Jan 21 eTariff Technical Conference Recap

Links Technology attended the FERC eTariff technical conference on January 21, 2011.  Even though many of you participated via phone, we thought it would be helpful to share our notes.

Contents

Agenda Item 1: Adding CFR Citation to Type of Filing CSV

FERC staff indicated that a new “citation” column would be added as the last column in the Type of Filing CSV. The reason for the citation reference is to aid tariff filers in selecting the type of filing to submit. This new data will be added to the existing rows in the CSV. A time line for availability was not provided. Once FERC makes this data available to us, we will incorporate it into TariffShark.

Agenda Item 2: eTariff Viewer Export Function

FERC is adding a feature to the eTariff Viewer that will enable tariff metadata and content to be downloaded in an XML format. This feature is still under development. A preliminary XML schema was provided for the conference and reviewed. Minor changes to the schema are likely based on the discussion.

At this time, FERC is strictly offering an interactive facility for downloading tariff data. It has not been designed to facilitate the automatic download of tariff data via software.

A rough time line for completion was provided. FERC is currently continuing its development and testing of the feature. Then it will be released as a Beta. FERC expects the feature to be official and live by March 31, 2011.

Agenda Item 3: Updated Descriptions in Type of Filing CSV

Under the Federal Power Act Electric (Market Based Rate) Public Utilities program, the description of filing type 1120 was updated from “Market Based Rate Request and Triennial Reveiw” to “Market Based Rate Triennial Reveiw” (misspelling care of FERC).

Under the Federal Power Act Electric (Traditional Cost of Service and Market Based Rates) Public Utilities program, the description of filing type 1150 was updated from “Market Based Rate Request and Triennial Reveiw” to “Market Based Rate Triennial Reveiw” (misspelling care of FERC).

In both cases, the change is merely to the description. There were no changes to how these filing types are treated or processed by FERC.

We will incorporate these changes into an intermediate release of TariffShark. We plan to do this at the same time as the changes relating to Agenda Item 1 above.

Agenda Item 4: Lessons Learned

  • When making a co-applicant filing, follow these steps:
    • ISO logs in to submit filing
    • ISO uploads XML
    • ISO adds co-applicants (note that only companies who have completed FERC company registration may be added)
  • Tariff filers are responsible for their service list. FERC will not create a service list based on information provided in a transmittal letter.
    • In the FERC web page provided as you submit your filing, you may add as many names to the service list as you like (note that only people who have eRegistered may be added)
    • Applicant and co-applicants are automatically added to the service list
    • FERC recommends regular use of the eTariff sandbox. It can be a quick way to get preliminary feedback on whether or not your filing will pass FERC validations. If your computer is configured to easily send your filing XML to the sandbox, it can be quicker than making an official submission as there are no web forms to fill out. Be mindful of the fact that the sandbox is not secure. Filings that you submit into the sandbox are not encrypted as they travel from your computer to FERC’s.
    • When you submit an eTariff filing, you should receive a confirmation email within a minute or so. Shortly thereafter, usually after just a few minutes, you should receive an acceptance or rejection email. If you do not receive such an email after a couple of hours, forward your confirmation email to etariff@ferc.gov inquiring as to the status of your filing. FERC’s software and systems have gotten better and better since eTariff went into effect on April 1, 2010, but an occasional filing can still get lost in the shuffle. At the conference, FERC staff urged filers to follow up with them when things don’t seem to be working right.
    • FERC has received a lot of filings where the “effective priority” field was not populated correctly. We can only assume these came from non-TariffShark filers. 🙂 FERC passed along an excellent related tip. If you find yourself having to set the effective priority frequently for certain sections of your tariff, you might consider breaking the section into smaller pieces as this will spread the frequent filing activity across multiple records and reduce the likelihood of having to set an effective priority.
  • For a tariff record, Version numbers must be unique.
    • You cannot submit a tariff record multiple times with the same Version.
    • Though it is not specifically required, when submitting the same record multiple times in the same filing via Option sets (which is rarely done), use different Version numbers on the record in each Option set. This suggestion comes about from the fact that FERC refers to submitted records in correspondence using their Description, Title, and Version. If the same Version is used in each Option set, it will not be clear which record is being referenced.
  • Within the content of a tariff record, if a reference is made to another tariff record, the other tariff record’s Description and Title must match the textual reference. This is especially true of tariff records that represent tables of contents.
  • If you need to file a correction to a Filing, use an Amendment type to correct statutory filings and use a Compliance type to correct compliance filings.
  • Statutory filings may be amended multiple times. In a complex scenario, the amendment filings can themselves be amended, thus creating something of an “amendment chain” (a bunch of related filings). As these filings are all extensions of the original filing, if you submit a withdrawal of any filing in the amendment chain, the entire proceeding will be withdrawn.
  • RTF Challenges – Microsoft Word is a very powerful word processor and can save all kinds of content in a RTF file. FERC has found that some types of content are not compatible with their systems and software.
    • Tariff filers have found that an RTF with an embedded image tends to be a VERY large file, often times too large to submit. FERC staff instructed that the latest version of Word 2007 saves such files as much smaller RTFs. If you’re running the latest Microsoft Word software, RTFs submitted with embedded images in 2011 and beyond should not be subject to this file size problem. Such RTFs even display fine in the eTariff Viewer.
    • FERC’s internal software for viewing and reviewing eTariff filings doesn’t contain the latest capabilities for viewing content…this remains a bit of a struggle. When content doesn’t look “right”, FERC analysts have been instructed to look at the content in the eTariff Viewer and in eLibrary.
    • Word Features to Avoid
      • Avoid automatic content (paragraph numbering, footnotes are two examples).
      • Never use text boxes.
      • Avoid complex tables (fancy fancy styling, cell merging and splitting, font orientation). Keep tables simple.
      • Keep Word styles simple. Use WordPad to view your RTF content to view your help identify potential issues.
      • Do not use drawing/diagramming objects. Instead, insert drawings as an image.
      • Do not embed Excel worksheets (insert as an image).
  • PDFs
    • Scanned PDFs must be OCR’d, which makes them searchable when opened in a PDF viewer.
    • Large tariff documents that are broken into pieces (sections or sheets) must be submitted in RTF format. This is nothing new, but it was reiterated at the conference.

Finally, as a side note…

From a timing standpoint, a filing is stamped as having been received when the XML file upload completes. This means that you may take your time with the subsequent screens in the filing process (e.g. adding co-applicants and parties to the service list).

If we missed anything that you caught at the technical conference or if your notes don’t quite match ours, please use the comments below to discuss.