FERC-725M, (DLO in RD22-2) Mandatory Reliability Standard: FAC-003-5, Transmission Vegetation Management

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
RD22-2 Combined Supporting Statement-Final 9-21-2022.docx	Supporting Statement A	Uploaded 2022-10-19	Repair queued
RD22-2 30 Day notice (Published) 9-9-2022.pdf	Supplementary Document	Uploaded 2022-10-07	Missing upstream
RD22-2 30-day notice 9-1-22clean (issued).docx	Supplementary Document	Uploaded 2022-10-07	Available
RD22-2 60-day notice (published).pdf	Supplementary Document	Uploaded 2022-10-07	Repair queued
RD22-2-000 60-day notice (Issued).docx	Supplementary Document	Uploaded 2022-10-07	Repair queued
Delegated Letter.pdf	Supplementary Document	Uploaded 2022-10-07	Repair queued
CFR-2019-title18-vol1-part40.pdf	Supplementary Document	Uploaded 2020-01-31	Repair queued
EPACT 2005 Section 215 (16 USC 824o).pdf	Supplementary Document	Uploaded 2013-06-06	Missing upstream

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
256327	RD22-2 One time estimate FAC-003-5 (Transmission Vegetation Management)		New
222406	FERC-725M (RD16-4, for one-time and ongoing, with one-time averaged over Yrs. 1-3)		Modified
207220	FERC-725M, Final Rule in RM12-16 (one-time and ongoing)		Modified

ICR Details

OMB Control No: 1902-0263	ICR Reference No: 202210-1902-003
Status: Received in OIRA	Previous ICR Reference No: 201912-1902-001
Agency/Subagency: FERC	Agency Tracking No: FERC-725M
Title: FERC-725M, (DLO in RD22-2) Mandatory Reliability Standard: FAC-003-5, Transmission Vegetation Management
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 10/20/2022

table that charts list comparision

	Requested	Previously Approved
Expiration Date	36 Months From Approved	04/30/2023
Responses	6,494	922
Time Burden (Hours)	45,290	714
Cost Burden (Dollars)	0	0

---

Abstract: FERC-725M, Mandatory Reliability Standard: FAC-003-5 (formerly FAC-003-4), Transmission Vegetation Management (OMB Control No. 1902-0263) for a three-year period and modifications due to RD-22-2 revisions. FERC-725M is an existing data collection with reporting requirements in 18 Code of Federal Regulations (CFR), Part 40. FAC-003-5 extends NERC’s vegetation management requirements to Generator Owners with qualifying interconnection facilities, including requirements to create and maintain records related to the Generator Owner’s vegetation management work plan and performance of inspections As stated by NERC in its Petition (dated 3/14/2016 [footnotes omitted]) in Docket No. RD16-4, “[t]he purpose of Reliability Standard FAC-003-4 (now FAC-003-5) is to require entities to manage vegetation located on transmission rights of way (ROW) and minimize encroachments from vegetation located adjacent to the ROW to reduce the risk of vegetation-related outages that could lead to Cascading. Proposed Reliability Standard FAC-003-4 reflects revisions developed under Project 2010-07.1 Vegetation Management to provide a revised gap factor applied in the Gallet equation supporting the appropriate Alternating Current Minimum Vegetation Clearance Distances (referred to herein as “MVCD values”) stated under the Reliability Standard. The MVCD value reflects the minimum distance between vegetation and conductors to prevent a flash-over. This revised gap factor was developed as a result of the 2015 Technical Report prepared by EPRI entitled Supplemental Testing to Confirm or Refine Gap Factor Utilized in Calculation of Minimum Vegetation Clearance Distances (“MVCD”): Tests: Results and Analysis (“EPRI Report”) filed at the Commission in Docket No. RM12-4-000 in compliance with the Commission’s directive in Order No. 777. The EPRI Report, the preliminary report preceding it, and EPRI’s recent update to the EPRI Report filed in Docket No. RM12-4-000 are attached at Exhibit E. As reflected in this Petition and the attached exhibits, the EPRI test results indicated that MVCD values under currently effective Reliability Standard FAC-003-3 might not be suitable or sufficiently conservative in all situations. The EPRI testing revealed that the gap factor used to determine those MVCD values under the Gallet equation was too high for all situations with varying tree and conductor configurations. The gap factor is a multiplier that adjusts MVCD values for different configurations of vegetation and conductors to avoid flashover (a lower gap factor correlates to higher MVCD values). The EPRI tests thus led to the conclusion that MVCD values under existing Reliability Standard FAC-003-4 appeared low. The EPRI test results demonstrated the Gallet equation should apply a more conservative, lower, gap factor of 1.0 to calculate MVCD values for Reliability Standard FAC-003-5. In the Delegated Order (dated 4/1/2022) in Docket No. RD22-2, FERC approved the revised Reliability Standard proposed by NERC.

---

Authorizing Statute(s): US Code: 16 USC 824o Name of Law: Energy Policy Act of 2005
  

Citations for New Statutory Requirements: None

---

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

---

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	87 FR 22202	04/14/2022
30-day Notice:	Federal Register Citation:	Citation Date:
	87 FR 55422	09/09/2022
Did the Agency receive public comments on this ICR? No

---

Number of Information Collection (IC) in this ICR: 3

table that charts list of burden

IC Title	Form No.	Form Name
FERC-725M (RD16-4, for one-time and ongoing, with one-time averaged over Yrs. 1-3)
FERC-725M, Final Rule in RM12-16 (one-time and ongoing)
RD22-2 One time estimate FAC-003-5 (Transmission Vegetation Management)

---

ICR Summary of Burden

table that charts list of burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	6,494	922	0	5,572	0	0
Annual Time Burden (Hours)	45,290	714	0	44,576	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Changing Regulations

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: For 725M (FAC-003 Reliability Standard), the change (increase in responses and decrease in manhours) is due to agency discretion as we have updated the method to determine affected entities and their responses. The new method of examining entities reflects separating the types of entities where there may have been a previous overlap. The estimate workload by entities is expected to decrease overall as entities have familiar with information collection and burden associated with compliance of the standard and tools in place to reduce the overall burden.

---

Annual Cost to Federal Government: $8,279

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

---

Common Form ICR:  No

---

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 10/20/2022

---