740 Supporting_Statement_5-22-2019

FERC-740 (OMB Control No. 1902-0254)

Supporting Statement for

FERC-740, Availability of E-Tag Information to Commission Staff

The Federal Energy Regulatory Commission (Commission or FERC) requests that the Office of Management and Budget (OMB) review and approve, for a three-year period, FERC-740 (Availability of E-Tag Information to Commission Staff). FERC-740 is an existing information collection. No changes are being made to the reporting or recordkeeping requirements.

Background

E-Tags, also known as Requests for Interchange, are used to schedule interchange transactions¹ in wholesale markets. E-Tags document the movement of energy across an interchange over prescribed physical paths, for a given duration, and for a given energy profile(s), and include information about those entities with financial responsibilities for the receipt and delivery of the energy. E-Tags may contain information about the different types of entities involved in moving power across interchanges, including generators, transmission system operators, energy traders, and Load Serving Entities. Currently, the North American Electric Reliability Corporation (NERC) and the Western Electricity Coordinating Council (WECC) receive all e-Tag data in the Eastern and Western Interconnections, respectively, in near real-time, to assist Reliability Coordinators in identifying transactions that may need to be curtailed to relieve overloads when transmission constraints occur. At present, NERC and WECC contract with OATI, a commercial vendor, for data management services related to e-Tags. E-Tags are also included in the business practice standards adopted by the North American Energy Standards Board (NAESB) ² and incorporated by reference into the Commission’s regulations and public utility tariffs.

E-Tagging was first implemented by NERC on September 22, 1999, as a process to improve the speed and efficiency of the tagging process, which had previously been accomplished by e-mail, facsimile, and telephone exchanges.³ E-Tags require that, prior to scheduling transactions, one of the market participants involved in a transaction must submit certain transaction-specific information, such as the source and sink control areas (now referred to as Balancing Authority Areas) and control areas along the contract path, as well as the transaction’s level of priority and transmission reservation Open Access Same-Time Information System (OASIS) reference numbers, to control area operators and transmission operators on the contract path.⁴

Communication, submission, assessment, and approval of an e-Tag must be completed before the interchange transaction is implemented.⁵ The Interchange Scheduling and Coordination (INT) group of NERC Reliability Standards sets forth requirements for implementing interchange transactions through e-Tags. E-Tags are submitted pursuant to the business practices set forth by NAESB. Those business practices incorporate the protocols enumerated in the NAESB Electronic Tagging Functional Specifications for communicating and processing e-Tags. NAESB business practice standards for the wholesale electric industry are mandatory when they have been incorporated by reference by the Commission into its regulations.⁶ Several of the incorporated business practice standards require processing e-Tags in accordance with these specifications.⁷

In Docket RM11-12,⁸ the Commission amended its regulations, pursuant to sections 222 and 307(a) of the Federal Power Act (FPA),⁹ to grant the Commission access, on a non-public and ongoing basis, to the complete electronic tags (e-Tags)¹⁰ used to schedule the transmission of electric power interchange transactions in wholesale markets. The Order required e-Tag Authors¹¹ (through their Agent Service¹²) and Balancing Authorities¹³ (through their Authority Service¹⁴) to provide the Commission access to the e-Tags covered by Order 771 by designating the Commission as an addressee on the e-Tags. After the Commission was designated as an addressee, the Commission accesses the e-Tags by contracting with a commercial vendor. The commercial vendor provides data management services and receives e-Tags addressed to the Commission. E-Tag Authors and Balancing Authorities were required to provide Commission access to e-Tag data under this Final Rule by no later than March 15, 2013.

In addition, the Order required that Regional Transmission Organizations (RTOs), Independent System Operators (ISOs) and their Market Monitoring Units (MMUs) be afforded access to complete e-Tags, upon request to e-Tag Authors and Authority Services, subject to their entering into appropriate confidentiality agreements.

For more information on the information on a typical E-Tag and what it looks like, see the Supplementary Documents (sample e-Tag, and explanation of data fields) in ROCIS and reginfo.gov submitted as part of this clearance package.

