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OMB Control No: 1902-0263	ICR Reference No: 201910-1902-001
Status: Historical Active	Previous ICR Reference No: 201607-1902-001
Agency/Subagency: FERC	Agency Tracking No: FERC-725M
Title: FERC-725M, Mandatory Reliability Standard: FAC-003-4, Vegetation Management
Type of Information Collection: Reinstatement without change of a previously approved collection	Common Form ICR: No
Type of Review Request: Emergency	Approval Requested By: 10/08/2019
OIRA Conclusion Action: Approved without change	Conclusion Date: 11/04/2019
	Date Received in OIRA: 10/08/2019
Terms of Clearance: OMB approves 3 months of an extension request while FERC works to reinstates this collection for the full 3 years.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	02/29/2020	12/31/2019
Responses	510	0	0
Time Burden (Hours)	2,296	0	0
Cost Burden (Dollars)	0	0	0

Abstract: As stated by NERC in its Petition (dated 3/14/2016 [footnotes omitted]) in Docket No. RD16-4, “[t]he 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. 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. The EPRI Report, the preliminary report preceding it, and EPRI’s recent update to the EPRI Report filed in Docket No. RM12-4-000 are attached at Exhibit E. 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 (dated 4/26/2016) in Docket No. RD16-4, FERC approved the revised Reliability Standard proposed by NERC.

Emergency Justfication: See the letter from FERC's General Counsel to OMB requesting reinstatement and an emergency extension of FERC-725M. The letter (dated 10/7/2019) is attached under 'Supplementary Documents.' FERC requests a 3-month Emergency Extension (to 12/31/2019, from 9/30/2019) of FERC-725M. The 60-day notice for FERC-725M was published in the Federal Register on 8/27/2019, 84 FR 44890, with a public comment period ending 10/28/2019. (It is included under Supplementary Documents.) The FERC-725M reporting and recordkeeping requirements are generally not submitted to the Commission but are prepared and retained for use by the compliance enforcement authority (NERC [the nation’s FERC-approved Electric Reliability Organization] or the Regional Entity). If that FERC-725M information were not required and available, it could jeopardize the reliability of the nation’s Bulk Power System and lead to additional sustained power outages. The Commission requires the information in the FERC-725M to implement statutory provisions of section 215 of the Federal Power Act (FPA). On 8/8/2005, Congress enacted the Electricity Modernization Act of 2005, which is Title XII, Subtitle A, of the Energy Policy Act of 2005 (EPAct 2005). 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, the Reliability Standards may be enforced by the ERO subject to Commission oversight, or the Commission can independently enforce Reliability Standards. Reliability Standards developed by the ERO and approved by the Commission apply to users, owners and operators of the Bulk-Power System as set forth in each Reliability Standard. FERC-725M includes Reliability Standard FAC-003-4 (Transmission Vegetation Management). Purpose of FAC-003-4: “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.” Need for FAC-003-4 Data, and Risk without Data: Vegetation contact with transmission lines was a major factor in two significant blackouts (WECC territory in 1996, and the August 2003 Northeast blackout). The documentation requirements related to vegetation management requirements assists respondents to manage vegetation located on rights-of-way and minimize vegetation encroachments. The documentation further provides a way for auditors to evaluate compliance with this standard. Failure to impose the requirements could jeopardize system reliability and lead to outages in the Bulk Power System.

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
Did the Agency receive public comments on this ICR? No

ICR Summary of Burden

	Total Approved	Change Due to Potential Violation of the PRA
Annual Number of Responses	510	510
Annual Time Burden (Hours)	2,296	2,296
Annual Cost Burden (Dollars)	0	0

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

Burden Increase Due to:

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

Burden Reduction Due to:

Short Statement:

Annual Cost to Federal Government: $5,481

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

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination. No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination. 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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