In last week’s blog article, eTariff Filing Level Associations, we introduced nine broad filing type categories. This article will use the same broad categories to answer the question “does my eTariff filing have to include tariff records”?
Normal – A “normal” filing generally initiates a statutory action against an existing eTariff. As such, proposed changes to an electronic FERC tariff would be made by submitting tariff records.
New – A “new” filing establishes a new Tariff Id (FERC’s term for what TariffShark calls a Tariff Database). This type of filing must include tariff records.
Refiled – Like a “new” filing, a “refiled” filing establishes a new Tariff Id. This type of filing must include tariff records.
Compliance – The circumstances surrounding a “compliance” type filing vary greatly. Some compliance filings will include tariff records and some will not.
Amendment – An “amendment” filing proposes changes to an earlier eTariff filing pending before the Commission. What’s being amended in a amendment filing are tariff records. Therefore, this type of filing must include tariff records.
Motion – A “motion” filing motions into effect tariff record from an earlier eTariff filing. Therefore, tariff records must be included in a motion filing. In order to add tariff records from an earlier filing to a “motion” filing, the Filed Tariff Record Versions in the earlier filing must have a FERC Response of Suspended”.
Withdraw – The sole purpose of a “withdraw” type filing is to withdraw an earlier eTariff filing pending before the Commission. A withdraw type filing must not include tariff records.
Report – Similar to an “amendment” filing, a “report” filing is used to supplement the record of an earlier eTariff filing pending before the Commission. Unlike the “amendment” type, however, a report type consists solely of attachments. Statutory tariff records are not allowed in this type of filing. It is valid, however, to include pro forma tariff records within a “report” filing.
Cancellation – A “cancellation” filing proposed to cancel an entire Tariff Id (FERC’s term for what TariffShark calls a Tariff Database). A cancellation filing must include a single tariff record, which carries the proposed effective date of the cancellation.
To summarize…
| Type of Filing | Includes Tariff Records? |
|---|---|
| Normal | Always |
| New | Always |
| Refiled | Always |
| Compliance | Sometimes |
| Amendment | Always |
| Motion | Always |
| Withdraw | Never |
| Report | Pro Forma Only |
| Cancellation | Exactly 1 |
If you would like to know more including tariff records in your eTariff filings or if you have any other questions, please comment below or contact TariffShark Support.
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