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Troubleshooting the Asset Appendix

Since the Federal Energy Regulatory Commission (FERC) issued Order 860 in 2021, market-based rate (MBR) sellers must report an asset appendix that offers the Commission a transparent perspective on each entity’s market power in wholesale electricity markets. This appendix typically includes detailed information about the assets owned or controlled by the applicant, which may include generating facilities, transmission assets, contracts, and other resources.


MBR sellers must ensure that the information provided to the FERC remains accurate and up-to-date, reflecting any changes in their asset ownership or control that could affect their market power assessment.


Customers regularly reach out to Systrends for support troubleshooting the asset appendix. Let’s walk through a few of the most common issues…


 

Missing Affiliates


When GenAssets don’t appear in your FERC asset appendix, start by reviewing your Entities-to-Entities and Start Dates.


At the foundation of the asset appendix is the “UUA”, or the ultimate upstream affiliate. All entities that share a UUA are linked in the asset appendix. Naturally, if an organization’s asset appendix is missing entities, begin by reviewing (and correcting) the UUAs reported for each missing affiliate.


If you’ve confirmed all affiliates share the proper UUA and the issue persists, turn to the relationship start dates in both the Entities-to-Entities and Entities-to-GenAssets data tables.  

Most often, confusion relates to a timing mismatch. The asset appendix will only show “current” affiliation, not future. So, if any of your relationship start dates have a future date, then it will not appear until that relationship start date has arrived. Note, however, that you are required to report generator assets not yet in operation. If you own the asset, you should report it.


If a seller is developing a generation asset that is not yet in service, enter the Commercial Operation Date (COD) as the relationship start date. If the COD is a date in the future, the generator asset will not appear in the asset appendix until that date. If a seller acquires a generator that is already in service, then you use the date of the contractual agreement as the start date.

 

MBR Portal Asset Appendix


Improper Affiliation


If you review your company’s asset appendix report and notice one or more entities are listed that should not be part of the organizational structure, it could be due to the other entities’ UUA data. Locate the CID of the entity that should not be part of the asset appendix and review their submitted Entities-to-Entities data. Contact the company (or FERC MBR staff) to see if the same UUA you and the other entity reported is correct. If the other entity agrees they reported a UUA they should not have, then they need to make a correction to deactivate the UUA with a relationship end date.


Alternatively, sellers often misreport their affiliation with investment firms with a Blanket Authorization Docket, like Vanguard and Blackrock. The FERC requires each entity reports investment firms with greater than 10% ownership stock by reporting each firm’s LEI in the “Reportable Entity ID” field and their corresponding docket number in the “Blanket Auth Docket Number” field, then inserting the entity’s CID in the “Utility ID” field. This mechanism allows the Commission to associate all entities with minority ownership positions from major financial institutions without linking them together in an asset appendix. However, entities may incorrectly report investment firms as a UUA, which can muddy the asset appendix. If you find this to be the case, chances are either you or the other entity reported it incorrectly and one will need to fix the submission before the asset appendix is accurate.


 

Locating the Asset Appendix Serial Number


The “AASN”, or the asset appendix serial number, is a unique identifier assigned to the asset appendix after each filing, which helps distinguish and track the specific asset appendix based on the last update submitted. In other words, each time a submission is made to the relational database, a new AASN is generated for the entity’s asset appendix. When you need to locate the AASN, there are a few ways to find it.


AASNs are populated in FERC acceptance emails. If you cannot find the most recent acceptance email, then you can log into the FERC MBR Portal and click on the “Asset Appendix Serial Numbers” menu option to locate it on that page.


If you need to reference an entity’s AASN for an eTariff Change in Status filing but your latest AASN is more than 15 days old, you can generate a fresh AASN on the Asset Appendix Serial Number page in FERC MBR portal. You do not have to make an MBR submission to obtain a recent AASN. However, if you have an update to submit to the relational database that should be done before the eTariff filing, then you will receive a current ASSN through the acceptance email.


A list of historical AASNs for every entity can be found in the MBR Reports section of the portal. The Asset Appendix Repository report details all AASNs ever generated for an entity that is searched.


When you need to view the actual asset appendix report that is generated by the relational database, use the Latest Asset Appendices report in the Portal located in the MBR Reports section.

 



The FERC MBR Asset Appendix can be confusing! Don’t hesitate to reach out to Systrends if we can help.

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