As we welcome the first day of February, I can’t help but think about all the EQR analysts who have just spent untold hours during the prior month compiling spreadsheet upon spreadsheet of electricity sales data. Section 205(c) of the Federal Power Act requires all electricity sellers to self-report power and transmission service sales (FERC FAQ) prior to the end of the month after the end of the quarter.
Before organized markets, this was a fairly straight-forward process: compile your sales deals related to your contracts, format and file. Only the highest volume shops faced significant complexity or data volumes that were insurmountable. However, now that ISOs and RTOs dominate much of the electricity industry, the workflow is tightly coupled with market settlements – with all its inherent complexity, sub hourly granularity of data and mind-boggling volume of transactions.
Experience Counts
I recall one of my first projects at PCI was to implement 5-minute support for our EQR Solution in the SPP Market and remember the joy I experienced from working with several talented PCI engineers and skilled utility analysts to create the enhanced solution. I can still vividly recall the fulfillment of a job well done following an SPP EQR market call that was held shortly after the first EQR filing deadline in 2014 for the SPP integrated marketplace:
- The ISO asked, “Did you file on-time, and if so, at what granularity?”
- The only respondents were the utilities I had worked with and they gave a resounding, “Yes, and at the 5-minute granularity!”
Fortunately, SPP publishes an EQR report that can be consumed and processed into a well formatted EQR filing without too much difficultly. Not all of you in other markets are so lucky! Working more recently in the CAISO MRTU and CAISO EIM markets, I quickly realized how truly fortunate PCI was to start with SPP. The complexity of three settlement markets – all at different levels of granularity – presented a significant challenge on its own, not to mention the many questions that arise during the analysis of those settlement markets:
- Is this an uplift related to a sale?
- I sold at a negative price. Is that a purchase or an import selling power?
- I purchased in DA, sold in RTUC, then sold again in RTD. What do I report?
- Flex Ramp: it’s not power and it’s not ancillary service. Should I report that?
- Before last quarter, I filed related to existing charge codes, but I now file under these new charge codes for very similar transactions. How will I explain what I filed to my auditors?
Processing a quarter’s worth of hourly, 15-minute, and/or 5-minute settlements data into EQR reportable transactions requires a systematic approach that produces a robust audit trail for trace-ability.
EQR Help is Available
Exactly how market transactions are categorized by you is somewhat open to interpretation. While FERC provides guidance for market participants, their expertise and guidance is primarily focused on the bilateral markets and off-system sales (one of the original intents of EQR filing). PCI has a proven EQR solution for the added complexity of ISO and RTO participation and our knowledgeable, experienced EQR analysts and engineers can help you answer those tough questions while producing a traceable audit trail with a flexible and transparent solution for EQR reporting. Visit our website or click on the “Contact PCI” button on our blog to learn more.
References: https://www.ferc.gov/resources/faqs/eqr-2013.asp#genEQR
