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OMB Control No: 1902-0248	ICR Reference No: 202606-1902-003
Status: Received in OIRA	Previous ICR Reference No: 202606-1902-001
Agency/Subagency: FERC	Agency Tracking No: FERC-725B
Title: FERC-725B, RD25-8 and Renewal, Mandatory Reliability Standards for Critical Infrastructure Protection (CIP)
Type of Information Collection: Revision of a currently approved collection	Common Form ICR: No
Type of Review Request: Regular	Date Submitted to OIRA: 06/16/2026

	Requested	Previously Approved
Expiration Date	36 Months From Approved	09/30/2026
Responses	259,379	262,733
Time Burden (Hours)	1,073,723	2,639,597
Cost Burden (Dollars)	0	0

Abstract: For RD25-8 updating CIP-002-8 and Renewal of the remaining: Reliability Standards CIP 003-10, CIP-004-8, CIP-005-8, CIP-006-7.1, CIP-007-7.1, CIP-008-7.1, CIP 009 7.1, CIP-010-5, CIP-011-4.1, CIP-013-3, CIP-14-3, and CIP-015-1. According to NERC, the Reliability Standards would allow responsible entities to fully implement virtualization and address risks associated with virtualized environments, such as “side channel” attacks where virtual systems executing on the same hardware could affect one another. NERC also states that the use of security objectives within the CIP Reliability Standards establishes a framework adaptable to newer technologies. NERC explains that its revisions would: (1) support different security models by adjusting language around perimeter-based models to accommodate other security models; (2) recognize “virtualization infrastructure and virtual machines through new and revised terms in the NERC Glossary;” (3) broaden “change management approaches beyond a baseline-only configuration to recognize the dynamic nature of virtualized technologies,” e.g., where such virtualized systems are no longer installed on specific servers; and (4) manage “accessibility and attack surfaces of a virtualized configuration.” In addition to the changes to facilitate virtualization, the proposed Reliability Standards incorporate clarifications found during the implementation of prior versions of the CIP Standards.

Authorizing Statute(s): US Code: 16 USC 824s-1 Name of Law: Federal Power Act
   US Code: 16 USC 824d Name of Law: Federal Power Act
   US Code: 16 USC 824o Name of Law: Federal Power Act

Citations for New Statutory Requirements: US Code: 16 USC 824s-1 Name of Law: Federal Power Act

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:
	91 FR 7274	02/17/2026
30-day Notice:	Federal Register Citation:	Citation Date:
	91 FR 35681	06/12/2026
Did the Agency receive public comments on this ICR? No

ICR Summary of Burden

	Total Request	Previously Approved	Change Due to Agency Discretion
Annual Number of Responses	259,379	262,733	-3,354
Annual Time Burden (Hours)	1,073,723	2,639,597	-1,565,874
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: Yes

Burden Reduction Due to: Cutting Redundancy

Short Statement: The updated CIP standards present new burden changes of 400 responses and 23,800 hrs. from RM24-8 already approved as well as the RD25-8 burden of 1,673 respondents for CIP-002-8 as stated above in the table within section #12. Making a total of 4,000 responses and 230,800 burden hrs. The Change due to Adjustment represents the updated burden for CIP 2-8 which has just an update in burden due to normal fluctuation, updated from 1,579 to 1,673 respondents. Also removing unnecessary double report burden and CIP-012-2 one time burden reported for RD24-3 was removed for this renewal.

Annual Cost to Federal Government: $221,407

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: Kayla Williams 410 786-5887 kayla.williams@cms.hhs.gov

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