OMB should reject EIA's proposal to require hourly operating data from balancing authorities, APPA says
Originally published January 29, 2014
APPA generally supports most of the revisions the Energy Information Administration has proposed making to its existing survey forms for electric utilities, including EIA-861 and EIA-861S, the association told the White House Office of Management and Budget. However, OMB should say no to the creation of a new form, EIA-930, under which the Energy Information Administration would collect hourly electric power operating data from balancing authorities, APPA said in comments filed with OMB on Jan. 23.
The EIA proposal for Form 930 "would create an excessive time burden for balancing authorities and would make sensitive information publicly available in near real-time," APPA told OMB.
Under the EIA proposal, balancing authorities would be required to submit hourly demand data on a web portal within 10 minutes of the end of the reporting hour and would have to post other hourly information by 7 a.m. the next business day, APPA said. "Posting this hourly information in near real-time poses serious data confidentiality concerns and may also lead to the exercise of market power against small load-serving balancing authorities."
"No business case has been made to justify the release of this information in real-time or near real-time," APPA said.
The EIA has argued that it needs this information to help policymakers develop innovative demand response and variable energy resource policies.
"Setting aside the question of whether these data are necessary for this purpose, APPA does not see why it is necessary to have this data published publicly in near real-time," the association said. "Even if EIA were to collect the information on an hourly basis, it could share the data with select interested parties and other key policymakers without revealing all of the data to the wide world," APPA said. "Think tanks, academic institutions and other analysts could then have access to the data after an appropriate period of time has elapsed."
OMB "should deny approval for this form and encourage EIA to convene industry-wide working sessions to identify data that are most likely to be useful, less burdensome alternatives for collecting the data, and ways to address commercial and security concerns," APPA said.
If OMB grants the EIA approval to move ahead with Form 930, it should allow a reasonable amount of time before balancing authorities must begin implementing the new requirements, APPA said.
The EIA has suggested that it would make March 1 the start date. "Considering that OMB will not be able to grant approval for this form until almost this exact date, this is a preposterously short time frame for would-be filers to implement their systems," APPA said. The association noted that when the Federal Energy Regulatory Commission expanded filing requirements for FERC's electric quarterly reports, the commission waited nearly a year before mandating that utilities comply with the new requirements.
In other comments regarding changes the EIA has proposed to its survey forms, APPA noted that a slight majority of public power utilities will now be eligible to complete the shorter EIA-861S instead of the longer EIA-861. APPA asked OMB to urge the EIA to add fields for respondents to provide the number of customers for each sector (residential, commercial and industrial). "This is readily available information that should not add any time burden," APPA said. "This information would allow industry analysts to observe any notable changes in the size and makup of smaller utilities without waiting five years for those utilities to report their complete information."
APPA thanked the EIA for its "willingness to listen to industry input, and to make revisions to its proposals where necessary."
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