FERC-725D Supporting Statement_032125-

FERC-725D (OMB Control No. 1902-0247)

Docket No. IC25-8-000

Transfer of FAC-003-5 and FAC-008-5

Supporting Statement for

FERC-725D (Facilities Design, Connections and Maintenance Reliability Standards)

The Federal Energy Regulatory Commission (Commission or FERC) requests OMB review and approval of the changes to reporting and recordkeeping requirements (evidence retention), as noted in Docket Nos. IC25-8-000, covering FERC-725D (Facilities Design, Connections and Maintenance Reliability Standards) (OMB Control No. 1902-0247). The following supporting statement is being submitted to renew FERC-725D and transfer FAC-003-5 (725M) and FAC-008-5 (725A) to 725D

1. CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY

On August 8, 2005, The Electricity Modernization Act of 2005, which is Title XII of the Energy Policy Act of 2005 (EPAct 2005), was enacted into law¹. EPAct 2005 added a new section 215 to the Federal Power Act (FPA), which requires a Commission-certified Electric Reliability Organization (ERO) to develop mandatory and enforceable Reliability Standards, subject to Commission review and approval.

Section 215 of the FPA requires a Commission-certified ERO to develop mandatory and enforceable Reliability Standards, subject to Commission review and approval.² Once approved, the Reliability Standards may be enforced by the ERO subject to Commission oversight or by the Commission independently.³ In 2006, the Commission certified NERC (North American Electric Reliability Corporation) as the ERO⁴ pursuant to section 215 of the FPA.⁵

On March 16, 2007 (pursuant to section 215(d) of the FPA), the Commission issued Order No. 693, approving 83 of the 107 initial Reliability Standards filed by NERC. Order 693 addressed several Reliability Standards. In the intervening years, numerous changes have been made to update, eliminate, or establish various Reliability Standards.

FERC-725D includes⁶:

Facilities Design, Connections, and Maintenance (FAC ) Reliability Standards
Standard	Name	Effective Date7	Previous Version
FAC-001-4	Facility Interconnection Requirements	1/1/2019	Replaced FAC-001-3 with RD22-5
FAC-002-4	Facility Interconnection Studies	1/1/2024	Replaced FAC-002-3 with RD22-5
FAC-003-5	Transmission Vegetation Management	4/1/2024	Replaced FAC-003-4 with RD22-2
FAC-008-5	Facility Ratings	10/1/2021	Replaced FAC-008-4 with RD24-1
FAC-011-4	System Operating Limits Methodology for the Operations Horizon	4/1/2017	Replaced FAC-011-3 with RD22-2
FAC-014-3	Establish and Communicate System Operating Limits	4/29/2009	Replaced FAC-014-2 with RD22-2

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

FERC-725D. Reliability standards mentioned within the examples below include Requirements (e.g. R1, R2, R3, etc.), Measurements (e.g. M1, M2, M3, etc.), and Compliance Monitoring Process - Evidence Retention for each standard.

Evidence Retention identifies the period of time an entity is required to retain specific evidence to demonstrate compliance. Examples of records being retained relate to Compliance Audit, Self-Certification, Spot Check, Compliance Investigation, and Self-Reporting.

The covered Reliability Standards are:

• FAC-001-4 (Facility Interconnection Requirements):

The purpose of Reliability Standard FAC-001-4 is to “avoid adverse impacts on the reliability of the Bulk Electric System, Transmission Owners and applicable Generator Owners must document and make Facility interconnection requirements available so that entities seeking to interconnect will have the necessary information.” Data for these interconnection requirements could include system protection and relay coordination, breaker duty and surge protection, grounding and safety issues, and operations matters such as abnormal frequency and voltages. These interconnection requirements are routinely reviewed to ensure that all the data needed to perform studies is available.

Need for Data, and Risk without Data: FAC-001-4 imposes the obligation to document, maintain, and publish interconnection requirements. Failure to properly maintain the interconnection requirement documents and make them available to entities upon request could adversely impact reliable planning and operation of the Bulk Electric System because data needed to perform studies to determine the impact of interconnecting facilities on existing interconnections as well as on affected systems may not be provided. Further, lack of these documents could result in inaccurate and uncoordinated interconnection studies, leading to possible instances of instability, uncontrolled separation and cascading failures. The requirements include retention periods that identify the period of time an entity is required to retain specific evidence to demonstrate compliance.

