FERC-715 supporting statement

FERC-715 (OMB Control No. 1902-0171)

Docket No. IC22-18-000

Supporting Statement for

FERC-715, Annual Transmission Planning and Evaluation Report

The Federal Energy Regulatory Commission (Commission or FERC) requests that the Office of Management and Budget (OMB) review and approve FERC-715, Annual Transmission Planning and Evaluation Report. FERC-715 (OMB Control No. 1902-0171) is an existing Commission data collection.

1. CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY

Section 213(b) of the Federal Power Act (FPA)¹ and 18 CFR 141.300 require each transmitting utility that operates integrated (i.e., non-radial) transmission system facilities, rated above 100 kilovolts (kV), to submit annually:

• Contact information;

• Base case power flow data (if it does not participate in the development and use of regional power flow data);

• Transmission system maps and diagrams used by the respondent for transmission planning;

• A detailed description of the transmission planning reliability criteria used to evaluate system performance for time frames and planning horizons used in regional and corporate planning;

• A detailed description of the respondent’s transmission planning assessment practices (including, but not limited to, how reliability criteria are applied and the steps taken in performing transmission planning studies); and

• A detailed evaluation of the respondent’s anticipated system performance as measured against its stated reliability criteria using its stated assessment practices.

This information assists the Commission in overseeing the reliability of the nation’s electricity transmission grid; taking action to prevent market manipulation; providing rate incentives to promote electric transmission investment; supplementing state transmission siting efforts in national interest electric transmission corridors; and reviewing certain holding company mergers and acquisitions involving electric utility facilities, as well as certain acquisitions of generating facilities by public utilities.

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

The FERC-715 enables the Commission to use the information as part of their regulatory oversight functions, including:

• The review of rates and charges;

• The disposition of jurisdictional facilities;

• The consolidation and mergers;

• The adequacy of supply and;

• Reliability of the nation’s transmission grid.

The FERC-715 enables the Commission to facilitate and resolve transmission disputes. Additionally, the Commission’s Office of Electric Reliability (OER) uses the FERC-715 data to help protect and improve the reliability and security of the nation’s bulk power system. OER oversees the development and review of mandatory reliability and security standards and ensures compliance with the approved standards by the users, owners, and operators of the bulk power system. OER also monitors and addresses issues concerning the nation’s bulk power system, including assessments of resource adequacy and reliability.

Without the FERC-715 data, the Commission would be unable to evaluate planned projects or requests related to transmission.

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

The Commission allows the FERC-715 application to be eFiled.

For current information on the FERC-715, submission guidelines, and instructions, see http://www.ferc.gov/docs-filing/forms/form-715/overview.asp.

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 information collected under FERC-715 is not duplicated and is not available elsewhere. There are no other Federal agencies responsible for the collection of power flow simulation data, transmission line diagrams, or detailed transmission planning reports.

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

The Commission uses eFiling for the FERC-715 as a means of reducing burden for respondents including small entities.

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

The Commission continually uses the information collected to review reliability issues and market structure relationships. The Commission also uses the data to review merger analysis. The United States Department of Justice (DOJ) uses the data for merger analysis and transmission line relief (TLR) calculation. The Energy Information Administration (EIA) uses the data to model various electricity markets. Finally, state regulatory authorities and potential transmission customers use the data to assess whether transmission capacity is available.

The Commission would be unable to perform its mandated review in a timely and accurate manner if they collected this information less frequently.

7. EXPLAIN ANY SPECIAL CIRCUMSTANCES RELATING TO THE INFORMATION

There are no special circumstances related to this collection.

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

In accordance with OMB requirements, the Commission published a 60-day notice on June 29, 2022 (87 FR 38741), providing an opportunity for public comment. The Commission received no comments in response.

The Commission also published a 30-day notice on September 8, 2022 (87 FR 54994).

9. EXPLAIN ANY PAYMENT OR GIFTS TO RESPONDENTS

There are no payments or gifts to FERC-715 respondents.

10. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS

The Commission considers the information collected in FERC-715 filings to be Critical Energy Infrastructure Information (CEII). The Commission releases this information only to requestors that file a request for CEII under the appropriate regulations and are approved for access.²

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

The Commission does not consider any of the questions in the FERC-715 of a sensitive nature that would be considered private.

12. ESTIMATED BURDEN OF COLLECTION OF INFORMATION

Estimate of Annual Burden:³ The Commission estimates the total annual burden and cost⁴ for this information collection as follows.

FERC-715, Annual Transmission Planning and Evaluation Report
Type of Response	Number of Respondents (1)	Annual Number of Responses per Respondent (2)	Total Number of Responses (1)*(2)=(3)	Average Burden & Cost Per Response (4)	Total Annual Burden Hours & Total Annual Cost (3)*(4)=(5)	Cost per Respondent ($) (5)÷(1)
Annual Transmission Planning and Evaluation Report	111	1	111	160 hrs.; $13,920	17,760 hrs.; $1,545,120	$13,920

13. ESTIMATE OF TOTAL ANNUAL COST OF BURDEN TO

RESPONDENTS

There are no non-labor or start-up costs. All costs are related to burden hours and are addressed in Questions #12 and #15.

14. ESTIMATED ANNUALIZED COST TO FEDERAL

GOVERNMENT

The estimate of the cost for “analysis and processing of filings” in the table below is based on salaries and benefits for professional and clerical support. This estimated cost represents staff analysis, decision-making, and review of any actual filings submitted in response to the information collections. The corresponding annual and hourly FERC costs use the figures for 2021.⁵

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 estimated annualized cost to the Federal Government follows.

	Number of Employees (FTEs)	Estimated Annual Federal Cost
PRA Administration Cost	-	$8,279
Data Processing and Analysis	0.5	$90,352 (rounded)
FERC Total		$98,631

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

There are no program changes, and there are no adjustments.

16. TIME SCHEDULE FOR PUBLICATION OF DATA

There are no tabulating, statistical or publication plans for the collection of information. The data are used for regulatory purposes only.

17. DISPLAY OF EXPIRATION DATE

OMB expiration dates for all of FERC’s information collections are posted at https://view.officeapps.live.com/op/view.aspx?src=https%3A%2F%2Fwww.ferc.gov%2Fsites%2Fdefault%2Ffiles%2F2022-08%2FInformation-Collections-8-3-2022.xlsx&wdOrigin=BROWSELINK.

In addition, upon renewal of this collection of information, the Commission will display the new expiration date at: Form No. 715 - Annual Transmission Planning and Evaluation Report | Federal Energy Regulatory Commission (ferc.gov)

18. EXCEPTIONS TO THE CERTIFICATION STATEMENT

There are no exceptions.

1 16 U.S.C. 824l(b)

2 18 CFR 388.113

3 “Burden” is 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, refer to 5 CFR 1320.3.

4 The Commission staff estimates that the industry’s hourly cost for wages plus benefits is similar to the Commission’s $87.00 FY 2021 average hourly cost for wages and benefits.

5 The estimate uses the FERC’s FY 2021 average annual salary plus benefits of one FERC full-time equivalent (FTE) of $180,703 per year or $87.00 per hour.

6