Resources Frequently Asked Questions (FAQs)
1. Who must file the FERC-580?
The information in the previous paragraph determines who must file. If based on this information, your utility is required to file it must report in this form the information requested for steam-electric generating stations regardless of percentage interest owned in them.
2. If a question is not applicable to our client should the question be left blank or should N/A be entered in the data field?
3. What is the proper docket number for the FERC Form 580 filing?
4. Can we submit our FERC Form 580 information in zipped files?
5. When the FERC Form 580 mentions the Commission it is my understanding that it is referring to the Federal Regulatory Energy Commission and not any state commissions. Therefore, only utilities with an AAC on file with the Commission (meaning FERC) are required to file the form. Is this a correct interpretation?
Yes. Commission refers to the Federal Energy Regulatory Commission and utilities required to file the FERC Form 580 are all FERC-jurisdictional utilities owning and/or operating at least one steam-electric generating station of 50 MW of greater capacity, or having a majority ownership interest in a jointly-owned steam-electric generating station of at least 50 MW or greater capacity and that had a cost-based tariff on file with the Commission during the reporting period.
6. What is an Automatic Adjustment Clause (AAC)?
Many rate schedules contain provisions for adjustments to rates based on changes in one or more elements of the cost incurred to provide the service. A utility calculates adjustments using procedures that have had prior regulatory approval. Where such adjustments in charges are permitted to occur automatically, without specific regulatory review of each adjustment, the rate schedule provisions are referred to as automatic adjustment clauses.
Many of the wholesale electric rate schedules public utilities file with the Commission contain provisions for automatic adjustment of rates. Current Commission policy permits acceptance of these types of energy cost rates, as well as comprehensive cost-of-service formula rates. These types of rates adjust automatically. The effect of the clause may be reflected in rates charged by the utility without notification to or filing with the Commission.
These types of automatic adjustment clauses correspond to the definition of AAC in the Public Utility Regulatory Policies Act of 1978 (PURPA). What was not included in this definition were so-called periodic review-of-rate clauses, where the Commission has routinely required filing of changes in rates pursuant to implementation of a review-of-rate clause.
A rate that may be subject to an after-the-fact public true-up proceeding and/or later refund is a rate that is not subject to prior hearing; a rate that adjusts only subject to after-the-fact review, and not prior review, is a rate that can and should be legitimately considered an automatic adjustment clause.
7. How does a filer delete a row of data that is not the last row they added? In other words, for question 2a, if they entered fifty rows of data and discover that the fifth row has data in it that they don’t want or need to report, how do they delete it?
8. If a company has an AAC but the formula produces a negative number (it is actually a credit to customers rather than a charge), does the company still complete all of FERC Form 580 or is there an exception where only AAC charges as opposed to credits elicit the reporting requirement?
9. When is our FERC Form 580 filing due?
10. What do I file in the FERC Form 580?
11. How should I name my electronic files?
You may if you wish, abbreviate your utility name.
Name your privileged interrogatory as: PRIVUtilityName2016Form580.pdf
12. How do I file a revised FERC Form 580?
The respondent should include a cover letter with the eFiled revision explaining the circumstances that required the revision.
13. Is the electronic form required in order to complete my 2016 FERC Form 580 filing?
14. May I ask the Commission to treat my responses to the FERC Form 580 as privileged?
15. How do I eFile my FERC Form 580?
- Start at the Commission's home page: www.ferc.gov.
- Select the Documents & Filing tab
- Selec eFiling from the drop-down.
- Select Log In.
- Select efiling.
» If you have not previously eRegistered, select the eRegister link and provide the requested information in order to create an account, otherwise, enter your registered email address and password.
Select Electric in the first column. Select Report / Form for existing docket number (Report / Form should show in the third column).
» Select Next.
» Select Docket - Enter docket number IN79-6 and select Search. The docket number will show in a new table. The plus sign in the Select column and a selected dockets row will drop down.
NOTE: if at any time you want to go back to a previous screen, select the back button provided on the eFiling screen, not the back button in the browser.
» Select Next.
Select the Public tab, then select Browse and designate a public file to upload. Enter a description in the space below the file name. Select Upload. Continue doing this until all your public files appear in the file upload table. Select the Privileged tab, then select Browse to upload your privileged file, enter a file description and select Upload. The eFiling system allows you to attach up to 200 files.