Evidence Retention: The applicable Functional Entity shall keep data or evidence to show compliance as identified below unless directed by its CEA to retain specific evidence for a longer period of time as part of an investigation:

• The responsible entities shall retain documentation as evidence for three years.

• If a responsible entity is found non-compliant, it shall keep information related to the non-compliance until mitigation is complete and approved or for the time specified above, whichever is longer.

• The CEA shall keep the last audit records and all requested and submitted subsequent audit records.

• FAC-002-4 (Facility Interconnection Studies):

The purpose of Reliability Standard FAC-002-4 is to “study the impact of interconnecting new or materially modified Facilities on the Bulk Electric System.” Under Reliability Standard FAC-002-4 each transmission planner and each planning coordinator shall study the reliability impact of interconnecting new--or materially modifying existing--generation, transmission, or electricity end-user facilities on affected systems. Reliability Standard FAC-002-4 requires transmission planners and planning coordinators to perform steady-state, short-circuit, and dynamic studies to evaluate system performance under both normal and contingency conditions. In addition, Reliability Standard FAC-002-4 requires each generator owner seeking to interconnect, each transmission owner, each distribution provider, and each load-serving entity that is seeking to interconnect new--or materially modifying existing--transmission facilities or end-user facilities to coordinate and cooperate on studies with its transmission planner and planning coordinator.

Need for Data, and Risk without Data: For Reliability Standard FAC-002-4, all applicable entities need to cooperate in sharing data so valid and complete studies can be performed to accurately assess the reliability impact of interconnecting new or materially modified facilities. Failing to conduct studies of these interconnecting facilities could lead to instances of violation with other national and regional standards. Also, actual system performance under normal and emergency conditions may not match the results of steady-state, short circuit and dynamic studies, which could impact Bulk Electric System reliability and lead to instances of instability, uncontrolled separation and cascading failures. These requirements include retention periods that identify the period of time an entity is required to retain specific evidence to demonstrate compliance. If a responsible entity is found non-compliant, it shall keep information related to the non-compliance until mitigation is complete and approved.

Evidence Retention: The following evidence retention periods identify the period of time an entity is required to retain specific evidence to demonstrate compliance. For instances where the evidence retention period specified below is shorter than the time since the last audit, the CEA may ask an entity to provide other evidence to show that it was compliant for the full time period since the last audit.

The Planning Coordinator, Transmission Planner, Transmission Owner, Distribution Provider, Generator Owner, applicable Generator Owner, and Load-Serving Entity shall keep data or evidence to show compliance as identified below unless directed by its CEA to retain specific evidence for a longer period of time as part of an investigation:

• The responsible entities shall retain documentation as evidence for three years.

• If a responsible entity is found non-compliant, it shall keep information related to the non-compliance until mitigation is complete and approved or for the time specified above, whichever is longer.

• The CEA shall keep the last audit records and all requested and submitted subsequent audit records.

• Further, each planning authority must self-certify its compliance to the compliance monitor once every three years. Reliability Standard FAC-011-3 requires similar documentation by the reliability coordinator. Reliability Standard FAC-014-2 requires the reliability coordinator, planning authority, transmission operator, and transmission planner to verify compliance through self-certification submitted to the compliance monitor annually. These entities must also document that they have developed SOLs consistent with the applicable SOL methodology and that they have provided SOLs to entities identified in Requirement 5 of the Reliability Standard. Further, the planning authority must maintain a list of multiple contingencies and their associated stability limits.

The next two standards (FAC-011-4, FAC-14-3) set requirements for the development of SOLs of the BPS for use in the planning and operation horizons. In addition, these standards ensure that the SOLs are determined based on established methodology. SOLs are based on certain operating criteria. These include, but are not limited to:

• Facility Ratings (Applicable pre-and post-Contingency equipment or facility ratings)

• Transient Stability Ratings (Applicable pre-and post-Contingency Stability Limits)

• Voltage Stability Ratings (Applicable pre- and post-Contingency Voltage Stability)

• System Voltage Limits (Applicable pre- and post-Contingency Voltage Limits)

• FAC-003-5 (Transmission Vegetation Management)

The purpose is to maintain a reliable electric transmission system by using a defense‐ in‐depth strategy to manage vegetation located on transmission rights of way (ROW) and minimize encroachments from vegetation located adjacent to the ROW, thus preventing the risk of those vegetation‐ related outages that could lead to Cascading.