A. JUSTIFICATION

1. Circumstances That Make the Collection of Information Necessary

Having access to the complete e-Tags used for interchange transactions enhances the Commission’s efforts to detect and prevent market manipulation and monitor market developments.

The Commission relies on its anti-manipulation authority under FPA section 222, along with its investigative authority under FPA section 307(a), as a basis for accessing e-Tag information related to wholesale electricity market transactions.

As part of the Energy Policy Act of 2005 (EPAct 2005),¹⁵ Congress granted the Commission authority over the prohibition of market manipulation in connection with the purchase or sale of electric energy and transmission subject to the Commission’s jurisdiction in FPA section 222. In addition, FPA section 222 prohibits energy market manipulation by “any entity,” including entities exempted from the Commission’s rate-related jurisdiction by FPA section 201(f).¹⁶ The application of this provision to “any entity” and not solely to public utilities is further evidenced by section 201(b)(2) of the FPA, which explicitly states that certain provisions, including section 222, shall apply to entities that fall within the scope of FPA section 201(f).¹⁷

Commission access to the information contained in e-Tags helps the Commission determine whether market manipulation is taking place and, absent these data, the Commission would be more limited in its ability to perform this function.

In addition to FPA section 222, FPA section 307(a) grants the Commission authority to “obtain[] information about the sale of electric energy at wholesale in interstate commerce and the transmission of electric energy in interstate commerce.” E-Tag data unquestionably provides “information about the sale of electric energy at wholesale in interstate commerce and the transmission of electric energy in interstate commerce.” Moreover, as discussed below with regard to the Commission’s need for e-Tag data, this information helps the Commission ascertain whether “any person, electric utility, transmitting utility, or other entity has violated or is about to violate any provisions of this Act or any rule, regulation, or order thereunder.” Obtaining e-Tag data from market participants or other entities is within the Commission’s authority under FPA section 307(a). And the Commission’s surveillance efforts are encompassed within its broad investigative authority as they are precisely what section 307 is designed to permit – i.e., “to determine whether any person [or entity]. . . has violated or is about to violate any provisions of the [FPA] … or in obtaining information about the sale of electric energy at wholesale in interstate commerce and the transmission of electric energy in interstate commerce.”

2. How, By Whom, And For What Purpose the Information Is To Be Used and the Consequences of Not Collecting the Information

In Order 771, the FERC-740 information collection (providing Commission staff access to e-Tag data) was implemented to provide the Commission, Market Monitoring Units (MMUs), Regional Transmission Organizations (RTOs), and Independent System Operators (ISOs) with information that allows them to perform market surveillance and analysis more effectively. The e-Tag information is necessary to understand the use of the interconnected electricity grid, particularly transactions occurring at interchanges. Due to the nature of the electricity grid, an individual transaction’s impact on an interchange cannot be assessed adequately in all cases without information from all connected systems, which is included in the e-Tags. The details of the physical path of a transaction included in the e-Tags helps the Commission to monitor interchange transactions effectively, detect and prevent price manipulation over interchanges, and ensure the efficient and orderly use of the transmission grid. For example, the e-Tag data allows the Commission to identify transmission reservations as they go from one market to another and link the market participants involved in that transaction.

Before the issuance of Order No. 771, the Commission relied on bespoke data requests to subjects of investigations to obtain this e-Tag data. The Commission used e-Tag data in its case against Gila River Power, LLC, to help demonstrate violation of its regulations prohibiting submission of inaccurate information, and similar provisions in the CAISO tariff by submitting transactions designated as wheel-through transactions (Gila River Power, LLC, 141 FERC ¶ 61,136 (2012)). E-Tag data was also necessary to resolve a similar case where Constellation Energy Commodities Group's admitted for falsely designating transactions as “Wheeling Through” transactions to improperly ensure awards of bids at multiple interties (Constellation Energy Commodities Group, Inc., 145 FERC ¶ 61,062 (2013)).

The FERC-740 data has enabled the Commission to obtain this data without the burden of preparing and responding to a data request. There are currently several confidential investigations in the Office of Enforcement that have used this data. Further, the Office of Enforcement has been incorporating FERC-740 data into its routine screening processes to detect potential market manipulation in the wholesale electric markets. By incorporating the e-Tag data into surveillance processes, the Commission is able to monitor the market, as a whole, for prohibited activities on an ongoing basis rather than as a response to a complaint.

