When submitting a Tariff Record Version (TRV) to FERC in an eTariff Filing, the Description and Version fields are required (must have a non-blank value) and the Title field is optional (may have a blank value). The combination of these three fields is commonly used by FERC in official correspondence to refer to a specific tariff record submission. Therefore, in order for FERC to be able to rely on these fields as a point of reference, the combination of the three values must be unique within a Tariff Database (which FERC refers to as Tariff ID).
FERC’s software does not enforce the rule above (though it could be made to do so at some point in the future). Instead, it is up to FERC analysts to detect these situations and enforce uniqueness of Description, Title, and Version. To date, either by design or by accident, staff’s detection and enforcement of these situations has not been happening with any regularity.
To avoid such situation, TariffShark enforces this rule via a combination of two different validations.
During Filing validation, if any of a Filing’s TRVs is found to contain a Version value that matches one already filed under the same Tariff Record (TR), fail message R011 results:
Filed Tariff Record Version “” has been previously filed with this version number.
During Filing validation, if any of a Filing’s TRVs is found to contain a combination of Description and Title values that match the values under a different TR, warning message R044 results:
Generally, the combination of a Tariff Record Version’s Description and Title must uniquely identify the record being filed. This Filing contains Tariff Record Version ““, which could be confused with ““. Submitting the Filing as is might result in a FERC rejection or instructive order to update the Description or Title to better distinguish these records.
If you have any questions or comments relating TariffShark’s Filing validation rules, we’d love to hear from you. Please comment below or contact Support.