[co-author: Juan Dawson]
On October 19, 2023, FERC issued a Notice of Proposed Rule Making (“NOPR”) proposing various changes to its Electric Quarterly Report (“EQR”) filing requirements. According to FERC, the proposed changes are designed to update the data collection process, improve data quality, increase market transparency, decrease costs of preparing necessary data for submission, and streamline compliance with future filing requirements. The following is a summary of the primary reforms proposed.
- Adoption of the New EQR System Based on XBRL-CSV Standard
FERC proposes to adopt a new EQR submission system based on the XBRL-CSV standard. According to FERC, XBRL-CSV enables the reporting of comprehensive, consistent, interoperable data that allows industry and other data users to automate submissions, extractions, and analyses, thereby making information sharing for users more efficient.
Additionally, FERC proposes providing pre-formatted templates for preparation of EQR submission files that conform with the XBRL-CSV system. For Sellers who only report Identification Data or Identification and Contract Data in the EQR with no changes from the previous quarter, FERC proposes an option that requires confirmation that no changes occurred to their EQR from the previous quarter.
FERC also proposes to release draft EQR taxonomies applicable to the new system and to hold technical conferences for public input before their adoption. Further, the NOPR proposes that after the XBRL-CSV system launches, FERC will migrate previously filed EQR data from the third quarter of 2013 through the quarter preceding the launch of the new XBRL-CSV system onto the new system.
- RTO/ISO Sales Data and Transaction Data Reports
The NOPR also seeks to require all RTOs/ISOs to produce EQR transaction data reports for their market participants based on the settlement data generated by the RTO/ISO as a way to standardize reporting and promote data accuracy by reducing the amount of data Sellers must manually manipulate in their EQR reports.
- Extended Filing Timeline
Further, the NOPR proposes to extend the current quarterly window—which ends one month after the close of the quarter—to end four months after the close of the filing quarter. This change will allow filers more time to prepare their initial EQR filings and incorporate a more complete and accurate set of RTO/ISO meter-corrected data into their submissions. FERC also proposes to allow Sellers to file data beginning any time during the quarter, or during the four-month filing period after the close of the quarter, instead of requiring Sellers to wait until the filing quarter ends. The NOPR also seeks to relax its current refiling policy by, among others, requiring EQR refilings only if the Seller determines that there are material corrections or omissions from its previously filed EQR(s).
- Modification and Data Reporting Requirements
In order to streamline reporting, the NOPR seeks to eliminate several data fields and associated characteristics that are available in other FERC reporting systems. FERC further proposes to eliminate Order No. 890’s requirement that transmission providers report transmission capacity reassignment information. Additionally, FERC proposes to eliminate the requirement for Sellers to identify the index price publisher(s) to which they report transactions in the EQR. Finally, FERC seeks to eliminate the requirements for Sellers to identify the index price publisher to which they report transactions and to report whether they use an exchange or broker to consummate a transaction. Under this change, if Sellers use an exchange, they must select the specific exchange from a FERC-provided list.
The NOPR was published in the Federal Register on October 27, 2023. Comments are due by December 26, 2023.
The NOPR, issued in Docket No. RM23-9, can be found here.
