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OMB Control No: 1902-0263	ICR Reference No: 201607-1902-001
Status: Historical Active	Previous ICR Reference No: 201309-1902-001
Agency/Subagency: FERC	Agency Tracking No: FERC-725M
Title: FERC-725M, (Delegated Order in RD16-4) Mandatory Reliability Standards:Generator Requirements at the Transmission Interface
Type of Information Collection: Revision of a currently approved collection	Common Form ICR: No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 09/21/2016
	Date Received in OIRA: 07/18/2016
Terms of Clearance: In accordance with 5 CFR 1320, the information collection is approved for three years.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	09/30/2019	36 Months From Approved	12/31/2016
Responses	510	0	96
Time Burden (Hours)	2,296	0	1,330
Cost Burden (Dollars)	0	0	0

Abstract: RD16-4. In its Petition proposing the revised Rel. Std., NERC states in part (footnotes omitted) that: “The purpose of proposed Reliability Standard FAC-003-4 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.6 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. … 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-003-4. Proposed Reliability Standard FAC-003-4, therefore proposes higher and more conservative MVCD values. These higher MVCD values will enhance reliability and provide additional confidence by applying a more conservative approach to determining the vegetation clearing distances.” In the Delegated Order in Docket RD16-4, FERC approves 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:
	81 FR 26543	05/03/2016
30-day Notice:	Federal Register Citation:	Citation Date:
	81 FR 46664	07/18/2016
Did the Agency receive public comments on this ICR? No

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to Agency Discretion
Annual Number of Responses	510	96	414
Annual Time Burden (Hours)	2,296	1,330	966
Annual Cost Burden (Dollars)	0	0	0

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

Burden Increase Due to: Miscellaneous Actions

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

Burden Reduction Due to:

Short Statement: On March 14, 2016, the North American Electric Reliability Corporation (NERC) filed a petition for Commission approval of proposed Reliability Standard FAC-003-4 (Transmission Vegetation Management). NERC seeks an effective date for the proposed Reliability Standard of the first day of the first calendar quarter three months after the effective date of the Commission’s order approving the proposed Reliability Standard, and requests approval of the retirement of currently-effective Reliability Standard FAC-003-3. NERC states in its petition that proposed Reliability Standard FAC-003-4 reflects revisions to the current Minimum Vegetation Clearance Distances (MVCDs) in Reliability Standard FAC-003-3 based on additional testing regarding the appropriate gap factor to be used to calculate clearance distances for vegetation. NERC explains that in response to the Commission’s directive as part of its approval of an earlier version of the Reliability Standard, FAC-003-2, NERC contracted with the Electric Power Research Institute (EPRI) to conduct this testing. As NERC notes, when the Commission approved Reliability Standard FAC-003-2, the Commission stated that “it is important that NERC develop empirical evidence that either confirms assumptions used in calculating the MVCD values based on the Gallet equation, or gives reason to revisit the Reliability Standard.” NERC states in its petition that preliminary testing conducted by EPRI indicated that the gap factor used to calculate MVCDs should be adjusted from 1.3 to 1.0, which would result in MVCD values higher than those in currently-effective Reliability Standard FAC-003-3. NERC explains that it worked with EPRI to finalize the gap factor verification, submitting a final report to the Commission in August 2015. In addition, NERC states that the EPRI report was updated in anticipation of the instant petition. NERC explains that the EPRI tests support the conclusion that MVCD values under currently-effective Reliability Standard FAC-003-3 are low and “demonstrate[] that the Gallet equation should apply a more conservative, lower gap factor of 1.0 to calculate MVCD values.” NERC further explains that proposed Reliability Standard FAC-003-4 proposes higher and more conservative MVCD values and, therefore, maintains that these revisions will “enhance reliability and provide additional confidence by applying a more conservative approach to determining the vegetation clearing distances.” NERC states that the revised clearances as reflected in Table 2 were moved into the text of the proposed Reliability Standard and that MVCD values were added for elevations up to 15,000 feet, but that no other substantive changes were made to the currently-effective Reliability Standard FAC-003-3. NERC’s filing was noticed on March 16, 2016, with interventions, comments and protests due on or before April 14, 2016. No comments were received. NERC’s uncontested petition is hereby approved by FERC Delegated Order pursuant to the relevant authority delegated to the Director, Office of Electric Reliability under 18 C.F.R. § 375.303 (2015). The estimated burden increase annually in Years 1-3 of 966 hours averages one-time implementation over 3 years; in Year 4 and subsequent years the additional burden is 414 hours.

Annual Cost to Federal Government: $5,481

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

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? 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? Uncollected

Agency Contact: Dennis Fuentes-Pedrosa 202 502-6627 dennis.fuentes-pedrosa@ferc.gov

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