Distribution Technology Capability Assessment - Supporting Statement

Supporting Statement for Requests for Approval under
the Paperwork Reduction Act and 5 CFR 1320
Distribution Technology Capability Assessment
OMB #
SECTION A. JUSTIFICATION:
1. Explain the circumstances that make the collection of information
necessary.
As the Balancing Authority of the region, TVA must ensure the electrical grid is
reliable. With the growth of Distributed Energy Resources (DER) on the distribution
system, TVA and the Local Power Companies (LPCs) must work in tighter
coordination to ensure the DER generation does not impact the reliability of the bulk
electric system. To support this goal, TVA must understand the current distribution
capabilities of the LPCs. Example of capabilities include but are not limited to
customer analytics, advanced asset management, advanced AMI, automated
switching, DER monitoring & control, grid planning and voltage optimization.
2. Indicate how, by whom, and for what purpose the information is to be
used. Except for a new collection, indicate the actual use the agency has
made of the information received from the current collection.
The information collected is reviewed by TVA staff and consultants to determine each
LPCs state of and plan for system modernization and will inform strategic investment
roadmaps and implementation plans that are being developed as part of the Regional
Grid Transformation initiative.
Summary level information will be provided to the participating LPCs to allow them
to gauge where they stand in terms of their technical capabilities compared to their
peers which could help give them useful information that informs their individual
priorities and investment plans.
3. Describe whether, and to what extent, the collection of information
involves the use of automated, electronic, mechanical, or other
technological collection techniques or other forms of information
technology.
The information will be submitted “online” for ease of access and ease of completion.
4. Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the
purposes described in Item 2 above.

An internal cross-functional team was used to review the questions to identify any
areas where TVA may have previously collected similar information.
5. If the collection of information impacts small businesses or other small
entities, describe any methods used to minimize burden.
There is no significant impact on a substantial number of small businesses; however,
TVA provides technical assistance to any small businesses that request it.
6. Describe the consequence to Federal program or policy activities if the
collection is not conducted or is conducted less frequently, as well as any
technical or legal obstacles to reducing burden.
TVA is the Balancing Authority of the area. A Balancing Authority Area is the
collection of generation, transmission, and loads within the metered boundaries of
the Balancing Authority. The Balancing Authority maintains load-resource balance
within this area. Further, a Balancing Authority is the responsible entity that
integrates resource plans ahead of time, maintains load-interchange-generation
balance within a Balancing Authority Area, and supports Interconnection frequency in
real time.
As more DER is sited on the distribution system, TVA needs to have visibility and
understanding of the DER to maintain the load-resource balance within this area. If
TVA is not able to maintain the load-resource balance, the electrical system reliability
will be compromised.
7. Explain any special circumstances that would cause an information
collection to be conducted in a manner:
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requiring respondents to report information to the agency more often than
quarterly;
requiring respondents to prepare a written response to a collection of
information in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of
any document;
requiring respondents to retain records, other than health, medical,
government contract, grant-in-aid, or tax records, for more than three
years;
in connection with a statistical survey, that is not designed to produce
valid and reliable results that can be generalized to the universe of study;
requiring the use of a statistical data classification that has not been
reviewed and approved by OMB;
that includes a pledge of confidentiality that is not supported by authority
established in statute or regulation, that is not supported by disclosure
and data security policies that are consistent with the pledge, or which
unnecessarily impedes sharing of data with other agencies for compatible
confidential use; or
requiring respondents to submit proprietary trade secrets, or other
confidential information unless the agency can demonstrate that it has
instituted procedures to protect the information's confidentiality to the
extent permitted by law.

None of these apply.
8. If applicable, provide a copy and identify the date and page number of
publication in the Federal Register of the agency's notice, required by 5 CFR
1320.8(d), soliciting comments on the information collection prior to
submission to OMB.
No notice has been created.
9. Explain any decision to provide any payment or gift to respondents, other
than remuneration of contractors or grantees.
No payments or gifts are provided.
10. Describe any assurance of confidentiality provided to respondents and
the basis for the assurance in statute, regulation, or agency policy.
The majority of information provided is not confidential. Most information collected
describes an LPC’s current state or potential future plans and is not of a sensitive or
personal nature.
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 information collection does not ask questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information.
The statement should:
•
Indicate the number of respondents, frequency of response, annual hour
burden, and an explanation of how the burden was estimated. Unless directed
to do so, agencies should not conduct special surveys to obtain information on
which to base hour burden estimates. Consultation with a sample (fewer than
10) of potential respondents is desirable. If the hour burden on respondents
is expected to vary widely because of differences in activity, size, or
complexity, show the range of estimated hour burden, and explain the
reasons for the variance. Generally, estimates should not include burden
hours for customary and usual business practices. * If this request for
approval covers more than one form, provide separate hour burden
estimates for each form and aggregate the hour burdens.
Number of responses:

Approximately 153.

