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TO:Interested Industry Parties

FROM: Caroline Trum, NAESB Deputy Director

RE:WEQ/WGQ FERC Forms Subcommittee Meeting Draft Minutes – September 14, 2015

DATE:October 27, 2015

WHOLESALE ELECTRIC AND WHOLESALE GAS QUADRANTS

FERC Forms Subcommittee Meeting

Conference Call

September 14, 2015 – 1:00 PM to 3:00 PM Central

DRAFTMINUTES

1.Welcome and Administrative Items

Mr. Brooks welcomed the participants to the meeting. Ms. Trum provided the antitrust guidelines reminder. Mr. Brooks reviewed the agenda with the participants. Ms. Davis moved, seconded by Ms. Crockett, to adopt the draft agenda as final. The motion passed a simple majority vote without opposition.

2.Continue to Discuss Informal Comments and Finalize Preliminary Topics Work Paper

Mr. Brooks reviewed the Preliminary Topics Work Paper the participants discussed during the last meeting. He stated that during the previous meeting, the participants had discussed through section four (XML validations) and suggested discussion begin with section five (form submittal). There was general agreement to proceed in this manner.

Mr. Brooks reviewed the informal comment submitted by Avista Corporation for section five as a representative from the company was unavailable. Mr. Thomas stated FERC understands the need for file submitters to be able to review and verify the information in the forms prior to submittal but that the intent with these changes to the filing process is for users to upload the XML file directly to the Commission through a portal. This new interface will likely not provide an opportunity to review the form or edit the data in the portal prior to the submittal. He noted that ideally, following the submittal of the form, users will receive a validation that the form was accepted or a notice that there were errors in the data.

Mr. Brooks noted that Avista Corporation suggests the use of EDGAR, a filing mechanism utilized by the Securities and Exchange Commission (SEC). Mr. Thomas stated that the FERC is evaluating the filing mechanism but has yet to make any determinations.

Mr. Bartholomot stated that at many companies, different departments are responsible for compiling the data in the various forms. He suggested that it would be beneficial if the XML schemas were built to allow developers to create software that would permit the forms be assembled by section. Mr. Thomas responded that FERC is interested in creating user-friendly XML schemas and validations.

There was a suggestion that there be a validation at the time of form submittal that would prevent an entity from submitting a form that contained invalid data. Mr. Brooks responded that these types of validations can be specified in the XML schema but also noted that third party vendors could develop validations as part of their software. Mr. Kravis suggested that there be a consideration of including a type of validation that will cross-reference data from previous years for the purpose of identifying values that are significantly different from previous filings. Mr. Thomas expressed a preference for the subcommittee to avoid development of validations that will add new levels of business analytics. He stated that program-level validations for data are acceptable and noted that after the new file format is implemented, FERC will still continue to perform an analysis on forms and form data as it does today.

Mr. Brook suggested the subcommittee consider the development of a process flow similar to the one created for eTariff. The participants reviewed the process flow included in the developed business practice standards. It was asked if there would be a development site that would allow for entities and third party software developers to test the submittal of forms prior to implementation. Mr. Goldenberg responded that given the XML level program validations and the use of third party software to create the forms, a Commission sponsored testing site may not provide any added value to the industry but stated that the need for one could be evaluated.

The participants next reviewed the additional topics raised by commenters. Mr. Kravis reviewed the comments submitted by Links Technology. He proposed that the subcommittee consider using the major/minor approach for future revisions to the XML schemas and that the subcommittee should develop a protocol for maintaining the documents to ensure synchronization. Mr. Thomas stated that decisions related to the future modifications to the forms and the accompanying XML schemas will be made by FERC. Mr. Goldenberg noted that FERC will likely follow the same process as it did in the eTariff effort for adopting any work produced by NAESB as a result of this effort.

Mr. Kravis stated that the last comment from Links Technology is to suggest that business-to-business (B2B) type arrangement is used to ensure that any response made by the Commission regarding form submittal is in a machine readable format that lists the errors and uniquely identifies data in which the error occurred. Mr. Thomas reiterated that FERC understands the need for a readable format and is open to a B2B solution.

Mr. Brooks reviewed the additional considerations submitted by the co-chairs. The participants briefly discussed the first two issues related to security. It was noted that both the forms and the data contained in the forms are made publically available which could have an impact on the level of security that is needed.

Mr. Brooks stated that there will need to be a decision made regarding the transport method for the files. He noted that there are numerous file transport methods available, such as FERC e-Library and Electronic Delivery Mechanism (EDM). Mr. Brooks stated that the WGQ utilizes EDM for its data transport method and noted that the Commission has already incorporated by reference NAESB WGQ Business Practice Standards related to EDM. Ms. Given asked if non-NAESB members were able to use NAESB Business Practice Standards. Ms. Trum stated that the NAESB standards are available to anyone who wishes to use them, and that while the standards are copyright protected, any entity or individual can purchase the standards. She reminded the participants that EDM is a popular data transport method and that the NAESB Business Practice Standards related to EDM are just one set of protocols. Mr. Thomas indicated that FERC is interested in a transport method that will allow entities to directly upload files to FERC. He stated that while a decision has not been made as to which method should be used, the Commission does not wish to pursue FERC e-Library, FERC Electronic Quarterly Report (EQR) transport, or the SEC Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system.

