156 FERC ¶ 61,045

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

18 CFR Part 35

[Docket No. RM16-17-000]

Data Collection for Analytics and Surveillance and Market-Based Rate Purposes 

(July 21, 2016)

AGENCY: Federal Energy Regulatory Commission.

ACTION: Notice of Proposed Rulemaking.

SUMMARY: The Federal Energy Regulatory Commission (Commission) proposes to 

revise its regulations to collect certain data for analytics and surveillance purposes from 

market-based rate (MBR) sellers and entities trading virtual products or holding financial 

transmission rights and to change certain aspects of the substance and format of 

information submitted for MBR purposes. The revisions proposed herein include new 

requirements for those entities to report certain information about their legal and financial 

connections to other entities to assist the Commission in its analytics and surveillance 

efforts. The Commission previously proposed to require certain market participants in 

the Commission-jurisdictional organized wholesale electric markets to file similar 

information about their financial and legal connections in the Collection of Connected 

Entity Data from Regional Transmission Organizations and Independent System 

Operators Notice of Proposed Rulemaking issued in Docket No. RM15-23-000 

(Connected Entity NOPR). However, as described herein, this proposal presents 
Docket No. RM16-17-000 ii

substantial revisions from what the Commission proposed in the Connected Entity 

NOPR, including, among other things: (i) a different set of filers; (ii) a reworked and 

substantially narrowed definition of Connected Entity; and (iii) a different submission

process. With respect to the MBR program, the proposals include: (i) adopting certain 

changes to reduce and clarify the scope of ownership information that MBR sellers must 

provide, similar to the notice of proposed rulemaking issued in Docket No. RM16-3-000

(Ownership NOPR); (ii) reducing the information required in asset appendices; and 

(iii) collecting currently- required MBR information and certain new information in a 

consolidated and streamlined manner. The Commission proposes all of these changes in 

order to eliminate duplication, ease compliance burdens, modernize its data collections, 

and render information collected through its programs usable and accessible for the 

Commission and its staff. In furtherance of this effort, in orders being issued 

concurrently with the instant NOPR, the Commission withdraws the Connected Entity 

NOPR issued in Docket No. RM15-23-000 and the Ownership NOPR issued in Docket 

No. RM16-3-000.

1 The Commission also proposes to eliminate the requirement that 

MBR sellers submit corporate organizational charts adopted in Order No. 816 in Docket 

No. RM14-14-000.

 

1 Collection of Connected Entity Data from Regional Transmission Organizations 

and Independent System Operators, 156 FERC ¶ 61,046 (2016); Ownership Information 

in Market-Based Rate Filings, 156 FERC ¶ 61,047 (2016).
Docket No. RM16-17-000 iii

DATES: Comments are due [INSERT DATE 45 days after publication in the 

FEDERAL REGISTER]

ADDRESSES: Comments, identified by docket number, may be filed in the following 

ways:

 Electronic Filing through http://www.ferc.gov. Documents created electronically 

using word processing software should be filed in native applications or print-toPDF format and not in a scanned format.

 Mail/Hand Delivery: Those unable to file electronically may mail or hand-deliver 

comments to: Federal Energy Regulatory Commission, Secretary of the 

Commission, 888 First Street, NE, Washington, DC 20426.

Instructions: For detailed instructions on submitting comments and additional 

information on the rulemaking process, see the Comment Procedures Section of this 

document

FOR FURTHER INFORMATION CONTACT:

Jamie Marcos

Office of Enforcement

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-6628

Jamie.marcos@ferc.gov

Laura Chipkin

Office of General Counsel

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-8615

Laura.chipkin@ferc.gov
Docket No. RM16

-17-000 iv

Melissa Lozano

Office of Energy Market Regulation

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-6267

melissa.lozano@ferc.gov

Byron Corum

Office of Energy Market Regulation

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-6555byron.corum@ferc.gov

SUPPLEMENTARY INFORMATION:
UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Data Collection for Analytics and 

Surveillance and Market-Based Rate 

Purposes

Docket No. RM16-17-000

NOTICE OF PROPOSED RULEMAKING

TABLE OF CONTENTS

Page Numbers

I. Background.................................................................................................................. 5

II. Discussion.................................................................................................................... 8

A. Proposals Regarding Connected Entity Information............................................. 13

B. Proposals Regarding MBR Information................................................................ 16

1. Ownership Information ..................................................................................... 18

2. Asset Appendix Information ............................................................................. 22

3. Indicative Screen and Other MBR Information ................................................ 30

C. Need and Authority: Analytics and Surveillance .................................................. 31

D. Nature of the Connected Entity Information Submissions.................................... 35

E. Legal Entity Identifiers.......................................................................................... 40

F. Confidentiality and Due Diligence........................................................................ 40

G. Filing Requirement for Existing and New Virtual/FTR Participants.................... 42

H. Baseline Submission Required of Existing MBR Sellers ..................................... 43

I. Ongoing Connected Entity Information Submission Requirements..................... 44

J. Ongoing MBR Seller Filing Requirements........................................................... 45

III. Information Collection Statement ......................................................................... 49

IV. Environmental Analysis ........................................................................................ 55

V. Regulatory Flexibility Act......................................................................................... 56

VI. Comment Procedures............................................................................................. 58

VII. Document Availability .......................................................................................... 59
156 FERC ¶ 61,045

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Data Collection for Analytics and Docket No. RM16-17-000

Surveillance and Market-Based Rate

Purposes

NOTICE OF PROPOSED RULEMAKING

(July 21, 2016)

1. The Federal Energy Regulatory Commission (Commission) proposes in this 

Notice of Proposed Rulemaking (NOPR) to amend its regulations to add Subpart K to 

Title 18 of the Code of Federal Regulation (CFR), which would include data collection 

requirements for market-based rate (MBR) sellers2and certain other participants in the 

organized wholesale electric markets subject to the Commission’s jurisdiction pursuant to 

the Federal Power Act (FPA), and revise Part 35, Subpart H, which governs MBR 

authorization for wholesale sales of electric energy, capacity, and ancillary services by 

public utilities.

3 Specifically, the Commission is proposing to revise its regulations to 

 

2 All references in this NOPR to “MBR seller” (or “MBR sellers”) refer to both 

entities seeking to obtain MBR authority by filing applications with the Commission and 

to MBR sellers seeking to retain market-based rate authority and is intended to have the 

same meaning as the defined term “Seller” in 18 CFR 35.36(a)(1). 

3 The organized wholesale electric markets subject to the Commission’s 

jurisdiction refers to the markets operated by Regional Transmission Organizations 

(RTOs) and Independent System Operators (ISO) operating in the United States. These 

RTOs and ISOs include: PJM Interconnection, L.L.C. (PJM), New York Independent 

(continued ...)
Docket No. RM16-17-000 2

add new data submission requirements for MBR sellers and entities, other than FPA 

section 201(f) entities,4that trade virtual products5 or hold financial transmission rights

(FTR) 6in the organized wholesale electric markets subject to the Commission’s 

 

System Operator, Inc. (NYISO), ISO New England Inc. (ISO-NE), California 

Independent System Operator Corporation (CAISO), Midcontinent Independent System 

Operator, Inc. (MISO), and Southwest Power Pool, Inc. (SPP).

4 See 18 U.S.C. 824(f) (2012).

5

“Virtual trading involves sales or purchases in an RTO/ISO day-ahead market 

that do not go to physical delivery. For example, virtual bidding allows entities that do 

not serve load to make purchases in the day-ahead market. Such purchases are 

subsequently sold in the real-time spot market. Likewise, entities without physical 

generating assets can make power sales in the day-ahead market that are subsequently 

purchased in the real-time market. By making virtual energy sales or purchases in the 

day-ahead market and settling these positions in the real-time, any market participant can 

arbitrage price differences between the two markets.” Market-Based Rates for Wholesale 

Sales of Electric Energy, Capacity and Ancillary Services by Public Utilities, Order 

No. 697, FERC Stats. & Regs. ¶ 31,252 at n.1047, clarified, 121 FERC ¶ 61,260, at P 921 

n.1047 (2007), order on reh’g, Order No. 697-A, FERC Stats. & Regs. ¶ 31,268, 

clarified, 124 FERC ¶ 61,055, order on reh’g, Order No. 697-B, FERC Stats. & Regs. 

¶ 31,285 (2008), order on reh’g, Order No. 697-C, FERC Stats. & Regs. ¶ 31,291 (2009), 

order on reh’g, Order No. 697-D, FERC Stats. & Regs. ¶ 31,305 (2010), aff’d sub nom. 

Mont. Consumer Counsel v. FERC, 659 F.3d 910 (9th Cir. 2011), cert. denied, 133 S. Ct. 

26 (2012). Organized wholesale electric markets offer various virtual products, including 

Up-To Congestion products, for which no generation is dispatched and no load is served, 

and obligations are met through cash settlement. Coaltrain Energy, L.P., et al., 

155 FERC ¶ 61,204 at P 15 (2016). “While virtual products carry no obligation to buy or 

sell physical power, they serve a direct role in day-ahead price formation as reflected in 

day-ahead [Locational Marginal Prices (LMP)]. As such, virtual products can: (i) be the 

price setting marginal factor in determining day-ahead LMPs; (ii) affect day-ahead 

dispatch; and (iii) affect other market participant positions.” Id.

6 The term “FTR” as used in this NOPR is intended to cover not only Financial 

Transmission Rights, a term used by PJM, ISO-NE, and MISO, but also Transmission 

Congestion Contracts in NYISO, Transmission Congestion Rights in SPP, and 

(continued ...)
Docket No. RM16-17-000 3

jurisdiction (Virtual/FTR Participants). The Commission is also proposing to require 

Virtual/FTR Participants to submit certain information to the Commission within 30 days 

of commencing trading of virtual or FTR products.

2. The purpose of this new data collection is to assist the Commission in 

understanding the financial and legal connections among market participants and other 

entities and their activities in Commission-jurisdictional electric markets. In this NOPR, 

the Commission also proposes to modify its regulations to change certain aspects of the 

substance and format of information submitted for MBR purposes. Specifically, we 

propose to collect currently-filed MBR information and the new information proposed to 

be collected in this NOPR in a consolidated and streamlined manner through a relational 

database,

7 which will eliminate duplication and render information collected for its MBR

and analytics and surveillance purposes more usable and accessible to the Commission 

and its staff.

3. As reflected in this NOPR, the Commission has reworked and substantially 

narrowed the definitions proposed in the Collection of Connected Entity Data from 

 

Congestion Revenue Rights in CAISO.

7 A relational database, or RDB, is a database model whereby multiple data tables 

relate to one another via unique identifiers. A relational database contains a table for 

each subject (e.g., generation assets) with every row in the table representing information 

regarding a single variable of that subject (e.g., a particular generation unit) and each 

column containing a particular quality of that variable (e.g., a generation unit’s capacity 

rating). Relational databases are structured to allow for easy data retrieval while avoiding 

inconsistencies and redundancies. 
Docket No. RM16-17-000 4

Regional Transmission Organizations and Independent System Operators NOPR in 

Docket No. RM15-23-000 (Connected Entity NOPR),

8

conforming them where possible 

to existing MBR affiliate definitions, and has entirely eliminated large portions of the 

data proposed for collection in that NOPR. In orders being issued concurrently with the 

instant NOPR, the Commission withdraws the Connected Entity NOPR9and the 

Ownership Information in Market-Based Rate Filings NOPR in Docket No. RM16-3-000 

(Ownership NOPR)10 and terminates those dockets.

11

 The Commission also proposes to 

remove the existing requirement that MBR sellers submit corporate organizational charts

adopted in Order No. 816 in Docket No. RM14-14-000.

12

 

8 Collection of Connected Entity Data from Regional Transmission Organizations 

and Independent System Operators, FERC Stats. & Regs. ¶ 32,711 (2015) (Connected 

Entity NOPR).

9 Connected Entity NOPR, FERC Stats. & Regs. ¶ 32,711.

10 Ownership Information in Market-Based Rate Filings, FERC Stats & Regs. 

¶ 32,713 (2015) (Ownership NOPR).

11 Collection of Connected Entity Data from Regional Transmission 

Organizations and Independent System Operators, 156 FERC ¶ 61,046 (2016);

Ownership Information in Market-Based Rate Filings, 156 FERC ¶ 61,047 (2016).

12 The organizational chart requirement was first suspended in the order that 

partially extended the compliance effective date of Order No. 816. See Refinements to 

Policies and Procedures for Market-Based Rates for Wholesale Sales of Electric Energy, 

Capacity and Ancillary Services by Public Utilities, Order No. 816, 80 Fed. Reg. 67,056 

(Oct. 30, 2015), FERC Stats. & Regs. ¶ 31,374 (2015), order on reh’g, Order No. 816-A, 

81 Fed. Reg. 33,375 (May 26, 2016), FERC Stats. & Regs. ¶ 31,382 (2016). The 

organizational chart requirement was again suspended in Order No. 816-A “until the 

Commission issues an order at a later date addressing this requirement.” Order 

No. 816-A, FERC Stats. & Regs. ¶ 31,382 at P 47.
Docket No. RM16-17-000 5

I. Background

4. Recently, the Commission sought to improve its analytics and surveillance of the 

electric markets by issuing the Connected Entity NOPR, which proposed collecting 

information from participants in Commission-jurisdictional organized wholesale electric 

markets concerning their ownership, employee, debt, and contractual connections. This 

information was to be submitted to the RTOs and ISOs, which in turn would provide the 

necessary information to the Commission. In some cases, the information sought under 

the Connected Entity NOPR was similar to, but somewhat different from, the information 

to be provided by MBR sellers. 

5. The desirability of consolidating MBR and Connected Entity data under one 

reporting regime was advocated to the Commission by members of the industry in 

comments responding to the Connected Entity NOPR. In the Connected Entity NOPR, 

the Commission proposed that each RTO and ISO be required to electronically deliver to 

the Commission, on an ongoing basis, data from its market participants13 that would: 

(i) identify the market participants by means of a common alpha-numerical identifier, 

specifically, a Legal Entity Identifier (LEI);

14 (ii) list their “Connected Entities,” which 

would include entities that have certain ownership, employment, debt, or contractual 

 

13 The Connected Entity NOPR proposed to require all RTO/ISO market 

participants, including MBR sellers and entities that solely participate in the RTO/ISO 

virtual and/or FTR markets, to report Connected Entity information. 

14 An LEI is a unique 20-digit alpha-numeric code assigned to a single entity. 

They are issued by the Local Operating Units of the Global LEI System. 
Docket No. RM16-17-000 6

relationships with market participants; and (iii) describe in brief the nature of the 

relationship of each Connected Entity. The Commission observed that there is a risk that 

a market participant may take actions to benefit another entity that bears a financial or 

legal relationship to it, and that entities under common control may collude to manipulate 

the market. Given the potential for such conduct, the Commission found it needed to 

understand the relationships and corresponding incentives between entities to help 

determine whether they might be engaging in acts of market manipulation. The 

Commission also described the deficiencies in scope, format, and timing of the existing 

data sources for the requisite information.15 

6. Many commenters objected to the proposed data submissions on the grounds that 

the information would be largely duplicative of other Commission reporting 

requirements, especially that of its MBR program. Several commenters objected to the 

Connected Entity NOPR on the grounds that the information to be submitted was based 

on a Connected Entity definition that was similar to, yet different from, the affiliate 

definition currently used in the MBR program. A common theme in the comments was 

the desirability of reconciling reporting requirements to accommodate the needs of both

the MBR and analytics and surveillance programs, thus eliminating the necessity of 

maintaining disparate, but partially overlapping, reporting regimes. 

 

15 See Connected Entity NOPR, FERC Stats. & Regs. ¶ 32,711 at PP 6-14.
Docket No. RM16-17-000 7

7. In the Connected Entity NOPR, the Commission also proposed that the Connected 

Entity information be submitted to the RTOs and ISOs, who would then pass it on to the 

Commission. A number of commenters objected to this mechanism as unwieldy and

unnecessarily burdensome.

8. Over the last two years, the Commission has also sought to modify, clarify, and 

streamline the Commission’s MBR requirements to, among other things, ease burdens on 

industry and the Commission. This initiative involved eliminating or refining some 

existing MBR requirements. The resulting reforms were set forth in Order Nos. 816 and 

816-A,16 and in the Ownership NOPR. In the Ownership NOPR, the Commission 

proposed to reduce and clarify the scope of ownership information that MBR sellers must 

provide, specifically to eliminate reporting of comprehensive ownership information 

required under Order No. 697-A that is not necessary for the Commission’s assessment of 

horizontal or vertical market power. Specifically, the Commission proposed that an 

MBR seller be required to identify and describe only two categories of “affiliate owners” 

(i.e., certain owners that meet the definition of “affiliate” in 18 CFR 35.36(a)(9)).

17 These 

 

16 Order No. 816, FERC Stats. & Regs. ¶ 31,374, order on reh’g, Order No. 816-

A, FERC Stats. & Regs. ¶ 31,382.

17 As specified in the Commission’s regulations, “affiliate” of a specified company 

means: (i) Any person that directly or indirectly owns, controls, or holds with power to 

vote 10 percent of more of the outstanding voting securities of the specified company;

(ii) Any company 10 percent or more of whose outstanding voting securities are owned, 

controlled, or held with power to vote, directly or indirectly, by the specified company; 

(iii) Any person or class or persons that the Commission determines, after appropriate 

notice and opportunity for hearing, to stand in such relation to the specified company that 

(continued ...)
Docket No. RM16-17-000 8

two categories are: (1) “ultimate affiliate owner(s),” defined as the furthest upstream 

affiliate owner(s) in the ownership chain; and (2) affiliate owners that have a franchised 

service area or MBR authority, or that directly own or control generation; transmission; 

intrastate natural gas transportation, storage or distribution facilities; or physical coal 

supply sources or ownership of or control over who may access transportation of coal 

supplies.18

9. The information proposed to be collected under the two separate NOPRs was 

different in scope. Commenters to the Connected Entity NOPR suggested that this 

incongruity be removed and that the information proposed in the Ownership NOPR and 

Connected Entity NOPR be collected contemporaneously to eliminate the burden of 

submitting duplicative information to the Commission. 

II. Discussion

10. The Commission appreciates these comments and agrees that compliance burdens 

should be minimized where possible. In response, the Commission considered whether 

the various reporting requirements needed for MBR and analytics and surveillance 

 

there is liable to be an absence of arm’s-length bargaining in transactions between them 

as to make it necessary or appropriate in the public interest or for the protection of 

investors or consumers that the person be treated as an affiliate; and (iv) Any person that 

is under common control with the specified company. For purposes of the affiliate 

definition in section 35.36(a)(9), owning, controlling or holding with the power to vote, 

less than 10 percent of the outstanding voting securities of a specified company creates a 

rebuttable presumption of lack of control. 18 CFR 35.36(a)(9)(v) (2015). 

18 Ownership NOPR, FERC Stats. & Regs. ¶ 32,713 at P 9. 
Docket No. RM16-17-000 9

purposes could be combined in such a way as to eliminate duplication and unnecessary 

differences, with the aim of providing the Commission with the information it needs in 

the least burdensome manner possible. 

11. The result of these efforts is embodied in the instant NOPR. In this NOPR, we 

propose to collect certain data for analytics and surveillance purposes and to change

certain aspects of the substance and format of information submitted for MBR purposes. 

Specifically, this NOPR sets out two categories of information submission requirements:

requirements applicable only to MBR sellers (MBR Information); and requirements

applicable to MBR sellers and Virtual/FTR Participants (Connected Entity Information). 

Connected Entity Information would be submitted both by MBR sellers (although not 

pursuant to the MBR program), and Virtual/FTR Participants. MBR Information would 

be submitted only by MBR sellers. As discussed below, we propose certain changes to 

the types of information currently required for MBR purposes and to the electronic 

format in which certain data will be submitted.

12. In this NOPR, we first describe the revised proposals regarding Connected Entity 

Information and proposals regarding MBR Information. Next, we discuss the need and 

authority for the collection of the Connected Entity Information as well as the nature of 

that information. We then discuss the proposed use of LEIs and discuss confidentiality 

and due diligence relating to the submission of Connected Entity Information. We next 

propose certain submission requirements for existing and new Virtual/FTR Participants 

and a baseline submission required of existing MBR sellers. Lastly, we propose ongoing 
Docket No. RM16-17-000 10

Connected Entity Information submission requirements and ongoing MBR seller filing 

requirements. 

