FERC has a database of electronic tariffs plus software that staff members use to fulfill the Commission’s eTariff obligations. It is important that the FERC database and your TariffShark database contain the same tariff information.
Some changes to eTariff data are initiated within TariffShark (for example, proposed changes to tariff content). When such changes are submitted to FERC via the eTariff filing process, that data ends up in FERC’s eTariff database. In other words, essentially, FERC’s database is updated as a direct result of you submitting an eTariff filing.
Other changes to eTariff data are initiated by the Commission (for example, the assignment of a docket number or the approval of a proposed change to tariff language). Unlike the submission of an eTariff to FERC, which arrives at the Commission in a computer-friendly XML format, changes that FERC makes to the data are communicated the old-fashioned way: via email and Commission order. This manual communication means that it is up to you, the TariffShark user, to manually update the data in TariffShark so that it reflects FERC actions.
What Data Changes Result from FERC Action?
When an eTariff filing has been accepted by the Commission, you will receive an email with the subject “FERC Acceptance for Filing in [DOCKETS]”. Upon receipt of this email, the Filing Status should be updated to “Filed”.
After a statutory period elapses or after FERC issues an order in response to a Filing, the Filing Status should be updated to “Complete”.
Refer to this TariffShark Blog article to learn more about Filing Status.
FERC Order Date
You may record the date of FERC’s order issued in response to your Filing in the FERC Order Date field. This is informational only within TariffShark as there is no business logic or validations that depend upon it.
When you receive the FERC email with the subject “FERC Acceptance for Filing in [DOCKETS]” for your Filing, it will contain the docket number. You may record this data in the Docket Number field, which is informational only in TariffShark (no business logic or validations depend upon it).
FERC Effective Date
A FERC order issued in response to an eTariff Filing may accept the tariff records’ proposed effective dates … or it may specify FERC-mandated effective dates (for example, when suspending a Filing). It is important that the effective dates accepted or mandated by FERC be recorded in TariffShark.
Tariff Record Versions in a Filing start out as “Draft” FERC Response in TariffShark. When a Filing is marked with a Status of “Filed”, the Filing’s Tariff Record Versions acquire a “Pending” FERC Response. At the end of the appropriate statutory period or when FERC issues its order (which is when the Filing Status should be updated to “Complete”), the FERC Response of each Tariff Record Version in a Filing must be updated appropriately. Example values for FERC Response are “Approved”, “Rejected”, and “Suspended”.
Refer to this TariffShark Blog article to learn more about TariffShark’s FERC Response field.
Why Is It Important to Update the FERC Data in TariffShark?
Filing Status and the FERC Response recorded on your Filings’ Tariff Record Versions play a critical role in TariffShark’s Filing validations. If these data values in TariffShark do not reflect their values in FERC’s eTariff system, when TariffShark performs its Filing validations, it could report a false validation error or miss a validation error altogether. An example of each is provided below.
False Validation Error Example
Validation Rule ID F019 – “When making an Withdrawal filing, the associated filing must have a status of “Filed” thus indicating that FERC has not yet acted upon it.”
If you left the Status of a Filing as “Draft” or if you prematurely updated the Status to “Complete”, this validation error will result when you attempt to withdraw the Filing.
Missed Validation Error Example
Validation Rule ID R009 – “Regarding : There is more than one version of this Tariff Record filed with an effective date of FTRV.ProposedEffectiveDate. In the event that FERC approves these, a unique priority must be assigned to each.”
When more than one version of a Tariff Record is filed with the same effective date, a unique effective priority must be assigned to each. TariffShark is not able to provide this feedback and alert you to potential effective priority value ambiguity if FERC Response values haven’t been updated accurately.
If you have questions about Filing Status, FERC Response or other FERC-related TariffShark data fields, we’d love to hear from you. Please comment below or contact TariffShark Support.