collapse, or Cascading impacting the Bulk Electric System. By focusing on the enumerated risks, the definition is meant to exclude locally‐applied relays that are not designed to mitigate wide‐area voltage collapse.” NERC states that the proposed UVLS Program definition “clearly identifies and separates centrally controlled undervoltage-based load shedding, which is now addressed by the proposed definition of Remedial Action Scheme.”

Proposed Reliability Standard PRC-010-1 applies to planning coordinators and transmission planners because “either may be responsible for designing and coordinating the UVLS Program…[and] also applies to Distribution Providers and Transmission Owners responsible for the ownership, operation and control of UVLS equipment as required by the UVLS Program established by the Transmission Planner or Planning Coordinator.” NERC explains that the planning coordinator or transmission planner that establishes a UVLS Program is responsible for identifying the UVLS equipment and the necessary distribution provider and transmission owner (referred to as “UVLS entities” in the Applicability section) that performs the required actions.

NERC states that proposed Reliability Standard PRC-010-1 “applies only after an entity has determined the need for a UVLS Program as a result of its own planning studies.” NERC explains that the eight requirements in proposed Reliability Standard PRC-010-1 meet four primary objectives: (1) the proposed standard requires applicable entities to evaluate a UVLS Program’s effectiveness prior to implementation, including coordination with other protection systems and generator voltage ride-through capabilities;(2) applicable entities must comply with UVLS program specifications and implementation schedule; (3) applicable entities must perform periodic assessment and performance analysis; and (4) applicable entities must maintain and share UVLS Program data.

Proposed Requirement R1 requires each planning coordinator or transmission planner that is developing a UVLS Program to evaluate the viability and effectiveness of its program before implementation to confirm its effectiveness in resolving the undervoltage conditions for which it was designed, and that it is integrated through coordination with generator ride-through capabilities and other protection and control systems. Also, the planning coordinator or transmission planner must provide the UVLS Program specifications and implementation schedule to the applicable UVLS entities. Requirement R2 requires UVLS entities to meet the UVLS Program’s specifications and implementation schedule provided by the planning coordinator or transmission planner or address any necessary corrective actions in accordance with Requirement R5.

Requirement R3 requires each planning coordinator or transmission planner to perform periodic comprehensive assessments at least every 60 calendar months to ensure continued effectiveness of the UVLS program, including whether the program resolves identified undervoltage issues and that it is integrated and coordinated with generator voltage ride-through capabilities and other specified protection and control systems. Requirement R4 requires each planning coordinator or transmission planner to commence a timely assessment of a voltage excursion subject to the UVLS Program, within twelve calendar months of the event, to evaluate whether the UVLS Program resolved the undervoltage issues associated with the event. Requirement R5 requires a planning coordinator or transmission planner to develop a corrective action plan for any program deficiencies identified during an assessment performed under either Requirement R3 or R4, and provide an implementation schedule to UVLS entities within three calendar months of its completion.

Pursuant to Requirement R6, a planning coordinator must update the data necessary to model its UVLS Program for use in event analyses and program assessments at least each calendar year. Requirement R7 requires each UVLS entity to provide data to its planning coordinator, according to the planning coordinator’s format and schedule, to support maintenance of the UVLS Program database. Requirement R8 requires a planning coordinator to provide its UVLS Program database to other planning coordinators and transmission planners within its Interconnection, and other functional entities with a reliability need, within thirty calendar days of a written request.

The Measures describe the evidence which entities have to be able to produce to demonstrate compliance with the Requirements. The Evidence Retention (Section1.3, Data Retention) explains how long the records must be retained

NERC proposes that PRC-010-1 and the revised definition of UVLS Program shall become effective on the first day of the first calendar quarter that is twelve months after the date that the standard and definition are approved by the Commission. NERC also proposes to retire PRC-010-0, PRC-020-1, PRC-021-1, and PRC-022-1³ at midnight of the day immediately prior to the effective date of PRC-010-1. Further, NERC explains that proposed Reliability Standard PRC-010-1 addresses reliability obligations that are set forth in Requirements R2, R4 and R7 of currently-effective Reliability Standard EOP-003-2. Since NERC has proposed to retire EOP-003-2⁴ in the petition seeking approval of proposed Reliability Standard EOP-011-1 (Docket No. RM15-7-00, discussed above), concurrent Commission action on the two petitions will prevent a possible reliability gap.

