FERC-725T supporting statement

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Supporting Statement
FERC-725T, Mandatory Reliability Standards for the Bulk-Power System: TRE Reliability Standards
Three-year approval of extension requested and update to BAL-001 TRE-2 (RD25-10)

The Federal Energy Regulatory Commission (FERC or Commission) requests that the Office of Management and Budget (OMB) review and approve the FERC-725T (Mandatory Reliability Standards for the Bulk-Power System: Texas Reliability Entity (TRE) Reliability Standards) information collection for a three-year period under OMB Control Number 1902-0273. The information collection requirements are contained in the Commission’s regulations in 18 CFR Part 40. Update of BAL-001-TRE-2.

1.	CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY

On August 8, 2005, the Electricity Modernization Act of 2005, which is Title XII,
Subtitle A, of the Energy Policy Act of 2005 (EPAct 2005), was enacted into law.1  EPAct 2005 added a new Section 215 to the FPA, which requires a Commission-certified Electric Reliability Organization (ERO) to develop mandatory and enforceable Reliability Standards which are subject to Commission review and approval.  Once approved, an ERO would enforce the Reliability Standards which are subject to Commission oversight.2

On February 3, 2006, the Commission issued Order No. 672, implementing section 215 of the FPA.3  Pursuant to Order No. 672, the Commission certified one organization, NERC, as the ERO.4  The ERO is required to develop Reliability Standards, which are subject to Commission review and approval.5  The Reliability Standards applies to users, owners and operators of the Bulk-Power System, as set forth in each Reliability Standard. 

Section 215(d)(2) of the FPA and the Commission’s regulations provide that the Commission may approve a proposed Reliability Standard if it determines that the proposal is just, reasonable, not unduly discriminatory or preferential, and in the public interest. The Commission specified in Order No. 672 certain general factors it would consider when assessing whether a particular Reliability Standard is just and reasonable.6  According to this guidance, a Reliability Standard must provide for the Reliable Operation of Bulk-Power System facilities and may impose a requirement on any user, owner or operator of such facilities. It must be designed to achieve a specified reliability goal and must contain a technically sound means to achieve this goal. The Reliability Standard should be clear and unambiguous regarding what is required and who is required to comply.

For the Texas Region, there is one regional standard BAL-001-TRE-2 whose purpose is to maintain Interconnection steady-state frequency within defined limits and is designed to work in conjunction with national standard BAL-001.


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

Reliability Standard BAL-001-TRE-2 is currently located in the FERC-725T (OMB Control No. 1902-0273) collection.  The purpose of Reliability Standard BAL-001-TRE-2 is to maintain interconnection steady-state frequency within defined limits.  The category 2 generator owners and generator operators will now have to follow Requirements R6 through R10.  Requirements R6, R7, R9, and R10 require the generator owner to set their governor parameters to be responsive to frequency obligations and provide notification to other entities when their governor is unavailable.  Requirement R8 requires generator operators notify their balancing authority of service status changes.


Reliability Standards TRE applies to entities registered as Generator Owners (GOs), Generator Operators (GOPs), and Balancing Authorities (BAs).  

Regional Reliability Standards TRE are comprehensive than the existing continent-wide Reliability Standards addressing frequency response. The expanded applicability of the regional Reliability Standard, thus, increases the reporting burden for entities that operate within the Electric Reliability Council of Texas (ERCOT) Interconnection.

The information collection requirements entail the setting or configuration of the Control System software, identification and recording of events, data retention, and submitting frequency measurable events to the compliance enforcement authority (a Regional Entity or NERC).

Control System software: Each GO must set its governor settings according to Requirement R6.  In order to modify its settings in the GO may have to generate governor test reports, governor setting sheets, and/or performance monitoring reports. 

Submitting frequency measurable events:  As per Requirement R1, the BA must identify and post information regarding Frequency Measurable Events (FME).  Further, the BA must calculate and report to the Compliance Enforcement Authority data related to Primary Frequency Response (PFR) performance of each generating unit/generating facility.

Data retention: The BA, GO, and GOP 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 as part of an investigation.  Compliance audits are generally about three years apart.

    • The BA shall retain a list of identified Frequency Measurable Events and shall retain FME information since its last compliance audit for Requirement R1, Measure M1.
    • The BA shall retain all monthly PFR performance reports since its last compliance audit for Requirement R2, Measure M2.
    • The BA shall retain all annual Interconnection minimum Frequency Response calculations, and related methodology and criteria documents, relating to time periods since its last compliance audit for Requirement R3, Measure M3.
    • The BA shall retain all data and calculations relating to the Interconnection’s Frequency Response, and all evidence of actions taken to increase the Interconnection’s Frequency Response, since its last compliance audit for Requirements R4 and R5, Measures M4 and M5.
    • Each GOP shall retain evidence from its last compliance audit for Requirement R8, Measure M8.
    • Each GO shall retain evidence since its last compliance audit for Requirements R6, R7, R9 and R10, Measures M6, M7, M9 and M10.

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

The use of current or improved technology and the medium are not covered in Reliability Standards and are, therefore, left to the discretion of each respondent.

We think that nearly all 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 portals. These portals are accessible through an internet browser password-protected user interface.

In general, the Commission supports the use of information technology to reduce burden.
 
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.  The Reliability Standard does not duplicate any other collections.

The Commission is unaware of any other source of information similar to the additional requirements.

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

In general, small entities may reduce their burden by taking part in a joint registration organization or a coordinated functional registration.  These options allow an entity to share its compliance burden with other entities.

