Cadwalader attorneys examined a Federal Energy Regulatory Commission ("FERC") order implementing specified clarifications to the existing Electric Quarterly Report ("EQR") reporting requirements and the accompanying EQR Data Dictionary.

The FERC order revised or affirmed the following reporting requirements and data fields: (1) Increment Name; (2) Commencement Date of Contract Terms; (3) Transmission-related data; (4) Time Zone field options; and (5) E-Tag ID-related data fields.

In the future, the attorneys noted, FERC will post "minor or non-material" changes to EQR reporting requirements and the EQR Data Dictionary to its website, and the notifications will be sent to EQR users via e-mail. FERC will no longer propose these types of changes in FERC orders or rulemaking and, as a result, will not provide opportunities for comment. Rather, when FERC deems "significant changes" to the EQR reporting requirements and the EQR Data Dictionary are necessary, they will be proposed in FERC Orders or rulemakings. FERC argued that this will enable the agency to make minor or non-material changes in a more timely manner.

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