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FERC Filings

INFORMATION DISCLOSURE COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION

III. The Data the Commission is Requesting Goes Beyond What is Currently Filed

The Commission posits that the proposed Index of Customers will not require the reporting of any more information than is currently filed. In the NOPR itself, the Commission states that the main purpose of the revised filing requirements is not to collect new information but rather to organize what information is already collected in a more efficient manner: “Simply put, [the NOPR] provides that the data currently filed in service agreements should be filed through the Index of Customers.” In many cases, this statement is incorrect. Today, many marketers currently file their data in aggregated form or give their data within ranges and the Commission has accepted those filings for years.
Any suggestion that parties should report purely financial transactions, such as book-outs, net-outs and open positions, is troubling. The Commission should clarify that any transaction that does not involve physical delivery of power is excluded from these reporting requirements. Otherwise, this NOPR would mandate the filings of hundreds of data points on transactions that do not go to delivery and would be largely meaningless. Most importantly, however, the Commission itself has stated that it does not have jurisdiction over book-outs and other financial transactions that do not go to delivery.
Finally, the NOPR indicates that its proposed Index of Customers would include point of receipt of power, which for many marketers is difficult to determine. In addition, the Commission is also requesting that marketers provide information that they do not currently collect, such as buyers’ DUNS numbers. Marketers should not have to report such data.
Currently, marketers file only Quarterly Transaction Reports, which do not include much of the information being sought here. The NOPR, then, is requesting significantly more information than is being currently filed by marketers.