13. Like the Connected Entity NOPR, this NOPR does not impose any filing 

requirements on entities that only sell natural gas.

19

 Also, like the Connected Entity 

NOPR, this NOPR proposes that entities that submit the required data to the Commission 

obtain and submit an LEI; however, it does not propose requiring reported Connected 

Entities or affiliate owners to obtain LEIs. Additionally, this NOPR proposes that all 

Connected Entity Information and most of the MBR Information be consolidated and 

submitted electronically into a relational database.

14. Specifically, we propose to consolidate the Commission’s collection of certain 

information for MBR and analytics and surveillance purposes in a relational database. 

We propose that the relational database information be submitted using an extensible 

markup language (XML) schema,20 which will permit filers to assemble an XML filing 

 

19 Entities that only sell natural gas may, however, be reported by an MBR seller 

or Virtual/FTR Participant if they qualify as Connected Entities under the proposed 

definition of Connected Entity. 

20 As the Commission previously explained, XML schemas facilitate the sharing 

of data across different information systems, particularly via the Internet, by structuring 

the data using tags to identify particular data elements. For example, each filed tariff 

change will include tags for the relevant information. The tagged information can be 

extracted and separately searched. See Electronic Tariff Filings, Order No. 714, FERC 

Stats. & Regs. ¶ 31,276, at P 12 & n.8 (2008). The Commission currently collects other 

data, including Electric Quarterly Reports (EQR) and eTariffs using XML. See Order 

No. 714, FERC Stats. & Regs. ¶ 31,276 (using XML for eTariff filings); see also Revised 

Public Utility Filing Requirements, Order No. 2001, FERC Stats. & Regs. ¶ 31,127, 

reh’g denied, Order No. 2001-A, 100 FERC ¶ 61,074, reh’g denied, Order No. 2001-B, 

(continued ...)
Docket No. RM16-17-000 11

package that includes all of the necessary attachments, including the cover letter and any 

related MBR tariffs. Upon the receipt of the filing, the XML schema will enable the 

Commission to parse21 the filed package into its component parts, place the filed 

documents into its eLibrary system where appropriate and provide the metadata22 that 

will permit automated organization of the filing and permit the Commission to search the 

relational database. The mechanics of and formatting for data submission by filers would 

be provided on the Commission’s website. 

15. A data dictionary posted on the Commission’s website would define the 

framework, i.e., terms and values, to be followed by users in submitting MBR and 

Connected Entity Information for inclusion in the relational database. The Commission 

would also post to its website any minor and non-material changes to the data dictionary

 

100 FERC ¶ 61,342, order directing filing, Order No. 2001-C, 101 FERC ¶ 61,314 

(2002), order directing filings, Order No. 2001-D, 102 FERC ¶ 61,334 (2003), order 

refining filing requirements, Order No. 2001-E, 105 FERC ¶ 61,352 (2003), clarification 

order, Order No. 2001-F, 106 FERC ¶ 61,060 (2004), order revising filing requirements, 

Order No. 2001-G, 120 FERC ¶ 61,270, order on reh’g and clarification, Order 

No. 2001-H, 121 FERC ¶ 61,289 (2007), Order revising filing requirements, Order 

No. 2001-I, FERC Stats. & Regs. ¶ 31,282 (2008) (using XML for EQRs).

21 Parse means to capture the hierarchy of the text in the XML file and transform it 

into a form suitable for further processing. Order No. 714, FERC Stats. & Regs. ¶ 31,276

at n.9.

22 Metadata is data or information beyond or about other data. For example, in the 

XML schema for eTariff, one required element is a proposed effective date and another 

element is the text of the tariff provision. The proposed effective date is considered to be 

metadata relative to the tariff text. See Order No. 714, FERC Stats. & Regs. ¶ 31,276 

at P 12 & n.10.
Docket No. RM16-17-000 12

as necessary and alert relational database users via email of any changes. 23 The current 

draft of this data dictionary is attached in Attachment D. We seek comment on the 

specific content for the relational database as set forth in the current draft of the data 

dictionary that is attached. In addition, Commission staff has been and will continue to 

conduct substantial outreach with the industry, including meetings and technical 

workshops on the data dictionary and the submittal process. A notice for the first 

workshop, which will focus on the draft data dictionary included as Attachment D, is 

being issued contemporaneously with this NOPR.24 

16. We anticipate that the data dictionary, the XML schema definition with 

appropriate validations, and a temporary test environment will be posted on the 

Commission website upon issuance of a final rule in this proceeding. In addition, we 

would also provide an email portal and other points of contact on the Commission 

 

23 The Commission proposes to utilize the same procedures set forth in 

the recently issued order addressing, among other things, revisions to the EQR Data 

Dictionary. See Filing Requirements for Electric Utility Service Agreements, 155 FERC 

¶ 61,280, at P 3 (2016) (“Going forward, consistent with section 35.10b of the 

Commission’s regulations, future minor or non-material changes to the reporting 

requirements and EQR Data Dictionary will be posted directly to the Commission’s 

website, and EQR users will be alerted via email. This process will enable the 

Commission to make necessary minor or non-material changes in a more timely manner. 

Conversely, significant changes to the EQR reporting requirements and the EQR Data 

Dictionary will be proposed in a Commission order or rulemaking, which would provide 

an opportunity for comment.”).

24 Notice of Technical Workshop on the Draft Data Dictionary Attached to the 

Data Collection for Analytics and Surveillance and Market-Based Rate Purposes Notice 

of Proposed Rulemaking, 156 FERC ¶ 61,045 (2016).
Docket No. RM16-17-000 13

website for filers to seek guidance from Commission staff on the final rule and technical 

aspects of making the required submissions.

A. Proposals Regarding Connected Entity Information 

17. The Commission received many comments objecting to the scope of the 

Connected Entity NOPR. The Commission carefully considered those comments and 

substantially clarified and narrowed the definitions proposed in this NOPR from those 

proposed in the Connected Entity NOPR. In addition, the definitions proposed in this 

NOPR reflect, where possible, the affiliate definitions found in the MBR regulations. To 

better align the Connected Entity Information requirements with the MBR Information 

requirements, we propose that the definition of Connected Entity ownership information 

be limited to “affiliates,” as defined for purposes of MBR requirements in 

section 35.36(a)(9) of the Commission’s regulations, that are either: (i) an “ultimate 

affiliate owner” of the entity, as defined for purposes of MBR requirements in 

section 35.37(a)(2); (ii) an entity that participates in Commission-jurisdictional 

organized wholesale electric markets; or (iii) an entity that purchases or sells financial 

natural gas or electric energy derivative products that settle off of the price of physical 

electric or natural gas energy products. We also propose to replace the category of 

“employees” proposed in the Connected Entity NOPR with a much narrower category of

“Trader,” which we propose to define as “a person who makes, or participates in, 

decisions and/or devises strategies for buying and selling physical or financial electric or 

natural gas energy products.” In addition, we propose to eliminate entirely the reporting

of debt instruments. We also propose to narrow and rework the category of contractual 
Docket No. RM16-17-000 14

Connected Entities reported from that originally proposed in the Connected Entity 

NOPR. As narrowed, the category will refer only to entities that have entered into an 

agreement with a submitting entity that “confers control over an electric generation asset 

that is used in, or offered into, wholesale electric markets.”

18. We also propose a reporting process that would permit, where possible, unified 

submissions of both MBR and Connected Entity Information. Additionally, we propose 

that, as discussed below, all the required data be submitted directly to the Commission 

rather than to the RTOs and ISOs. This will obviate the need for RTOs and ISOs to act 

as middlemen in the collection process, as proposed in the Connected Entity NOPR, and 

eliminate the need for multiple RTO/ISO filings for entities that participate in more than 

one Commission-jurisdictional organized wholesale electric market.

19. Because there are separate legal justifications and regulations for the various data 

submissions proposed in this NOPR, it is useful to think of the requirements in two parts: 

those pertaining to the MBR program, and those pertaining to analytics and surveillance. 

As discussed below, we propose that all MBR sellers largely continue to submit data 

under the existing MBR regulations, with certain modifications proposed in this NOPR.

25

 

We further propose that MBR sellers be required to submit data under the Connected 

Entity regulations proposed in this NOPR. We propose that Virtual/FTR Participants that

 

25 For a short-hand comparison of the Ownership NOPR and the Existing MBR 

Requirements with the current NOPR proposal, see Attachment A: Comparison of 

Ownership NOPR and Existing MBR Requirements with the Current NOPR Proposal.
Docket No. RM16-17-000 15

do not require MBR authority would submit data only under the Connected Entity 

regulations proposed in this NOPR. We propose to require that the XML filing indicate 

whether a particular piece of information is submitted for MBR purposes. Undesignated 

information would, therefore, be considered as provided pursuant to the Connected Entity 

requirements. These indications are necessary to allow an entity seeking to obtain or 

retain MBR authority to identify the specific information necessary to support its 

requested authorization consistent with our regulations. Entities that trade solely virtual 

instruments and/or FTRs are not required to obtain MBR authority, and therefore would 

not be required to submit MBR Information. Therefore, the only information such 

entities would need to submit to the Commission would be that needed for analytics and

surveillance purposes.

20. The Commission believes that entities submitting only Connected Entity data 

should be subject to the same candor requirements of section 35.41(b) of the 

Commission’s regulations as are MBR sellers. This regulation requires MBR “sellers,”

as defined in section 35.36(a)(1) of the Commission’s regulations, to submit accurate, 

factual, and complete information in any communication with the Commission, 

Commission-approved market monitors, RTOs, and ISOs. Therefore, we propose to add 

a new section 35.50(d) that would require the same candor from Virtual/FTR Participants 
Docket No. RM16-17-000 16

in any of their communications with the Commission, Commission-approved market 

monitors, RTOs, and ISOs, and jurisdictional transmission providers.

26

B. Proposals Regarding MBR Information 

21. The Commission uses a two-part approach when assessing whether a seller should 

be granted MBR authority: (1) whether the seller and its affiliates lack, or have 

adequately mitigated, market power in generation (i.e., horizontal market power); and 

(2) whether the seller and its affiliates lack, or have adequately mitigated, market power 

in transmission and whether the seller or its affiliates can erect other barriers to entry

(i.e., vertical market power).

27

 In Order No. 697, the Commission adopted two indicative 

screens for assessing horizontal market power: the pivotal supplier screen and the 

wholesale market share screen.28 The pivotal supplier screen evaluates the MBR seller’s 

potential to exercise market power based on the seller’s uncommitted capacity at the time 

of annual peak demand in the relevant market. The wholesale market share screen 

measures whether a seller has a dominant position in the market by analyzing the number 

 

26 In the Connected Entity NOPR, the Commission proposed to require market 

participants to certify, on a yearly basis, that their Connected Entity data is 

comprehensive and accurate. Connected Entity NOPR, FERC Stats. & Regs. ¶ 32,711 

at P 30. This NOPR does not propose to include that requirement. 

27 See Order No. 816, FERC Stats. & Regs. ¶ 31,374 at P 4; Order No. 697, FERC 

Stats. & Regs. ¶ 31,252 at P 399.

28 Order No. 697, FERC Stats. & Regs. ¶ 31,252 at PP 62-63.
Docket No. RM16-17-000 17

of megawatts (MW) of uncommitted capacity it owns or controls, relative to the 

uncommitted capacity of the relevant market.

22. With respect to the vertical market power analysis, in cases where a public utility 

or its affiliates owns, operates, or controls transmission facilities, the Commission 

requires that there be a Commission-approved Open Access Transmission Tariff (OATT) 

on file or that the seller or its applicable affiliate qualifies for waiver of the OATT 

requirement.29 The Commission also considers an MBR seller’s ability to erect other 

barriers to entry as part of the vertical market power analysis.30 As such, the Commission 

requires a seller to provide a description of its ownership or control of, or affiliation with 

an entity that owns or controls, intrastate natural gas transportation, storage or 

distribution facilities; and physical coal supply sources and ownership of or control over 

who may access transportation of coal supplies.31 

23. MBR sellers currently are required to submit an asset appendix in an electronic 

spreadsheet format listing all generation assets owned or controlled by the MBR seller 

and its affiliates, broken out by balancing authority and geographic region and including, 

 

29Id. P 408. See also Kingfisher Wind, LLC, 151 FERC ¶ 61,276, at PP 26-27 

(2015) (providing guidance on how qualified sellers can claim blanket OATT waiver 

under Order No. 807 and demonstrate lack of vertical market power).

30 Order No. 697, FERC Stats. & Regs. ¶ 31,252 at PP 440-451.

31 Id. P 447; 18 CFR 35.37(e) (2015). The Commission previously had also 

required MBR sellers to describe sites for generation capacity, but eliminated this 

requirement in Order No. 816. See Order No. 816, FERC Stats. & Regs. ¶ 31,274.
Docket No. RM16-17-000 18

among other things, the in-service date and certain capacity rating information. The asset 

appendix also must reflect all electric transmission and natural gas intrastate pipelines 

and/or gas storage facilities owned or controlled by the MBR seller and its affiliates and 

the location of such facilities and include the size of the facility. Finally, in Order 

No. 816, the Commission instituted a requirement that the asset appendix include certain 

information regarding long-term power purchase agreements and, in Order No. 816-A, 

the Commission modified certain asset appendix reporting requirements.32

1. Ownership Information

24. In Order No. 697-A, the Commission set forth a requirement that an MBR seller 

seeking to obtain or retain MBR authority must identify all of its upstream owners as 

well as describe the business activity of its owners and whether they are involved in the 

energy industry. Specifically, footnote 258 of Order No. 697-A states:

A seller seeking market-based rate authority must provide information 

regarding its affiliates and its corporate structure or upstream ownership. 

To the extent that a seller’s owners are themselves owned by others, the 

seller seeking to obtain or retain market-based rate authority must identify 

those upstream owners. Sellers must trace upstream ownership until all 

upstream owners are identified. Sellers must also identify all affiliates. 

Finally, an entity seeking market-based rate authority must describe the 

business activities of its owners, stating whether they are in any way 

involved in the energy industry.33

 

32 See Order No. 816, FERC Stats. & Regs. ¶ 31,374 at PP 139-145, app. B, Asset 

Appendix; Order No. 816-A, FERC Stats. & Regs. ¶ 31,382 at PP 58, 61, 63, app. B, 

Asset Appendix.

33 Order No. 697-A, FERC Stats. & Regs. ¶ 31,268 at n.258.
Docket No. RM16-17-000 19

25. As noted above, a seller seeking MBR authority must show that it and its affiliates 

do not have, or have adequately mitigated, horizontal and vertical market power. Given 

that information about owners that do not meet the definition of affiliates under 

section 35.36(a)(9) is not necessary to evaluate horizontal or vertical market power, 

continuing to require information on unaffiliated owners may create a burden that is 

unrelated to the Commission’s determination whether a MBR seller qualifies for MBR 

authority. Thus, the instant NOPR proposes to revise the requirements of Order 

No. 697-A such that MBR sellers would only be required to provide information on

certain “affiliate owners” (i.e., owners that meet the definition of “affiliate” provided in 

18 CFR 35.36(a)(9)).

34

 That is, consistent with the proposal in the Ownership NOPR, we 

propose that MBR sellers need to identify only those affiliate owners that either: (1) are 

an “ultimate affiliate owner,” defined as the furthest upstream affiliate owner(s) in the 

ownership chain; or (2) have a franchised service area or MBR authority, or directly own 

or control generation; transmission; intrastate natural gas transportation, storage or 

distribution facilities; physical coal supply sources or ownership of or control over who 

may access transportation of coal supplies.35 

 

34 The Ownership NOPR similarly proposed to limit the ownership information 

requirements to information regarding affiliate owners. See Ownership NOPR, FERC 

Stats. & Regs. ¶ 32,713 at P 9. 

35 See id.
Docket No. RM16-17-000 20

26. In addition, consistent with the Commission’s proposal in the Ownership NOPR, 

we propose that, where an MBR seller is directly or indirectly owned or controlled by a 

foreign government or any political subdivision of a foreign government or any 

corporation which is owned in whole or in part by such entity, the MBR seller identify 

such foreign government, political subdivision, or corporation as part of its ownership 

narrative.

36

 This information is useful in protecting public utility customers against 

inappropriate cross-subsidization and affiliate abuse concerns possible when controlling 

interests in a public utility are held by a foreign government, any political subdivision of 

a foreign government, or any corporation which is owned in whole or in part by such 

entity. Finally, we also propose, as the Commission did in the Ownership NOPR, that 

with respect to any owners that an MBR seller represents to be passive, the MBR seller 

affirm in its ownership narrative that its passive owner(s) own a separate class of 

securities, have limited consent rights, do not exercise day-to-day control over the 

company, and cannot remove the manager without cause.37 

27. We believe that limiting the category of owners for which MBR sellers have to 

provide information will be less burdensome for the industry and more useful to the 

Commission for purposes of determining whether a seller qualifies for MBR authority. 

 

36 See Ownership NOPR, FERC Stats. & Regs. ¶ 32,713 at P 11.

37 See Ownership NOPR, FERC Stats. & Regs. ¶ 32,713 at P 13 (citing AES 

Creative Resources, L.P., 129 FERC ¶ 61,239 (2009) (distinguishing between controlling 

interests and passive investment interests)). 
Docket No. RM16-17-000 21

We propose changes to the regulatory text in section 35.37(a)(2) to implement the 

changes to the level of ownership information required and to require that certain 

ownership information be provided in a format specified on the Commission’s website, 

so that it can be included in the relational database. 

28. We propose that the first time an entity is identified as an affiliate owner by an 

MBR seller in an XML submission, the relational database will create a unique identifier 

for that entity. A list of all of these entities and their associated unique identifiers, along 

with limited identifying information (e.g., business address) would be published on the 

Commission’s website. Once a unique identifier is assigned to an entity, all MBR sellers 

would be responsible for using this unique identifier when identifying their affiliate 

owners in future XML submissions.38 To the extent an MBR seller submits its 

relationship with an affiliate owner as privileged under section 388.112 of the

Commission’s regulations, the MBR seller-affiliate owner relationship would remain 

confidential if it qualifies for such treatment. However, the identity of the affiliate owner 

and its unique identifier or LEI (without an indication of its affiliations) would be 

included in the public list on the Commission’s website. We seek comment on this 

proposal.

 

38 If the affiliate owner has an LEI, the MBR seller should use the LEI as the 

unique identifier, which would take the place of a Commission-generated identifier on 

the published list. 
Docket No. RM16-17-000 22

29. Once the MBR seller submits all the required affiliate owner information to the 

relational database through the XML filing, the database would be able to generate a 

corporate organizational chart. Thus, we also propose to amend section 35.37(a)(2) to 

remove the requirement for MBR sellers to submit corporate organizational charts

adopted in Order No. 816.

30. While there will be some increased burden in the short-term associated with 

providing ownership information in the relational database, the reduction of ownership 

information required to be reported and the elimination of the corporate organizational

chart requirement represent a net decrease in burden for MBR sellers. We seek comment 

on these proposals.

2. Asset Appendix Information

31. Currently, MBR sellers submit in an electronic spreadsheet format an asset 

appendix that contains information about long-term firm purchases and assets that they

and all of their affiliates own or control. We propose to amend this requirement such 

that, for purposes of the asset appendix requirement: (i) information be submitted in 

XML format as specified on the Commission’s website so that it can be included in the 

relational database; and (ii) each MBR seller would no longer report assets owned by its 

affiliates with MBR authority.39 Once an MBR seller identifies its ultimate affiliate 

 

39 This proposal is specific to the relational database requirement to provide asset 

appendix information. This does not relieve MBR sellers from the requirements to 

consider and discuss affiliate assets as part of their horizontal and vertical market power 

analyses.
Docket No. RM16-17-000 23

owner(s), the relational database would be able to identify all the affiliates (i.e., those 

with a common upstream owner) with MBR authority (that have each filed an asset 

appendix with its own assets) and create an asset appendix for the MBR seller that 

includes all of the assets of its affiliates with MBR authority. That asset appendix would 

be placed into eLibrary as part of the MBR seller’s filing. For example, Company F’s 

filing identifies two ultimate affiliate owners, Company A and Company B. The 

relational database would recognize that two other MBR sellers, Company C and 

Company D, also identify Company A as an ultimate affiliate owner (making those 

two companies also affiliates of Company F) and that Company E has identified 

Company B as an ultimate affiliate owner (making Company E another affiliate of 

Company F). The relational database would then be able to construct a complete asset 

appendix for Company F, which would reflect any and all assets reported by Companies 

A, B, C, D, and E, which are all affiliates of Company F. Given the proposed 

requirement discussed below that existing MBR sellers make a baseline informational 

submission including asset appendix information, we expect that whenever an MBR 

seller would need to submit a filing on which the Commission has to act (e.g., an initial 

application, triennial submission, or change in status filing), all of the information 

necessary for the relational database to create a complete asset appendix (i.e., information 

on affiliates’ assets) would exist in the relational database. 

