February 24, 2021 | 2 minute read


By August 2, 2021, Market-Based Rate (“MBR”) sellers had to populate, organize, and update their asset appendix information in a new database to comply with the Federal Energy Regulatory Commission’s (“FERC”) Order No. 860.  A test sandbox for exploring features and understanding the new system became available and FERC’s live database became available for actual compliance submittals beginning April 1, 2021.  The new relational database replaced the current Excel forms used to submit asset appendices to FERC.  

Bracewell LLP’s 30-minute webinar provided an overview of the new requirements, how the new system will work, and how MBR sellers could begin to prepare. The webinar took place from 1 – 1:30 p.m. CT on Tuesday, March 4, 2021. 

Among other topics, the webinar covered:
•             Changes implemented through FERC Order Nos. 860 and 861;
•             How the new relational database will function;
•             Implementation deadlines;
•             What companies can do to prepare; and
•             How sellers will use the database when making future filings. 

Further Information on FERC Order No. 860:
In 2019, FERC issued Order No. 860, requiring MBR Sellers to submit market, asset, and ownership information in .XML format to a new relational database (similar to eTariff filings). The purpose of the relational database is to streamline the market information reporting process currently accomplished through Excel-based asset appendices while allowing for greater transparency.

By August 2, 2021, companies seeking to obtain or retain MBR authority were required to submit much of the same information included in the current Excel form, organized according to a newly published data dictionary compatible with the new database.  Ultimately, FERC intended the relational database to reduce Sellers’ reporting burden and make market information more accessible to FERC staff.  Once the relational database was functional, it automatically cross-referenced data regarding related assets and generated an asset appendix. While the relational database was expected to make MBR reporting less onerous over time, these initial filings required careful preparation.  

Bracewell is committed to assisting clients to prepare for and comply with Order 860.