Requirement R1: Each applicable Transmission Owner and applicable Generator Owner shall manage

vegetation to prevent encroachments into the Minimum Vegetation Clearance

Distance (MVCD) of its applicable line(s), operating within their Rating and all Rated

Examples of acceptable forms of evidence may include dated attestations, dated

reports containing

R3. Each applicable Transmission Owner and applicable Generator Owner shall have

documented maintenance strategies or procedures or processes or specifications it

uses to prevent the encroachment of vegetation into the MVCD of its applicable lines

R4. Each applicable Transmission Owner and applicable Generator Owner, without any

intentional time delay, shall notify the control center holding switching authority for

the associated applicable line when the applicable Transmission Owner and applicable

Generator Owner has confirmed the existence of a vegetation condition that is likely

to cause a Fault at any moment.

R5. When an applicable Transmission Owner and an applicable Generator Owner are

constrained from performing vegetation work on an applicable line operating within

its Rating and all Rated Electrical Operating Conditions, and the constraint may lead to

a vegetation encroachment into the MVCD prior to the implementation of the next

annual work plan, then the applicable Transmission Owner or applicable Generator

Owner shall take corrective action to ensure continued vegetation management to

prevent encroachments.

R6. Each applicable Transmission Owner and applicable Generator Owner shall perform a

Vegetation Inspection of 100% of its applicable transmission lines (measured in units

of choice ‐ circuit, pole line, line miles or kilometers, etc.) at least once per calendar

year and with no more than 18 calendar months between inspections.

R7. Each applicable Transmission Owner and applicable Generator Owner shall complete

100% of its annual vegetation work plan of applicable lines to ensure no vegetation

encroachments occur within the MVCD. Modifications to the work plan in response

to changing conditions or to findings from vegetation inspections may be made

(provided they do not allow encroachment of vegetation into the MVCD) and must be

documented. The percent completed calculation is based on the number of units

actually, completed divided by the number of units in the final amended plan

(measured in units of choice ‐ circuit, pole line, line miles or kilometers, etc.).

Evidence Retention:

The following evidence retention period(s) identify the period of time an entity

is required to retain specific evidence to demonstrate compliance. For instances

where the evidence retention period specified below is shorter than the time

since the last audit, the Compliance Enforcement Authority may ask an entity to

provide other evidence to show that it was compliant for the full‐time period

since the last audit.

The applicable entity shall keep data or evidence to show compliance as

identified below unless directed by its Compliance Enforcement Authority to

retain specific evidence for a longer period of time as part of an investigation.

• The applicable Transmission Owner and applicable Generator Owner retains

data or evidence to show compliance with Requirements R1, R3, R5, R6 and

R7, for three calendar years.

• The applicable Transmission Owner and applicable Generator Owner retains

data or evidence to show compliance with Requirement R4, Measure M4 for

most recent 12 months of operator logs or most recent 3 months of voice

recordings or transcripts of voice recordings, unless directed by its

Compliance Enforcement Authority to retain specific evidence for a longer

period of time as part of an investigation.

• If an applicable Transmission Owner or applicable Generator Owner is found

non‐compliant, it shall keep information related to the non‐compliance until

found compliant or for the time period specified above, whichever is longer.

• FAC-008-5 (Facility Ratings)

Purpose is to ensure that Facility Ratings used in the reliable planning and operation of the Bulk Electric System (BES) are determined based on technically sound principles. A Facility Rating is essential for the determination of System Operating Limits.

R1. Each Generator Owner shall have documentation for determining the Facility Ratings

of its solely and jointly owned generator Facility(ies) up to the low side terminals of

the main step up transformer if the Generator Owner does not own the main step up

transformer and the high side terminals of the main step up transformer if the

Generator Owner owns the main step up transformer.

R2. Each Generator Owner shall have a documented methodology for determining Facility

Ratings (Facility Ratings methodology) of its solely and jointly owned equipment

connected between the location specified in R1 and the point of interconnection with

the Transmission Owner.

R3. Each Transmission Owner shall have a documented methodology for determining

Facility Ratings (Facility Ratings methodology) of its solely and jointly owned Facilities

(except for those generating unit Facilities addressed in R1 and R2).