32. We believe that this proposed approach would reduce the burden on MBR sellers 

given that they would no longer have to submit detailed information on all of their 

affiliates’ assets. However, we recognize that an MBR seller’s current asset appendix 
Docket No. RM16-17-000 24

could include assets that are owned or controlled by an entity that does not have MBR 

authority, such as a generating plant owned by an affiliate that only makes sales under 

cost-based rates. If that MBR seller does not have a requirement to submit the 

information related to the affiliated generating plant into the relational database, that 

information could be “lost.” Accordingly, for purposes of completeness, we propose to 

require that the MBR seller include in its relational database filing any assets that are 

owned or controlled by an affiliate that does not have MBR authority. In that way, these 

assets would be included in the asset appendix that the relational database generates for 

the MBR seller.

33. A potential issue with this proposed approach is that the filing MBR seller would

not be directly responsible for all the information that is included in its asset appendix; 

some of the information that will be used to generate the complete asset appendix will 

have been reported by its affiliates. We propose that a filing MBR seller incorporate by 

reference its affiliates’ most recent relational database submittals or otherwise 

acknowledge that the information from its affiliates’ relational database submittals will 

be included as part of the MBR seller’s asset appendix. We anticipate that MBR sellers 

(and the public) will be able to access reports from the relational database’s up-to-date 

asset information through a Commission-established interface. Thus, the filing MBR 

seller would have prior notice of the asset appendix the relational database would 

generate and would be able to note any perceived errors when making its filing. In 

addition, once the relational database generates and reports the MBR seller’s full asset 

appendix to eLibrary (including information on the affiliates’ assets), the MBR seller 
Docket No. RM16-17-000 25

could file to amend the asset appendix posted to eLibrary if the MBR seller believes that 

the asset appendix generated by the relational database contains errors.40 

34. As noted above, we believe that the approach proposed above in which an MBR 

seller reports only its own assets (and those of any affiliate without MBR authority) 

would represent an overall decrease in burden on MBR sellers. However, the 

Commission is also considering an alternative approach whereby MBR sellers continue 

to provide information on all of their affiliates’ assets when submitting asset appendix 

information for the relational database. An advantage to this approach would be that the 

filer would be submitting all of the information itself and not having to rely on 

information submitted by its affiliates. One disadvantage to this approach is that, to the 

extent more than one MBR seller submits information about an asset, the more recently 

submitted data would overwrite the earlier-submitted data in the relational database such 

that the database would reflect only the most recently filed information. Thus, if 

Company A submits a triennial filing and reports that it sold a 150 MW generating plant 

(Plant 1), it would delete that plant from its asset appendix. The following day, if 

Company B, an affiliate of Company A, submits a triennial filing and is unaware of the 

sale of Plant 1 by Company A, and it includes Plant 1 in the asset appendix, because the 

more recently added information by Company B would “overwrite” the deletion made by 

 

40 To the extent that an MBR seller believes that its affiliate has submitted 

incorrect data, we expect them to work together to have the correct information submitted 

into the relational database. We note that each MBR seller is responsible for submitting 

accurate, factual, and complete information to the Commission.
Docket No. RM16-17-000 26

Company A, it would appear in the relational database that Company A still owns 

Plant 1. While this “overwrite” would not impact the content of MBR sellers’ filings, it 

would be problematic for the accuracy of the database given that more recently added 

information may not always represent the most current or accurate information. For this 

reason, we propose the option detailed above whereby each MBR seller does not report to 

the relational database the assets owned by its affiliates with MBR authority. As noted 

above, the owner of the facility generally should be the best source for information 

regarding its own facility. We seek comment on the proposed approach as well as the 

alternative approach.

35. In addition to these proposed changes in the submission of asset appendix 

information, we propose four additional discrete changes to the information required to 

be reported regarding assets. First, MBR sellers currently are free to report their 

generation in the asset appendix on a facility-wide basis, i.e., they are not required to 

report on a unit-specific basis. We propose instead to require that each generation unit be 

reported separately for purposes of the relational database and that MBR sellers report the 

Plant Name, Plant Code, Generator ID and Unit Code (if applicable) information from 

the Energy Information Agency (EIA) Form EIA-860 database.41 The use of this Form 

EIA-860 information will ensure that each unit is uniquely identified, which will enable 

the relational database to identify when information is being provided about a generating 

 

41 The Form EIA-860 data is available on the Internet at 

https://www.eia.gov/electricity/data/eia860/.
Docket No. RM16-17-000 27

unit that is already part of the relational database and reduce duplication of data. While 

there may be an initial small increase in burden associated with transitioning to reporting 

generation-related information on a unit-specific basis, we believe that better tracking of 

which MBR seller owns or controls each specific unit will improve the Commission’s 

ability to assess sellers’ market power, particularly in cases where various units at a 

single facility may be owned or controlled by more than one seller. This also aligns the 

Commission’s required unit identifying information with the EIA identifying 

information, essentially adopting the EIA nomenclature, which should simplify

regulatory requirements for the industry.

36. Second, we propose that MBR sellers be required to report in the relational 

database the “Telemetered Location: Market/Balancing Authority Area” and 

“Telemetered Location: Geographic Region” in which the unit should be considered for 

market power purposes when that location differs from the reported physical location.42 

Currently, the asset appendix has columns entitled “Location: Market/Balancing 

Authority Area” and “Location: Geographic Region” where MBR sellers are expected to 

provide the physical location of their generation units. These columns help the 

Commission match the information in the asset appendix to the MBR seller’s market 

power analysis. However, some generation units are considered to be in a different 

 

42 MBR sellers currently are required to report the market/balancing authority area 

and region where generation is located. We propose that such information continue to be 

reported for purposes of the relational database.
Docket No. RM16-17-000 28

market/balancing authority area and geographic region for market power purposes than 

the market/balancing authority area and geographic region in which they are physically 

located (e.g., generation units that are pseudo-tied into a different balancing authority 

area). Requiring MBR sellers to report in the relational database the “Telemetered 

Location: Market/Balancing Authority Area” and “Telemetered Location: Geographic 

Region” will ensure that the Commission is able to properly match identified generation 

units with the markets/balancing authority areas and geographic regions in which they are 

studied in an MBR seller’s market power analysis.

37. Third, we propose to require MBR sellers to include information on long-term 

firm sales (i.e., those one year or longer) in their relational database submissions. This 

would correspond with the requirement added in Order No. 816 that MBR sellers provide 

information in the asset appendix regarding long-term firm purchases. This requirement 

to report sales in addition to purchases will help ensure that purchasers and sellers report 

and treat transactions in a consistent and accurate manner. To the extent that an MBR 

seller believes there are any unique qualities of the contract that would not otherwise be 

captured by the relational database, the seller is free to explain this as part of its 

horizontal market power discussion. 

38. Finally, similar to the requirement for reporting generating units, we propose that, 

for unit-specific power purchase agreements, MBR sellers provide the associated Plant 

Code and Generator ID from the Form EIA-860 database, which will provide the unique 

identifier for that unit. 
Docket No. RM16-17-000 29

39. We also propose to eliminate some of the asset information requirements currently 

reported in the asset appendix. For example, we propose that, for purposes of the 

relational database, MBR sellers no longer be required to report the size (kV and length) 

of transmission facilities and no longer be required to identify specific transmission 

facilities. Instead, we propose that MBR sellers only report in the relational database

whether they have transmission facilities covered by an OATT in a particular balancing 

authority area and region. With respect to the natural gas pipeline information currently 

required to be reported in the list of transmission assets and natural gas intrastate 

pipelines and gas storage facilities (transmission list) portion of the asset appendix, we 

propose to revise the requirements so that the MBR seller will only be required to 

indicate for purposes of the relational database whether they own natural gas pipelines 

and storage facilities, and if so, to identify in which balancing authority area and region 

those assets are located. We expect that these proposed changes would reduce the burden 

on MBR sellers associated with the transmission list of the current asset appendix. 43 We 

seek comments on these proposals. 

 

43 We note that although these proposals would reduce the level of detail currently 

required to be provided in the asset appendix about electric transmission and natural gas 

assets, they do not affect the descriptive information and representations that MBR sellers 

are required to provide for purposes of the vertical market power analysis under 18 CFR 

35.37(d), (e).
Docket No. RM16-17-000 30

3. Indicative Screen and Other MBR Information

40. As noted above, current Commission regulations at section 35.37(c)(4) require that 

MBR sellers submit their indicative screens in an electronic spreadsheet format. We 

propose to amend that regulation to require that the indicative screen information instead 

be submitted in XML format as specified on the Commission’s website, which will 

enable the information to be included in the relational database. We anticipate that once 

an MBR seller submits the required screen information to the relational database through 

the XML filing, the database will format the indicative screens for inclusion in the record 

in eLibrary. In this way, the generated indicative screens will be available for public 

comment, as part of the MBR seller’s filing, and also be available to the Commission and 

staff in the relational database for ease of access and analysis. MBR sellers would still be 

required to submit to the Commission all work papers underlying their indicative screens. 

Such work papers would be included as an attachment to the relevant filing. We seek 

comments on these proposals.

41. The proposed information to be collected from MBR sellers via the new XML 

format is detailed in the attached draft data dictionary. As discussed above, most of this 

information is already part of a market-based rate filing, but some of it is new 

information. The types of existing MBR information that we propose to require an MBR 

seller to submit in XML for inclusion in the relational database include: (i) MBR seller 

category status for each region in which the MBR seller has MBR authority; (ii) markets 

in which the MBR seller is authorized to sell ancillary services; (iii) Commission-ordered 

seller-specific mitigation, if any; and (iv) whether the MBR seller’s MBR authority is
Docket No. RM16-17-000 31

limited to certain balancing authority areas. In addition, we propose to require MBR 

sellers to submit two new categories of information in XML for inclusion in the relational 

database: (i) the effective date of the initial grant of market-based rate authority to the 

MBR seller and (ii) Connected Entity Information, as explained elsewhere in this NOPR.

42. As discussed above, we propose to amend the Commission’s regulations at 

section 35.37 to include this additional information being reported for MBR purposes and 

to add a new section 35.51 to include a requirement for MBR sellers to provide 

Connected Entity Information in the relational database. We seek comment on these 

proposed changes.

C. Need and Authority: Analytics and Surveillance

43. In the Connected Entity NOPR, the Commission discussed the importance to its 

analytics and surveillance of understanding the financial and legal connections among

market participants and other entities. The Commission pointed out that screening 

market activity for anomalies must include understanding the circumstances surrounding 

a given pattern of trading, including the possible motivations for that behavior, which can 

sometimes be found in the legal or contractual relationships entities bear to one another. 

However, as the Commission also found, the few existing sources of such relationship 

information are inadequate because of scope, format, or timing reasons.44 The 

 

44 Connected Entity NOPR, FERC Stats. & Regs. ¶ 32,711 at PP 12-14.
Docket No. RM16-17-000 32

Commission therefore believed that it was necessary to obtain such data from the market 

participants themselves.

44. In the instant NOPR, we propose to require the direct submission of Connected 

Entity Information not only from MBR sellers but also from entities that trade solely in 

virtuals and FTRs. The Commission has the authority under FPA section 205 to regulate 

the practices in which these entities engage insofar as those practices affect jurisdictional 

rates. Consequently, as discussed more fully below, we propose to now require that such 

entities submit Connected Entity Information and their LEIs within 30 days of 

commencing trading of virtual products or holding FTRs in Commission-jurisdictional 

organized markets and then provide ongoing updates to their Connected Entity 

Information to the Commission through the relational database.

45. The authority for obtaining Connected Entity data is found, as described in the 

Connected Entity NOPR, in the Commission’s anti-manipulation authority under section 

222 of the FPA, its investigative authority under section 307(a) of the FPA, its 

administrative powers under section 309 of the FPA, and its inspection and examination 

authority under section 301(b) of the FPA, as well as in sections 205 and 206 of the 

FPA.

45

 Section 205 of the FPA provides that “[a]ll rates and charges made, demanded, 

or received by any public utility for or in connection with the transmission or sale of 

 

45 16 U.S.C. 824d , 824e, 824v, 825(b), 825f(a), 825h.
Docket No. RM16-17-000 33

electric energy subject to the jurisdiction of the Commission, and all rules and regulations 

affecting or pertaining to such rates or charges, shall be just and reasonable . . . .”

46

46. The U.S. Supreme Court recently concluded that sections 205(a) and 206(a) grant 

the Commission the authority and the duty to ensure that the practices directly affecting 

the rates charged by public utilities for the sale of electric energy for resale, and the 

transmission of electric energy in interstate commerce, are just and reasonable.47 In the 

organized markets, the locational marginal price (LMP) for sales of energy, capacity, and

ancillary services are established through markets administered by the RTOs and ISOs, 

which are public utilities. Virtual trades directly affect those LMPs, since they are

submitted in the same way and at the same time as all other bids and offers in the dayahead market, and are cleared along with other bids and offers, thus affecting the 

outcome of the day-ahead market.48 In addition, market participants that hold FTRs may 

be incentivized to use physical or virtual transactions to directly affect LMPs in such a 

way as to benefit their FTR holdings.49 All these prices must be just and reasonable 

under the Commission’s mandate. 

 

46 16 U.S.C. 824d.

47 FERC v. Elec. Power Supply Ass’n, 136 S. Ct. 760 (2016).

48 See Cal. Indep. Sys. Operator Corp., 110 FERC ¶ 61,041, at P 30 n. 21 (2005).

49 See ETRACOM LLC, 155 FERC ¶ 61,284 (2016) (in which the Commission 

found that ETRACOM engaged in a scheme to submit virtual supply transactions in order 

to affect power prices and economically benefit its Congestion Revenue Rights); see also

Black Oak Energy, LLC v. FERC, 725 F.3d 230, 240 (D.C. Cir. 2013) (Black Oak)

(continued ...)
Docket No. RM16-17-000 34

47. The Commission has confirmed its jurisdiction to regulate FTRs under FPA 

sections 205 and 206 as charges or contracts “in connection with” jurisdictional 

transmission service and “affecting” such service,

50

 and, in Order No. 697, made note of 

its monitoring authority over the RTO/ISO market rules addressing virtual and FTR 

transactions and over the market participants engaged in those transactions.51 Moreover, 

the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) has upheld 

the Commission’s authority to regulate virtual traders as participants in Commissionregulated wholesale energy markets.52

 The Commission has held that virtual trades that

affect the price of jurisdictional electricity fall within its jurisdiction.53 

48. Accordingly, the Commission’s authority to require the submission of Connected

Entity Information is unrelated to whether a given participant in the energy markets is a 

public utility or not, or whether it is seeking MBR authority or not. Consequently, the 

Commission has the authority to impose reasonable requirements on entities that solely 

 

(“Since their business interests are purely speculative, FERC explained, the virtual 

marketers pose a threat as potential market manipulators.”).

50 See, e.g., Cal. Indep. Sys. Operator Corp., 89 FERC ¶ 61,153 (1999), order on 

reh’g, 94 FERC ¶ 61,343 (2001).

51 See Order No. 697, FERC Stats. & Regs. ¶ 31,252 at P 921.

52 Black Oak, 725 F.3d 230 at 238-41.

53 See, e.g., Coaltrain Energy, L.P., 155 FERC ¶ 61,204, at PP 247-249 (2016).
Docket No. RM16-17-000 35

trade virtuals and hold FTRs as a condition of participation in those product markets. 

These requirements include candor and the disclosure of Connected Entity Information. 

49. MBR sellers would also be subject to Connected Entity reporting. The

Commission proposes that FPA section 201(f) entities, which in the main consist of 

municipalities and certain cooperatives (as well as their associated joint action agencies), 

would not be included in the reporting requirements. These entities are not subject to 

FPA sections 205 and 206; furthermore, due to their financial structures, they have 

substantially reduced incentives to commit market manipulation.54

D. Nature of the Connected Entity Information Submissions

50. Data proposed for submission by entities for the purpose of analytics and

surveillance would be greatly streamlined from that proposed under the Connected Entity 

NOPR.

55

 This information would be submitted both by MBR sellers (although not 

pursuant to the MBR program), and Virtual/FTR Participants. The proposed regulatory 

text pertaining to the Connected Entity Information, as well as the proposed regulatory 

text pertaining to revised MBR requirements, is set out at the end of this NOPR. 

 

54 See Dairyland Power Cooperative, 37 FPC 12 (1967) (discussing the 

characteristics of certain section 201(f) entities that distinguish them from privatelyowned companies).

55 For a short-hand comparison of the Connected Entity NOPR proposals and the 

the current NOPR proposal, see Attachment B: Comparison of Connected Entity NOPR 

Proposal and Current NOPR Proposal.
Docket No. RM16-17-000 36

51. The Connected Entity Information requirements would be applicable to MBR 

sellers and Virtual/FTR Participants. We propose to define the term “Virtual/FTR 

Participants” as entities that buy, sell, or bid for virtual instruments or financial 

transmission or congestion rights or contracts, or hold such rights or contracts in 

organized wholesale electric markets, not including entities defined in section 201(f) of 

the FPA. Organized wholesale electric markets would include ISOs and RTOs as those 

terms are defined in section 35.46 of the Commission’s regulations. In addition, we 

propose to use the same definition for “Seller” as in the MBR context and defined in 

section 35.36(a)(1) of the Commission’s regulations. We seek comments on these 

proposed definitions. The Commission is also not proposing to require entities that hold 

only Auction Revenue Rights to submit Connected Entity Information, but seeks 

comment on this aspect of the proposal.56 

52. We still propose to use the term “Connected Entity” under the proposed 

regulations, but the categories of entities included and their definitions are reduced and 

narrowed from that proposed in the Connected Entity NOPR, as described below. 

(a) Ownership and control: The proposed regulation would limit upstream,

downstream, and common ownership/control relationship reporting, to 

affiliates, as defined in 18 CFR 35.36(a)(9), that are either: (1) ultimate 

affiliate owners of the entity, as defined in 18 CFR 35.37(a)(2), (2)

 

56 Auction Revenue Rights are entitlements to FTR auction revenues that are 

allocated based on historical transmission usage or the funding of transmission upgrades.
Docket No. RM16-17-000 37

participants in Commission-jurisdictional organized wholesale electric 

markets, or (3) entities that purchase or sell financial natural gas or electric 

energy derivative products that settle off of the price of physical electric or 

natural gas energy products. 

(b) Employees: The proposed regulation would limit reportable employees or 

contractors to include only traders, defined as a person who makes, or 

participates in, decisions and/or devises strategies for buying or selling 

physical or financial Commission-jurisdictional electric products or 

physical natural gas.

(c) Debt: The proposed regulation would eliminate the debt instruments and 

structured transactions reporting requirement proposed in the Connected 

Entity NOPR.

(d) Contracts: The proposed regulation would refine the definition in the 

Connected Entity NOPR to require reporting by the filing entity only of 

those entities that have entered into an agreement with it that “confers 

control over an electric generation asset that is used in, or offered into,

wholesale electric markets.” Agreements that confer control are those that 

grant one of the parties the right to make trading decisions for an electric 

generation asset of another party or to offer an electric generation asset into 

the wholesale electric markets.
Docket No. RM16-17-000 38

We seek comment on this proposed definition of Connected Entity. In particular, we 

seek comment on the proposed definition of “trader” as used in the Connected Entity 

definition. 