Further, the FERC-740 data has been used by the Commission to better understand certain aspects of market design and to inform the Commission about various proceedings. Access to the data, for example, assisted in the review of San Francisco Bay Area Rapid Transit v. Pacific Gas and Electric Co. (151 FERC ¶ 61,030 (2015)), a complaint proceeding involving e-Tags associated with importing power into the CAISO Balancing Authority Area. Further, last year, the Commission used FERC-740 data to analyze certain aspects of Public Service Company of New Mexico’s application for market-based rate authority (153 FERC ¶ 61,060, at P 65 (2015)).

Order No. 771 provided the Commission access to e-Tags by requiring that Purchasing-Selling Entities (PSEs) and Balancing Authorities (BAs), list the Commission on the "CC" list of e-Tags so that the Commission can receive a copy of the e-Tags.

Without the e-Tag data, it would be more difficult for the Commission to fulfill its mission to assure just and reasonable rates.

3. Describe Any Consideration Of The Use Of Improved Technology To Reduce Burden And Technical Or Legal Obstacles To Reducing Burden.

The Commission obtains the e-Tag data in an electronic format. The Commission accesses the e-Tags by contracting with a commercial vendor, OATI. In early 2014, the North American Energy Standards Board (NAESB) incorporated the requirement that the Commission be added to the “CC” list on e-Tags as part of the tagging process.¹⁸ Even before NAESB added the FERC requirement to the tagging standards, the rules behind the "CC" list requirement had already been programmed into the industry standard tagging software so as to make the inclusion of FERC in the "CC" list automatic. The Commission understands that PSEs and BAs use existing, automated procedures to create and validate the e-Tags in a way that provides the Commission with access to them. In the rare event that a new BA would need to alert e-Tag administrators that certain tags it generates qualify for exemption under the Commission’s regulations (e.g., transmissions from a new Canadian BA into another Canadian BA), this administrative function would be expected to require less than an hour of effort total from both the BA and an e-Tag administrator to include the BA on the exemption list. New exempt BAs occur less frequently than every year, but for the purpose of estimation we will conservatively assume one appears each year creating an additional burden associated with the Commission’s FERC-740 requirement of $60.59.

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 as OMB review dates arise or as the Commission may deem necessary in carrying out its regulatory responsibilities. In order to eliminate duplication of effort or data, the Commission deliberately relied on existing industry processes and procedures to facilitate the collection of this information. The minimal change in the e-Tag specification required by the Commission, the addition of "FERC" as an entity with "CC list" access to the reservation, was necessary to allow access to the data across the industry for the first time. The e-Tag information is unique to each transaction and needed and used by industry to conduct normal business; FERC is accessing that existing information. To date, the Commission has found no duplication of application data elsewhere.

5. Methods Used To Minimize Burden in Collection of Information Involving Small Entities

Pre-existing procedures for processing and communicating e-Tags, which were largely automated, have been used to facilitate Commission access to e-Tags. The Commission requires that the Agent Service used by e-Tag Authors include the Commission on the CC list of entities with view-only rights to the e-Tags covered by the Final Rule in RM11-12.¹⁹ The inclusion of the Commission on the CC list happens automatically when an e-Tag Author submits its e-Tag request.

6. Consequence to Federal Program If Collection Were Conducted Less Frequently

The data collection is fully automated and automatic. Less frequent collection of the data would require burdensome reprogramming to little end. Less frequent access to the e-Tag data means an increased chance of unchecked anti-competitive or manipulative behavior among market participants.

7. Explain Any Special Circumstances Relating To the Information Collection

The basic requirement is that FERC be included as an addressee on the e-Tags. This is done automatically by the system.

8. Describe Efforts to Consult Outside the Agency: Summarize Public Comments and the Agency's Response to These Comments

The 60-day Notice²⁰ was published in the Federal Register, 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 collection of data. FERC received no comments.

The 30-day Notice²¹ will also be published in the Federal Register and request public comment.

9. Explain Any Payment or Gifts to Respondents

No payments or gifts are made to respondents.

