UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Data Collection for Analytics and Surveillance and Market-Based Rate Purposes } Docket No. RM16-17-000
COMMENTS OF THE EDISON ELECTRIC INSTITUTE AND ELECTRIC POWER SUPPLY ASSOCIATION
EPSA and EEI jointly filed Order 860 supplemental comments at the FERC in response to the Commission’s March 18 notice seeking comments on a proposal to collect additional data from certain MBR sellers with ultimate upstream affiliates that have been granted a blanket authorization under section 203(a)(2) of the FPA. The Commission proposes revisions to the data dictionary that accompanies the relational database established in Order 860 to include new requirements for those MBR sellers to report connections to an entity whose securities were acquired pursuant to the blanket authorization (Institutional Investor Non-Controlling Ultimate Upstream Affiliate, or “II NC-UUA”). As a threshold matter, EEI/EPSA question the need for information on II NC-UUAs in the relational database. If the Commission moves forward with its proposal to collect information about II NC-UUAs (Data Dictionary Change Proposal), EEI/EPSA assert changes are needed to make the Data Dictionary Change Proposal less cumbersome, more understandable and easier to implement. EEI/EPSA provide suggestions and include a modified Data Dictionary in Attachment A to the comments.