53. We recognize that the agreements that would fall into the Contracts category of 

this proposed definition of Connected Entity are already reported to the Commission in 

EQR. However, for the Commission to be able to efficiently use EQR data in lieu of 

including the Contracts category of the Connected Entity definition, we would have to 

implement changes to how EQRs are filed that would allow staff to easily pair EQR data 

with Connected Entity Information. Therefore, as an alternative to including the 

Contracts category of the Connected Entity definition, we are also considering the option 

of requiring MBR sellers to include their LEIs in their EQR submissions, which would 

facilitate coordination between the two datasets. We request comment on: (1) the 

feasibility of this alternative approach; (2) whether this alternative approach is preferable 

to inclusion of the Contracts category of Connected Entity Information; and (3) the 

burden such a requirement would impose on MBR sellers.

54. We also propose to require MBR sellers and Virtual/FTR Participants to provide 

their Purchaser Seller Entity (PSE) NAESB/OATI webRegistry Entity Code(s) (PSE ID),

if available, as part of their Connected Entity Information submission. The PSE ID is the 

entity identifier that appears in the contract/market paths field of an e-Tag. The PSE ID 

would assist the Commission in pairing the information submitted pursuant to this NOPR 
Docket No. RM16-17-000 39

with other datasets, such as e-Tags.57 We are proposing that MBR sellers and 

Virtual/FTR Participants who have a PSE ID report that identifier as part of their 

Connected Entity Information submissions. However, we are not proposing that those 

entities that do not have a PSE ID obtain one. We seek comment on this proposal.

55. As mentioned above, certain information specified in this NOPR is sought for the 

purpose of determining whether MBR authority is to be granted or retained, while other 

information is sought for the Commission’s analytics and surveillance. For that reason,

the regulations pertaining to these data submissions are set out in different regulatory text 

sections, with the MBR-specific requirements set out in subpart H of part 35 and the 

regulatory text for the Connected Entity Information set out in a new subpart K of part 

35. However, this NOPR proposes coordinating the deadlines for reporting the two types 

of data wherever possible, thereby allowing entities that must submit data under both 

categories (MBR and Connected Entity) to combine it in a single submission. As noted 

above, instructions on the specific formatting and other technical requirements for these 

submissions will be set out on the Commission’s website. The Commission will hold 

substantial outreach meetings with members of the industry, to determine the most 

effective, expeditious, and cost-effective method of structuring these submissions. 

 

57 Availability of E-Tag Information to Commission Staff, Order No. 771, 77 FR 

76367 (Dec. 28, 2012), FERC Stats. & Regs. ¶ 31,339 (2012), order on reh’g and 

clarification, 142 FERC ¶ 61,181 (2013), order on reh’g and clarification, 153FERC 

¶ 61,177 (2015).
Docket No. RM16-17-000 40

E. Legal Entity Identifiers

56. In the Connected Entity NOPR, the Commission discussed its past dissatisfaction 

with the available methods for identifying entities that must make filings with the 

Commission.58 The Commission found that the information available was often 

imprecise and out of date and proposed to require market participants to obtain an LEI, 

which is unique to the acquirer. This proposal generally was met with favor in the 

comments to the Connected Entity NOPR. In this NOPR, the Commission proposes 

requiring that all entities that must make either MBR or Connected Entity Information

filings, obtain and maintain an LEI, and report it to the Commission in its XML 

submission for inclusion in the relational database. 

F. Confidentiality and Due Diligence 

57. As was the case with data to be collected under the Connected Entity NOPR, the 

information received under this proposal for analytics and surveillance would be treated 

as non-public and confidential. The Commission has long experience with maintaining 

the non-public status of information used for investigative purposes, and this applies 

equally to its analytics and surveillance program. Information submitted for MBR 

purposes will be made public via publication in eLibrary, and potentially through other 

means, such as the asset appendix interface discussed above unless confidential treatment 

 

58 Connected Entity NOPR, FERC Stats. & Regs. ¶ 32,711 at P 24.
Docket No. RM16-17-000 41

is requested pursuant to the Commission regulations.

59

 Connected Entity Information

would be kept non-public unless the Commission authorized its release under the 

provisions of Part 1b of its regulations.

60

58. The Commission appreciates that when extensive data must be submitted to a 

regulatory entity, occasionally some data may, despite an entity’s best efforts to achieve 

accuracy, turn out to be incomplete or incorrect. In the case of such inadvertent errors, 

the Commission’s practice is simply to require that a corrected submittal be made without 

sanctions of any kind. The intentional or reckless submittal of incorrect or misleading 

information could, however, result in the imposition of sanctions, including civil 

penalties, as has occurred in other contexts.

61

 An entity can protect itself against such a 

result by applying due diligence to the retrieval and submission of the required 

information.

 

59 See 18 CFR 388.112.

60 18 CFR pt. 1b. The protected nature of the collected information would not, 

however, prohibit the Commission from sharing it on a confidential basis, with market 

monitors, RTOs and ISOs. Such sharing was explicitly authorized in Southwest Power 

Pool, Inc., 137 FERC ¶ 61,046, at P 20 (2011).

61 See, e.g., Berkshire Power Company LLC and Power Plant Management 

Services LLC, 154 FERC ¶ 61,259, at PP 15-16 (2016); Coaltrain Energy, L.P, 

155 FERC ¶ 61,204, at PP 274-287 (2016); City Power Marketing, LLC and K. Stephen 

Tsingas, 152 FERC ¶ 61,012, at P 216 (2015); Constellation Energy Commodities Group, 

Inc. 145 FERC ¶ 61,062, at P 5 (2013); Gila River Power, LLC, 141 FERC ¶ 61,136, 

at P 12 (2012).
Docket No. RM16-17-000 42

G. Filing Requirement for Existing and New Virtual/FTR Participants62

59. We propose to require Virtual/FTR Participants to submit an Initial Connected 

Entity Submission, as defined in section 35.50(b), to engage, or continue to engage, in the 

virtual and/or FTR markets within the organized wholesale electric markets. The Initial 

Connected Entity Submission would: (i) contain the ownership, trader, and contract

information set forth in the regulation regarding Connected Entity Information; and 

(ii) report its LEI. The Commission would not issue an order approving the Initial 

Connected Entity Submission. We propose that any current Virtual/FTR Participant

submit the Initial Connected Entity Submission within 90 days of the publication of a 

Final Rule in the Federal Register. We further propose that, thereafter, any new 

Virtual/FTR Participant submit an Initial Connected Entity Submission within 30 days of 

commencing trading of virtual or FTR products. For new Virtual/FTR Participants that 

commence trading of virtual or FTR products during the initial 90-day period after 

publication of the Final Rule in the Federal Register, the 30-day timeline for submission 

of Connected Entity Information would begin to run after the 90 days has elapsed. To the 

extent an entity is both an MBR seller and a Virtual/FTR Participant, we propose that 

entity follow the submission deadlines and requirements applicable to MBR sellers. We 

request comments on this proposed submission process. 

 

62 For a short-hand summary of the proposed submission process for both MBR 

sellers and Virtual/FTR Participants, see Attachment C: Proposed Submission Processes 

for MBR Sellers and Virtual/FTR Participants. 
Docket No. RM16-17-000 43

H. Baseline Submission Required of Existing MBR Sellers63

60. In the case of existing MBR sellers, we propose to require each MBR seller to 

make a baseline submission that will include both Connected Entity and MBR 

Information in order to establish the relational database.

61. The baseline submission would be due within 90 days of the publication of a Final 

Rule in the Federal Register and include: 

(i) the Connected Entity Ownership information set forth in the regulation 

regarding Connected Entity Information (i.e., affiliates, as defined in 

section 35.36(a)(9) of the Commission’s regulations, that: (a) are ultimate 

affiliate owners; (b) participate in organized wholesale electric markets; or 

(c) purchase or sell financial natural gas or electric energy derivative 

products that settle off the price of electric or natural gas energy products);

(ii) its LEI;

(iii) the MBR information as set forth in the data dictionary (i.e., (a) MBR seller 

category status for each region in which the MBR seller has MBR

authority, (b) markets in which the MBR seller is authorized ancillary 

services, (c) mitigation, if any, and (d) whether the MBR seller has limited 

the regions in which it has MBR authority); 

 

63 For a short-hand summary of the proposed submission process for both MBR 

sellers and Virtual/FTR Participants, see Attachment C: Proposed Submission Processes 

for MBR sellers and Virtual/FTR Participants.
Docket No. RM16-17-000 44

(iv) MBR Ownership information (i.e., affiliate owners that are: (a) ultimate 

affiliate owners64 and (b) affiliate owner that have a franchised service area 

or MBR authority or directly own or control generation; transmission 

intrastate natural gas transportation, storage or distribution facilities; 

physical coal supply sources or ownership of or control over who may 

access transportation of coal supplies; 

(v) Connected Entity Trader and Contracts information; and

(vi) Asset Appendix information as set forth in the data dictionary. 

MBR sellers should submit current information, even if different from information 

included in their most recent MBR filing with the Commission. 

62. This submission is intended to establish a baseline of information in the relational 

database, not to evaluate an MBR seller’s MBR authority. Thus, the Commission would

not act on the baseline filing. The information in this baseline submission would not be 

deemed accepted or approved by the Commission. 

I. Ongoing Connected Entity Information Submission Requirements

63. Thereafter, in the case of both MBR sellers and Virtual/FTR Participants, changes 

in connection would be required to be submitted within 30 days of the change. We 

propose to define a change in connection for purposes of updating Connected Entity 

 

64 When information, such as ultimate affiliate owner, is required to be submitted 

for both MBR and analytics and surveillance purposes, it should be designated as MBR 

Information and will be treated as public information unless the filer specifically requests 

non-public treatment in accordance with 18 CFR 388.112. 
Docket No. RM16-17-000 45

Information as occurring when: (i) an entity becomes a Connected Entity of a Seller or 

Virtual/FTR Participant; or (ii) an entity ceases to be a Connected Entity of a Seller or 

Virtual/FTR Participant. With regard to the Contracts category of Connected Entity 

relationships, we propose to include a de minimis threshold of 100 MW for reporting 

changes in connection. Thus, a change in connection related to connections that are 

created by an agreement would occur when a Seller or Virtual/FTR Participant enters 

into, terminates, or amends an agreement that results in the parties conferring control of 

100 MW or more of the output of an electric generation asset. We seek comments on this 

proposed definition of change in connection and our proposal to include a 100 MW 

de minimis threshold for reporting changes of connection related to the Contracts 

category. 

64. The 30-day time period for submitting changes in connection corresponds to the 

time period to report MBR-required changes in status, thus permitting a single combined 

filing. For any submissions required under this NOPR, entities subject to both MBR and 

Connected Entity requirements may include both the MBR and Connected Entity 

Information in the same format, so long as the time periods for submission applicable to 

each category are met.

J. Ongoing MBR Seller Filing Requirements

65. We further propose to revise our regulations to add a new section 35.51 requiring 

that new MBR sellers, within 30 days of the date of the issuance of the order granting 

MBR authority, make a submission of their: (i) Connected Entity Ownership 

information, as defined in section 35.49(c)(1); (ii) Trader information, as defined in 
Docket No. RM16-17-000 46

section 35.49(d)(2); and (iii) Contract information, as defined in section 35.49(d)(3.

Thereafter, Sellers shall make filings updating this information within 30 days of a 

change in connection, as defined in section 35.49(e). We also note that MBR sellers 

would still be required to make change in status filings pursuant to section 35.42(a), and 

would be required to update other information quarterly, as set forth in the proposed 

section 35.42(d). 

66. We also propose a new section 35.42(d) to require MBR sellers to update the 

relational database on a quarterly basis to reflect any changes to previously-submitted 

information that did not trigger a change in status filing under section 35.42(a), a change 

in connection submission under the proposed section 35.49(e), or any other MBR-related 

filing such as a notice of cancellation of or revision to an MBR tariff to change an MBR 

seller’s category status.

65

 For example, updates that would be required include: 

(1) retirement of a generation asset; (2) capacity rating changes to an existing generation 

asset;66 (3) acquisition of a generation asset that is a reportable asset67 but not required to 

 

65 When making any filing that affects information captured in the relational 

database, including a notice of cancellation, MBR sellers would be required to include an 

XML file to update the relational database. See P [65], infra.

66 The Commission’s change in status regulation regarding generation-related 

assets is limited to cumulative net increases of 100 MW or more; thus, not all changes in 

generation assets create a change in status filing obligation. See 18 CFR 35.42(a). 

67 As the Commission clarified in Order No. 816, behind-the-meter generation 

and certain qualifying facilities would not be reportable assets. Order No. 816 FERC 

Stats. & Regs. ¶ 31,374 at PP 23, 44 (sellers are not required to include behind-the-meter 

generation in their asset appendices, indicative screens, or for purposes of calculating the 

(continued ...)
Docket No. RM16-17-000 47

be reported in a change in status filing; (4) loss of affiliation with an affiliate owner that 

has a franchised service area or MBR authority, or directly owns or controls generation,

transmission, interstate natural gas transportation, storage or distribution facilities,

physical coal supply sources, or ownership of or control over who may access 

transportation of coal supplies that does not trigger a change in connection submission; 

and (5) changes to business card information of the Seller or its affiliate owner(s) 

(e.g., name of legal entity name, headquarters address, address of legal formation, 

website, business registry, and business registry reference number) that will be used as a 

way to distinguish entities with similar names and characteristics from one another. In 

this way, information in the relational database would be fully updated on a regular basis

while avoiding duplication of other reporting requirements. To the extent that a Seller 

needs to make a change in status filing, change in connection submission, and/or a 

quarterly update, it may do so in a single filing to the extent the Commission’s rules on 

timing of change in status filings and change in connection are met. That is, a quarterly 

submission could include the requisite change in status filing and/or the requisite change 

in connection submission so long as it is not made more than 30 days after the relevant 

change in status or change in connection event.

 

change in status threshold; qualifying facilities that are exempt from FPA section 205 and 

facilities that are behind-the-meter facilities do not need to be reported in the asset 

appendix or indicative screens).
Docket No. RM16-17-000 48

67. Maintaining the accuracy of the database is not only important to ensure the 

usefulness of the relational database for the Commission’s analytics and surveillance 

program, but is also necessary to generate accurate asset appendices for inclusion in an 

MBR seller’s MBR filings and organizational charts for use by the Commission. As 

described above, the relational database will generate an asset appendix for the MBR 

seller based on information that is provided by its affiliates. The quarterly update 

requirement will ensure that when an MBR seller makes a filing requiring an asset 

appendix, the asset appendix generated by the relational database would reflect current 

information on its affiliates’ assets.68 We propose that the quarterly updates be treated as 

informational.

68. Other than the changes identified herein, we propose that the substantive 

requirements for MBR-related filings (i.e., initial applications for MBR authority, 

triennial filings, and change in status updates) remain the same as that currently in effect. 

However, such filings would be made as an XML filing package that includes all of the 

necessary attachments, as described above. Similarly, MBR sellers’ notices of 

cancellation of, or amendments to, their MBR tariffs would include an XML file to 

update relevant relational database information, if any. As noted elsewhere in this 

 

68 Currently, asset appendix information is only provided as part of initial MBR 

applications, triennial updated market power filings, and some notice of change in status

filings.
Docket No. RM16-17-000 49

NOPR, instructions on the specific formats and mechanics of such submissions will be 

included on the Commission’s website. 

III. Information Collection Statement

69. The collections of information contained in this proposed rule are being submitted 

to the Office of Management and Budget (OMB) for review under section 3507(d) of the 

Paperwork Reduction Act of 1995, 44 U.S.C. 3507(d). We solicit comments on the 

Commission’s need for this information, whether the information will have practical 

utility, the accuracy of the provided burden estimates, ways to enhance the quality, 

utility, and clarity of the information to be collected, and any suggested methods for 

minimizing respondents’ burden, including the use of automated information techniques. 

Respondents subject to the filing requirements of this proposed rule will not be penalized 

for failing to respond to these collections of information unless the collections of 

information display a valid OMB control number. 

70. The proposed rule will affect MBR sellers and Virtual/FTR Participants. Burden 

estimates are provided for each category.69

 

69 The estimated hourly cost (salary plus benefits) provided in this section are 

based on the figures for May 2015 posted by the Bureau of Labor Statistics for the 

Utilities sector (available at http://www.bls.gov/oes/current/naics2_22.htm) and updated 

March 2016 for benefits information (at http://www.bls.gov/news.release/ecec.nr0.htm). 

The hourly estimates for salary plus benefits are:

 Legal (code 23-0000), $128.94

 Computer and mathematical (code 15-0000), $60.54

 Information systems manager (code 11-3021), $91.63

 IT security analyst (code 15-1122), $58.00

 Auditing and accounting (code 13-2011), $53.78

(continued ...)
Docket No. RM16-17-000 50

71. The Commission recognizes that there will be an initial implementation burden 

associated with providing the Commission the requested data. For example, MBR sellers

and Virtual/FTR Participants will be required to obtain an LEI if they do not already have 

one.

70 LEI acquisition is largely administrative with some optional legal review. We 

estimate one hour of person-time to acquire an LEI ($42.25), 71 added to the estimated 

$250 cost of obtaining the LEI itself totaling $292.25 in year one. There is also an 

estimated $150 annual fee for maintaining the LEI, plus the associated one burden hour 

for an ongoing annual cost of $192.25. The LEI information may also be submitted in 

the FERC-920 (Electric Quarterly Report).

72. MBR sellers already submit most of the requested information to the Commission

as part of their applications, notices of change in status and triennial updated market 

power analyses. For MBR sellers, the proposed rule enlarges the scope of information to 

be collected while also reducing requirements for some existing collections. In year one, 

we estimate that the average MBR seller will spend forty to one-hundred hours collecting 

 

 Information and record clerk (referred to as administrative work in the 

body) (code 43-4199), $37.69

70 While some other regulators already require that certain entities obtain an LEI, 

for the purposes of these estimates, we assume that no MBR seller or Virtual/FTR 

Participant already has an LEI.

71 Using the average hourly cost of salary plus benefits provided above, the 

following weights were applied to estimate the average hourly cost of $42.25: ninetyfive percent information and record clerk, five percent legal.
Docket No. RM16-17-000 51

and providing this additional information, with an ongoing burden in subsequent years of 

thirteen hours.

73. Under the proposed rule, Virtual/FTR Participants will be required to submit a 

subset of the information MBR sellers are required to submit. Because exclusively 

Virtual/FTR Participants tend to be smaller than MBR sellers and because the 

information collected is not as extensive, we estimate that Virtual/FTR Participants, on

average, will spend twenty hours collecting and providing this information in year one, 

with an ongoing burden in subsequent years of eight hours.

74. Some of the ongoing, incremental costs will be incurred by MBR sellers and 

Virtual/FTR Participants when they are required to submit information about certain 

changes within thirty days of the change. Based on the current average of change in 

status filings submitted by MBR sellers each year, we estimate that ten percent of 

affected entities will submit changes on an annual basis. 

