January 23, 2020 New Data Collections Requirement for MBR Companies

The Commission issued Order No. 860 on July 18, 2019 which amended the Commission's market based rate reg-ulations at 18 C.F.R. section 35, subpart H, effective Octo-ber 1, 2020. 
 
Order No. 860 provides that the Commission will begin collecting certain market-based rate information through a relational database, including: certain upstream ownership information, asset appendix information (including a new requirement to report long-term firm purchases) for the seller and its affiliates that do not have market-based rate authority, indicative screen information, and certain other market-based rate information. In addi-tion, sellers will be required to update the database on a monthly basis to reflect any changes and the change in status filing requirement is changed to a quarterly obligation.
 
After January 31, 2021, no asset appendices or indicative screens may be submitted as attachments to filings through the eFiling system.
 
In Spring 2020, the Commission plans to post a list of Frequently Asked Questions on its website. The following deadlines will apply to market-based rate sellers and applicants:
 
Fall 2020 – Obtain FERC generated IDs for reportable entities that do not have CIDs or LEIs, and Asset IDs for reportable generation assets without an EIA code.
 
February 1, 2021 – Informational baselines submissions based on current information are due.
•Sellers that have received market-based rate authority on or by Decem-ber 31, 2020 must make a baseline submission into the relational database by close of business.
•Sellers that have filed for market-based rate authority, but have NOT received an order granting market-based rate authority as of January 1, 2021 must make a baseline submission into the relational database by close of business. However, when submitting their application, these sellers also must submit indicative screens and asset appendices as attachments to their filings through the eFiling system.
 
February 28, 2021 – Notices for any changes in status that take place be-tween October 1, 2020 and December 31, 2020, are due. Thereafter, future notice of change in status obligations will align with the timeline used for EQRs as described in Ongoing Reporting Requirements section. Applicants seeking market-based rate authority on or after February 1, 2021 will be required to make a submission into the relational database prior to filing an initial market-based rate application.
 
In August a rehearing request was requested and the commission granted the rehearing in September, 2019. Systrends intends to build the necessary soft-ware. Unfortunately we currently do not have a enough information to start any type of coding. We are hoping to hear more about the Data Collections requirement at the Forms Technical Conference in February.
 
UPDATE: January 10, 2020 FERC issued an update about the Relational Database Requirement and put out an updated XSD, XML Schema, Data Dictionary and Test Environment. Systrends will be developing software for this new FERC requirement. We are currently reviewing all of the specifications, XSDs and Test environment and will build the necessary application. We have talked about making it part of the eTariff application (as a separate tab inside the software to generate the specific XML for the relational database but it will make that decision after we know all the requirements first.
 
Technical Workshop for this requirement will be held February 27, 2020 from 9am - 12:30 pm eastern. You can join in person at FERC Commission Meeting Room or via webcast.