10. Describe Any Assurance of Confidentiality Provided To Respondents

The Commission recognizes that some of the information contained in the e-Tags is likely commercially sensitive.²² Disclosure of such data could result in competitive harm to market participants and the market as a whole if disclosed without reasonable confidentiality restrictions.²³ Accordingly, the Commission has not made complete e-Tags publicly available. Furthermore, to the extent persons file requests to obtain data from the Commission under the Freedom of Information Act (FOIA), any commercially-sensitive data would be protected from disclosure if it satisfies the requirements of exemption 4 of the Freedom of Information Act (FOIA).²⁴ After the E-Tag Authors and Balancing Authorities designated the Commission as an addressee, the Commission has been accessing the e-Tags by contract with a commercial vendor, subject to confidentiality restrictions.

While the Commission finds that e-Tag data should be made available to RTOs, ISOs, and MMUs, this should be done subject to appropriate confidentiality restrictions. Furthermore, the Commission notes that such information may be shared among RTOs, ISOs and MMUs as part of an investigation of possible market violations or market design flaws as long as reasonable measures are taken to ensure that the information remains non-public.²⁵

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 contain any questions of a sensitive nature.

12. Estimated Burden of Collection of Information

The Commission understands that PSEs and BAs use existing, automated procedures to create and validate the e-Tags in a way that provides the Commission with access to them. In the rare event that a new BA would need to alert e-Tag administrators that certain tags it generates qualify for exemption under the Commission’s regulations (e.g., transmissions from a new Canadian BA into another Canadian BA), this administrative function would be expected to require less than an hour of effort total from both the BA and an e-Tag administrator to include the BA on the exemption list. New exempt BAs occur less frequently than every year, but for the purpose of estimation we will conservatively assume one appears each year creating an additional burden and cost of one hour and $65.68.²⁶

The process is completely automatic and part of the normal business requirement, so FERC is including only a ‘placeholder’ burden of one hour for any new Balancing Authority which may enter the field and need to perform the initial set-up to identify FERC as a ‘cc’ for e-Tags. Additional details are provided in Question 15, below.

The Commission estimates the annual public reporting burden and cost (rounded) for the information collection as follows.

FERC-740	Number of Respondents (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)
Purchasing-Selling Entities (e-Tag Authors)	355	4,482 (rounded)	1.591,208	Automatic, so 0 burden and cost	Automatic, so 0 burden and cost	Automatic, so 0 burden and cost
Balancing Authorities	81	19,645 (rounded) 4	1.591,208	Automatic, so 0 burden and cost	Automatic, so 0 burden and cost	Automatic, so 0 burden and cost
New Balancing Authority [as noted above]	1	1	1	1 hr.; $65.68	1 hr.; $65.68	$65.68
Total	471				1 hr.; $65.68	$65.68

13. Estimate of Total Annual Cost Burden to Respondents

There are no costs that are not associated with labor hours. Burden hour cost are detailed in #12 and #15.

14. Estimated Annualized Cost to Federal Government

The estimate of the cost for ‘analysis and processing of filings’ is based on salaries and benefits for professional and clerical support. This estimated cost represents staff analysis, decision-making, and review of the data.

The Paperwork Reduction Act (PRA) Administrative Cost is the average annual FERC cost associated with preparing, issuing, and submitting materials necessary to comply with the PRA for rulemakings, orders, or any other vehicle used to create, modify, extend, or discontinue an information collection. It also includes the cost of publishing the necessary notices in the Federal Register.

The estimate of the cost to the Federal Government is based on salaries for professional and clerical support.

	Number of Employees (FTE)	Estimated Annual Federal Cost ($)
Analysis and Processing of filings27	1.5	247,230
Cost for obtaining the data from 3rd party28	-	$60,000
PRA29 Administrative Cost		$4,931
FERC Total		$312,161

15. Reasons for Changes in Burden Including the Need for Any Increase

Because the process is completely automatic and part of the normal business requirement, we are retaining only a ‘placeholder’ burden of one hour for any new Balancing Authority which may enter the field and need to perform the initial set-up to identify FERC as a ‘cc’ for e-Tags.

The current inventory and requested estimates follow.