75. All MBR sellers will incur the cost associated with submitting quarterly updates to 

information previously submitted into the relational database to the extent such changes 

did not trigger a change in status or change in connection submission. We estimate that 

during a given year, approximately half of the 2,100 MBR sellers will be required to 

submit the quarterly report. 
Docket No. RM16-17-000 52

The following table summarizes the estimated burden and cost changes due to the 

proposed rule:72

 

72 Note that the Commission is also proposing decreases in certain requirements 

(such as providing organizational charts and a reduction in the scope of ownership

information). Any associated burden decreases are not included in the table at this time 

because the Commission is seeking comment on these changes. However, the EQR 

changes we are currently seeking comment on are included in the table.
Docket No. RM16-17-000 53

Number of 

Respondent

s

Annual 

Number of 

Responses 

per 

Responden

t

Total 

Number 

of 

Response

s 

Burden 

hours per 

Respons

e

 Hourly Cost 

per 

Response

Total Burden 

Cost Per 

Response

Total Burden 

Hours Per 

Respondent

Total Burden 

Cost Per 

Respondent

Total Annual 

Burden Hours

Total Annual 

Burden Cost 

(1) (2) (1)(2)=(3) (4) (5) (4)(5) = (6) (2)(4) = (7) (2)(6) = (8) (1)(7) = (9) (1)(8)=(10)

MBR

LEI acquisition burden 2,100 1 2,100 1 $ 42.25 $ 42 1 $ 42 2,100 $ 88,725 

First year, incremental costs associated 

with the collection of additional 

connected entity and MBR information 

(e.g. unit level information and NERC PSE 

IDs) 2,100 1 2,100 42 $ 42.25 $ 1,775 42 $ 1,775 88,200 $ 3,726,450 

First year, incremental cost of formatting 

changes and initial filing (using method 

described in NOPR)

Category 1 Sellers 1,050 1 1,050 30 $ 76.28 $ 2,288 30 $ 2,288.40 31,500 $ 2,402,820 

Category 2 Sellers 1,050 1 1,050 60 $ 76.28 $ 4,577 60 $ 4,576.80 63,000 $ 4,805,640 

Ongoing incremental costs associated 

with the collection and reporting of 

additional connected entity information 

and MBR information (e.g. unit level 

information) 210 1 210 8 $ 42.25 $ 338 8 $ 338 1,680 $ 70,980 

Ongoing quarterly updates for MBR 

information (as required) 1,050 1 1,050 4 $ 42.25 $ 338 4 $ 338 4,200 $ 354,900 

Sub total for MBR-Only First year(Cat.1) 73 $ 4,105 121800 $ 6,217,995 

 First year(Cat.2) 103 $ 6,394 153300 $ 8,620,815 

 Ongoing 12 $ 676 5,880 $ 425,880 

FTR/Virtual Only

LEI acquisition burden 2,000 1 2,000 1 $ 42.25 $ 42 1 $ 42 2,000 $ 84,500 

First year, incremental costs associated 

with the collection of additional 

surveillance information 2,000 1 2,000 16 $ 42.25 $ 676 16 $ 676 32,000 $ 1,352,000 

First year Virtual/FTR submission 2,000 1 2,000 4 $ 76.28 $ 305 4 $ 305 8,000 $ 610,240 

Ongoing incremental costs associated 

with the collection and reporting of 

additional connected entity information 200 1 200 8 $ 42.25 $ 338 8 $ 338 1,600 $ 67,600 

Sub total for FTR/Virtual First year 21 $ 1,023 42,000 $ 2,046,740 

 Ongoing 8 $ 338 1,600 $ 67,600 

 First year 317,100 $ 16,885,550 

 Ongoing 7,480 $ 493,480 

EQR Changes

First year implementation in Q1 for 

sellers [ongoing burden is negligible] 2100 1 2100 0.25 $ 42.25 $ 11 0.25 $ 11 525 $ 22,181 

 First year 0.25 $ 11 525 $ 22,181 

 Ongoing 0 $ - 0 $ - 

 First year 317,625 $16,907,731 

 Ongoing 7,480 $ 493,480

Burden Changes as proposed in NOPR in RM16-17-000

Respondent/Incremental Burden Category

Total burden changes due to NOPR 

RM16-17-000

FERC-919

FERC-920 (EQR)

Sub total for FERC-919

Sub total for EQR Changes

76. The table above contains estimates of the number of MBR sellers and Virtual/FTR 

Participants. We estimate that there are 2,100 MBR sellers based on the number of MBR 

filings; of those approximately half are Category 1 in all regions and half are Category 2 
Docket No. RM16-17-000 54

in one or more regions. We estimate 2,000 Virtual/FTR Participants using data submitted 

by the RTO/ISOs in accordance with Order No. 760. 

Titles: Refinements to Policies and Procedures for Market-Based Rates for Wholesale 

Sales of Electric Energy, Capacity and Ancillary Services by Public Utilities; and 

Requirements for Sellers and Virtual/FTR Participants for Analytics and Surveillance 

Purposes (FERC-919), and Electric Quarterly Report (FERC-920)

Action: Proposed revisions to existing information collections.

OMB Control Nos.: 1902-0234 (FERC-919) and 1902-0255 (FERC_920)

Respondents for this Rulemaking: MBR sellers and Virtual/ FTR Participants.

Frequency of Information: Initial implementation, compliance filing, and periodic 

updates (annually and quarterly).

77. Necessity of Information: The Commission’s data collection requirements and 

processes must keep pace with market developments and technological advancements. 

Collecting and formatting data as discussed in this NOPR will provide the Commission 

with the necessary information to identify and address potential manipulative behavior,

better inform Commission policies and regulations, and generate asset appendices and 

organizational charts, all while eliminating duplicative reporting requirements. The new 

process will also make the information more usable and accessible to the Commission 

and its staff in the least burdensome manner possible.

78. Internal Review: The Commission has made a preliminary determination that the 

proposed revisions are necessary in light of technological advances in data collection 

processes. The Commission has assured itself, by means of its internal review, that there 
Docket No. RM16-17-000 55

is specific, objective support for the burden estimate associated with the information 

requirements.

79. Interested persons may obtain information on the reporting requirements by 

contacting the Federal Energy Regulatory Commission, Office of the Executive Director, 

888 First Street, NE, Washington, DC 20426 [Attention: Ellen Brown, e-mail: 

DataClearance@ferc.gov, phone: (202) 502-8663, fax: (202) 273-0873].

80. Comments concerning the information collections proposed in this NOPR, and the 

associated burden estimates, should be sent to the Commission in this docket and may 

also be sent to the Office of Management and Budget, Office of Information and 

Regulatory Affairs, Washington, DC 20503 [Attention: Desk Officer for the Federal 

Energy Regulatory Commission]. For security reasons, comments should be sent by 

e-mail to OMB at the following e-mail address: oira_submission@omb.eop.gov. Please 

reference FERC-919 and FERC-920 and OMB Control Nos. 1902-0234 (FERC-919) and 

1902-0255 (FERC_920)in your submission.

IV. Environmental Analysis

81. The Commission is required to prepare an Environmental Assessment or an 

Environmental Impact Statement for any action that may have a significant adverse effect 

on the human environment.73 The Commission has categorically excluded certain actions 

 

73 Regulations Implementing the National Environmental Policy Act, Order 

No. 486, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs. Regulations Preambles 

1986-1990 ¶ 30,783 (1987).
Docket No. RM16-17-000 56

from these requirements as not having a significant effect on the human environment.74 

The actions proposed here fall within a categorical exclusion in the Commission’s 

regulations, i.e., they involve information gathering, analysis, and dissemination.75 

Therefore, environmental analysis is unnecessary and has not been performed.

V. Regulatory Flexibility Act 

82. The Regulatory Flexibility Act of 1980 (RFA)76 generally requires a description 

and analysis of proposed rules that will have significant economic impact on a substantial 

number of small entities. The RFA mandates consideration of regulatory alternatives that 

accomplish the stated objectives of a rule so as to minimize any significant economic 

impact on a substantial number of small entities. The Small Business Administration’s 

(SBA) Office of Size Standards develops the numerical definition of a small business.77

The SBA revised its size standard for electric utilities (effective January 22, 2014) to a 

standard based on the number of employees, including affiliates (from a standard based 

 

74 Order No. 486, FERC Stats & Regs. ¶ 30,783.

75 18 CFR 380.4 (2015).

76 5 U.S.C. 601-612.

77 13 CFR 121.101.
Docket No. RM16-17-000 57

on megawatt hours).78 Under SBA’s current size standards, MBR sellers likely come 

under one of the following categories and associated size thresholds:79

 Hydroelectric power generation, at 500 employees

 Fossil fuel electric power generation, at 750 employees

 Nuclear electric power generation, at 750 employees

 Other electric power generation (e.g., solar, wind, geothermal, biomass, and 

other), at 250 employees

 Electric bulk power transmission and control, at 500 employees

 Electric power distribution, at 1,000 employees

 Wholesale Trade Agents and Brokers,80 at 100 employees

83. Based on available data, the percentage of small firms affected by the NOPR is 

estimated to be at least 78 percent.81 We recognize that the rule will impact small electric 

utilities, electric power distribution, electric bulk power transmission and control, and 

power marketers and estimate the economic impact below. The economic impact of this 

proposed rule is directly related to the size and complexity of the organization, that is, the 

 

78 SBA Final Rule on “Small Business Size Standards: Utilities,” 78 FR 77343 

(Dec. 23, 2013).

79 13 CFR 121.201, Sector 22, Utilities.

80 The NAICS category 425120 (Wholesale Electronic Markets and Agents and 

Brokers, within Subsector 425) covers Power Marketers.

81 For the analysis in this NOPR, we are using a conservative number of 

1000 employee threshold to conduct a comprehensive analysis.
Docket No. RM16-17-000 58

more entities to which a company is related, the more generation assets it owns or 

controls, the more traders it employs, and the more market activities in which it 

participates, the more information must be reported. Therefore, it is reasonable to assume

that the cost of complying for small entities will be significantly less than the cost for 

large ones, and the amount of information that a small entity will be required to collect, 

maintain, and transmit is likely to be small.

84. We estimate the cost in year one (including burden hours, plus cost of acquiring 

the LEI) for small companies to be $1,273- - $6,644. The annual cost starting in Year 2 

(including burden hours, plus cost of maintaining the LEI) is estimated to be $488-$826. 

According to SBA guidance, the determination of significance of impact “should be seen 

as relative to the size of the business, the size of the competitor’s business, and the impact 

the regulation has on larger competitors.”82 Based on the above analysis, the reporting 

requirements proposed in this NOPR should not have a significant economic impact on a 

substantial number of small entities.

VI. Comment Procedures

85. The Commission invites interested persons to submit comments on the matters and 

issues proposed in this notice to be adopted, including any related matters or alternative 

proposals that commenters may wish to discuss. Comments are due [INSERT DATE 45 

 

82 U.S. Small Business Administration, A Guide for Government Agencies How to 

Comply with the Regulatory Flexibility Act, May 2012, 

https://www.sba.gov/sites/default/files/advocacy/rfaguide_0512_0.pdf, p. 18.
Docket No. RM16-17-000 59

after publication in the FEDERAL REGISTER]]. Comments must refer to Docket 

No. RM16-17-000, and must include the commenter's name, the organization they 

represent, if applicable, and their address in their comments.

86. The Commission encourages comments to be filed electronically via the eFiling 

link on the Commission's web site at http://www.ferc.gov. The Commission accepts 

most standard word processing formats. Documents created electronically using word 

processing software should be filed in native applications or print-to-PDF format and not 

in a scanned format. Commenters filing electronically do not need to make a paper 

filing.

87. Commenters that are not able to file comments electronically must send an 

original of their comments to: Federal Energy Regulatory Commission, Secretary of the 

Commission, 888 First Street NE, Washington, DC 20426.

88. All comments will be placed in the Commission's public files and may be viewed, 

printed, or downloaded remotely as described in the Document Availability section 

below. Commenters on this proposal are not required to serve copies of their comments 

on other commenters.

VII. Document Availability

89. In addition to publishing the full text of this document in the Federal Register, the 

Commission provides all interested persons an opportunity to view and/or print the 

contents of this document via the Internet through the Commission's Home Page 

(http://www.ferc.gov) and in the Commission's Public Reference Room during normal 
Docket No. RM16-17-000 60

business hours (8:30 a.m. to 5:00 p.m. Eastern time) at 888 First Street, NE, Room 2A, 

Washington DC 20426.

90. From the Commission's Home Page on the Internet, this information is available 

on eLibrary. The full text of this document is available on eLibrary in PDF and 

Microsoft Word format for viewing, printing, and/or downloading. To access this 

document in eLibrary, type the docket number excluding the last three digits of this 

document in the docket number field.

91. User assistance is available for eLibrary and the Commission’s website during 

normal business hours from the Commission’s Online Support at (202) 502-6652 (toll 

free at 1-866-208-3676) or email at ferconlinesupport@ferc.gov, or the Public Reference 

Room at (202) 502-8371, TTY (202) 502-8659. E-mail the Public Reference Room at 

public.referenceroom@ferc.gov.

List of subjects in 18 CFR Part 35 

Electric power rates, Electric utilities, Reporting and recordkeeping requirements.

By direction of the Commission.

( S E A L )

Nathaniel J. Davis, Sr.,

Deputy Secretary.
Docket No. RM16-17-000 61

In consideration of the foregoing, the Commission proposes to amend Part 35 

Chapter I, Title 18, Code of Federal Regulations, as follows. 

Part 35 – FILING OF RATE SCHEDULES AND TARIFFS

1. The authority citation for Part 35 continues to read as follows:

Authority: 16 U.S.C. 791a-825r; 2601-2645; 31 U.S.C. 9701; 42 U.S.C. 

7101-7352.

2. Amend § 35.37 to revise paragraph (a)(2) and (c)(4)to read as follows:

§ 35.37 Market power analysis required.

(a) * * *

(2) When submitting a market power analysis, whether as part of an initial 

application or an update, a Seller must include a description of its ownership structure 

that identifies all ultimate affiliate owner(s), i.e., the furthest upstream affiliate(s) in the 

ownership chain. A Seller must also identify all affiliate owners that have a franchised 

service area or market-based rate authority, and all affiliate owners that directly own or 

control: generation; transmission; intrastate natural gas transportation, storage or 

distribution facilities; physical coal supply sources or ownership of or control over who 

may access transportation of coal supplies. The term “affiliate owner” means any owner 

of the Seller that is an affiliate of the Seller as defined in § 35.36(a)(9). The Seller must 

also provide a list of assets, certain specified information regarding affiliate owners, and 

other required market-based rate information in an XML schema for input into a 

relational database prepared in conformance with the instructions posted on the 

Commission’s website. 
Docket No. RM16-17-000 62

* * * * *

 (c)(1) * * *

 (4) A Seller must provide its horizontal market power screens in an XML 

schema for input into the relational database, prepared in conformance with the 

instructions posted on the Commission’s website.

* * * * *

3. Amend § 35.42 by:

a. Revising paragraphs (a)(2)(iii) and (iv).

b. Adding (a)(2)(v).

d. Revising paragraph (c).

e. Adding paragraph (d).

The revisions and additions read as follows:

§ 35.42 Change in status reporting requirement.

(a) * * *

(2) * * *

(iii) Owns, operates or controls transmission facilities; 

(iv) Has a franchised service area; or

(v) Is an ultimate affiliate owner, defined as the furthest upstream affiliate(s) in

the ownership chain. 

* * * * *

(c) Changes in status must be prepared in conformance with the instructions 

posted on the Commission’s website.
Docket No. RM16-17-000 63

(d) A Seller must report on a quarterly basis any changes to its previouslysubmitted relational database information. These submissions will be made for each of 

the four calendar quarters of each year, in accordance with the following schedule: for the 

period from January 1 through March 31, submit by April 30; for the period from April 1 

through June 30, submit by July 31; for the period July 1 through September 30, submit

by October 31; and for the period October 1 through December 31, submit by January 31. 

The submission must be prepared in conformance with the instructions posted on the 

Commission’s website.

4. Remove Appendix A to Subpart H of Part 35.

5. Remove Appendix B to Subpart H of Part 35.

6. Add subpart K to read as follows: 

Subpart K –Data Collection Requirements for Sellers and Participants in Organized 

Wholesale Electric Markets.

Sec.

35.48 Applicability.

35.49 Definitions.

35.50 Requirements for Virtual/FTR Participant.

35.51 Requirements for New Sellers.

§ 35.48 Applicability.

This subpart establishes the requirements for Sellers and Virtual/FTR Participants 

for the purpose of providing information to the Commission to conduct surveillance and 

analysis of the wholesale electric markets.

§ 35.49 Definitions.

As used in this subpart:
Docket No. RM16-17-000 64

(a) Virtual/FTR Participant means an entity that buys, sells, or bids 

for virtual instruments or financial transmission or congestion 

rights or contracts, or holds such rights or contracts in organized 

wholesale electric markets, not including entities defined in 

Section 201(f) of the Federal Power Act.

(b) Seller refers to a Seller as defined in § 35.36(a)(1).

(c) Organized Wholesale Electric Market includes an independent 

system operator and a regional transmission organization as those 

terms are defined in § 35.46.

(d) Connected Entity is defined as follows:

(1) Ownership. An entity that is an affiliate of a Seller or 

Virtual/FTR Participant pursuant to 35.36(a)(9), and meets 

one or more of the following criteria: (i) is an ultimate 

affiliate owner of the Seller or Virtual/FTR Participant, as 

defined in § 35.37(a)(2), (ii) participates in organized 

wholesale electric markets, or (iii) purchases or sells financial 

natural gas or electric energy derivative products that settle 

off the price of physical electric or natural gas energy 

products.

(2) Traders. Traders employed or engaged by the Seller or 

Virtual/FTR Participant. Trader means a person who makes, 

or participates in, decisions and/or devises strategies for 
Docket No. RM16-17-000 65

buying or selling physical or financial Commissionjurisdictional electric products or physical natural gas. 

(3) Contracts. An entity that has entered into an agreement with a 

Seller or Virtual/FTR Participant that confers control over an 

electric generation asset that is used in, or offered into,

wholesale electric markets. Agreements that confer control

are those that grant one of the parties the right to make 

trading decisions for an electric generation asset of another 

party or to offer an electric generation asset into the 

wholesale electric markets.

(e) Change in connection occurs when: (1) an entity becomes a 

Connected Entity of a Seller or Virtual/FTR Participant as 

defined in § 35.49(d); or (2) an entity ceases to be a Connected 

Entity of a Seller or Virtual/FTR Participant as defined in § 

35.49(d). With regard to the Contracts category of Connected 

Entity relationships as described in § 35.49(d)(3), a change in 

connection occurs when a Seller or Virtual/FTR Participant

enters into, terminates, or amends an agreement that results in the 

parties conferring control of 100 MW or more of the output of an 

electric generation asset. 

§ 35.50 Requirements for Virtual/FTR Participant
Docket No. RM16-17-000 66

(a) Reporting Requirement. Virtual/FTR Participant shall acquire a 

Legal Entity Identifier designation, obtainable through the Global 

LEI System, and identify their Connected Entities to the 

Commission through the submission of an XML schema for 

input into a relational database, consistent with the instructions

posted on the Commission’s website.

(b) Initial Connected Entity Submission. Virtual/FTR Participants 

that do not have market-based rate authority shall make an initial 

submission, defined herein as an Initial Connected Entity 

Submission, within 30 days of commencing participation in an 

organized wholesale electric market. The Initial Connected 

Entity Submission shall contain the Virtual/FTR Participant’s (i) 

Ownership Information, as defined in § 35.49(d)(1), (ii) Trader 

information, as defined in § 35.49(d)(2), (iii) Contract 

information, as defined in § 35.49(d)(3), and (iv) Legal Entity 

Identifier designation, obtainable through the Global LEI System. 

(c) Ongoing Reporting Requirement. Virtual/FTR Participants shall 

make submissions updating their information within 30 days of a 

change of connection, as defined in § 35.49(e).

(d) Communications. Consistent with the requirements imposed on 

Sellers in § 35.41(b), Virtual/FTR Participants must provide 

accurate and factual information and not submit false or 
Docket No. RM16-17-000 67

misleading information, or omit material information, in any 

communication with the Commission, Commission-approved 

market monitors, Commission-approved regional transmission 

organizations, Commission-approved independent system 

operators, or jurisdictional transmission providers, unless the 

Virtual/FTR Participant exercises due diligence to prevent such 

occurrences.

§ 35.51 Requirements for New Sellers. 

Reporting Requirement. Within 30 days of the order granting 

initial market-based rate authority, Sellers shall provide, through 

the submission of an XML schema for input into a relational 

database consistent with the instructions posted on the 

Commission’s website: (i) Ownership Information, as defined in 

§ 35.49(d)(1), (ii) Trader information, as defined in §

35.49(d)(2), and (iii) Contract information, as defined in §

35.49(d)(3). Thereafter, Sellers shall make filings updating their 

information within 30 days of a change of connection, as defined 

in § 35.49(e).
Docket No. RM16-17-000 68

Note: The following Attachment will not appear in the Code of Federal Regulations.

Attachment A

Comparison of Ownership NOPR and Existing MBR Requirements with the Current NOPR Proposal

OWNERSHIP NOPR AND EXISTING MBR REQUIREMENTS CURRENT NOPR PROPOSAL

Scope/Filers All MBR sellers.83 All MBR sellers 

Format Initial MBR applications, triennial updates, and changes in status 

filings are submitted through eFiling or eTariff. Information submitted 

in text (e.g., Word or .pdf) format or electronic spreadsheet. 

Ownership information provided in text format and in corporate 

organizational chart; assets of seller and affiliates provided in 

electronic spreadsheet format and sometimes in text format; and 

indicative screens provided in electronic spreadsheet format. 

MBR sellers would be required to submit relevant filings through a separate 

filing portal into a relational database. Filings would contain data in XML 

format and attachments in text (e.g., Word and .pdf) and electronic spreadsheet 

format. MBR sellers will submit certain MBR Information including ownership, 

asset and indicative screen information required pursuant to 18 CFR § 35.37 to 

the Commission through the submission of an XML file for input into a 

relational database, consistent with the Commission’s instructions posted on the 

FERC website. 

