Why is FERC asking for comments on grid balancing paperwork again?

Four standards, one renewal request

FERC published the notice on November 5, 2026. Comments are due January 4, 2027. The collection carries OMB control number 1902-0268 and the internal label FERC-725R. It bundles four BAL reliability standards that have been in effect for years. BAL-001-2 took effect July 1, 2016. BAL-002-3 followed April 1, 2019. BAL-003-2 started December 1, 2020. BAL-005-1 began January 1, 2019. No new requirements are proposed. The Commission simply asks whether the existing paperwork burden remains justified.

The standards apply to users, owners, and operators of the bulk-power system. Congress mandated this framework in the Energy Policy Act of 2005. That law added section 215 to the Federal Power Act. It required a certified Electric Reliability Organization to develop mandatory standards. FERC certified the North American Electric Reliability Corporation as that organization in 2006. NERC develops the standards. FERC approves them. Then either NERC or FERC can enforce them.

The heaviest lift sits in frequency response

BAL-003-2 dominates the burden estimate. It requires balancing authorities to compile data on 28 frequency events per year. Each event demands roughly 10 hours of verification and review. That yields 280 hours per authority annually. With 97 registered balancing authorities plus one frequency response sharing group, the standard generates 2,744 total responses. The projected cost reaches $2,288,222. That is more than 90 percent of the entire collection's $2,496,446 price tag. BAL-001-2 and BAL-002-3 each impose 12 hours per respondent per year. BAL-005-1 asks for just one hour. The reserve sharing groups — six of them — file only under BAL-002-3. Their addition raises that standard's respondent count to 103. The total annual burden across all four standards comes to 29,937 hours. FERC derived the hourly rate from Bureau of Labor Statistics data. It blends 75 percent of an electrical engineer's wage at $92.32 with 25 percent of an information clerk's wage at $56.60. The result: $83.39 per hour.

Who files and what it costs

The NERC Compliance Registry listed 97 U.S. balancing authorities as of July 21, 2026. Six reserve sharing groups and one frequency response sharing group also appear. Each balancing authority files annual reports for three of the four standards. For BAL-003-2 they file 28 times. The cost per authority varies wildly. Under BAL-001-2, BAL-002-3, and BAL-005-1 the average is roughly $1,000 per year. Under BAL-003-2 the average jumps to $23,349. The frequency response sharing group faces the same per-event cost. Its total is $23,349 because it files 28 times as a single entity.

The Commission invites comments on four specific questions. Whether the collection is necessary for the Commission's functions. Whether the burden and cost estimates are accurate. How to improve quality, utility, and clarity. How to minimize burden through automation or other technology.

What happens after January 4

After the comment period closes, FERC will review submissions and forward the package to the Office of Management and Budget. OMB decides whether to renew the collection for another three-year cycle. If approved, the same reporting obligations continue unchanged. A new standard, BAL-007-1.1, is scheduled to take effect in April 2027. It will be folded into future FERC-725R renewals. That standard covers near-term energy reliability assessments. The current notice does not address it. The docket number for this proceeding is IC26-43-000. Comments can be emailed to DataClearance@FERC.gov or mailed to the Commission's Washington headquarters. The contact person is Kayla Williams at (202) 502-6468.