R6. Each Transmission Owner and Generator Owner shall have Facility Ratings for its

solely and jointly owned Facilities that are consistent with the associated Facility

Ratings methodology or documentation for determining its Facility Ratings.

R8. Each Transmission Owner (and each Generator Owner subject to Requirement R2)

shall provide requested information as specified below (for its solely and jointly

owned Facilities that are existing Facilities, new Facilities, modifications to existing

Facilities and re-ratings of existing Facilities) to its associated Reliability

Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission

Owner(s) and Transmission Operator(s).

Evidence Retention: The following evidence retention period(s) identify the

period of time an entity is required to retain specific evidence to demonstrate

compliance. For instances where the evidence retention period specified below

is shorter than the time since the last audit, the Compliance Enforcement

Authority may ask an entity to provide other evidence to show that it was

compliant for the full-time period since the last audit.

The applicable entity shall keep data or evidence to show compliance as

identified below unless directed by its Compliance Enforcement Authority to

retain specific evidence for a longer period of time as part of an investigation.

• The Generator Owner shall keep its current documentation (for R1) and any

modifications to the documentation that were in force since last compliance

audit period for Measure M1 and Measure M6.

• The Generator Owner shall keep its current, in force Facility Ratings

methodology (for R2) and any modifications to the methodology that were in

force since last compliance audit period for Measure M2 and Measure M6.

• The Transmission Owner shall keep its current, in force Facility Ratings

methodology (for R3) and any modifications to the methodology that were in

force since the last compliance audit for Measure M3 and Measure M6.

• The Transmission Owner and Generator Owner shall keep its current, in force

Facility Ratings and any changes to those ratings for three calendar years for

Measure M6.

• The Transmission Owner (and Generator Owner that is subject to

Requirement R2) shall keep evidence for Measure M8 for three calendar

years.

• If a Generator Owner or Transmission Owner is found non-compliant, it shall

keep information related to the non-compliance until found compliant.

• The Compliance Enforcement Authority shall keep the last audit and all

subsequent compliance records.

• FAC-011-4(System Operating Limits Methodology for the Operations Horizon)

Reliability Standard FAC-011-3 requires each reliability coordinator to develop a SOL methodology for determining which of the stability limits associated with the list of multiple contingencies are applicable for use in the operating horizon based on actual or expected system conditions.

Requirement R1 of FAC-011-3 states that the Planning Authority shall have a documented SOL Methodology for use in developing SOLs within its planning authority area. R1 indicates that the SOL Methodology must be applicable to developing SOLs used in the planning horizon, state that SOLs shall not exceed associated facility ratings, and include a description of how to identify the subset of SOLs that qualify as IROLs.

Requirement R2 of FAC-011-3 identifies specific considerations that must be included in the methodology in a pre-contingency state and following one or multiple contingencies.

Requirement R3 of FAC-011-3 requires that the methodology for determining SOLs shall include as a minimum a description of the study model, selection of the applicable contingencies, level of detail of system models used to determine SOLs, allowed uses of Special Protection Systems.

Evidence Retention:

The Reliability Coordinator shall keep all superseded portions to its SOL Methodology for 12 months beyond the date of the change in that methodology. In addition, entities found non-compliant shall keep information related to the non-compliance until found compliant.

The Compliance Monitor shall keep the last audit and all subsequent compliance records.

The Planning Authority shall make the following available for inspection during an on-site audit by the Compliance Monitor or within 15 business days of a request as part of an investigation upon complaint: Superseded portions of its SOL Methodology that had been made within the past 12 months, Evidence that the SOL Methodology, and any changes to the methodology that occurred within the past 12 months were issued to all required entities.

• FAC-014-3 (Establish and Communicate System Operating Limits)

Reliability Standard FAC-014-2 requires each reliability coordinator, planning authority, transmission planner and transmission operator to develop and communicate SOL limits in accordance with the methodologies developed pursuant to FAC-011-3. FAC-014-2 requires the reliability coordinator to ensure that SOLs are established for its “reliability coordinator area” and that the SOLs are consistent with its SOL methodology. It provides that each transmission operator, planning authority and transmission planner must establish SOLs as directed by its reliability coordinator that are consistent with the reliability coordinator’s methodology. Further, FAC-014-2 requires the reliability coordinator, planning authority and transmission planner to provide its SOLs to those entities that have a reliability-related need.

