Commission Information Collection Activities (FERC-725B); Comment Request; Extension
In compliance with the requirements of the Paperwork Reduction Act of 1995, 44 U.S.C. 3506(c)(2)(A), the Federal Energy Regulatory Commission (Commission or FERC) is soliciting ...
Notice of information collection and request for comments.
SUMMARY:
In compliance with the requirements of the Paperwork Reduction Act of 1995, 44 U.S.C. 3506(c)(2)(A), the Federal Energy Regulatory Commission (Commission or FERC) is soliciting public comment on the currently approved information collection, FERC-725B (1902-0248), Mandatory Reliability Standards, Critical Infrastructure Protection (CIP)—Update to CIP-015. This update changes the CIP-015-1 standard to CIP-015-2 which reflects the changes implemented through Order RD26-6-000 issued on August 10, 2026.
DATES:
Comments on the collections of information are due December 14, 2026.
ADDRESSES:
Please submit comments via email to
DataClearance@FERC.gov.
You must specify Docket No. (RD26-6-000) in your email. If you are unable to file electronically, comments may be filed by USPS mail or by hand (including courier) delivery:
Mail via U.S. Postal Service only, addressed to:
Federal Energy Regulatory Commission, Secretary of the Commission, 888 First Street NE, Washington, DC 20426.
Hand (including courier) delivery to:
Federal Energy Regulatory Commission, 12225 Wilkins Avenue, Rockville, MD 20852.
Type of Request:
Update to the currently approved information collection requirements within Reliability Standard CIP-015-2.
Abstract:
On June 18, 2026, the North American Electric Reliability Corporation (NERC), the Commission-certified Electric Reliability Organization (ERO), filed a petition with the Commission seeking approval of proposed Critical Infrastructure Protection (CIP) Reliability Standard CIP-015-2 (Cyber Security — Internal Network Security Monitoring). NERC also requested approval of the associated implementation plan, violation risk factors, and violation severity levels, and the retirement of the currently effective Reliability Standard CIP-015-1. NERC states that proposed Reliability Standard CIP-015-2 improves upon the currently approved Reliability Standard CIP-015-1 by establishing requirements that extend internal network security monitoring (INSM) to include electronic access control or monitoring systems (EACMS) and physical access control systems (PACS) outside of the electronic security perimeter. NERC explains the proposed revisions prevent a potential gap in the coverage of the standard that could allow an attacker to use compromised EACMS and PACS outside the electronic security perimeter to access the operational technology environment inside the electronic security perimeter. NERC contends that proposed Reliability Standard CIP-015-2 addresses the Commission's directive in Order No. 907, and as clarified in Order No. 907-A, to extend INSM beyond the electronic security perimeter to all systems in an entity's CIP-networked environment.[1]
NERC's filing was published in the
Federal Register
, 91 FR 38413 (June 25, 2026), with interventions and protests due on or before July 20, 2026. Timely motions to intervene were filed by Ameren Illinois Company, Ameren Transmission Company of Illinois, and Union Electric Company. Pursuant to Rule 214 of the Commission's Rules of Practice and Procedure, 18 CFR 385.214 (2025), the timely, unopposed motions to intervene serve to make the entities that filed them parties to this proceeding.
Type of Respondents:
Distribution Provider, Generator Operator, Generator Owner, Reliability Coordinator, Transmission Operator, and Transmission Owner.
Estimate of Annual Burden:[2]
The Commission estimates the annual public reporting burden for the information collection as:
FERC-725B—(Mandatory Reliability Standards for Critical Infrastructure Protection [CIP] Reliability Standards) Update to CIP-015-2
Number and
type of
respondent 3
Annual
number of
responses per
respondent
Total
number of
responses
Average burden per
response (hours) 4
& cost per response
Total annual burden (hours) & total annual cost 5
($)
Average
cost per
respondent
(1)
(2)
(1) * (2) = (3)
(4)
(3) * (4) = (5)
(5) ÷ (1)
CIP-015-2
360
6
2,160
14 hrs.; $1,897.14
30,240 hrs.; $4,097,822.40
$11,382.84
Total Burden of CIP-015-2
2,160
30,240 hrs.; $4,097,822.40
Comments:
Comments are invited on: (1) whether the collection of information is necessary for the proper performance of the functions of the Commission, including whether the information will have practical utility; (2) the accuracy of the agency's estimate of the burden and cost of the collection of information, including the validity of the methodology and assumptions used; (3) ways to enhance the quality, utility and clarity of the information collection; and (4) ways to minimize the burden of the collection of information on those who are to respond, including the use
( printed page 64923)
of automated collection techniques or other forms of information technology.
Dated: October 7, 2026.
Debbie-Anne A. Reese,
Secretary.
Footnotes
1.
Critical Infrastructure Protection Reliability Standard CIP-015-1—Cyber Security—Internal Network Security Monitoring,
Order No. 907, 191 FERC ¶ 61,224,
order on clarification,
Order No. 907-A, 192 FERC ¶ 61,171 (2025).
2.
The Commission defines burden as the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a federal agency. For further explanation of what is included in the information collection burden, reference 5 Code of Federal Regulations 1320.3.
3.
The NERC Compliance Registry, as of August 2026, identifies approximately 1,706 unique U.S. entities that are subject to mandatory compliance with CIP Reliability Standards. Of this total, we estimate that 360 entities will face an increased paperwork burden under Reliability Standard CIP-015-2.
4.
The estimates for cost per hour are $135.51/hour (averaged based on the following occupations):
Office and Administrative Support (90th percentile) (Occupation Code: 43-0000): $57.73/hour
The estimated hourly cost (salary plus benefits) is a combination of the following categories from the Bureau of Labor Statistics (BLS) website, June 12, 2026, links to reference, Occupational Employment and Wage Statistics and
www.bls.gov/oes/current/naics2_22.htm.
44 U.S.C. 3506(c)(2)(A)
elibrary.ferc.gov/eLibrary/search
18 CFR 385.214
www.bls.gov/oes/current/naics2_22.htm