Remedial Action Scheme (RAS):

NERC proposes an effective date for the revised Reliability Standards and the revised definition of “Remedial Action Scheme” on the first day of the first calendar quarter that is twelve months after Commission approval. NERC also proposes that for entities with existing schemes that become newly classified as “Remedial Action Schemes” resulting from the application of the revised definition, the entities will have additional time of up to twenty-four months from the effective date to be fully compliant with all applicable Reliability Standards. Further, NERC asks the Commission to take final action concurrently with the NERC petition on proposed Reliability Standard PRC-010-1 (Docket No. RM15-12-000) because “[t]he proposed definitions of UVLS Program and Remedial Action Scheme in each project have been coordinated to cover centrally controlled UVLS as a Remedial Action Scheme. Final action by the Commission is needed contemporaneously on both petitions to facilitate implementation and avoid a gap in coverage of centrally controlled UVLS.”

3. DESCRIBE ANY CONSIDERATION OF THE USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE THE BURDEN AND TECHNICAL OR LEGAL OBSTACLES TO REDUCING BURDEN

These collections do not require information to be filed with the Commission. However, they do contain information collection and record retention requirements for which using current technology is an option.

4. DESCRIBE EFFORTS TO IDENTIFY DUPLICATION AND SHOW SPECIFICALLY WHY ANY SIMILAR INFORMATION ALREADY AVAILABLE CANNOT BE USED OR MODIFIED FOR USE FOR THE PURPOSE(S) DESCRIBED IN INSTRUCTION NO. 2

The Commission periodically reviews filing requirements concurrent with OMB review or as the Commission deems necessary to eliminate duplicative filing and to minimize the filing burden. Under this proceeding, Reliability Standards EOP-011-1, PRC-010-1, and RAS redefinition do not duplicate any filing requirements (other than those being replaced as described in the NOPR).

5. METHODS USED TO MINIMIZE THE BURDEN IN COLLECTION OF INFORMATION INVOLVING SMALL ENTITIES

FERC estimates that there are 15⁵ small entities applicable to this rule. FERC considers the impact of the rule to be very minimal. In general, small entities may reduce their burden by taking part in a joint registration organization or a coordinated functional registration. These options allow a small entity to share the compliance burden with other entities and, thus, to minimize their own compliance burden. Detailed information regarding these options is available in NERC’s Rule of Procedure at Sections 507 and 508⁶.

6. CONSEQUENCE TO FEDERAL PROGRAM IF COLLECTION WERE CONDUCTED LESS FREQUENTLY

If the requirements of these standards (and revision of RAS) were performed less frequently, NERC would not be provided the necessary information to appropriately assess the compliance with the requirements of each standard (and the revision of RAS).

7. EXPLAIN ANY SPECIAL CIRCUMSTANCES RELATING TO THE INFORMATION COLLECTION

There is one special circumstance as described in 5 CFR 1320.5(d)(2) related to this information collection. For Reliability Standard PRC-010-1, the applicable entity shall retain documentation as evidence for six calendar years. Industry felt strongly that a six-year cycle was technically sound and much less burdensome and costly when considering possible options such as: (a)performing the engineering work more frequently and retaining the records for a shorter period (such as 3 years), or (b)performing the engineering work less frequently and retaining the records for a longer period (six years). There is a very limited group of engineers that have the technical skill set to perform the work, and it does not need to be performed as often as every three years. Industry said that performing the engineering work less frequently and retaining the records for six years was a much less onerous, burdensome, and expensive solution.

Audits are usually performed every 3 years, so the data retention requirements otherwise generally present no special circumstances.

The data retention requirement in the Reliability Standard EOP-011-1 states:

• The Transmission Operator shall retain the current Operating Plan(s), evidence of review or revision history plus each version issued since the last audit and evidence of compliance since the last audit for Requirements R1 and R4and Measures M1 and M4.

• The Balancing Authority shall retain the current Operating Plan(s), evidence of review or revision history plus each version issued since the last audit and evidence of compliance since the last audit for Requirements R2 and R4, and Measures M2 and M4.

• The Reliability Coordinator shall maintain evidence of compliance since the last audit for Requirements R3, R5, and R6 and Measures M3, M5, and M6.

The data retention requirement in the Reliability Standard PRC-010-1 states:

• The Planning Coordinator, Transmission Planner, Distribution Provider, and Transmission Owner shall keep data or evidence to show compliance as identified below unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation.

