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OMB Control No: 1902-0263	ICR Reference No: 202210-1902-003
Status: Historical Active	Previous ICR Reference No: 201912-1902-001
Agency/Subagency: FERC	Agency Tracking No: FERC-725M
Title: FERC-725M, (DLO in RD22-2) Mandatory Reliability Standard: FAC-003-5, Transmission Vegetation Management
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: 01/27/2023
	Date Received in OIRA: 10/20/2022
Terms of Clearance: Agency will revisit the burden estimates for 725M in the next renewal, to account for entities becoming familiar with the FAC-003-5 requirements.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	01/31/2026	36 Months From Approved	04/30/2023
Responses	6,494	0	922
Time Burden (Hours)	45,290	0	714
Cost Burden (Dollars)	0	0	0

Abstract: FERC-725M, Mandatory Reliability Standard: FAC-003-5 (formerly FAC-003-4), Transmission Vegetation Management (OMB Control No. 1902-0263) for a three-year period and modifications due to RD-22-2 revisions. FERC-725M is an existing data collection with reporting requirements in 18 Code of Federal Regulations (CFR), Part 40. FAC-003-5 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 Reliability Standard FAC-003-4 (now FAC-003-5) 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-003-5. In the Delegated Order (dated 4/1/2022) in Docket No. RD22-2, 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:
	87 FR 22202	04/14/2022
30-day Notice:	Federal Register Citation:	Citation Date:
	87 FR 55422	09/09/2022
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	6,494	922	5,572
Annual Time Burden (Hours)	45,290	714	44,576
Annual Cost Burden (Dollars)	0	0	0

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

Burden Increase Due to: Changing Regulations

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

Burden Reduction Due to:

Short Statement: For 725M (FAC-003 Reliability Standard), the change (increase in responses and decrease in manhours) is due to agency discretion as we have updated the method to determine affected entities and their responses. The new method of examining entities reflects separating the types of entities where there may have been a previous overlap. The estimate workload by entities is expected to decrease overall as entities have familiar with information collection and burden associated with compliance of the standard and tools in place to reduce the overall burden.

Annual Cost to Federal Government: $8,279

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? No

Agency Contact: David O'Conner 202 502-6695

View ICR - OIRA Conclusion