MBR Ownership 

Information

Ownership NOPR proposed that an MBR seller be required to provide 

a narrative identifying ultimate affiliate owner(s), i.e., the furthest 

upstream affiliate(s) in the ownership chain and all affiliate owners that 

have a franchised service area or market-based rate authority or that 

directly own or control: generation; transmission; intrastate natural gas 

transportation, storage or distribution facilities; physical coal supply 

sources or ownership of or control over who may access transportation 

of coal supplies. The term “affiliate owner” means any owner of the 

MBR seller that is an affiliate of the MBR seller as defined in 18 CFR 

§ 35.36(a)(9).

Retains Ownership NOPR proposal regarding the substance of the ownership 

information to be provided. Would be submitted in narrative (i.e., text) format 

and XML format for the relational database. 

MBR Asset 

Information

MBR sellers required to submit asset appendices including assets 

owned by themselves and their affiliates in electronic spreadsheet 

format.

MBR sellers would submit information (including unit-specific information and 

long-term firm power purchases and sales) about assets they and their non-MBR 

seller affiliates own to the relational database in XML format.

MBR Change in 

Status filing 

Ownership NOPR proposed to require a notice of change in status 

when MBR seller becomes affiliated with a new ultimate affiliate 

owner, defined as the furthest upstream affiliate(s) in the ownership 

chain to § 35.42(v). 

Includes Ownership NOPR proposal to require that new ultimate affiliate owners 

be reported as a change in status. 

Legal Entity 

Identifiers (LEI)

None MBR sellers would be required to acquire an LEI and report it to the 

Commission.

MBR Corporate Order No. 816 requires that MBR sellers submit corporate Proposes to eliminate the requirement that MBR sellers submit corporate 

 

83 The term “MBR seller” includes both sellers with market-based rate authority and those filing applications for market-based rate 

authority.
Docket No. RM16-17-000 69

OWNERSHIP NOPR AND EXISTING MBR REQUIREMENTS CURRENT NOPR PROPOSAL

Organizational Chart organizational chart. The Commission has granted an extension of 

time for MBR sellers to comply with this requirement.

organizational charts. 

MBR Format of 

Indicative Screens

Order No. 816 requires that MBR sellers submit indicative screens 

(pivotal supplier and market share screens) in a workable electronic 

spreadsheet format. 

MBR sellers would submit indicative screen information to the relational 

database using XML. 
Docket No. RM16-17-000 70

Note: The following Attachment will not appear in the Code of Federal Regulations.

Attachment B

Comparison of Connected Entity NOPR Proposal and Current NOPR Proposal

CONNECTED ENTITY NOPR PROPOSAL CURRENT NOPR PROPOSAL

Scope/Filers All RTO/ISO market participants. All MBR sellers and Virtual/FTR Participants

Format All RTO/ISO market participants would report their Connected 

Entities to the RTOs/ISOs in which they participate. 

MBR sellers and Virtual/FTR Participants would be required to report their 

Connected Entities to the Commission through the submission of an XML 

file for input into a relational database, consistent with the Commission’s 

instructions posted on the FERC website. 

Connected Entity 

Definition:

Ownership/Control

Proposed a broad definition which included:

 Passive owners

 Holders of non-voting stock, and

 Limited partners

Proposes a more narrow definition which essentially tracks MBR affiliate 

definition and does not propose to include: 

 Passive owners

 Holders of non-voting stock, or 

 Limited partners

Connected Entity 

Definition:

Employees

Proposed to require reporting of:

 Chief executive officer;

 Chief financial officer;

 Chief compliance officer; and 

 Traders of a market participant. 

Proposes reporting of Traders of MBR sellers or Virtual/FTR Participants 

only.

Connected Entity 

Definition:

Debt interests

Proposed to require reporting of certain debt interests and 

structured transactions.

No similar provision included. The debt category has been eliminated in this 

proposal.

Connected Entity 

Definition:

Contracts

Proposed reporting of entities that have entered into certain 

agreements with the market participant such as:

 tolling agreements,

 energy management agreements, 

 asset management agreements, 

 fuel management agreements, 

 operating management agreements, and 

 energy marketing agreements.

Limits proposed reporting to only entities that have entered into an agreement 

with an MBR seller or Virtual/FTR Participant that confers control over an 

electric generation asset that is used in or offered into wholesale electric 

markets. 

An alternate proposal is to have MBR sellers submit their LEIs with their 

quarterly EQR submissions.

Connected Entity Change 

in Connection Reporting

Market participants would be required to update their RTO/ISO 

Connected Entity submissions within 15 days.

MBR sellers and Virtual/FTR Participants would be required to update their 

Connected Entity Information within 30 days of a Change in Connection.

Certification Participation in the RTO/ISO markets would be conditioned on 

each market participant certifying, on a yearly basis, that its 

Connected Entities filed data is comprehensive and accurate.

No certification requirement proposed.
Docket No. RM16-17-000 71

CONNECTED ENTITY NOPR PROPOSAL CURRENT NOPR PROPOSAL

Legal Entity Identifiers 

(LEI)

Each reporting market participant would be required to acquire an 

LEI and report it to the RTOs/ISOs in which they participate.

MBR sellers and Virtual/FTR Participants each would be required to acquire 

an LEI and report it to the Commission.
Docket No. RM16-17-000 72

Note: The following Attachment will not appear in the Code of Federal Regulations.

Attachment C

Proposed Submission Processes for MBR Sellers and Virtual/FTR Participants

MBR SELLERS VIRTUAL/FTR PARTICIPANTS

Timeline Contents Commission 

Response

Timeline Contents Commission 

Response

Baseline 

Filing/Initial 

Connected 

Entity 

Submission

Existing sellers 

as defined in 

§35.36 file 

within 90 days 

after the 

effective date of 

the final rule

1) Connected Entity ownership 

information, as defined in 

§35.49(d)(1), 

2) MBR information as set forth 

in the data dictionary (e.g., 

category status, mitigation, 

authorized markets, etc.), and

3) MBR Ownership Information 

regarding (a) ultimate 

affiliate owners and (b) 

affiliate owner(s) that have a 

franchised service area or 

MBR authority or directly 

own or control generation, 

transmission, intrastate 

natural gas transportation, 

storage or distribution 

facilities, physical coal 

supply sources or ownership 

of or control over who may 

access transportation of coal 

supplies. 

4) Trader information, as 

defined in §35.49(d)(2),

5) Contract information, as 

defined in §35.49(d)(3), 

6) Legal Entity Identifier 

designations, and

7) Asset Appendix Information 

as set forth in the data 

dictionary.

None Existing Virtual/FTR 

Participants file an Initial 

Connected Entity 

Submission within 90 

days of publication of the 

final rule in the Federal 

Register

New Virtual/FTR 

Participants file an Initial 

Connected Entity 

Submission within 30 

days of commencing 

participation in the 

organized wholesale 

electric markets

1) Connected Entity 

ownership 

information, as 

defined in 

§35.49(d)(1),

2) Trader information, 

as defined in 

§35.49(d)(2) 

3) Contract 

information, as 

defined in 

§35.49(d)(3), and 

4) Legal Entity 

Identifier 

designations

None. Commission 

staff verifies that all 

required information 

was submitted. 

Change in 

Connection 

and Change 

Sellers file notice 

of change in 

status within 30 

Narrative description of the 

change and a relational database 

update when the change in status 

Commission (or 

delegated) order 

accepting or rejecting 

Virtual/FTR Participants 

file updates to their 

information within 30 

Provide updates only to 

information that has 

changed.

None
Docket No. RM16-17-000 73

MBR SELLERS VIRTUAL/FTR PARTICIPANTS

in Status 

Filings

days of a change 

in status as 

defined in 

§35.42 and 

update 

Connected Entity 

Information 

within 30 days of 

a change in 

connection as 

defined in 

§ 35.49(e)

affects information submitted to 

the relational database. For 

Connected Entity Information, 

updates to relational database 

only for information that has 

changed.

notice of change in 

status.

No action on Change 

in Connection

days of a Change in 

Connection, as defined in 

§ 35.49(e).

Initial 

Application 

for MBR

MBR sellers file 

for MBR 

authority prior to 

selling energy, 

capacity and 

ancillary services 

A package of information that 

includes:

1) MBR Information per 

§35.37, MBR Ownership 

Information, Legal 

Entity Identifier 

designation, Asset 

Information, and 

Indicative Screen 

information in XML 

format and as set forth in 

the data dictionary,

2) Transmittal Letter and 

narrative (uploaded as an 

attachment)

3) Indicative Screen work 

papers and alternative 

evidence, if any 

(uploaded as an 

attachment)

4) Tariff sheets in XML 

format

Commission order 

accepting or rejecting 

application.

Not Applicable

New MBR 

Seller 

Reporting 

Requirement 

Filing

New sellers file 

within 30 days 

after the grant of 

MBR authority. 

1) Connected Entity ownership 

information, as defined in 

§35.49(d), 

2) MBR information as set forth 

in the data dictionary (e.g., 

category status, mitigation, 

authorized markets if selflimited, etc.),

None. Commission 

staff verifies that all 

required information 

was submitted. 

Not Applicable
Docket No. RM16-17-000 74

MBR SELLERS VIRTUAL/FTR PARTICIPANTS

3) Trader information, as 

defined in §35.49(d)(2) and

4) Contract information, as 

defined in §35.49(d)(3)

Updated 

Market Power 

Analysis 

Triennial 

Filing 

MBR sellers that 

are Category 2 as 

defined in 

§35.36, every 3 

years, according 

to regional 

schedule in 

Appendix C to 

Order No. 816 or 

on Commission 

website

A package of information that 

includes:

1) MBR Information per 

§35.37 and as set forth in 

the data dictionary, MBR 

Ownership Information, 

Asset Information, and 

Indicative Screen 

information in XML 

format

2) Transmittal Letter and 

narrative (uploaded as an 

attachment)

3) Indicative Screen work 

papers and alternative 

evidence, if any 

(uploaded as an 

attachment)

Commission (or 

delegated) order 

accepting or rejecting 

submission.

Not Applicable

Quarterly 

Report

MBR seller files 

at the end of 

each quarter 

On a quarterly basis, MBR sellers 

report any changes to previouslysubmitted information that did not 

trigger a change in status or 

change in connection filing and 

update the relational database to 

reflect any such changes. 

None Not Applicable
75

Note: The following Attachment will not appear in the Code of Federal Regulations.

Attachment D

Draft Data Dictionary for FERC Website

Overview of Tables

Table Type Table Name Table Description

Filing information Filing metadata including links to attached documents (e.g. transmittal letters)

Natural Person Traders as defined in the proposed in proposed section 35.49 (d)(2) and natural person affiliates as defined in section 35.36(a)(9)

Entities

Legal entities required to report (MBR sellers and Virtual/FTR Participants) or be reported (affiliates as defined in section 35.36(a)(9) or Connected Entites as 

defined in proposed section 35.49)

Generation Assets Generation asset information (generator details from Asset Appendix)

MBR Information (multiple small tables) Information on entities with MBR Authorization

Long Term PPAs Long term PPAs as required by MBR regulations

Contracts Reportable contracts (as defined by the proposed section 35.49(d)(3) 

Indicative Screen PSS Pivotal supplier indicative screen

Indicative Screen MSS Market share indicative screen

Entities to Entities Reportable ownership or control relationships (as defined by the proposed rule or existing regulation) 

Natural Person Affiliates to Entities Reportable ownership or control relationships where an owner or controller is a natural person (as defined by the proposed rule or existing regulation) 

Entities to Generation Assets Reportable ownership or control relationships between entities and generation assets (as defined by the proposed rule or existing regulation) 

Seller Entities to Vertical Assets Reportable ownership or control relationships between seller entities and transmission or inputs to electric power production (may be multiple tables)

Entities to RTO/ISO Accounts Mapping of entities to RTO/ISO identifiers for all filing entities and their connected entities (non-traders)

Traders to RTO/ISO Accounts Mapping of traders to RTO/ISO identifiers

Entities to NAESB/OATI Purchaser Seller Entity ID Mapping of entities to NAESB/OATI Purchaser Seller Entity identifiers

Traders to Entities Traders to entities mapping

Entities to CID CIDs associated with a given entity

BAAs List of BAAs with NERC identifiers (also codes for non-NERC areas such as submarkets)

Regions List of FERC regions with FERC region identifiers

BAAs to Regions A mapping of BAAs to regions including dates to capture changes

RTO and ISO Names Standard RTO and ISO names

EIA-860 Views Tables necessary to cross-validate EIA generator information

LEI Registry Current LEI data tables

CIDs List of valid, current CIDs Dimension Tables (Not included here) Linking tables Fact tables
76

Filing Information

Column Description Field Definition Validations

Filing ID Unique filing ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing date Date filing was submitted Date Not null

Filer LEI

LEI of the entity for whom the filing is being made; 

Multiple entries allowed Character (20), Foreign Key Must match Legal Entity Identifier in the LEI registry

Docket No. of filing Docket No. assigned to current filing (if applicable) Character Must match docket

Reason for filing Indicator for why filing is being made Character

0- Baseline (new filing)

1- Change in status (update to ownership or asset 

appendix information that meets CIS requirements)

2- Update to MBR information (succession or tariff 

revision)

3- Triennial updated market power analysis

4- Quarterly compliance filing w/non-substantive 

changes (does not need to be noticed and acted on)

5- Initial Connected Entity Submission

6- Change in Connection Submission

Concur to filing

Unique filing ID of associated filing. Used to 

incorporate all information in associated filing by 

reference (if applicaple). Integer Nullable. If exists should match Filing ID.

Concur to MSS

Unique Market Share Screen Record ID of screen(s) to 

incorporate by reference (if applicaple); Multiple 

entries allowed Integer

Nullable. If exists should match Market Share Screen 

Record ID.

Concur to PSS

Unique Pivotal Supplier Record ID of screen(s) to 

incorporate by reference (if applicaple); Multiple 

entries allowed Integer

Nullable. If exists should match Pivotal Supplier Record 

ID.

Transmittal Letter/Petition

Transmittal letter document (if applicable); same as 

existing eTariff doc type. Character Same as existing eTariff doc type.
77

Natural Persons (Affiliates and Traders)

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

First name First name Character

Must match previous filings unless 

changes have occurred

Middle Initial Middle initial Character

Must match previous filings unless 

changes have occurred

Last name Last name Character

Must match previous filings unless 

changes have occurred

Trader Flag Indicates person is trader Binary

Natural Person Affiliate Flag Indicates person is natural person affiliate Binary

Contact Information 

Contact information for natural person 

affiliates (may be multiple fields) Character

Must match previous filings unless 

changes have occurred

Entity Information

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Entity ID Public, FERC generated ID for affiliate owners with no CID or LEI Character, Foreign Key Check against existing Owner IDS

Entity Name Entity name Character

Not null, must match previous filings, must match name as 

registered in the formation jurisdiction

Business Card Information 

for entities without an LEI

For entities without an LEI, we will collect the address of the headquarters 

of the legal entity and the address of legal formation. Multiple fields

Should be consistent between filings unless changes have 

occurred
78

Generation Assets

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Plant Name Full EIA-860 Plant Name assigned to the Plant in the EIA-860 Report Character Must match Plant Name found in EIA-860

EIA Plant Code "Plant Code" assigned to the plant as found in EIA-860 reports Character, Composite Foreign Key Must match "Plant Code" found in EIA-860

EIA Gen ID "Generator ID" assigned to the specific generator as found in EIA-860 reports Character, Composite Foreign Key Must match "Generator ID" found in EIA-860

EIA Unit Code

"Unit Code" assigned to multiple generators found in EIA-860 reports (if 

applicable) Character, Composite Foreign Key Must match "Unit Code" found in EIA-860 (if appropriate)

In-Service Date The date the unit first came into service Date None

Capacity Rating: Nameplate (MW)

As defined in FERC Order Nos. 816/816-A and example on FERC.gov; should 

reflect the generator's capacity Number None

Capacity Rating: Adjusted Result of Capacity Rating Methodology Defined in P 266 of FERC Order No. 816 Number None

Adjusted Capacity Rating Options

Which Capacity Rating Methodology Defined in P 266 of FERC Order No. 816 

was used to find the value inputted into "Capacity Rating: Adjusted" field Character

(S)easonal

5-yr (U)nit

5-yr (E)IA

(A)lternative 

Methodology Used for Alternate: 

Narrative description of capacity rating option as discussed in FERC Order No. 

816 at P 106, if an "(A)lternative" method was used Character None

Location: Market/Balancing Authority Area

Identifier for the market/balancing authority area where the generator is 

physically located; one of the six RTO/ISOs or their designated submarkets or 

a NERC-defined Balancing Authority Area name; Multiple entries allowed Character, Foreign Key

Must match a code on the list of market/BAA codes that 

will be maintained on FERC.gov

Location: Geographic Region

Identifier for the MBR designated region where the generator is physically 

located; one of the six FERC defined regions; Multiple entries allowed Character, Foreign Key

Must match a code on the list of MBR designated region 

codes that will be maintained on FERC.gov

Telemetered Location: Market/Balancing 

Authority Area

Identifier for the market/balancing authority area that is the destination 

(sink) market/balancing authority area of remote generation or where a 

generator is pseudo-tied or committed with long term transmission rights 

(i.e. where this generation should be studied in an MBR filing); One of the six 

RTO/ISOs or their designated submarkets or a NERC-defined Balancing 

Authority Area name; Multiple entries allowed Character, Foreign Key

Must match a code on the list of market/BAA codes that 

will be maintained on FERC.gov

Telemetered Location: Geographic Region

Identifier for the MBR designated region that is the destination (sink) region 

of remote generation or where a generator is pseudo-tied or committed with 

long term transmission rights (i.e. where this generation should be studied in 

an MBR filing); One of the six FERC defined regions; Multiple entries allowed Character, Foreign Key

Must match a code on the list of MBR designated codes 

that will be maintained on FERC.gov

Explanatory notes and clarifications Optional narrative description Character None

Publication Flag Indicates the row information can/will be made public Character

Privileged (M)

Public (P)

CEII (X)
79

MBR Information

MBR Authorization Information

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

Docket Granting MBR Authority

Docket number of order first granting the entity market-based rate 

authorization Character

ERXX-XXX-XXX, or 

XXXFERCXX,XXXX(XXXX), not null

Date Approval Was First Effective

Date that entity's market-based rate tariff became effective. If 

new filing, proposed effective date. Date Not null

Docket of Cancellation

Docket number of order accepting the cancellation of the entity's 

market-based rate authorization Date

ERXX-XXX-XXX, or 

XXXFERCXX,XXXX(XXXX), not null

Date cancellation was effective

Effective date of the cancellation of the entity's market-based rate 

tariff (if applicable). If this is a cancellation filing, proposed 

effective date. Date None

Category Status by Region

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

Region Region identifier Character, Foreign Key Must match FERC regions

Category Status in Region

Category status in region (current regions are Northwest, 

Southwest, Southeast, Northeast, Central, and SPP) Integer

Not null

0 - No Category designation

1- Category 1

2- Category 2

Publication Flag Indicates the row information can/will be made public Character

Privileged (M)

Public (P)

CEII (X)
80

MBR Information (Continued)

Mitigations

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

Mitigation BAA

Identifier for the NERC-defined BAA or FERC designated region, 

market/submarket studied where the entity is not allowed to 

transact at market-based rates (if applicable). Character, Foreign Key Must match FERC regions

Mitigation Region Region identifier Character, Foreign Key

Must match a code on the list of 

market/BAA codes that will be 

maintained on FERC.gov

Mitigation narrative

Narrative description of mitigation specifying BAAs, regions, type 

of mitigation, etc. Character None

Self-Limited MBR Authorization

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

Authorized in Region/BAA

Identifier for the market/balancing authority area where the entity 

is allowed to transact at market-based rates (if applicable). Character, Foreign Key

Must match a code on the list of 

market/BAA codes that will be 

maintained on FERC.gov

Region or BAA type Region or BAA Character Required

Ancillary Services Authorization 

Column Description Field Definition Validations

Record ID Unique filing ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

Authorized ancillary service sales region

Market where entity is authorized to sell ancillary services 

(RTO/ISO or Non-RTO/ISO) Character None
81

MBR Information (Continued)