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

The purpose of this Reliability Standard is to establish and maintain adequate frequency response in the ERCOT region.  If the frequency in a system gets out of balance it can lead to load shedding and blackouts.  The information collection requirements help ensure adequate levels of frequency response.  The frequency of the requirements was vetted and approved by industry consensus in the NERC standard development process.  Reduced frequency would likely lead to increased risk of load shedding and blackout.

7.	EXPLAIN ANY SPECIAL CIRCUMSTANCES RELATING TO THE INFORMATION COLLECTION

There are no special circumstances related to the information collection.

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

RD25-10
In accordance with OMB requirements, the Commission published a 60-day notice7 and a 30-day notice8 to the public regarding this information collection on 12/22/2025 and 3/2/2026 respectively.  Within the public notices, the Commission noted that it would be requesting a three-year extension of the public reporting burden. The Commission received no comments from the public regarding this information collection.

Renewal
In accordance with OMB requirements, the Commission published a 60-day notice9 and a 30-day notice10 to the public regarding this information collection on 3/4/2026 and 5/29/2026 respectively.  Within the public notices, the Commission noted that it would be requesting a three-year extension of the public reporting burden.  The Commission received no comments from the public regarding this information collection.

9.	EXPLAIN ANY PAYMENT OR GIFTS TO RESPONDENTS

There are no payments or gifts to respondents.

10.	DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS

According to the NERC Rule of Procedure11, “…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 due to the Reliability Standards to FERC.  Rather, they submit the information to NERC, the regions, 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.

There are no questions of a sensitive nature associated with the FERC-725T reporting requirements.

12.	ESTIMATED BURDEN OF COLLECTION OF INFORMATION

The applicable requirements from the eight applicable Reliability Standards largely consist of sharing and communicating readily available data and information for category 2 resources.  Thus, Commission staff anticipate that the paperwork burden should be minimal for category 2 resources.  The number of respondents, in the tables below, are based on good faith estimates provided by NERC, in August 2025, to Commission staff for the number of entities that either own or operate category 2 resources.  
The Commission estimates the Public Reporting burden for the FERC-725T information collection as follows: 

RD25-10 revisions for FERC-725T: Mandatory Reliability Standard for the TRE-BAL
 
Number of Respondents12
(1)
Annual Number of Responses per Respondent
(2)
Total Number of Responses (1)*(2)=(3)
Average Burden & Cost Per Response13
(4)
Total Annual Burden Hours & Total Annual Cost
(3)*(4)=(5)
Cost per Respondent
 ($)
(5)÷(1)
BAL-001-TRE-2 
Annual Review and Record Retention
30
 (GO)

1
30

8 hrs.
$508.16
 240 hrs.
$15,244.80 
$508.16


23 (GOP)
1
23
4 hrs.
$254.08
92 hrs.
$5,843.84
$254.08
TOTAL

+53

+332 hrs.
$21,088.64
$762.24

Renewal Table:
FERC-725T (Mandatory Reliability Standards for the Bulk-Power System: TRE (BAL-001-TRE-2) Reliability Standards)

Number of Respondents14
(1)
Annual Number of Responses per Respondent
(2)
Total Number of Responses (1)*(2)=(3)
Average Burden & Cost Per Response15
(4)
Total Annual Burden Hours & Total Annual Cost
(3)*(4)=(5)
Cost per Respondent
 ($) Rounded
(5)÷(1)
Annual Review and Evidence Retention
1 (BA)

1
1
18 hrs.; 
$1,143.36
 18 hrs.; 
$1,143.36
$1,143


309 (GO)
1
309
2 hrs.; 
$127.04
618 hrs.;
$39,255.36
$127


220 (GOP)
1
220
2 hrs.; 
$127.04
440 hrs.;
$27,948.80
$127

RD25-10 Total 

+53

+332 hrs.

TOTAL

583

1,408 hrs.;
$89,436.16



13. ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS

There are no capital or start-up costs associated with this collection.  All of the costs are associated with the burden hours and accounted for in Question #12.

14. ESTIMATE OF THE TOTAL ANNUAL COST TO FEDERAL GOVERNMENT


Number of Employees (FTE)
Estimated Annual Federal Cost
Analysis and Processing of filings16
0
$0  
PRA17 Administrative Cost18

$8,404
FERC Total

$8,404

The Commission bases its estimate of the “Analysis and Processing of filings” cost to the Federal Government 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 collection.
	
15.	REASONS FOR CHANGES IN BURDEN INCLUDING THE NEED FOR ANY INCREASE

Change due to Agency Adjustment in Agency
The burden is related to the maintenance and submission of event log data and evidence retention (i.e. record retention) as illustrated in Question #12 of this supporting statement.   The large change in burden is due to counting each entity’s function separately which previously missed overlapping entities.  Also, there has been an increase in number of renewable energy entities in the Texas region.
Program Change Due to Agency Discretion
An increase in generator Owners and Generator Operators due to the changes in RD25-10.
The following table shows the change to the burden due to the adjustments mentioned above.  The table reflects format used in reginfo.gov and ROCIS.


Total Request
Previously Approved
Change due to Adjustment in Estimate
Program Change Due to Agency Discretion
Annual Number of Responses
583
421
+109
53
Annual Time Burden (Hr.)
1,408 
856
+220
332
Annual Cost Burden ($)
0
0
0
0


16.	TIME SCHEDULE FOR THE PUBLICATION OF DATA

There are no tabulations, statistical analysis, or publications of information planned for the FERC-725T information collection.

17.	DISPLAY OF EXPIRATION DATE

The expiration date is displayed in a table posted on ferc.gov at https://www.ferc.gov/information-collections.

18.	EXCEPTIONS TO THE CERTIFICATION STATEMENT

The Commission will not be using statistical survey methodology for this information collection.