Evidence Retention:

The Reliability Coordinator shall keep all superseded portions to its SOL Methodology for 12 months beyond the date of the change in that methodology. In addition, entities found non-compliant shall keep information related to the non-compliance until found compliant.

The Compliance Monitor shall keep the last audit and all subsequent compliance records.

The Planning Authority shall make the following available for inspection during an on-site audit by the Compliance Monitor or within 15 business days of a request as part of an investigation upon complaint: SOL Methodology(ies), SOLs, including the subset of SOLs that are IROLs and the IROLs supporting information, Evidence that SOLs were distributed, Evidence that a list of stability-related multiple contingencies and their associated limits were distributed, Distribution schedules provided by entities that requested SOLs.

These last two Reliability Standards (FAC 011-3, FAC 14-2) serve an important reliability purpose in ensuring that SOLs used in the reliable planning and operation of the BPS are determined based on an established methodology. Moreover, they clearly identify the entities to which they apply and contain clear and enforceable requirements.

In general, information collection and evidence retention requirements related to Reliability Standards are not submitted to, or retained for audit by, FERC. Rather they are submitted to, or retained for audit by, NERC or the Compliance Enforcement Authority, as specified in each individual Reliability Standard. Without collecting this information, reliability of the bulk-power system could become compromised, potentially resulting in outages.

The purpose of these Reliability Standards is to ensure:

• generators remain in operation during specified voltage and frequency excursions; properly coordinate protective relays and generator voltage regulator controls; and

• generator models accurately reflect the generator’s capabilities and equipment performance

• planners and operators have access to actual and forecast demand and energy data as needed to perform resource adequacy studies

• system-level modeling data and validation requirements necessary for developing planning models and the Interconnection-wide cases that are integral to analyzing the reliability of the Bulk-Power System

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

The use of current or improved technology is not covered in Reliability Standards and is therefore left to the discretion of each reporting entity. Commission staff estimates that nearly all of the respondents are likely to make and keep related records in an electronic format. Each of the eight Regional Entities has a well-established compliance portal for registered entities to electronically submit compliance information and reports. The compliance portals allow documents developed by the registered entities to be attached and uploaded to the Regional Entity’s portal. Compliance data can also be submitted by filling out data forms on the portals. These portals are accessible through an internet browser password protected user interface.

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 concurrent with OMB review or as the Commission deems necessary to eliminate duplicative filing and to minimize the filing burden. This information is not available elsewhere. The standard-developing group (the ERO and various stakeholders) think these areas need to be addressed and documented as indicated in the NERC Petition.

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

Small entities generally can reduce their burden by taking part in a joint registration organization or a coordinated function registration. These options allow an entity the ability to share its compliance burden with other similar entities.

Detailed information regarding these options is available in NERC’s Rules of Procedure at sections 507 and 508.⁸

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

FAC-001-4 imposes the obligation to document, maintain, and publish interconnection requirements. Failure to properly maintain the interconnection requirement documents and make them available to entities upon request could adversely impact reliable planning and operation of the Bulk Electric System because data needed to perform studies to determine the impact of interconnecting facilities on existing interconnections as well as on affected systems may not be provided. Further, lack of these documents could result in inaccurate and uncoordinated interconnection studies, leading to possible instances of instability, uncontrolled separation and cascading failures. The requirements include retention periods that identify the period of time an entity is required to retain specific evidence to demonstrate compliance.

For Reliability Standard FAC-002-4, all applicable entities need to cooperate in sharing data so valid and complete studies can be performed to accurately assess the reliability impact of interconnecting new or materially modified facilities. Failing to conduct studies of these interconnecting facilities could lead to instances of violation with other national and regional standards. Also, actual system performance under normal and emergency conditions may not match the results of steady-state, short circuit and dynamic studies, which could impact Bulk Electric System reliability and lead to instances of instability, uncontrolled separation and cascading failures. These requirements include retention periods that identify the period of time an entity is required to retain specific evidence to demonstrate compliance. If a responsible entity is found non-compliant, it shall keep information related to the non-compliance until mitigation is complete and approved.

As for FAC-003-5, FAC-008-5, FAC-011-4, and FAC-014-2, the establishment of how to identify SOLs and use it within the planning and operating horizons is critical to the reliability of the BPS. Failure to keep accurate data could cause contingency cases to be out of date and problem areas not being properly identified.

