FERC Filings
INFORMATION DISCLOSURE COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION
V.
The Commission’s Burden Estimate is Inaccurate
In the NOPR, the Commission estimates that the Index of Customers will save marketers over a million dollars on a recurring basis of personnel cost with the revised filing procedures. This estimate fails to recognize serious logistical issues and is inaccurate for several reasons. First, the Commission shows estimated hours saved only by those entities that file service agreements, which marketers currently do not file. The burden estimate shows that the Index of Customers would take as much time to produce as the Quarterly Transaction Reports, but it is not clear whether the Commission has considered that the Index would contain significantly more information that is currently filed in the quarterly reports. Moreover, a requirement to provide all transaction data (yearly, monthly, weekly, etc.) on an hourly basis will generate a tremendous amount of data and that data will need to be manipulated in order to put in the format requested by the Commission. These efforts will require a significant number of staff hours to be expended on an ongoing basis.
Secondly, the burden estimate fails to recognize that many companies with multiple entities with market-based rates would, under the proposed rulemaking, have to maintain multiple web sites, in some cases a dozen or more. Furthermore, the cost of establishing and maintaining these web sites with the innumerable data that FERC is proposing be reported would be significantly more than the Commission has projected. While the costs may not be entirely prohibitive, it is important that the Commission recognize the revised filing requirements will not be inexpensive to implement as the Commission estimates. In addition, unlike regulated entities that can recover compliance costs in their rates, competitive market participants must fund these efforts directly. These costs are not insignificant.