• The applicable entity shall retain documentation as evidence for six calendar years. If an applicable entity is found non‐compliant, it shall keep information related to the non‐compliance until mitigation is complete and approved, or for the time specified above, whichever is longer.

• The Compliance Enforcement Authority shall keep the last audit records and all requested and submitted subsequent audit records.

8. DESCRIBE EFFORTS TO CONSULT OUTSIDE THE AGENCY: SUMMARIZE PUBLIC COMMENTS AND THE AGENCY’S RESPONSE

The ERO process to establish Reliability Standards is a collaborative process with the ERO, Regional Entities, and other stakeholders developing and reviewing drafts and providing comments. The final proposed reliability standards were submitted by NERC to the FERC for review and approval.

In addition, each FERC rulemaking (both proposed and final rules) is published in the Federal Register thereby providing public utilities and licensees, state commissions, Federal agencies, and other interested parties an opportunity to submit data, views, comments or suggestions concerning the proposed collections of data. The proposed rule was published in the Federal Register on 6/24/2015 (80 FR 36293).

9. EXPLAIN ANY PAYMENT OR GIFTS TO RESPONDENTS

There are no gifts or payments given to the respondents.

10. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS

According to the NERC Rules of Procedure⁷, “…a Receiving Entity shall keep in confidence and not copy, disclose, or distribute any Confidential Information or any part thereof without the permission of the Submitting Entity, except as otherwise legally required.” This serves to protect confidential information submitted to NERC or Regional Entities.

Responding entities do not submit the information collected under the proposed Reliability Standard to FERC. Rather, they maintain it internally. Since there are no submissions made to FERC, FERC provides no specific provisions in order to protect confidentiality.

11. PROVIDE ADDITIONAL JUSTIFICATION FOR ANY QUESTIONS OF A SENSITIVE NATURE, SUCH AS SEXUAL BEHAVIOR AND ATTITUDES, RELIGIOUS BELIEFS, AND OTHER MATTERS THAT ARE COMMONLY CONSIDERED PRIVATE.

This collection does not include any questions of a sensitive nature.

12. ESTIMATED BURDEN OF COLLECTION OF INFORMATION

The estimated public reporting burden due to this NOPR in Dockets RM15-7-000, RM15-12-000, and RM15-13-000 follows. The burden due to this NOPR is in addition to the baseline of burden covered in FERC-725A for the existing versions of the standards which are being retired, replaced, or combined. (See Footnotes 3 and 4 for more information.)

The first set of tables details the burden changes for each standard (EOP-011-1 [going into FERC-725S] and, PRC-010-1 [going into FERC-725G4]); the second set of tables summarizes the effect for each collection.

FERC-725S, as modified by Rel. Std. EOP-011-1 in the NOPR8
	Number of Applicable Registered Entities (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden (Hours) & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
RC tasks necessary for EOP-011-1 compliance	11	1	11	1,500 hrs.; $92,3879	16,500 hrs.; $1,016,257	$92,387

FERC-725G4, as implemented by Rel. Std. PRC-010-1 in the NOPR10
	Number of Applicable Registered Entities (1)		Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden (Hours) & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
DP – Requirement 2	2	1		23	36 hrs.;11 $1,906.32	828 hrs.; $43,845.36	$1,906
TP - Requirement2	3	1		3	36 hrs.;12 $1,906.32	324 hrs.; $17,156.07	$1,906
DP - Requirement2 Data Retention	23	1		23	12 hrs.; $367.9213	276 hrs.; $8,462.16	$368
TP – Requirement2 Data Retention	3	1		3	12 hrs.; $367.92	36 hrs.; $1,103.76 14	$368
TOTAL						1,464 hrs.; $70,567.35

The proposed revisions to the Remedial Action Scheme (RAS) definition and proposed Reliability Standards are not expected to result in changes to the scope of systems covered by the proposed Reliability Standards and other Reliability Standards that include the term Remedial Action Scheme. Therefore, the Commission does not expect the proposed revisions to the RAS to affect applicable entities’ current reporting burden.

13. ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS

There are no start-up or other non-labor costs.

Total Capital and Start-up cost: $0

Total Operation, Maintenance, and Purchase of Services: $0

All of the costs in the proposed rule are associated with burden hours (labor) and described in Questions #12 and #15 in this supporting statement.