There must be at least one public file for each privileged submission. This can be your cover letter describing the filing and asking for privileged treatment.
Note: Use PRIV as the first four characters of the file name for a privileged file to avoid uploading a file with the wrong security level.
There is a feature at the bottom of the file upload table to change the security designation if the file wasn't uploaded as privileged and should have been.
When FERC accepts a filing with multiple security classes, the system puts the files under different accession numbers and links them as document components in eLibrary so eFile the privileged and public files during the same session and they will be linked in eLibrary.
» Select Next at the bottom of the screen.
Specify Filing Parties
Select either On behalf of another Party(ies) and enter the company name below or As an Individual, whichever applies.
» Select Next.
Specify the person to whom communication should be addressed
Enter your email address in the contact email block and select Add as Signer or Add as Other Contact. Note: a signer email address must be included as every filing must have a designated signer.
Enter Form 580 of [your utility name].
Review the information shown. Ensure the file labeled privileged has the correct security level chosen. If any of the information is incorrect, select the Back button and correct your information as necessary. Select Submit.
A new screen will appear that states: You have successfully submitted the filing and will receive an email confirmation shortly. Select the Printable submission confirmation receipt button and a receipt will appear that states the date, time and submission ID for your filing. You should also receive a confirmation of receipt by email with the same information, a link to additional information for your filing and the status of your filing. When the Commission accepts your filing, that status will change to accepted.
16. How can I get a copy of FERC Form 580s my utility previously filed?
» Select on General Search.
» Enter a date range for the filing.
» Under the Class/Type dropdown, select Form 580.
» Enter all or part of your utility's name in the Text Search Box and
» Select Search.
A list of your filings will provide links to your documents submitted.
17. In completing our FERC Form 580 filing due this year, for jointly-owned generating stations for which our company is the operator, should we report 100% of the expenses and other information (including the other joint owners' expenses and statistics) or just the expenses and statistics relating to our company's ownership percentage?
18. I am receiving many error messages when entering information into the form. The form will not allow adding reporting year in question 6a. The form is not saving the contract names I entered. What is wrong?
19. What does CFR mean?
20. I still have questions. Who do I ask?
21. If we do not have any rate schedules with a wholesale automatic adjustment clause do we leave question 2 blank?
Yes, in this case, leave question 2 blank.
22. In some cases our agreements go back to 1967 or before and do not have FERC docket numbers but Federal Power Commission (FPC) numbers. In addition, the documents predate eLibrary. In these cases should we report the FPC numbers in question 2?
Either the FPC or FERC docket numbers are fine. However, the FPC docket number is preferred in these cases. We also prefer to have the docket number of the very first rate schedule filing.
23. If a rate schedule with an AAC was first filed before 1990, but since then has been refiled in its entirety, do we need to attach a copy of it for question 2?
No, in this case you do not need to attach a copy of the rate schedule. If the rate schedule has been re-filed in its entirety since 1990, but certain sheets have been amended since then, you still do not have to file the rate schedule or amended sheets with your FERC Form 580.
24. Our company has IPP contracts with power plants owned by other companies. We do not supply the fuel via a long-term contract. Each power plant is supplied by short term gas supply (spot and day-ahead markets). Do we need to report on those IPP contracts in FERC Form 580 questions 6a & 6b?
25. Can you confirm that for question 3, the utility completing FERC Form 580 should only include QF and IPP contract information?
26. Why can I not enter information for only energy charges AND all purchased power costs for any one particular purchase?
27. Where can I find a list of our utility's QF and IPP purchases?
28. Is the Commission looking for information detailing all of our customer owned generation contracts from which we purchase energy that is injected into our distribution system?
Note: FERC is asking for information regarding QF and IPP purchases only. Hover with your cursor over the cell below the column labeled Year to see the message supporting this. The desk reference also states this.
29. Are the questions in the columns under All purchased power costs only relevant to fuel adjustment clauses (FACs)?
30. What is meant by system reserve capacity requirement?
31. What is a system operator?
32. What is meant by the question: Did the AAC used for cost recovery, include the system reserve capacity criteria by which the system operator decides whether a reliability purchase is required?
33. Where can I find an example of system reserve capacity criteria in a tariff?
34. If purchased power was wind generated, what do you mean by: was the avoided cost comparison done on a contract-by-contract basis?