FERC-740	Total Request	Previously Approved	Change due to Adjustment in Estimate	Change Due to Agency Discretion
Annual Number of Responses	1	1	0	0
Annual Time Burden (Hr.)	1	1	0	0
Annual Cost Burden ($)	0	0	0	0

16. Time Schedule for Publication of Data

There is no publication of the data.

17. Display of the Expiration Date

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

18. Exceptions to the Certification Statement

There are no exceptions.

1 NERC’s Glossary of Terms Used in Reliability Standards (updated November 15, 2012) defines an interchange transaction as “[a]n agreement to transfer energy from a seller to a buyer that crosses one or more Balancing Authority Area boundaries.” See http://www.nerc.com/files/Glossary_of_Terms.pdf.

2 See, e.g., NAESB Wholesale Electric Quadrant (WEQ) Business Practice Standards (Coordinate Interchange) requirement 004-1 (“All requests to implement bilateral Interchange (excluding Interchange for emergency energy) between a Source BA and a Sink BA, where one or both BAs are located in either the Eastern Interconnection or Western Interconnection, shall be accomplished by the submission of a completed and accurate RFI) to the Sink BA’s registered e-Tag Authority Service”) and requirement 004-2 (“Until other means are adopted by NAESB, the primary method of submitting the RFI [Request for Interchange] shall be an e-Tag communicated to and managed by the Sink BA’s registered e-Tag authority service using protocols compliant with the Version 1.8.1 Electronic Tagging Functional Specification.”) NAESB Wholesale Electric Quadrant (WEQ) Business Practice Standards (Version 003), published July 31, 2012.

3 Open-Access Same-Time Information System and Standards of Conduct, 90 FERC ¶ 61,070 at 61,258-59 (2000).

4 Id.

5 See Mandatory Reliability Standards, Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 795, order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007).

6 See Standards for Business Practices and Communication Protocols for Public Utilities, Order No. 676, FERC Stats. & Regs. ¶ 31,216, (2006), reh’g denied, Order No. 676-A, final rule, 116 FERC ¶ 61,255 (2006), Order No. 676-B, FERC Stats. & Regs. ¶ 31,246 (2007), final rule, Order No. 676-C, FERC Stats. & Regs. ¶ 31,274 (2008), order granting clarification and denying reh’g, Order No. 676-D, 124 FERC ¶ 61,317 (2008), final rule, Order No. 676-E, FERC Stats. & Regs. ¶ 31,299 (2009), final rule, Order No. 676-F, FERC Stats. & Regs. ¶ 31,309 (2010).

7 See supra note 9.

8 Order 771 (issued 12/20/2012) is posted at http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=13138135; Order 771-A (issued 3/8/2013) is posted at http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=13199903; Order No. 771-B (issued 11/19/2015) is posted at http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=14049297.

9 16 U.S.C. 824v, 825f.

10 For purposes of this document, “complete e-Tags” refers to: (1) e-Tags for interchange transactions scheduled to flow into, out of or within the United States’ portion of the Eastern or Western Interconnection, or into the Electric Reliability Council of Texas and from the United States’ portion of the Eastern or Western Interconnection, or from the Electric Reliability Council of Texas into the United States’ portion of the Eastern or Western Interconnection; and (2) information on every aspect of each such e-Tag, including all applicable e-Tag-IDs, transaction types, market segments, physical segments, profile sets, transmission reservations, and energy schedules.

11 E-Tag Authors are typically Purchasing-Selling Entities. A Purchasing-Selling Entity is the entity that purchases or sells, and takes title to, energy, capacity, and Interconnected Operations Services. Purchasing-Selling Entities may be affiliated or unaffiliated merchants and may or may not own generating facilities. See NAESB Electronic Tagging Functional Specifications, Version 1.8.1.1, at 15.

12 The Agent Service provides the ability for initial creation of an e-Tag and the electronic transfer of that information to the appropriate Authority Service. E-Tag Authors are responsible for providing this service directly or by arranging with a third party to provide this service as their agent. See NAESB Electronic Tagging Functional Specifications, Version 1.8.1.1, at 24.