7. EXPLAIN ANY SPECIAL CIRCUMSTANCES RELATING TO THE INFORMATION COLLECTION

There are no special circumstances as described in 5 CFR 1320.5(d)(2).

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

The ERO process to develop Reliability Standards is a collaborative process involving the ERO, Regional Entities and other stakeholders developing and reviewing drafts, and providing comments, vetting and voting (possibly multiple rounds) on the standards, with the final proposed standard(s) submitted to the FERC for review and approval.⁹ In addition, each FERC Paperwork Reduction Act (PRA) notice is published in the Federal Register thereby providing public utilities and licensees, state commissions, Federal agencies, and other interested parties an opportunity to submit data, views, comments or suggestions concerning the collections of data.

This supporting statement is set out to reflect the transfer of FAC-003-5 from FERC-725M and FAC-008-5 from 725A into FERC-725D. The 60-day Federal Register notice published on January 27, 2025 (90 FR 8208), with no comment received. The 30-day notice was published on April 11, 2025 (90 FR 15457).

9. EXPLAIN ANY PAYMENT OR GIFTS TO RESPONDENTS

The Commission does not make payments or provide gifts for respondents related to these collections.

10. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS

According to the NERC Rules of Procedure, “…a Receiving Entity shall keep in confidence and not copy, disclose, or distribute any Confidential Information or any part thereof without the permission of the Submitting Entity, except as otherwise legally required.” This serves to protect confidential information submitted to NERC or Regional Entities.

Responding entities do not submit the information collected for Reliability Standards to FERC. Rather, they submit the information to NERC, the regional entities, or maintain it internally. Since there are no submissions made to FERC, FERC provides no specific provisions in order to protect confidentiality.

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.

These collections do not contain any questions of a sensitive nature.

12. ESTIMATED BURDEN OF COLLECTION OF INFORMATION

In the table below, the renewal Docket No. IC25-8-000.

The Commission estimates an increase (adjustment) in the annual public reporting burden for the FERC-725D. In an effort to target similar NERC Reliability Standards by family the following manhours associated with two FAC (Facilities) Reliability Standards (FAC-008-5 and FAC-003-5 from 725M) is being transferred from 725A (1902-0244) to the 725D (1902-0247), where other FAC standards are collected, as shown below in the table:

	Number of Entity10 (1)	Number of Annual Responses Per Entity (2)	Total Number of Responses (1) *(2) = (3)	Average Number of Burden Hours per Response11 (4)	Total Burden Hours (3) *(4) = (5)
Transferred from FERC-725M to FERC-725D
Annual Review and Record Retention	191(TO)	1	191	1.91 hrs. $134.98/hrs.	364.81 hrs. $25,781.12
	731(GO)	1	731	.48 hrs. $33.92 hrs.	349.41 hrs. $24,728.14
Carryover from RD22-2 Exp. 2026	1,393	4	5,572	8 hrs. $565.36	44,576 hrs. $3,150,185.92
Total for FAC-003-5			6,494		45,290.22 hrs. $3,200,659.85

	Number of Entity12 (1)	Number of Annual Responses Per Entity (2)	Total Number of Responses (1) *(2) = (3)	Average Number of Burden Hours per Response13 (4)	Total Burden Hours (3) *(4) = (5)
Transferred from FERC-725A to FERC-725D
Annual review and record retention	324 (TO)	1	324	200 hrs. $70.67/hrs.	64,800 hrs. $4,579,416
	1210 (GO)	1	1210	80 hrs. $70.67/hrs.	96,800 hrs. $6,840,856
Total for FAC-008-5			1,534		161,600 hrs. $11,420,272

13. ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS

There is no start-up, capital, or other non-labor hour cost associated with the PRA aspects of FERC-725D. All costs are associated with burden hours and are addressed in Questions 12 and 15.

14. ESTIMATED ANNUALIZED COST TO FEDERAL GOVERNMENT

The Regional Entities and NERC do most of the data processing, monitoring and compliance work for Reliability Standards. Therefore, there are no costs for analysis and processing of filings.

The PRA Administrative Cost (estimate of $8,396 annually) is a Federal Cost associated with preparing, issuing, and submitting materials necessary to comply with the Paperwork Reduction Act of 1995 (PRA) for rulemakings, orders, or any other vehicle used to create, modify, extend, or discontinue an information collection. This average annual cost includes requests for extensions, all associated rulemakings or orders, and other changes to the collection, as well as necessary publications in the Federal Register.