14. ESTIMATED ANNUALIZED COST TO FEDERAL GOVERNMENT

The Regional Entities and NERC do most of the data processing, monitoring and compliance work for Reliability Standards. Any involvement by the Commission is covered under the FERC-725 collection (OMB Control No. 1902-0225) and is not part of this request or package.

The estimated annualized cost to the Federal Government for FERC-725S and FERC-725G4 as related to the requirements in the NOPR in RM15-7-000, RM15-12-000 and RM15-13-000 follows.

FERC-725S	Number of Employees (FTEs)	Estimated Annual Federal Cost
FERC-725S Analysis and Processing of filings	0	$0
Paperwork Reduction Act Administrative Cost15		$5,193
TOTAL		$5,193

FERC-725G4	Number of Employees (FTEs)	Estimated Annual Federal Cost
FERC-725G4 Analysis and Processing of filings	0	$0
Paperwork Reduction Act Administrative Cost16		$5,193
TOTAL		$5,193

15. REASONS FOR CHANGES IN BURDEN INCLUDING THE NEED FOR ANY INCREASE

Inventory prior to implementation of the NOPR in Docket Nos. RM15-7-000, RM15-12-000, and RM15-13-000. The existing OMB-approved annual burden is:

• FERC-725S (OMB Control No. 1902-0270):3,980 hours [details in first table below]

• FERC-725G4 (OMB Control No. 1902-TBD):0 hours.

FERC-725S, Existing Burden Estimate for Reliability Standard EOP-010-1 Prior to Implementation of the NOPR
Reliability Standard Number	Type of Respondents	Number of Respondents17 (1)	Number of Responses per Respondent (2)	Average Burden Hours Per Response (3)	Total Annual Burden Hours (1)x(2)x(3)	Total Annual Cost18
EOP-010-1 (R1)	Reliability Coordinator	16	1	20	320	$19,200 ($60/hr)
EOP-010-1 (R3)	Transmission Operator	183	1	20	3,660	$219,600 ($60/hr)
TOTAL					3,980	$238,800

FERC-725G4 is a new (and temporary) collection and, thus, has no existing burden approved by OMB. Any burden hours and cost applied to FERC-725G4 is intended eventually to reside in FERC-725G (OMB Control No. 1902-0252).

Implementation of the NOPR in Docket Nos. RM15-7-000, RM15-12-000, and RM15-13-000.

[The burden due to this NOPR is in addition to the baseline of burden covered in FERC-725A for the existing versions of the standards which are being retired, replaced, or combined. (See Footnotes 3 and 4 for more information.)]

As explained in the NOPR, “the Commission proposes to approve Reliability Standards EOP-011-1 (Emergency Operations) and PRC-010-1 (Undervoltage Load Shedding). NERC explains that the proposed Reliability Standards consolidate, streamline, and clarify the existing requirements of certain currently-effective Emergency Preparedness and Operations (EOP) and Protection and Control (PRC) standards. The Commission also proposes to approve NERC’s revised definition of the term “Remedial Action Scheme” as set forth in the NERC Glossary of Terms Used in Reliability Standards (NERC Glossary), and modifications of specified Reliability Standards to incorporate the revised definition. Further, the Commission proposes to approve assigned violation risk factors and violation severity levels, proposed implementation plans, and the retirement of certain currently-effective Reliability Standards. The Commission discusses concerns regarding several of NERC’s proposals and, depending on the comments provided in response, the Commission may direct NERC to develop further modifications to address the concerns and possibly delay the retirement of one currently-effective standard.”

Summary of Current and New Burden.

FERC-725S	Total Request	Previously Approved	Change due to Adjustment in Estimate	Change Due to Agency Discretion
Annual Number of Responses	210	199	0	+11
Annual Time Burden (Hr)	20,480	3,980	0	+16,500
Annual Cost Burden ($)	$0	$0	$0	$0

FERC-725G4	Total Request	Previously Approved	Change due to Adjustment in Estimate	Change Due to Agency Discretion
Annual Number of Responses	52	0	0	+52
Annual Time Burden (Hr)	1,464	0	0	+1,464
Annual Cost Burden ($)	$0	$0	$0	$0

16. TIME SCHEDULE FOR PUBLICATION OF DATA

There are no tabulating, statistical or tabulating analysis or publication plans for the collection of information.

