Additional EQR Filing Costs Expected for 2012

At the July EQR Users Workshop, we learned that FERC is gearing up to completely renovate their EQR filing system. The application that is currently used (Microsoft Visual FoxPro) has reached the end of its life due to age; it is having stability and capacity issues; and Microsoft is only planning to support it for a few more years. FERC is proposing a new XML application system entitled “EQR Validation with XSD.” XSD stands for XML Schema Definition.  The application is somewhat similar to the XML application used for E-Tariff filings.  We were told that there will be a free web application available to download; however, this web application should only be used for the most basic filings (e.g., less than 200 transactions) because everything will need to be manually entered.  Software to load the XML packages with EQR data will need to be either developed by the filers' internal IT departments or filers will need to procure the software from third party vendors.  Thus, the changes for filers with larger EQR filings will be significant.

FERC is planning on releasing a prototype of the XSD application as soon as possible and it will release the final XSD application in January 2012.  FERC plans to require companies to begin using either the new XSD application or the web application for the first quarter filings due in April 2012. The software required for this XML application may place a large financial burden on companies that have larger EQR filings in terms of developing and testing the software or procuring the software from vendors. At the workshop, there was a lot of opposition in terms of the timeline and its financial impacts and it looks to be a hotly contested issue in the coming months. We will report on the future comment dates and further workshops as they are announced by FERC.

For more information, please contact Toni Frost at This e-mail address is being protected from spambots. You need JavaScript enabled to view it or 202-296-1500.