35. Can you provide guidance as to how often the utility needs to compare costs to determine if total purchased power costs were less than the total avoided variable costs?
36. Do we report net metering arrangements at the retail level e.g. small photovoltaic systems on homeowner’s roofs?
37. Question 4a does not appear to have a drop-down to select yes or no and I am unable to type the word no after the question. How should this be handled?
38. In question 4b, are you looking for only specific mechanisms for emission allowance cost recovery, or do you want to know if those costs are being recovered via billing of customers?
39. What does origin of emission allowance cost mean? What are you looking for in response?
40. Question 4 asks for 2014 and 2015 costs that are recovered through an AAC. My utility's clause recoveries are not assessed as they are incurred. How do I determine which costs to report?
41. What is the definition of emission allowance?
This definition is based on Environmental Protection Agency regulations for specific air pollutants found in: 40 CFR 72.2, 96.102, 97.102, 96.202, 97.202, 96.302 and 97.302.
42. Our utility procures both coal and natural gas for generation. Is the Commission looking for responses regarding both coal and natural gas procurement?
43. How do we answer question 5 in a privileged format?
44. Are we required to submit a copy of our fuel procurement policies and practices?
45. If we do not specify impurity content in our contracts in question 6a, do we have to specify quality, including impurity content in our deliveries in question 6b?
46. Our utility has separate contracts for natural gas as a commodity and contracts with for natural gas transportation (pipelines). Question 6 provides dropdowns for gas supply contracts and gas transportation contracts. Which dropdowns do we use for each scenario?
47. Will you accept the FERC Form 580 with all 2014 contracts listed followed by all 2015 contracts listed?
48. What is the difference between fuel quantity in question 6a and fuel quantity in question 6b?
49. Is the intent that question 6 is limited to filers with fuel adjustment clauses or is it that question 6 is limited to filers with a fuel-related AAC?
50. We buy coal at the mines (FOB - Origin). My assumption is that we should report only the coal's fuel price - and NOT the transportation cost component in question 6, correct?
51. We have a few contracts in which impurity content is not specified. How should we indicate this in the form? Would inserting an N/A be acceptable?
52. Are there any circumstances under which we should be completing question 6 for no. 2 fuel oil?
53. If we have NAESB supply contracts that are evergreen, do we list each contract, by supplier, by plant and by pool?
54. Several years ago, we were allowed to file some of the price data that I believe was then in question 3, confidentially. Is that option still available?
55. If we leave blank rows (created by a deleted contract) will that cause a problem?
56. Is it acceptable to attach an Excel spreadsheet that provides the necessary information in lieu of typing it into the form?
57. Our utility has separate contracts for natural gas as a commodity and contracts with pipelines for the transportation of gas. Question 6 asks about fuel supply contracts, yet in the contract type section there are pull downs for both the gas supply and for gas transportation. We are confused about how to respond to this question and what is meant by gas transportation if it is not the pipeline contracts. Do we need to respond to this question for natural gas transportation contracts?
58. I am attempting to enter data for one contract with two years of delivery data. I cannot see any way to identify the delivery year in question 6b Delivered characteristics so I am creating a separate contract for each delivery year, even though there is only one actual contract. That way, I have the 2014 contract and the delivered characteristics for 2014, and the 2015 contract with its characteristics for 2015. Is this the correct method, or should I be doing something else?
For any given contract, for each of the two reporting years, fuel deliveries must be entered by destination plant. For example, for Contract A, in reporting year 2014, fuel delivery information in 6b must be entered for plants a, b c, etc.
Information is requested by:
59. We did not test the quality characteristics of the oil or gas we received via pipeline at the plant so we do not know what to enter in the quality characteristic cells in question 6.
60. Question 6b refers to consumed fuel. Do we enter information for delivered or consumed fuel?
61. Do I need to report contracts in question 6 for fuels where my utility has no fuel adjustment clause?
62. Is the destination plant dropdown to the right of the words destination plant and the type of purchase point dropdown below the text Type of Purchase Point?
63. Where do I enter the contract name in question 6c?
64. Should we exclude information from the answer to question 6 when purchases are made through the RTOs/ISOs, and the seller is unknown?
With regard to cost-based AACs for sales or energy at system incremental cost, FERC is interested in knowing about long-term purchases whose costs are specifically mentioned or included in an AAC. FERC does not want to know what purchases set system incremental costs.