FERC-725 Non-Substantive justification:
The information collection affected by this order is FERCâ725, âCertification of Electric Reliability Organization; Procedures for Electric Reliability Standardsâ (OMB Control Number 1902-0225). The information collection requirements in the order for RD22-4 are covered by and included in, the existing OMB-approved FERC-725.
-This order directs the ERO to develop and submit to the Commission for approval within 90 days of the date of this order a work plan describing, in detail, how the ERO plans to modify its registration processes to identify and register owners and operators of unregistered Inverter-based Resources (IBRs) that in the aggregate, materially impact the reliable operation of the Bulk-Power System, as discussed in the body of this order. NERC is required to submit progress updates every 90 days after approval of the work plan.
-NERC is hereby directed to complete modifications in accordance with its work plan within 12 months of Commission approval of the work plan, complete identification of owners and operators of IBRs that are connected to the Bulk Power System and that, in the aggregate, materially impact the reliable operation of the Bulk-Power System within 24 months of Commission approval of the work plan and complete identification of owners and operators of IBR and complete registration of unregistered IBR owners and operators so they are required to comply with applicable Reliability Standards within 36 months of Commission approval of the work plan, as discussed in the body of this order.
The FERC-725 contains the following information collection elements:
-Self Assessment and ERO (Electric Reliability Organization) Application: The Commission requires the ERO to submit to FERC a performance assessment report every five years. The next assessment is due in 2024. Each Regional Entity submits a performance assessment report to the ERO. Submitting an application to become an ERO is also part of this collection.
-Reliability Assessments: 18 CFR 39.11 requires the ERO to assess the reliability and adequacy of the Bulk-Power System in North America. Subsequently, the ERO must report to the Commission on its findings. Regional entities perform similar assessments within individual regions. Currently the ERO submits to FERC three assessments each year: long term, winter, and summer. In addition, NERC also submits various other assessments as needed.
-Reliability Standards Development: Under Section 215 of the FPA, the ERO is charged with developing Reliability Standards. Regional Entities may also develop regional specific standards. Reliability Standards are one of the three principal mechanisms provided to FERC to ensure reliability on the Bulk-Power System.
-Reliability Compliance: Reliability Standards are mandatory and enforceable upon approval by FERC. In addition to the specific information collection requirements contained in each standard (cleared under other information collections), there are general compliance, monitoring and enforcement information collection requirements imposed on applicable entities. Audits, spot checks, self-certifications, exception data submittals, violation reporting, and mitigation plan confirmation are included in this area.
-Stakeholder Survey: The ERO uses a stakeholder survey to solicit feedback from registered entities in preparation for its three year and five-year self-performance assessment.
-Other Reporting: This category refers to all other reporting requirements imposed on the ERO or regional entities in order to comply with the Commissionâs regulations. For example, FERC may require NERC to submit a special reliability assessment. This category captures these types of one-time filings required of NERC or the Regional Entities.
The Commission implements its responsibilities through 18 CFR Part 39.
US Code:
16 USC 824o
Name of Law: Energy Policy Act of 2005
There was a decrease from seven to six in the number of Regional Entities because the Florida Reliability Coordinating Council (FRCC) dissolved in July 2019. The decrease changed the number of responses from 29.4 to 25.2 Regional entities.
⢠Other changes from previous estimates come from new data in the proposed NERC 2022 Business Plan and Budget to reflect changes in the number of FTEs working in applicable areas.
⢠Reviewing the NERC Compliance database, we determined the number of unique U.S. entities was updated from 1,409 to 1,496.
⢠Lastly, in several instances, the amount of time an FTE devotes to a given function may have been increased or decreased.
$4,525,854
No
No
No
No
No
No
No
David O'Conner 202 502-6695
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:
(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;
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.
RM22-4 725_Non-Substantive Change Justification 11-25-2022.docx
ORDER RD22-4 (published).pdf
Registered Entities