13 A Balancing Authority is responsible for integrating resource plans ahead of time, maintaining load-interchange-generation balance within a Balancing Authority Area and supporting Interconnection frequency in real-time. See NAESB Electronic Tagging Functional Specifications, Version 1.8.1.1, at 10. Sink Balancing Authorities, defined as the Balancing Authority in which the load (sink) is located for an Interchange Transaction, use an Authority Service to electronically validate e-Tags and distribute them for approval by other entities. See NAESB Electronic Tagging Functional Specifications, Version 1.8.1.1, at 17, 24.

14 The Authority Service validates and distributes e-Tags for approval on behalf of the Sink Balancing Authority. See NAESB Electronic Tagging Functional Specifications, Version 1.8.1.1, at 24.

15 EPAct 2005, Pub. L. No. 109-58, 119 Stat. 594 (2005).

16 16 U.S.C. 824(f).

17 In particular, FPA section 201(b)(2) provides: “Notwithstanding section 201(f), the provisions of section[] . . . 222 shall apply to the entities described in such provisions, and such entities shall be subject to the jurisdiction of the Commission for purposes of carrying out such provisions and for purposes of applying the enforcement authorities of this Act with respect to such provisions.” 16 U.S.C. 824(b)(2).

18 NAESB Electronic Tagging Functional Specifications, Version 1.8.2

19 Following issuance of the Final Rule in Docket RM11-12 and the Commission’s registration in the OATI webRegistry, the Commission issued a notice February 26, 2013 (available at http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=13189928) specifying that “FERC” is the entity code that should be used to ensure that the Commission is an addressee on the e-Tags.

20 The Notice (in Docket No. IC19-18-000) is posted on FERC’s eLibrary at https://elibrary.ferc.gov/idmws/common/OpenNat.asp?fileID=15188869. It was published in the Federal Register at 84 FR 10820 (March 22, 2019).

21 The Notice is posted in FERC’s eLibrary system at https://elibrary.ferc.gov/idmws/common/OpenNat.asp?fileID=15252406.

22 Market participants currently treat e-Tags as confidential because they contain potentially commercially sensitive information. See NAESB Electronic Tagging Functional Specifications, section 1.4.2.1, Version 1.8.1.1, at 26.

23 The Commission has granted requests for privileged or confidential treatment of similar non-public data. See, e.g., N.Y. Indep. Sys. Operator, Inc., 131 FERC ¶ 61,169, at P 15 (2010) (granting such treatment for data relating to specific generator or other equipment details, transmission system information, bidding strategies, generator reference levels, generator costs, guarantee payments, and the associated relevant time periods); see also S. Cal. Edison Co., 135 FERC ¶ 61,201, at P 20 (2011); Hydrogen Energy Cal. LLC, 135 FERC ¶ 61,068, at P 25 (2011); N.Y. Indep. Sys. Operator, Inc., 130 FERC ¶ 61,029, at P 3 (2010).

24 FOIA exemption 4 protects “trade secrets and commercial or financial information obtained from a person [that is] privileged or confidential.” 5 U.S.C. 552(b)(4) (2006), amended by Open Government Act of 2007, Pub. L. No. 110-175, 121 Sta. 2524 (2007); accord 18 CFR 338.107(d).

25 See Southwest Power Pool, Inc., 129 FERC ¶ 61,163 (2009), order on reh’g, 137 FERC ¶ 61,046 (2011); N. Y. Indep. Sys. Operator, Inc., 136 FERC ¶ 61,116 (2011).

26 The estimated hourly cost (wages plus benefits) provided in this section is based on the figures for May 2017 posted by the Bureau of Labor Statistics for the Utilities sector (available at https://www.bls.gov/oes/current/naics2_22.htm), assuming:

• 15 minutes legal (code 23-0000), at $143.68/hour

• 45 minutes information and record clerk (code 43-4199), at $39.68/hour.

27 The estimate uses the FERC’s FY 2018 average annual salary plus benefits of one FERC FTE (full-time equivalent [$164,820 per year or $79.00 per hour]). (These estimates were updated in May 2018.)

28 The Commission accesses the e-Tags by contracting with a commercial vendor, OATI.

29 Paperwork Reduction Act of 1995 (PRA)

12