17. DISPLAY OF EXPIRATION DATE

The expiration dates are displayed in a table posted on ferc.gov at http://www.ferc.gov/docs-filing/info-collections.asp.

18. EXCEPTIONS TO THE CERTIFICATION STATEMENT

The Commission does not use the data collected for this reporting requirement for statistical purposes.

1 FERC-725G4 is a temporary collection number in order to submit this ICR and NOPR to OMB timely. Long-term, the FERC-725G4 information collection requirements should be included in FERC-725G (Mandatory Reliability Standards for the Bulk-Power System: PRC Standards; OMB Control No. 1902-0252). However, there is another, unrelated ICR for FERC-725G, which is pending OMB review at this time, and only one item can be pending at a time per OMB Control No. Therefor we are using the temporary collection number FERC-725G4.

2 North American Electric Reliability Corp., 116 FERC ¶ 61,062, order on reh’g & compliance, 117 FERC ¶ 61,126 (2006), aff’d sub nom. Alcoa, Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009).

3 Reliability Standards PRC-010-0, PRC-021-1, and PRC-022-1 were approved in Order 693 (issued March 16, 2007 in Docket No. RM06-16) and are included in FERC-725A (Mandatory Reliability Standards for the Bulk-Power System; OMB Control No. 1902-0244).

Reliability Standard PRC-020-1 was never approved or enforced by FERC.

4 Reliability Standard EOP-003-2 (approved in Order 763, issued May 7, 2012, in Docket No. RM11-20-000) is included in FERC-725A (Mandatory Reliability Standards for the Bulk-Power System, OMB Control No. 1902-0244).

5 31.9% of affected entities

6 http://www.nerc.com/FilingsOrders/us/RuleOfProcedureDL/NERC_ROP_Effective_20140701_updated_20140602%20(updated).pdf

7 Section 1502, Paragraph 2, available at NERCs website.

8 RC=Reliability Coordinator

9 The 1,500 hour figure is broken into 1,300 hours at the engineer wage rate and 200 hours at the clerk wage rate. These estimates assume that the engineer’s wage rate will be $66.35/hr., and the clerk’s wage rate will be $30.66/hr. These figures are taken from the Bureau of Labor Statistics, data for May 2014 (and posted April 1, 2015), at http://www.bls.gov/oes/current/naics2_22.htm; Occupation Code: 17-2071 (engineer) and 43-4071 (clerk).

10 DP = distribution provider and TP = transmission planner.

11 The 36 hour figure is broken into 24 hours at the engineer wage rate and 12 hours at the clerk wage rate. These estimates assume that the engineer’s wage rate will be $66.35/hr. and the clerk’s wage rate will be $30.66/hr. These figures are taken from the Bureau of Labor Statistics, data for May 2014 (and posted April 1, 2015), at http://www.bls.gov/oes/current/naics2_22.htm; Occupation Codes 17-2071 (engineer) and 43-4071 (clerk).

12 Id.

13 The wage rate for a clerk is used for managing data retention.

14 Note that there was an inadvertent mathematical error in the NOPR. It stated 108 hrs. (rather than 36 hrs.) and $3,311.28 (rather than $1,103.76). The estimates for burden hours, corresponding cost, and resulting totals have been corrected in this supporting statement and submittal to OMB.

15 The PRA Administrative Cost is a Federal Cost associated with preparing, issuing, and submitting materials necessary to comply with the Paperwork Reduction Act (PRA) for rulemakings, orders, or any other vehicle used to create, modify, extend, or discontinue an information collection.   This average annual cost includes requests for extensions, all associated rulemakings (not just this NOPR), and other changes to the collection.

16 The PRA Administrative Cost is a Federal Cost associated with preparing, issuing, and submitting materials necessary to comply with the Paperwork Reduction Act (PRA) for rulemakings, orders, or any other vehicle used to create, modify, extend, or discontinue an information collection.   This average annual cost includes requests for extensions, all associated rulemakings (not just this NOPR), and other changes to the collection.

17 This number was calculated by adding all the applicable entities while removing double counting caused by entities registered under multiple functions.

18 The estimated hourly loaded cost (salary plus benefits) for an engineer is assumed to be $60/hour, based on salaries as reported by the Bureau of Labor Statistics (BLS) (http://bls.gov/oes/current/naics2_22.htm).  Loaded costs are BLS rates divided by 0.703 and rounded to the nearest dollar (http://www.bls.gov/news.release/ecec.nr0.htm).

10