New Landscape for Electric Transactional Regulatory Reporting

On July 11, FERC hosted a technical conference to discuss the Revisions to the Electric Quarterly Report Filing Process Notice of Proposed Rulemaking (NOPR) released at its June 2012 meeting.  The NOPR proposed to replace the current EQR filing system, which is based on uploading files to FERC-provided FoxPro software, to allow for submission of EQR data through FERC's eFiling system either in CSV or XML format.  In the NOPR, FERC indicated its expectation that the new filing process would be implemented for the Q3 2013 filing, which is due October 31, 2013.  Comments on the NOPR are due Tuesday, September 4, 2012.

At the July 11 technical conference, FERC Staff discussed the goals of the EQR "Refresh" and a number of the proposed changes.  Among the technical details discussed were the submission of filings in CSV or XML format and the creation of a new platform for accessing filed data.

Specifically, as discussed in the NOPR, FERC is proposing that filers will be able to choose between utilizing either a CSV or XML-based filing approach.  Although FERC Staff is still determining how the processes will work, from last week's discussion, it appears that the CSV approach will most closely mimic the current process, but will likely be most appropriate for entities with smaller filings. 

FERC Staff's preferred approach for EQR filing entities, particularly those with larger filings, appears to be the XML process, which will likely require filing entities to either develop their own XML-based software or purchase software from a third-party vendor.  Staff is in the process of making a draft XML schema available to the public.  Staff also advised that a "sandbox" XML site will be available through which filers may test files prior to filing.  It is unclear whether the XML process will include an information validation process outside of the sandbox. 

Additionally, FERC Staff noted it is in the process of creating a new web platform for viewing and downloading filed data.  Both data filed under the new system and historical data will be available through the new web platform.

FERC Staff alluded to additional technical conferences as the process progresses, but no such conferences have been scheduled at this time.  EQR filers should continue to monitor the process going forward.