	Number of Employees (FTE)	Estimated Annual Federal Cost
Analysis and Processing of filings14	0	0
PRA Administrative Cost		$8,396
FERC Total		$8,396

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

Burden estimates for the following Reliability Standards in FERC-725D are unchanged as follows:

• FAC-001-4 remains unchanged at 498 responses.

• FAC-002-4 remains unchanged at 399 responses

• FAC-011-4 and FAC-014-3 remain unchanged at 470 responses.

For this notice and moving forward, Evidence Retention is included in the burden estimates for all standards.

• There is an increase in burden hours (both program change and adjustments) from 77,477 to 284,367 to reflect FAC-003-5 and FAC-008-5.

• The totals were updated to reflect the current burden changes for FAC-003-5 and FAC-008-5:

FERC-725D	Total Request	Previously Approved	Change due to Adjustment in Estimate	Change Due to Agency Discretion
Annual Number of Responses	10,395	2,467	7,928	0
Annual Time Burden (Hr.)	284,367	77,477	206,890	0
Annual Cost Burden ($)	0	0	0	0

16. TIME SCHEDULE FOR PUBLICATION OF DATA

There are no data publications.

17. DISPLAY OF EXPIRATION DATE

The PRA information (including expiration dates and OMB Control Nos.) is posted at http://www.ferc.gov/docs-filing/efiling.asp

18. EXCEPTIONS TO THE CERTIFICATION STATEMENT

The Commission does not use statistical methods for FERC-725D.

1 The Energy Policy Act of 2005, Pub. L. No 109-58, Title XII, Subtitle A, 119 Stat. 594, 941 (2005), codified at 16 U.S.C. 824o (2006).

2 Id. 824o(c), (d).

3 Id. 824o(e).

4 “Electric Reliability Organization” or “ERO” means the organization certified by the Commission the purpose of which is to establish and enforce Reliability Standards for the Bulk-Power System, subject to Commission review.

5 North American Electric Reliability Corp., 116 FERC ¶ 61,062, order on reh’g and compliance, 117 FERC ¶ 61,126 (2006), order on compliance, 118 FERC ¶ 61,190, order on reh’g, 119 FERC ¶ 61,046 (2007), aff’d sub nom. Alcoa Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009).

6 The table is based on a table from the NERC website at https://www.nerc.net/standardsreports/standardssummary.aspx

7 This column represents the effective date of the most recent approved version for each respective standard.

8 Details of the current ERO Reliability Standard processes are available on the NERC website at http://www.nerc.com/FilingsOrders/us/RuleOfProcedureDL/Appendix_3A_StandardProcessesManual_20130626.pdf.

9 Details of the current ERO Reliability Standard processes are available on the NERC website at http://www.nerc.com/FilingsOrders/us/RuleOfProcedureDL/Appendix_3A_StandardProcessesManual_20130626.pdf.

10 These values were derived from the NERC Compliance data of April 16, 2024, using only unique United States registered entities.

11 The estimated hourly cost (salary plus benefits) is a combination based on the Bureau of Labor Statistics (BLS), as of 2024, for 75% of the average of an Electrical Engineer (17-2071) $79.31/hr., 79.31 x .75 = 59.4825 ($59.48-rounded) ($59.48/hour) and 25% of an Information and Record Clerk (43-4199) $44.74/hr., $44.74 x .25% = 11.185 ($11.19 rounded) ($11.19/hour), for a total ($59.48+$11.19 = $70.67/hour).

12 These values were derived from the NERC Compliance data of April 16, 2024, using only unique United States registered entities.

13 The estimated hourly cost (salary plus benefits) is a combination based on the Bureau of Labor Statistics (BLS), as of 2024, for 75% of the average of an Electrical Engineer (17-2071) $79.31/hr., 79.31 x .75 = 59.4825 ($59.48-rounded) ($59.48/hour) and 25% of an Information and Record Clerk (43-4199) $44.74/hr., $44.74 x .25% = 11.185 ($11.19 rounded) ($11.19/hour), for a total ($59.48+$11.19 = $70.67/hour).

14 Based upon FERC’s 2024 FTE average salary plus benefits ($207,787)

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