With the beginning of spring comes warmer weather, blooming flowers, and April compliance deadlines! There are numerous filings required by FERC and across the RTOs (NYISO, PJM, MISO, ISO-NE, SPP & CAISO). The most common items Energy Marketers are obligated to file are listed below.  Feel free to contact us if you have any questions on these upcoming deadlines.

FERC

Electric Quarterly Reports (EQRs)

There have been a number of delays and some software upgrades with the EQR filing system. FERC recently released its final order on the matter, which you can read about on this blog here. The EQR submission windows are listed below. Remember, EQRs are required to be filed even if there are no wholesale sales to report.

• The period for filing Q3 2013 EQRs will be April 1, 2014 to April 30, 2014.
• The period for filing Q4 2013 EQRs will be May 1, 2014 to May 31, 2014.
• The period for filing Q1 2014 EQRs is extended to June 1, 2014 to June 30, 2014.
• The period for filing Q2 2014 EQRs, will remain July 1, 2014 to July 31, 2014.

Interlock Reports (FERC Form 561)

For our friends with interlocking positions at multiple FERC-jurisdictional entities, your annual reports are due April 30. For background, Form 561 details electric public utility officer and board of director positions that officers and directors held within and outside their affiliated public utility at any point during the preceding year. The reports are based on last year’s information.

ISOs/RTOs

Officer Certification Forms

Generally speaking, all RTOs require their members to submit an Annual Certification Form by April 30 of each year.  This form must be signed by a company officer and notarized after completion.  By signing the form, the officer is attesting your organization meets the ISO/RTO’s threshold minimum participation criteria, which may include any or all of the following:

• Minimum capitalization requirements
• Risk management policy that addresses material credit, liquidity, and other market risks that could affect the company’s ability to pay its ISO/RTO invoice
• Training
• Communication capabilities
• Information on company activities, operations, etc.

Company Financials

Companies that use their balance sheets to meet the minimum capitalization standards are generally required to submit audited financials by April 30. Implementation of this requirement differs by RTO.  For example, in NYISO, Market Participants that are utilizing audited financial statements to meet the capitalization criteria must submit the most recent year‘s audited annual financial statements (the financial statements must demonstrate at least US $10 million in assets or at least US $1 million in tangible net worth).  In ISO-NE, annual audited financial statements are required for Market Participants that 1)represent at least .05% of the total settlement dollars through the ISO for the prior calendar year or 2) have an established credit limit.

And . . . 

 This year, PJM members are also being asked to re-verify the sector for which they qualify and to provide an updated Affiliate Disclosure form. These two items are due April 30.  Finally, ISO-NE members must submit an Information Disclosure Form by April 30 as well.