Who should submit a baselineQF: As November 2, 2021 looms (and is far scarier than Halloween), QF and DER owners may be asking, “What am I worried about?” But the impending deadline for the reference submissions of Order # 860 may have an impact some QF and some DER. Although it may be almost too late for those who are subject to, but are unaware of their obligations, to do timely For Submission 860 of the Ordinance, action can be taken now by QFs and DERs with the Market Based Rates (MBR) authority.
For various reasons, some QFs have the power of MBR: they can no longer sell under PURPA and are too large to be exempt from the regulation of Section 205 of the FPA; they can have the authority of the MBR as a security measure in case they do not comply with the QF; they may fear losing QF status due to changes in the 1 mile rule; among other reasons. With regard to DERs, while many DERs are renewable energies and sized to be exempt from FPA Section 205 regulation and therefore from order no.860, some DERs, such as autonomous storage in front of the meter, will be “sellers” with the order number. .860 commitments. Determining if a QF or DER has an order requirement # 860 is straightforward, does the entity that owns / controls the asset have an MBR tariff on file? If so, there is a basic obligation of Ordinance 860, even if the entity has never made a sale subject to the regulation of Section 205 of the FPA. FERC maintains a list of entities with MBR on this page (look to the right of the page for a link to “electric utilities with an approved tariff authority based on market (including contact details)”).
For QF / DERs who belatedly realize that they have an order obligation no.860, if they cannot gather the data required by order no.860 and learn to submit them in two weeks, an extension request may be an option. Some QFs, especially those whose sales are all exempt under 18 CFR 292.601, may wish to reconsider whether they need MBR clearance and seek to cancel their MBR tariffs effective November 1, 2021. or before. While this seller may be technically non-compliant with Order 860, as long as the Commission grants the cancellation date, FERC may choose not to require compliance between November 2sd and the effective date of the cancellation. (This option applies to anyone with an unnecessary or unused MBR tariff.) Other issues with order number 860 regarding QFs and DERs are discussed below.
QF with MBR tariffs and order number 860 Firm long term sales data. If a QF is a seller with an order requirement # 860, their most important determination is whether their long-term firm sales, if any, should be reported. The answer is yes, unless the sales are made under PURPA (“made under PURPA” would apparently include exempt sales made under 18 CFR 292.601). While a QF’s PPA may better indicate whether its sales are made under PURPA, QFs with MBR tariffs would likely have to “marry” their order number 860 and EQR reports. A disconnect between the two would be evident in an audit situation.
Data obligations for long-term firm purchases from QFs and DERs. As reporting sellers who make long-term outright purchases from QF and DER, they can save a lot of time and effort if: 1) they know whether QFs and DERs selling them farm electricity at long term sell such potency under PURPA (as opposed to Section 205 of the FPA); or 2) their purchases can be treated as behind-the-counter purchases. Long-term firm purchases do not need to be reported by sellers if the sale is under PURPA or considered to be behind the meter. Checking if a QF is selling under PURPA can be as easy as checking that the seller does not have an MBR tariff. If a QF seller has an MBR rate, again EQR is a logical place to determine if the seller considers a sale to be reported to FERC. As for DERs that are not also QFs (probably a small minority of DERs), those that do not have MBR tariffs are likely engaged in a net metering program where energy is not purchased at all; all sales are subject to PURPA; and / or there is no firm long-term purchase anyway.
Data obligations for sellers whose production portfolios include QFs and DERs. Sellers with both large and small production portfolios, especially sellers who are also transport owners, often have no reason to gain QF status for the small producers they own and who might be. qualified from QF. For example, these Vendors can install PV in their own substations. Some vendors own and lease 1 MW and smaller renewable resources which are QFs. As these sellers fill out their production asset data for Order # 860, they need to know if they can omit some under-meter production exemptions or QF asset reporting exemptions, thus saving money. time and resources. Presumably, such a generation has always been omitted from asset schedules in the past, but Order # 860 should prompt a closer look at what is excluded, as the more assets to report, the greater the burden of statement for the seller is high.
A final note. As with the deployment of EQR and eTariff, Order # 860 itself remains a work in progress. Salespeople need to be patient as the system evolves and data collection “rules” are more fully documented. As discussed above, there is numerous nuances in the collection of data, even in the small corner of decree n ° 860 relating to QF and DER. Additionally, as the first status and triennial changes are submitted, the asset schedules generated by FERC may not resemble the previously submitted asset schedules until further improvements are made. by the Commission. For example, an asset schedule that includes the same exact vertical asset multiple times should not be a cause for alarm, as the data collection process requires all common property sellers to report certain vertical assets.