Frequency of Response: Every two years.

Annual Hour Burden: 2 hours per LPC. Therefore, the Total Annual Hour Burden is
306 hours (2 hours x 153 LPCs = 306 hours). Burden is estimated by completion of
the assessment by consulting staff.
Total estimated annualized cost for respondents to provide information: $7,286.
Provide estimates of annualized cost to respondents for the hour burdens for
collections of information, identifying and using appropriate wage rate categories.
The cost of contracting out or paying outside parties for information collection
activities should not be included here. Instead, this cost should be included under
item 13.
Annualized cost per applicant: The average hourly wage for the states in the TVA
service area is $23.81. This estimate was calculated using a snapshot of data taken
on 2-14-2019 from the U.S. Bureau of Labor Statistics National Compensation
Survey on Wages from the following sources:
https://www.bls.gov/regions/southeast/newsrelease/countyemploymentandwages_mississippi.htm

https://www.bls.gov/regions/southeast/newsrelease/countyemploymentandwages_kentucky.htm
https://www.bls.gov/regions/southeast/newsrelease/countyemploymentandwages_alabama.htm
https://www.bls.gov/regions/southeast/newsrelease/countyemploymentandwages_tennessee.htm
https://www.bls.gov/regions/southeast/newsrelease/countyemploymentandwages_georgia.htm
https://www.bls.gov/regions/southeast/newsrelease/countyemploymentandwages_northcarolina.htm
https://www.bls.gov/regions/mid-atlantic/newsrelease/countyemploymentandwages_virginia.htm

Based on the estimated 2 hour burden, the total annualized time cost for all
applicants is $7,286 ($23.81 x 306 = $7,286).
13. Provide an estimate for the total annual cost burden to respondents or
record keepers resulting from the collection of information. Do NOT include
the labor cost (wage equivalent) of the burden hours described in Question 12
(above). The information required here corresponds to that in #14 on the 83-I (cost
to the public).
The cost estimate should be split into two components:
a. a total capital and start-up cost component (annualized over its
expected useful life) and
b. a total operation and maintenance and purchase of services
component. The estimates should take into account costs associated
with generating, maintaining, and disclosing or providing the
information. Include descriptions of methods used to estimate major

cost factors including system and technology acquisition, expected
useful life of capital equipment, the discount rate(s), and the time
period over which costs will be incurred. Capital and start-up costs
include, among other items, preparations for collecting information
such as purchasing computers and software; monitoring, sampling,
drilling and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost
burdens and explain the reasons for the variance. The cost of purchasing or
contracting out information collections services should be a part of this cost burden
estimate. In developing cost burden estimates, agencies may consult with a sample
of respondents (fewer than 10), utilize the 60-day pre-OMB submission public
comment process and use existing economic or regulatory impact analysis associated
with the rulemaking containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or services, or
portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory
compliance with requirements not associated with the information collection, (3) for
reasons other than to provide information or keep records for the government, or (4)
as part of customary and usual business or private practices.
Capital and startup cost do not apply this assessment.
14. Provide estimates of annualized costs to the Federal government.
Include here a description of the method used to estimate costs to the Federal
government, which should show the quantification of hours, operational expenses
(such as equipment, overhead, printing, and staff support), and any other expense
which would not have been incurred without this collection of information. If there
will be no costs beyond the normal labor costs for staff, state so.
The cost of creating and deploying the assessment and later analyzing the results is
estimated to be $200,000. This cost includes consulting and TVA labor.
15. Explain the reasons for any program changes or adjustments reported
on the burden worksheet.
Not applicable.
16. For collections of information whose results will be published, outline
plans for tabulation and publication. Address any complex analytical
techniques that will be used. Provide the time schedule for the entire
project, including beginning and ending dates of the collection of
information, completion of report, publication dates, and other actions.
Not applicable.

17. If seeking approval to not display the expiration date for OMB approval
of the information collection, explain the reasons that display would be
inappropriate.
Not applicable.
18. Explain each exception to the topics of the certification statement
identified in “Certification for Paperwork Reduction Act Submissions,”
Not applicable.

Section B. Collections of Information Employing Statistical Methods
This information collection does not employ statistical methods.