What Is Effective Priority?
Originally, FERC created the tariff record Effective Priority field to be a tie breaker for when two versions of the same tariff record were submitted proposing the same effective date (presumably in separate filings, but more on this later). Should FERC approve both versions, the one with the higher Effective Priority value would be the one considered effective on the effective date.
The Effective Priority field must be populated for every tariff record in an eTariff filing and can have any numeric value between between 1 and roughly 2.1 billion (2,147,483,647 to be exact). TariffShark provides a default value suitable for most situations.
Though the practice is not specifically supported and is certainly discouraged by FERC staff, some eTariff filers have taken to submitting multiple versions of the same tariff record in the same filing. The most common reason this is done is to take content changes approved by the Commission on an earlier version of a tariff record and apply those changes to subsequent versions of the same tariff record. When multiple versions of the same tariff record are included in a filing, each must have a unique Effective Priority value regardless of the effective dates proposed on the records.
One of the highest priority goals for TariffShark is ease of use. Users (a) shouldn’t need to understand the complex rules surrounding Effective Priority described above and (b) shouldn’t need to concern themselves with populating a field with an arbitrary number. To that end, TariffShark is built with the intellligence to understand the rules described above.
For most filings, where Effective Priority doesn’t even come into play, you don’t need to do anything with it in TariffShark. On the occasions where Effective Priority needs to be populated in order to distinguish multiple versions of the same tariff record, TariffShark calls it to your attention.
While working on your filing in TariffShark, you may see the Set Effective Priority command in the SmartBar. It shows up only when it’s needed and, for most filing scenarios, a user will never see the command.
Clicking the command opens the Set Effective Priority form, which displays all conflicting versions of the tariff record in Effective Priority sequence. The form provides the ability to move the tariff record being filed up and down among the other tariff record versions until it is positioned where needed. TariffShark calculates an appropriate Effective Priority value and saves it. Users need not enter an arbitrary number between 1 and 2.1 billion.
If the Set Effective Priority command is ever NOT used when needed, the Filing will fail TariffShark’s validations, where a “Solve” link is provided next to the validation error as a shortcut to the Set Effective Priority screen.
If All Else Fails
What if a scenario unfolds for which TariffShark isn’t prepared and the Set Effective Priority command isn’t available? What if a user wishes to send FERC a specific Effective Priority value rather than allowing TariffShark to compute the value?
TariffShark Hammerhead has a secret (until now) feature that gives users total control over Effective Priority if that is what they want. On the Update Filed Tariff Record Version screen, the Effective Priority field is displayed in a disabled textbox. As long as the Filed Tariff Record Version’s (FTRV’s) FERC Response is “Draft”, double-clicking the textbox enables it, thus allowing users to enter an appropriate value.
If you have any questions or comments relating the Effective Priority field, we’d love to hear from you. Please comment below or