FERC Filings

Motion for Clarification of the Electric Power Supply Association re: Price Discovery in Natural Gas and Electric Markets

Data Providers Should Not Have To Report At "All" Trading Locations To Obtain Safe Harbor Protections

Another question has arisen as to whether data providers must provide information at all trading locations in order to satisfy the Commission’s safe harbor provisions. Clearly, reporting at the specific location must include all transactions at that location. However, even if reporting is done at aggregated trading locations rather than at delivery points, there may be trading hubs that are thinly traded or where a particular market participant might prefer not to disclose its activities because it would compromise commercially sensitive information. In that case, data providers should not be precluded from safe harbor protection if they report all information at particular points, but do not provide any information at other points. Alternatively, the Commission could provide safe harbor protection if data providers provide information at all the aggregated trading points within a specific region (for transactions occurring within that region), while not requiring that data providers report in other regions to obtain safe harbor protection for the region in which they are reporting.

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