Why Is FERC Asking for Comments on a Form Nobody Commented On Last Time?

The Federal Energy Regulatory Commission has reopened the comment period for Form 561, the annual report that tracks when utility executives also sit on boards of banks, insurers, and fuel suppliers. The previous comment window closed September 8 with zero submissions, and the reporting rules themselves haven't changed.

What Form 561 Actually Tracks

A public utility officer or director files Form 561 when they also hold a position at a financial institution or an insurance company. The requirement also extends to security underwriters, electrical equipment suppliers, and fuel providers. Any entity controlled by one of those is covered as well.

Positions at any of the 20 largest purchasers of electric energy from that utility — the entities with the highest electricity expenditures — are also captured. Section 305(c)(2) of the Federal Power Act defines the covered entities. The filing deadline and the requirement to make the information public are also set by statute.

Review of interlocking positions and identification of possible conflicts of interest are the Commission's stated uses for the data.

The Renewal Cycle

The Paperwork Reduction Act of 1995 requires agencies to renew approved information collections every three years. FERC-561 carries OMB Control No. 1902-0099. The current approval cycle included a comment period that ended September 8, 2026.

No comments were received. The notice published September 15 opens a new 30-day window closing October 15, 2026.

Comments go to OMB through reginfo.gov. A copy must also be emailed to DataClearance@FERC.gov with Docket No. IC26-37-000 and the collection number FERC-561. The agency specifically invites input on whether the collection remains necessary and whether the burden estimates are accurate. It also asks how to improve quality and clarity. It also asks how to minimize burden through automation or other technology.

Who Files and What It Costs

Staff estimates respondents. Each files once per year. That yields total responses. Average burden per response is 0.25 hours. The cost per response is $25.50, based on the Commission's 2026 average salary plus benefits of $213,003 per full-time equivalent — $102.00 per hour.

Total annual burden: 675 hours. Total annual cost: $68,850. Cost per respondent: $25.50.

These figures appear in the burden table published with the notice.

What Happens Next

If comments arrive by October 15, OMB will consider them before deciding on the three-year extension. If none arrive — as happened last time — the renewal proceeds on the existing terms.

The form itself, the filing deadline, the covered entities, and the public availability rule all remain governed by the Federal Power Act and 18 CFR 131.31. The notice does not indicate any planned revision to the form or the regulation.

The sources this article was written from

  • "Federal Register, 91 FR 58436, September 15, 2026
    https://www.federalregister.gov/documents/2026/09/15/2026-18873/commission-information-collection-activities-ferc-561-comment-request-extension"

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