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View ICR - OIRA Conclusion
OMB Control No:
ICR Reference No:
Previous ICR Reference No:
Agency Tracking No:
FERC-520, Application for Authority to Hold Interlocking Interlocking Directorate Positions
Type of Information Collection:
Extension without change of a currently approved collection
Common Form ICR:
Type of Review Request:
OIRA Conclusion Action:
Approved with change
Retrieve Notice of Action (NOA)
Date Received in OIRA:
Terms of Clearance:
In accordance with 5 CFR 1320, the information collection is approved for three years.
Inventory as of this Action
36 Months From Approved
Time Burden (Hours)
Cost Burden (Dollars)
The FERC-520, "Application for Authority to Hold Interlocking Directorate Positions", originates in FPA Section 305(b) of the FPA. It is an application requesting FERC authorization for board members of regulated electric utilities who plan to simultaneously be holding positions on the corporate boards of related or similar businesses. This corporate activity is known as an "interlocked directorate." Under the FPA the holding of certain defined interlocking corporate positions is unlawful unless the Commission has authorized the interlocks to be held. Before assuming an interlocked board position, an applicant must demonstrate that neither public nor private interests will be adversely affected by the holding of the position. The FERC-520 identifies the applicant and provides FERC with a list and information about any interlocking position the applicant seeks authorization to hold. Moreover, the form collects information related to the applicant's financial interests, other officers and directors of the firms involved, and the nature of business relationships among the firms.
US Code: 16 USC 825(d) Name of Law: Federal Power Act
Citations for New Statutory Requirements:
Associated Rulemaking Information
Stage of Rulemaking:
Federal Register Citation:
Not associated with rulemaking
Federal Register Notices & Comments
Federal Register Citation:
76 FR 12091
Federal Register Citation:
76 FR 34217
Did the Agency receive public comments on this ICR?
Number of Information Collection (IC) in this ICR:
Application for Authority to Hold Interlocking Interlocking Directorate Positions
ICR Summary of Burden
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
Annual Time Burden (Hours)
Annual Cost Burden (Dollars)
Burden increases because of Program Change due to Agency Discretion:
Burden Increase Due to:
Burden decreases because of Program Change due to Agency Discretion:
Burden Reduction Due to:
A concern developed in 2004 that FERC-520 applications for authorizations to hold interlocked positions were not being filed before individuals assumed the interlocked positions, as required. In response, the Commission issued its June 2004 interlocking directorate policy statement in PL04-10-000 and Order 664 in September 2005. The burden estimate for the FERC-520 in this request is based on recent Commission experience and the actual number of FERC-520 filings made between 2008 and 2010. The number of informational applications has increased steadily from 87 in 2004 to 335 in 2010. The Commission began to separate the FERC-520 filings by types of application in its OMB clearance estimates in 2008 because the number of each type of application filed had been changing significantly. Breaking the data out by type of filing allows these changes to be easily seen. The last OMB clearance package divided the FERC-520 filings only into two categories: full and informational filings. Decreases in the number of initial and informational applications has necessitated the separate tracking and reporting of three types of possible applications and the burden hours each imposes. Therefore, this OMB clearance package adds Notice of Change filings, further breaking down the categories of FERC-520 to capture, convey and begin to analyze all types of FERC-520s. The decrease in the number of FERC-520 applications may be due to directors retaining their positions longer because of the slow economy. There is a change in the annual cost estimates since the last submission in 2008 due mainly to a decrease in the number of FERC-520 filers. However, the per hour cost estimate for each collection has increased since 2008 because the Commission is using an updated salary estimate.
Annual Cost to Federal Government:
Does this IC contain surveys, censuses, or employ statistical methods?
Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002?
Is this ICR related to the Affordable Care Act [PPACA, P.L. 111-148 & 111-152]?
Is this ICR related to the Dodd-Frank Act [Dodd-Frank Wall Street Reform and Consumer Protection Act, P.L. 111-203]?
Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)?
Norma McOmber 202 502-8022
Common Form ICR:
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.