Operating Reserves Authorization 

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

Operating reserves showing

Indicates whether a entity has made an additional showing that 

must be made to get MBR authorization for operating reserves Binary (Y/N) None

Market/BAAs authorized to sell operating 

reserves

Identifier for the NERC-Defined BAA or FERC designated 

submarket studied where the entity is authorized to sell operating 

reserves (if applicable). Character

Must match a code on the list of 

market/BAA codes that will be 

maintained on FERC.gov
82

PPAs

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Source Name of source Character Nullable

Source Type Generator, Region, BAA, ISO Character Not null if source exists

Source Key Unique identifier for source Character, Composite Foreign Key Not null if source exists

Sink Unique identifier for sink Character Nullable

Sink Type Generator, Region, BAA, ISO Character Not null if sink exists

Sink Key Unique identifier for source Character, Foreign Key Not null if sink exists

Type of PPA Identifies if the reporting entity is the buyer or seller of energy Character

Not null

Purchase (P)

Sale (S)

Other (O)

Reporting entity identifier Legal Entity Identifier of reporting entity identifier Character, Foreign Key Not null

Counterparty identifier Legal Entity Identifier of counterparty if exists Character, Foreign Key None

Buyer Name/Contact info If LEI does not exist Character Should match entities tab

Multi-lateral contract identifier

Unique to filing identifier for multi-lateral contracts which are input 

on multiple rows Character If exists, multiple entries should exist

Signed Date When was the contract signed Date Valid date, not null

Start Date When does the agreement go into effect Date Valid date, not null

End Date When does the agreement end Date Valid date, not null

Date of last change Date of last change to contract Date Valid date

Amount 

If the contract is for capacity, input the specified amount of MW. If it 

is an energy-only contract; convert the units into MW equivalents 

using the formula set forth in Order No. 816 at PP 140-144, and FN 178 Numeric Not null

Alternative Attributing 

Methodology

If using a different method to attribute capacity of a contract, please 

explain, support, and justify the methodology as required by Order 

No. 816 at P 144 Character None

Contractual Details

Narrative description of any unique qualities of this contract not 

captured elsewhere Character None

Publication Flag

Indicates the security level of this contract information (contract 

information submitted for MBR purposes must be public) Character

Privileged (M)

Public (P)

CEII (X)
83

Other Contracts

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing or affiliated entity Character, Foreign Key Not null

LEI of Counterparty If exists Character, Composite Foreign Key None

Counterparty Name If LEI does not exist Character, Composite Foreign Key Should match entities tab

Multi-lateral contract identifier Unique (to filing) identifier for multi-lateral contracts which are input on multiple rows Character, Composite Foreign Key If exists, multiple entries should exist

Signed Date When was the contract signed Date Valid date, not null

Start Date When does the agreement go into effect Date Valid date, not null

End Date When does the agreement end Date Valid date, not null

Date of last change Date of last change to contract Date Valid date

EIA code(s) of relevant assets EIA codes of assets relevant to contract Character Required

Control Conferred to Filer Indicates if the filer is controlling the asset Character Required
84

Indicative Screen for Pivotal Supplier

Column Description Field Definition Validations

Pivotal Supplier Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

Filing ID of last change Used to link tables. Filing identifier from filing info table (Foreign Key) Character, Composite Foreign Key Not null

New Study

Used to indicate whether the entity is providing a new study with the 

associated submittal Character, Composite Foreign Key

1 - New (not based on previously accepted screens)

0 - Screens rely on screens previously accepted by the 

Commission

Study Year

The 12 consecutive months from December of a calendar year to November 

of the next calendar year MM/YYYY-MM/YYYY None

Study Area

Identifier for the NERC-Defined BAA or FERC designated market or 

submarket studied with the associated submittal Character, Foreign Key Must match FERC region, market, or BAA

Seller Installed Capacity Inside

Row A of the Pivotal Supplier Study Screen; Seller and Affiliate (owned, 

controlled or under LT contract) Installed Capacity (inside the Study Area) in 

MW. Integer Non Negative Integer

Seller Installed Capacity Remote 

Row A1 of the Pivotal Supplier Study Screen; Seller and Affiliate (owned, 

controlled or under LT contract) Remote Capacity (outside the Study Area) 

in MW. Integer Non Negative Integer

Seller LT Purchases inside 

Row B of the Pivotal Supplier Study Screen; Seller and Affiliate Long-Term 

Firm Purchases (inside the Study Area) in MW. Integer Non Negative Integer

Seller LT Purchases outside 

Row B1 of the Pivotal Supplier Study Screen; Seller and Affiliate Long-Term 

Firm Purchases (outside the Study Area) in MW. Integer Non Negative Integer

Seller LT Sales in and outside 

Row C of the Pivotal Supplier Study Screen; Seller and Affiliate (owned, 

controlled or under LT contract) Capacity providing Long-Term Firm Sales 

(inside and outside the Study Area) in MW. Integer Non Negative Integer

Seller Uncommitted Capacity Imports 

Row D of the Pivotal Supplier Study Screen; Seller and Affiliate (owned, 

controlled or under LT Contract) Uncommitted Capacity Imports in MW. Integer Non Negative Integer

Non-Affiliate Installed Capacity Inside

Row E of the Pivotal Supplier Study Screen; Non-Affiliate (owned, 

controlled or under LT contract) Installed Capacity (inside the Study Area) in 

MW. Integer Non Negative Integer

Non-Affiliate Installed Capacity Remote 

Row E1 of the Pivotal Supplier Study Screen; Non- Affiliate (owned, 

controlled or under LT contract) Remote Capacity (outside the Study Area) 

in MW. Integer Non Negative Integer

Non-Affiliate LT Purchases inside 

Row F of the Pivotal Supplier Study Screen; Non-Affiliate Long-Term Firm 

Purchases (inside the Study Area) in MW. Integer Non Negative Integer

Non-Affiliate LT Purchases outside 

Row F1 of the Pivotal Supplier Study Screen; Non-Affiliate Long-Term Firm 

Purchases (outside the Study Area) in MW. Integer Non Negative Integer

Non-Affiliate LT Sales in and outside 

Row G of the Pivotal Supplier Study Screen; Non-Affiliate (owned, 

controlled or under LT contract) Capacity providing Long-Term Firm Sales 

(inside and outside the Study Area), in MW. Integer Non Negative Integer

Non-Affiliate Uncommitted Capacity Imports 

Row H of the Pivotal Supplier Study Screen; Non-Affiliate (owned, 

controlled or under LT Contract) Uncommitted Capacity Imports, in MW. Integer Non Negative Integer
85

Indicative Screen for Pivotal Supplier (Continued)

Study Area Reserve Requirement 

Row I of the Pivotal Supplier Study Screen; Reserve Requirement, for the 

Study Area, in MW. Integer Non Negative Integer

Seller Reserve Requirement 

Row J of the Pivotal Supplier Study Screen; Amount of Reserve 

Requirement Attributable to Seller, in MW, if any. Integer Non Negative Integer

Total Uncommitted Supply 

Row K of the Pivotal Supplier Study Screen; Sum of Rows A, A1, B, B1, D, E, 

E1, F, F1 and H minus Rows C, G, I and M of the Pivotal Supplier Screen, in 

MW. Integer Non Negative Integer

Study Area Annual Peak Load 

Row L of the Pivotal Supplier Study Screen; Annual Peak Load, for the 

Study Area in MW. Integer Non Negative Integer

Average Daily Peak Load Month

Row M of the Pivotal Supplier Study Screen; Average Daily Peak Native 

Load in the Peak Month, for the Study Area, in MW. Integer Non Negative Integer

Seller Average Peak Daily Load

Row N of the Pivotal Supplier Study Screen; Amount of Average Daily Peak 

Native Load in Peak Month Attributable to Seller, in MW. Integer Non Negative Integer

Wholesale Load 

Row O of the Pivotal Supplier Study Screen; Wholesale Load Proxy, in MW. 

Row L minus Row M. Integer Non Negative Integer

Net Uncommitted Supply 

Row P of the Pivotal Supplier Study Screen; Row K minus Row O of the 

Pivotal Supplier Screen in MW. Integer Non Negative Integer

Seller Uncommitted Capacity 

Row Q of the Pivotal Supplier Study Screen; Sum of Rows A, A1, B, B1, and 

D, minus Rows C, J and N of the Pivotal Supplier Screen in MW. Integer Non Negative Integer

Result

Unnamed row in the Pivotal Supplier Study Screen below Row Q with text 

stating "(Pass if Line Q < Line P) (Fail is Line Q > Line P)" Character "Pass" or "Fail"

Total Imports 

Unnamed row in the Pivotal Supplier Study Screen; Total Imports, as filed 

by Seller. Sum of Row D and Row H. Integer Non Negative Integer

Seller Percentage SIL

Unnamed row in the Pivotal Supplier Study Screen; Seller Uncommitted 

Capacity Imports (Row D) divided by SIL value. Numeric None

Non-Affiliate Percentage SIL

Unnamed row in the Pivotal Supplier Study Screen; Non-Affiliate 

Uncommitted Capacity Imports (Row H) divided by SIL value. Numeric None

SIL Value 

Unnamed row in the Pivotal Supplier Study Screen; Simultaneous 

Transmission Import Limit (SIL) value in MW, from Submittal 1 Puget Sound 

Energy, Inc. 135 ¶ FERC 61, 254 (2011) or Commission-accepted SIL value for 

Study Year and Study Area. Integer Non Negative Integer

SIL Limit Exceeded 

Unnamed row in the Pivotal Supplier Study Screen below SIL value with 

text "Do Total Imports exceed SIL value? (is U <= V)". Character "Yes" or "No"
86

Indicative Screen for Market Share

Column Description Field Definition Validations

Market Share Screen Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI

Legal Entity Identifier from entities table of entity 

making filing. Character (20), Foreign Key Must match LEI registry

New Study

Used to indicate whether the entity is providing a 

new study with the associated submittal Character, Composite Foreign Key

0- New (not based on previously accepted screens)

1- Screens rely on screens previously accepted by the Commission

Filing ID of last change

Used to link tables. Filing identifier from filing info 

table (Foreign Key) Character, Composite Foreign Key Not null

Study Year

The 12 consecutive months from December of a 

calendar year to November of the next calendar 

year MM/YYYY-MM/YYYY None

Study Area

Identifier for the NERC-Defined BAA or FERC 

designated market or submarket studied with the 

associated submittal

"Study Area" from the header of the Market 

Share Study Screen. Must match a code on the list of market/BAA codes that will be maintained on FERC.gov

Seller Installed Capacity Inside Winter 

Row A of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT contract) 

Installed Capacity (inside the Study Area) in MW. 

Winter Season Integer Non Negative Integer

Seller Installed Capacity Inside Spring 

Row A of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT contract) 

Installed Capacity (inside the Study Area) in MW. 

Spring Season Integer Non Negative Integer

Seller Installed Capacity Inside Summer 

Row A of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT contract) 

Installed Capacity (inside the Study Area) in MW. 

Summer Season Integer Non Negative Integer

Seller Installed Capacity Inside Fall 

Row A of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT contract) 

Installed Capacity (inside the Study Area) in MW. 

Fall Season Integer Non Negative Integer

Seller Installed Capacity Remote Winter 

Row A1 of the Market Share Study Screen; Seller 

and Affiliate (owned, controlled or under LT 

contract) Remote Capacity (outside the Study Area) 

in MW. Winter Season Integer Non Negative Integer

Seller Installed Capacity Remote Spring 

Row A1 of the Market Share Study Screen; Seller 

and Affiliate Capacity (owned, controlled or under 

LT contract) Remote Capacity (outside the Study 

Area) in MW. Spring Season Integer Non Negative Integer

Seller Installed Capacity Remote Summer 

Row A1 of the Market Share Study Screen; Seller 

and Affiliate (owned, controlled or under LT 

contract) Remote Capacity (outside the Study Area) 

in MW. Summer Season Integer Non Negative Integer

Seller Installed Capacity Remote Fall 

Row A1 of the Market Share Study Screen; Seller 

and Affiliate (owned, controlled or under LT 

contract) Remote Capacity (outside the Study Area) 

in MW. Fall Season Integer Non Negative Integer
87

Indicative Screen for Market Share (continued)

Seller LT Purchases inside Winter

Row B of the Market Share Study Screen; Seller and 

Affiliate Long-Term Firm Purchases (inside the 

Study Area) in MW. Winter Season Integer Non Negative Integer

Seller LT Purchases inside Spring

Row B of the Market Share Study Screen; Seller and 

Affiliate Long-Term Firm Purchases (inside the 

Study Area) in MW. Spring Season Integer Non Negative Integer

Seller LT Purchases inside Summer

Row B of the Market Share Study Screen; Seller and 

Affiliate Long-Term Firm Purchases (inside the 

Study Area) in MW. Summer Season Integer Non Negative Integer

Seller LT Purchases inside Fall

Row B of the Market Share Study Screen; Seller and 

Affiliate Long-Term Firm Purchases (inside the 

Study Area) in MW. Fall Season Integer Non Negative Integer

Seller LT Purchases outside Winter

Row B1 of the Market Share Study Screen; Seller 

and Affiliate Long-Term Firm Purchases (outside 

the Study Area) in MW. Winter Season Integer Non Negative Integer

Seller LT Purchases outside Spring

Row B1 of the Market Share Study Screen; Seller 

and Affiliate Long-Term Firm Purchases (outside 

the Study Area) in MW. Spring Season Integer Non Negative Integer

Seller LT Purchases outside Summer

Row B1 of the Market Share Study Screen; Seller 

and Affiliate Long-Term Firm Purchases (outside 

the Study Area) in MW. Summer Season Integer Non Negative Integer

Seller LT Purchases outside Fall

Row B1 of the Market Share Study Screen; Seller 

and Affiliate Long-Term Firm Purchases (outside 

the Study Area) in MW. Fall Season Integer Non Negative Integer

Seller LT Sales in and outside Winter

Row C of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT contract) 

Capacity providing Long-Term Firm Sales (inside 

and outside the Study Area), in MW. Winter Season Integer Non Negative Integer

Seller LT Sales in and outside Spring

Row C of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT contract) 

Capacity providing Long-Term Firm Sales (inside 

and outside the Study Area), in MW. Spring Season. Integer Non Negative Integer

Seller LT Sales in and outside Summer

Row C of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT contract) 

Capacity providing Long-Term Firm Sales (inside 

and outside the Study Area), in MW. Summer 

Season. Integer Non Negative Integer

Seller LT Sales in and outside Fall

Row C of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT contract) 

Capacity providing Long-Term Firm Sales (inside 

and outside the Study Area), in MW. Fall Season. Integer Non Negative Integer
88

Indicative Screen for Market Share (continued)

Seller Average Outages Winter

Row D of the Market Share Study Screen; Seller and 

Affiliate Capacity (owned, controlled or under LT 

Contract) Seasonal Average Planned Outages in 

MW. Winter Season. Integer Non Negative Integer

Seller Average Outages Spring

Row D of the Market Share Study Screen; Seller and 

Affiliate Capacity (owned, controlled or under LT 

Contract) Seasonal Average Planned Outages in 

MW. Spring Season. Integer Non Negative Integer

Seller Average Outages Summer

Row D of the Market Share Study Screen; Seller and 

Affiliate Capacity (owned, controlled or under LT 

Contract) Seasonal Average Planned Outages in 

MW. Summer Season. Integer Non Negative Integer

Seller Average Outages Fall

Row D of the Market Share Study Screen; Seller and 

Affiliate Capacity (owned, controlled or under LT 

Contract) Seasonal Average Planned Outages in 

MW. Fall Season. Integer Non Negative Integer

Seller Uncommitted Capacity Imports Winter

Row E of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT Contract) 

Uncommitted Capacity Imports, in MW. Winter 

Season Integer Non Negative Integer

Seller Uncommitted Capacity Imports Spring

Row E of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT Contract) 

Uncommitted Capacity Imports, in MW. Spring 

Season Integer Non Negative Integer

Seller Uncommitted Capacity Imports Summer

Row E of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT Contract) 

Uncommitted Capacity Imports, in MW. Summer 

Season Integer Non Negative Integer

Seller Uncommitted Capacity Imports Fall

Row E of the Market Share Study Screen; Seller and 

Affiliate (owned, controlled or under LT Contract) 

Uncommitted Capacity Imports, in MW. Fall Season Integer Non Negative Integer

Study Area Average Peak Native Load Winter

Row F of the Market Share Study Screen; Average 

Peak Native Load, for the Study Area, in MW. 

Winter Season. Integer Non Negative Integer

Study Area Average Peak Native Load Spring

Row F of the Market Share Study Screen; Average 

Peak Native Load, for the Study Area, in MW. 

Spring Season. Integer Non Negative Integer

Study Area Average Peak Native Load Summer

Row F of the Market Share Study Screen; Average 

Peak Native Load, for the Study Area, in MW. 

Summer Season. Integer Non Negative Integer

Study Area Average Peak Native Load Fall

Row F of the Market Share Study Screen; Average 

Peak Native Load, for the Study Area, in MW. Fall 

Season. Integer Non Negative Integer
89

Indicative Screen for Market Share (continued)

Seller Average Peak Native Load Winter

Row G of the Market Share Study Screen; Amount 

of Average Peak Native Load Attributable to Seller, 

in MW, if any, in the Winter Season. Integer Non Negative Integer

Seller Average Peak Native Load Spring

Row G of the Market Share Study Screen; Amount 

of Average Peak Native Load Attributable to Seller, 

in MW, if any, in the Spring Season. Integer Non Negative Integer

Seller Average Peak Native Load Summer

Row G of the Market Share Study Screen; Amount 

of Average Peak Native Load Attributable to Seller, 

in MW, if any, in the Summer Season. Integer Non Negative Integer

Seller Average Peak Native Load Fall

Row G of the Market Share Study Screen; Amount 

of Average Peak Native Load Attributable to Seller, 

in MW, if any, in the Fall Season. Integer Non Negative Integer

Non-Affiliate Average Peak Native Load Winter

Row H of the Market Share Study Screen; Amount 

of Average Peak Native Load Attributable to NonAffiliate, in MW, if any, in the Winter Season. Integer Non Negative Integer

Non-Affiliate Average Peak Native Load Spring

Row H of the Market Share Study Screen; Amount 

of Average Peak Native Load Attributable to NonAffiliate, in MW, if any, in the Spring Season. Integer Non Negative Integer

Non-Affiliate Average Peak Native Load Summer

Row H of the Market Share Study Screen; Amount 

of Average Peak Native Load Attributable to NonAffiliate, in MW, if any, in the Summer Season. Integer Non Negative Integer

Non-Affiliate Average Peak Native Load Fall

Row H of the Market Share Study Screen; Amount 

of Average Peak Native Load Attributable to NonAffiliate, in MW, if any, in the Fall Season. Integer Non Negative Integer

Study Area Reserve Requirement Winter

Row I of the Market Share Study Screen; Reserve 

Requirement, for the Study Area, in MW. Winter 

Season. Integer Non Negative Integer

Study Area Reserve Requirement Spring

Row I of the Market Share Study Screen; Reserve 

Requirement, for the Study Area, in MW. Spring 

Season. Integer Non Negative Integer

Study Area Reserve Requirement Summer

Row I of the Market Share Study Screen; Reserve 

Requirement, for the Study Area, in MW. Summer 

Season. Integer Non Negative Integer

Study Area Reserve Requirement Fall

Row I of the Market Share Study Screen; Reserve 

Requirement, for the Study Area, in MW. Fall 

Season. Integer Non Negative Integer
90

Indicative Screen for Market Share (continued)

Seller Reserve Requirement Winter

Row J of the Market Share Study Screen; Amount of 

Reserve Requirement Attributable to Seller, in MW, 

if any, in the Winter Season. Integer Non Negative Integer

Seller Reserve Requirement Spring

Row J of the Market Share Study Screen; Amount of 

Reserve Requirement Attributable to Seller, in MW, 

if any, in the Spring Season. Integer Non Negative Integer

Seller Reserve Requirement Summer

Row J of the Market Share Study Screen; Amount of 

Reserve Requirement Attributable to Seller, in MW, 

if any, in the Summer Season. Integer Non Negative Integer

Seller Reserve Requirement Fall

Row J of the Market Share Study Screen; Amount of 

Reserve Requirement Attributable to Seller, in MW, 

if any, in the Fall Season. Integer Non Negative Integer

Non-Affiliate Reserve Requirement Winter

Row K of the Market Share Study Screen; Amount 

of Reserve Requirement Attributable to NonAffiliate, in MW, if any, in the Winter Season. Integer Non Negative Integer

Non-Affiliate Reserve Requirement Spring

Row K of the Market Share Study Screen; Amount 

of Reserve Requirement Attributable to NonAffiliate, in MW, if any, in the Spring Season. Integer Non Negative Integer

Non-Affiliate Reserve Requirement Summer

Row K of the Market Share Study Screen; Amount 

of Reserve Requirement Attributable to NonAffiliate, in MW, if any, in the Summer Season. Integer Non Negative Integer

Non-Affiliate Reserve Requirement Fall

Row K of the Market Share Study Screen; Amount 

of Reserve Requirement Attributable to NonAffiliate, in MW, if any, in the Fall Season. Integer Non Negative Integer

Non-Affiliate Installed Capacity Inside Winter 

Row L of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Installed Capacity (inside the Study Area) in MW. 

