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OMB Control No: 1902-0263	ICR Reference No: 201912-1902-001
Status: Historical Active	Previous ICR Reference No: 201910-1902-001
Agency/Subagency: FERC	Agency Tracking No: FERC-725M
Title: FERC-725M, Mandatory Reliability Standard: FAC-003-4, Vegetation Management
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR: No
Type of Review Request: Regular
OIRA Conclusion Action: Approved with change	Conclusion Date: 04/17/2020
	Date Received in OIRA: 02/13/2020
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	04/30/2023	36 Months From Approved	04/30/2020
Responses	922	0	510
Time Burden (Hours)	714	0	2,296
Cost Burden (Dollars)	0	0	0

Abstract: FERC-725M, Mandatory Reliability Standard: FAC-003-4, Vegetation Management (OMB Control No. 1902-0263) for a three-year period. FERC-725M is an existing data collection with reporting requirements in 18 Code of Federal Regulations (CFR), Part 40. FAC-003-4 extends NERC’s vegetation management requirements to Generator Owners with qualifying interconnection facilities, including requirements to create and maintain records related to the Generator Owner’s vegetation management work plan and performance of inspections 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.

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:
	84 FR 44891	08/27/2019
30-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 8278	02/13/2020
Did the Agency receive public comments on this ICR? No

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to Agency Discretion	Change Due to Adjustment in Estimate
Annual Number of Responses	922	510	317	95
Annual Time Burden (Hours)	714	2,296	-101	-1,481
Annual Cost Burden (Dollars)	0	0	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: Yes

Burden Reduction Due to: Miscellaneous Actions

Short Statement: FERC is adjusting the burden in FAC-003-4 to reflect the latest number of applicable entities based on the NERC Compliance Registry as of July 26, 2019. According to the NERC Compliance Registry as of July 26, 2019, there are 946 generator owners and 328 transmission owners registered in North America. We estimate that approximately 10 percent (or 95) of these generator owners have interconnection facilities that are applicable to the standard. FERC is also removing all “one-time” burden which has been completed.

Annual Cost to Federal Government: $4,832

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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