The participants discussed the need to develop an alternative method for submitting the forms in the event of a long duration internet failure. It was noted by FERC staff that the statutory requirements for the forms currently being addressed by the subcommittee will likely mean a back-up system is unnecessary.

Mr. Collins stated that FERC staff is working to identify the common fields across the various forms to provide the subcommittee with the identification of commonalities as it begins work on the XML schemas. There was a question related to how the Commission will display for the public the data included in the forms. Mr. Brooks stated that the subcommittee is responsible for developing the XML representation of the data that needs to be included in the forms and explained that how that information is used and displayed by FERC it is outside of the scope of subcommittee work.

3.Discuss Future Assignments, if any

Action Items

  1. Mr. Spangler and Mr. Brooks will work to finalize the work paper based on discussions during the meeting, including the development of a process flow.
  2. Ms. Trum will provide a link to the process flow included in the eTariff standards.
  3. NAESB will work with the subcommittee co-chairs to schedule the next meeting.

4.Next Steps and Meetings

The NAESB office will send out an agenda for the next meeting once scheduled.

5.Adjourn

The meeting adjourned at 3:05 PM Central on a motion by Mr. Cargas, seconded by Mr. Barracchini.

6.Attendance*

First Name / Last Name / Organization / Quadrant / Segment
Caleb / Adcock / Tucson Electric Power Company / WEQ / Transmission Owner
Rick / Avila / Kinder Morgan / WGQ / Pipeline
Tony / Barracchini / FERC / N/A / N/A
Henri / Bartholomot / Edison Electric Institute / N/A / N/A
Jonathan / Booe / NAESB / N/A / N/A
Dick / Brooks / ISO-New England / WEQ / IGO
Ellen / Brown / FERC / N/A / N/A
James / Cargas / City of Houston / RMQ / Retail Electric End Users/Public Agencies
John / Collins / FERC / N/A / N/A
David / Crabtree / TECO / WEQ / Distribution
Valerie / Crockett / TVA / WGQ / End User
John / Cutting / NYISO / WEQ / IGO
Dale / Davis / Williams / WGQ / Pipeline
Kay / Dennison / TransCanada / WGQ / Pipeline
Martha / Dukes / El Paso Electric Company / WEQ / Transmission Owner
Fiodor / Filzow / Eversource Energy / WEQ / Transmission Owner
Dave / Francis / MISO / WEQ / IGO
Nicole / Given / Association of Oil Pipe Lines / N/A / N/A
Nicholas / Gladd / FERC / N/A / N/A
Michael / Goldenberg / FERC / N/A / N/A
Patrick / Herm / LG&E and KU Energy / WEQ / Transmission Owner
Jason / Johnson / American Electric Power Service Corporation / WEQ / IGO
Gary / Kravis / Links Technology / WEQ / Technology/Services
Kelly / Louque / Entergy Services / WGQ / End User
Elizabeth / Mallett / NAESB / N/A / N/A
Elizabeth / McArdle / Pepco Holdings, Inc. / WEQ / Transmission Owner
Stacey / McPherson / Public Service Company of New Mexico / WEQ / Marketer/Broker
Megan / Miller / Spectra Energy / WGQ / Pipeline
Kellie / Parker / Southern Star Central Gas Pipeline / WGQ / Pipeline
Matthew / Peterson / Regulatory Economic Group LLC / N/A / N/A
Eric / Raible / LG&E and KU Energy LLC / WEQ / Transmission Owner
Sara / Rogers / ONEOK Partners GP, LLC / WGQ / Pipeline
Gil / Rosado / ConEdison Company of New York / WGQ / LDC
Leigh / Spangler / Latitude Technologies / WGQ / Services
Ryan / Strean / Xcel Energy Inc. / WEQ / Marketer/Broker
Tony / Suarez / TVA / WEQ / Marketer/Broker
Gerald / Thomas / FERC / N/A / N/A
Kathy / Thornton / Enbridge (U.S.) Inc. / WGQ / Pipeline
Caroline / Trum / NAESB / N/A / N/A
Peri / Ulrey / Natural Gas Supply Association / WGQ / Producers
Tommy / Waggoner / Southern Company / WEQ / Generator
John / Waggoner / ISO New England / WEQ / IGO
Colin / Walcavich / National Grid / WEQ / Transmission Owner
Kathy / York / TVA / WEQ / Generation
Randy / Young / Boardwalk Pipeline Partners LP / WGQ / Pipeline

*Please note that attendees that did not provide their name are not included in the attendance list above. If you did attend this meeting and are not listed, please contact the NAESB office, and we will update this record.

WEQ/WGQ FERC Forms Subcommittee Draft Meeting Minutes – September 14, 2015

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