Winter Season. Integer Non Negative Integer

Non-Affiliate Installed Capacity Inside Spring 

Row L of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Installed Capacity (inside the Study Area) in MW. 

Spring Season. Integer Non Negative Integer

Non-Affiliate Installed Capacity Inside Summer 

Row L of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Installed Capacity (inside the Study Area) in MW. 

Summer Season. Integer Non Negative Integer

Non-Affiliate Installed Capacity Inside Fall 

Row L of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Installed Capacity (inside the Study Area) in MW. 

Fall Season. Integer Non Negative Integer
91

Indicative Screen for Market Share (continued)

Non-Affiliate Installed Capacity Remote Winter 

Row L1 of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Remote Capacity (outside the Study Area) in MW. 

Winter Season. Integer Non Negative Integer

Non-Affiliate Installed Capacity Remote Spring 

Row L1 of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Remote Capacity (outside the Study Area) in MW. 

Spring Season. Integer Non Negative Integer

Non-Affiliate Installed Capacity Remote Summer 

Row L1 of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Remote Capacity (outside the Study Area) in MW. 

Summer Season. Integer Non Negative Integer

Non-Affiliate Installed Capacity Remote Fall 

Row L1 of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Remote Capacity (outside the Study Area) in MW. 

Fall Season. Integer Non Negative Integer

Non-Affiliate LT Purchases inside Winter

Row M of the Market Share Study Screen; NonAffiliate Long-Term Firm Purchases (inside the 

Study Area), in MW. Winter Season. Integer Non Negative Integer

Non-Affiliate LT Purchases inside Spring

Row M of the Market Share Study Screen; NonAffiliate Long-Term Firm Purchases (inside the 

Study Area), in MW. Spring Season. Integer Non Negative Integer

Non-Affiliate LT Purchases inside Summer

Row M of the Market Share Study Screen; NonAffiliate Long-Term Firm Purchases (inside the 

Study Area), in MW. Summer Season. Integer Non Negative Integer

Non-Affiliate LT Purchases inside Fall

Row M of the Market Share Study Screen; NonAffiliate Long-Term Firm Purchases (inside the 

Study Area), in MW. Fall Season. Integer Non Negative Integer

Non-Affiliate LT Purchases outside Winter

Row M1 of the Market Share Study Screen; NonAffiliate Long-Term Firm Purchases (outside the 

Study Area), in MW. Winter Season. Integer Non Negative Integer

Non-Affiliate LT Purchases outside Spring

Row M1 of the Market Share Study Screen; NonAffiliate Long-Term Firm Purchases (outside the 

Study Area), in MW. Spring Season. Integer Non Negative Integer

Non-Affiliate LT Purchases outside Summer

Row M1 of the Market Share Study Screen; NonAffiliate Long-Term Firm Purchases (outside the 

Study Area), in MW. Summer Season. Integer Non Negative Integer

Non-Affiliate LT Purchases outside Fall

Row M1 of the Market Share Study Screen; NonAffiliate Long-Term Firm Purchases (outside the 

Study Area), in MW. Fall Season. Integer Non Negative Integer
92

Indicative Screen for Market Share

(continued)
93

Non-Affiliate LT Sales in and outside Winter

Row N of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Capacity providing Long-Term Firm Sales (inside 

and outside the Study Area), in MW. Winter 

Season. Integer Non Negative Integer

Non-Affiliate LT Sales in and outside Spring

Row N of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Capacity providing Long-Term Firm Sales (inside 

and outside the Study Area), in MW. Spring Season. Integer Non Negative Integer

Non-Affiliate LT Sales in and outside Summer

Row N of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Capacity providing Long-Term Firm Sales (inside 

and outside the Study Area), in MW. Summer 

Season. Integer Non Negative Integer

Non-Affiliate LT Sales in and outside Fall

Row N of the Market Share Study Screen; NonAffiliate (owned, controlled or under LT contract) 

Capacity providing Long-Term Firm Sales (inside 

and outside the Study Area), in MW. Fall Season. Integer Non Negative Integer

Non-Affiliate Average Outages Winter

Row O of the Market Share Study Screen; NonAffiliate Capacity (owned, controlled or under LT 

Contract) Seasonal Average Planned Outages in 

MW. Winter Season. Integer Non Negative Integer

Non-Affiliate Average Outages Spring

Row O of the Market Share Study Screen; NonAffiliate Capacity (owned, controlled or under LT 

Contract) Seasonal Average Planned Outages in 

MW. Spring Season. Integer Non Negative Integer

Non-Affiliate Average Outages Summer

Row O of the Market Share Study Screen; NonAffiliate Capacity (owned, controlled or under LT 

Contract) Seasonal Average Planned Outages in 

MW. Summer Season. Integer Non Negative Integer

Non-Affiliate Average Outages Fall

Row O of the Market Share Study Screen; NonAffiliate Capacity (owned, controlled or under LT 

Contract) Seasonal Average Planned Outages in 

MW. Fall Season. Integer Non Negative Integer

Non-Affiliate Uncommitted Capacity Imports Winter

Row P of the Market Share Study Screen; NonAffiliate Capacity (owned, controlled or under LT 

Contract) Uncommitted Capacity Imports in MW. 

Winter Season Integer Non Negative Integer

Non-Affiliate Uncommitted Capacity Imports Spring

Row P of the Market Share Study Screen; NonAffiliate Capacity (owned, controlled or under LT 

Contract) Uncommitted Capacity Imports in MW. 

Spring Season Integer Non Negative Integer

Non-Affiliate Uncommitted Capacity Imports Summer

Row P of the Market Share Study Screen; NonAffiliate Capacity (owned, controlled or under LT 

Contract) Uncommitted Capacity Imports in MW. 

Summer Season Integer Non Negative Integer

Non-Affiliate Uncommitted Capacity Imports Fall

Row P of the Market Share Study Screen; NonAffiliate Capacity (owned, controlled or under LT 

Contract) Uncommitted Capacity Imports in MW. 

Fall Season Integer Non Negative Integer
94

Indicative Screen for Market Share 

(continued)
95

Total Competing Supply Winter 

Row Q of the Market Share Study Screen; Sum of 

Rows L, L1, M, M1, and P minus Rows H, K, N and O 

of the Market Share Screen in MW. Winter Season Integer None

Total Competing Supply Spring 

Row Q of the Market Share Study Screen; Sum of 

Rows L, L1, M, M1, and P minus Rows H, K, N and O 

of the Market Share Screen in MW. Spring Season Integer None

Total Competing Supply Summer 

Row Q of the Market Share Study Screen; Sum of 

Rows L, L1, M, M1, and P minus Rows H, K, N and O 

of the Market Share Screen in MW. Summer Season Integer None

Total Competing Supply Fall 

Row Q of the Market Share Study Screen; Sum of 

Rows L, L1, M, M1, and P minus Rows H, K, N and O 

of the Market Share Screen in MW. Fall Season Integer None

Seller Uncommitted Capacity Winter 

Row R of the Market Share Study Screen; Sum of 

Rows A, A1, B, B1, and E, minus Rows C, D, G and J 

of the Market Share Screen in MW. Winter Season Integer None

Seller Uncommitted Capacity Spring 

Row R of the Market Share Study Screen; Sum of 

Rows A, A1, B, B1, and E, minus Rows C, D, G and J 

of the Market Share Screen in MW. . Spring Season Integer None

Seller Uncommitted Capacity Summer 

Row R of the Market Share Study Screen; Sum of 

Rows A, A1, B, B1, and E, minus Rows C, D, G and J 

of the Market Share Screen in MW. Summer 

Season Integer None

Seller Uncommitted Capacity Fall 

Row R of the Market Share Study Screen; Sum of 

Rows A, A1, B, B1, and E, minus Rows C, D, G and J 

of the Market Share Screen in MW. Fall Season Integer None

Total Seasonal Uncommitted Capacity Winter 

Row S of the Market Share Study Screen; Sum of 

Row Q and Row R of the Market Share Screen in 

MW. Winter Season Integer None

Total Seasonal Uncommitted Capacity Spring 

Row S of the Market Share Study Screen; Sum of 

Row Q and Row R of the Market Share Screen in 

MW. Spring Season Integer None

Total Seasonal Uncommitted Capacity Summer 

Row S of the Market Share Study Screen; Sum of 

Row Q and Row R of the Market Share Screen in 

MW. Summer Season Integer None

Total Seasonal Uncommitted Capacity Fall 

Row S of the Market Share Study Screen; Sum of 

Row Q and Row R of the Market Share Screen in 

MW. Fall Season Integer None

Seller Market Share Winter

Row T of the Market Share Study Screen; Row R 

divided by Row S of the Market Share Screen in 

percentage. Winter Season Integer None

Seller Market Share Spring

Row T of the Market Share Study Screen; Row R 

divided by Row S of the Market Share Screen in 

percentage. Spring Season Integer None

Seller Market Share Summer

Row T of the Market Share Study Screen; Row R 

divided by Row S of the Market Share Screen in 

percentage. Summer Season Integer None

Seller Market Share Fall

Row T of the Market Share Study Screen; Row R 

divided by Row S of the Market Share Screen in 

percentage. Fall Season Integer None
96

Indicative Screen for Market Share (continued)

Total Imports Winter

Row U of the Market Share Study Screen; Total 

Uncommitted Capacity Imports in MW, as filed by 

Seller. Sum of Row E and Row P. Winter Season Integer None

Total Imports Spring

Row U of the Market Share Study Screen; Total 

Uncommitted Capacity Imports in MW, as filed by 

Seller. Sum of Row E and Row P. Spring Season Integer None

Total Imports Summer

Row U of the Market Share Study Screen; Total 

Uncommitted Capacity Imports in MW, as filed by 

Seller. Sum of Row E and Row P. Summer Season Integer None

Total Imports Fall

Row U of the Market Share Study Screen; Total 

Uncommitted Capacity Imports in MW, as filed by 

Seller. Sum of Row E and Row P. Fall Season Integer None

SIL Value Winter

Row V of the Market Share Study Screen; 

Simultaneous Transmission Import Limit (SIL) value 

in MW, from Submittal 1 Puget Sound Energy, Inc. 

135 ¶ FERC 61, 254 (2011) or Commission-accepted 

SIL value for Study Year and Study Area. Winter 

Season Integer None

SIL Value Spring

Row V of the Market Share Study Screen; 

Simultaneous Transmission Import Limit (SIL) value 

in MW, from Submittal 1 Puget Sound Energy, Inc. 

135 ¶ FERC 61, 254 (2011) or Commission-accepted 

SIL value for Study Year and Study Area. Spring 

Season Integer None

SIL Value Summer

Row V of the Market Share Study Screen; 

Simultaneous Transmission Import Limit (SIL) value 

in MW, from Submittal 1 Puget Sound Energy, Inc. 

135 ¶ FERC 61, 254 (2011) or Commission-accepted 

SIL value for Study Year and Study Area. Summer 

Season. Integer None

SIL Value Fall

Row V of the Market Share Study Screen; 

Simultaneous Transmission Import Limit (SIL) value 

in MW, from Submittal 1 Puget Sound Energy, Inc. 

135 ¶ FERC 61, 254 (2011) or Commission-accepted 

SIL value for Study Year and Study Area. Fall 

Season. Integer None

SIL Limit Exceeded Winter

Unnamed row in the Market Share Study Screen 

below SIL value with text "Do Total Imports exceed 

SIL value? (is U <= V)" Winter Season. "Yes" or "No" Character 

SIL Limit Exceeded Spring

Unnamed row in the Market Share Study Screen 

below SIL value with text "Do Total Imports exceed 

SIL value? (is U <= V)" Spring Season. "Yes" or "No" Character 

SIL Limit Exceeded Summer

Unnamed row in the Market Share Study Screen 

below SIL value with text "Do Total Imports exceed 

SIL value? (is U <= V)" Summer Season. "Yes" or "No" Character 

SIL Limit Exceeded Fall

Unnamed row in the Market Share Study Screen 

below SIL value with text "Do Total Imports exceed 

SIL value? (is U <= V)" Fall Season. "Yes" or "No" Character 
97

Entities to Entities

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Owner/Controller ID LEI, CID, or Entity ID Character, Foreign Key Foreign Key

Owner/Controller ID Type 'LEI', 'CID', or 'Entity ID' Character

Ownee/Controlee ID LEI, CID, or Entity ID Character, Composite Foreign Key Foreign Key

Ownee/Controlee ID Type 'LEI', 'CID', or 'Entity ID' Character

Ownership flag Flag indicating filer owns all/part of entity Binary (Y/N) Binary

Ownership percentage Percentage of ownership Integer 1-100 or null if entity just controls

Ownership start date Date ownership started Date Valid date or null if entity does not own

Ownership end date Date ownership ended Date Valid date or null if entity does not own

Control flag Flag indicating filer controls entity Binary (Y/N)

Control start date Date control started for either the filing entity or controlling entity Date Valid date or null if entity does not control

Control end date Date control ended for either the filing entity or controlling entity Date Valid date or null if entity does not control

Ownership/control Notes Narrative description if necessary Character None

Ownership type Ownership type, multiple types allowed Integer

0- Ultimate affiliate owner 

1- Affiliate owner that has a franchised service 

area 

2- Affiliate owner that has MBR authority

3- Affiliate owner that directly owns or controls 

generation 

4- Affiliate owner that directly owns or controls 

transmission; intrastate natural gas 

transportation, storage or distribution facilities; 

physical coal supply sources or ownership of or 

control over who may access transportation of 

coal supplies.

Publication Flag Indicates the row information can/will be made public Character

Privileged (M)

Public (P)

CEII (X)
98

Natural Person Affiliates to Entities

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Owner Name Name Character, Foreign Key Foreign Key

Owner Contact information Contact information (multiple columns) Character, Foreign Key None

Ownee/Controlee ID LEI, CID, or Entity ID Character, Foreign Key Foreign Key

Ownee/Controlee ID Type 'LEI', 'CID', or 'Entity ID' Character None

Ownership flag Flag indicating filer owns all/part of entity Binary (Y/N) Binary

Ownership percentage Percentage of ownership Integer 1-100 or null if entity just controls

Ownership start date Date ownership started Date Valid date or null if entity does not own

Ownership end date Date ownership ended Date Valid date or null if entity does not own

Control flag Flag indicating filer controls entity Binary (Y/N) Binary

Control start date Date control started for either the filing entity or controlling entity Date Valid date or null if entity does not control

Control end date Date control ended for either the filing entity or controlling entity

Mapping of entities to ISO identifiers for 

filing entity and downstream affiliates 

where appropriate Valid date or null if entity does not control

Ownership/control Notes Narrative description if necessary Character None

Ownership type Ownership type, multiple types allowed Integer

0- Ultimate affiliate owner 

1- Affiliate owner that has a franchised service 

area 

2- Affiliate owner that has MBR authority

3- Affiliate owner that directly owns or controls 

generation 

4- Affiliate owner that directly owns or controls 

transmission; intrastate natural gas 

transportation, storage or distribution facilities; 

physical coal supply sources or ownership of or 

control over who may access transportation of 

coal supplies.

Publication Flag Indicates the row information can/will be made public Character

Privileged (M)

Public (P)

CEII (X)
99

Entities to Generation Assets

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

EIA Plant Code of affiliated generation "Plant Code" assigned to the plant as found in EIA-860 reports Character, Composite Foreign Key Must match "Plant Code" found in EIA-860

EIA Gen ID of affiliated generation "Generator ID" assigned to the specific generator as found in EIA-860 reports Character, Composite Foreign Key Must match "Generator ID" found in EIA-860

EIA Unit Code of affiliated generation "Unit Code" assigned to multiple generators found in EIA-860 reports (if applicable) Character, Composite Foreign Key Must match "Unit Code" found in EIA-860 (if appropriate)

Ownership flag Flag indicating filer owns all/part of generator Binary (Y/N) Binary

Ownership percentage Percentage of ownership Integer 0-100 or null if entity just controls

Ownership start date Date ownership started Date Valid date or null if entity does not own

Ownership end date Date ownership ended Date Valid Date

Control flag Flag indicating filer controls generator (can be combined with ownership) Binary (Y/N) Binary

Controlling entity Name of controlling entity if not controlled by filer Character Should be consistent across filings

Controlling entity LEI LEI of controlling entity Character (20), Foreign Key Can be null

Control start date Date control started for either the filing entity or controlling entity Date Valid date

Control end date Date control ended for either the filing entity or controlling entity Date Valid Date

Vertical Assets

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

Asset Type Intrastate pipeline, gas storage, gas distribution, or other input. Character Must be in the list

Asset Region/BAA

One of the six RTO/ISOs or their designated submarkets or a NERC-defined 

Balancing Authority Area name. Multiple entries allowed. Character, Foreign Key

Must be a FERC region or match a code on the list of 

market/BAA codes that will be maintained on 

FERC.gov

Asset Region Type Region or BAA Character Region or BAA

Explanatory notes and 

clarifications Optional narrative description Character None

Entities to RTO/ISO Accounts

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

RTO/ISO RTO/ISO identifier Character, Composite Foreign Key Must match standard RTO/ISO identifiers

RTO/ISO Account ID Account identifier for RTO/ISOs (use multiple rows for multiple accounts) Character, Composite Foreign Key Foreign Key to RTO/ISO

RTO/ISO Account Start Date Date filing entity started using the RTO/ISO account Date Valid date

RTO/ISO Account End Date Date filing entity stopped using the RTO/ISO account Date Valid date
100

Traders to RTO/ISO Accounts

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

Trader Name Trader name (may be multiple fields) Character, Composite Foreign Key Must match person from People table

RTO/ISO RTO/ISO identifier Character, Composite Foreign Key Must match standard RTO/ISO identifiers

RTO/ISO Account ID Account identifier for RTO/ISOs (use multiple rows for multiple accounts) Character, Composite Foreign Key Foreign Key to RTO/ISO

RTO/ISO Account Start Date Date trader started using the RTO/ISO account Date Valid date

RTO/ISO Account End Date Date trader stopped using the RTO/ISO account Date Valid date

Traders to Entities

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

Trader Name Trader name (may be multiple fields) Character, Composite Foreign Key Must match person from People table

Trader Title Title (use multiple rows for traders with multiple positions) Character

Consistent between filings for same person in 

the same position

Entities to Associated CIDs

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of filing entity. Character (20), Foreign Key Must match LEI registry

Associated CIDs CIDs associated with filer Character, Composite Foreign Key Must match an extant CID

Entities to NAESB/OATI Purchaser Seller Entity ID

Column Description Field Definition Validations

Record ID Unique record ID generated by the database Primary Key, Auto-incrementing integer Primary Key (not null, unique)

Filing ID Unique filing ID generated by the database Integer, Foreign Key Foreign Key

Filer LEI Legal Entity Identifier from entities table of entity making filing. Character (20), Foreign Key Must match LEI registry

 NAESB/OATI Purchaser Seller Entity ID NAESB/OATI Purchaser-Seller Entity (PSE) identifier (e-Tag) Character, Composite Foreign Key Foreign Key to RTO/ISO

 NAESB/OATI PSE Start Date Date filing entity started using the NAESB/OATI PSE ID Date Valid date

 NAESB/OATI PSE End Date Date filing entity stopped using the NAESB/OATI PSE ID Date Valid date