On September 22, 2016, FERC issued a notice seeking comments on proposed revisions and clarifications of Electric Quarterly Report (“EQR”) reporting requirements and corresponding updates to the EQR Data Dictionary. Notably, FERC proposes to significantly expand the instances in which transmission providers must report ancillary services transaction data. FERC also proposes to require filers to submit certain tariff-related information that they submit in the e-Tariff system, require filers to submit time zone information in connection with transmission capacity reassignment transactions, and clarify how filers should report booked out transactions.

With regard to ancillary services transaction data, FERC’s proposal would require transmission providers to report information about transactions made under all of their ancillary services agreements in the Transaction Data section of the EQR. Currently, transmission providers are required to report only information about their ancillary services agreements in the Contract Data section if the contract provides for the sale of the ancillary services product. According to FERC, the current reporting requirement does not provide adequate visibility into the actual sales and rates being charged for ancillary services, especially where transmission providers have increased their reliance on markets to meet their ancillary services obligations. FERC thus proposes to institute the more stringent reporting requirement to “help the Commission, the public, and the industry determine the actual rates being charged for service under these agreements and to increase price transparency into the wholesale ancillary services markets.”

With regard to the remaining proposed revisions, FERC states that the changes related to tariff-related information and time zone information are necessary to facilitate consistency and accuracy in EQR reporting. Meanwhile, FERC’s proposal related to booked out transactions – which involve energy or capacity committed bilaterally for delivery but not delivered due to some offsetting or countervailing trade – would allow EQR filers to distinguish between booked out energy and booked out capacity.

FERC stated explicitly in the notice that it is seeking comments on these proposed revisions because they would constitute significant changes that are not appropriate to implement by simply posting the changes to FERC’s public website and emailing EQR filers, which FERC does for minor non-material EQR reporting changes. Comments are due within sixty days of the notice being published in the Federal Register and will be placed in FERC’s public file.

FERC’s Notice Seeking Comments on Proposed Revisions to Electric Quarterly Report Reporting Requirements can be found here.