TariffShark supports FERC’s recent notice regarding restricting the use of word processing software to include headers, footers, or footnotes when submitting eTariffs as RTF files. As a powerful and flexible tool, TariffShark offers filers various degrees of control over their tariff content and it allows them to stray from FERC’s guidance. This article discusses both TariffShark’s compliance with FERC’s notice and cautionary aspects depending on various filing situations.
Background and Details
On September 6, 2017, FERC issued a notice under Docket No. RM01-5-000 (Accession No. 20170906-3057) that tariff text posted in Rich Text Format (RTF) should not have footnotes, headers, or footers created programmatically using word processing software. This is because the Commission’s electronic tariff system (eTariff) does not reproduce this type of content in RTF on its website. If headers, footers, or footnotes are needed, filers should enter them separately in the body of the document on each page without using automated program features such as Insert Footnote or Insert Header or Insert Footer tools in word processors like Microsoft Word.
Let’s look at FERC’s guidance and discuss how to best use TariffShark in a compliant fashion.
Refer to Figure 1 below for a representation of a TRV as it would look if being edited in “TariffShark Microsoft Word” with a TariffShark Header and Footer; a Microsoft Word-style header and footer; and a Microsoft Word footnote. Then compare Figure 1 to each of the following scenarios and their Figures to see the RTF that TariffShark would generate.
FERC Guidance: Do NOT use Microsoft Word headers and footers when submitting RTF Files
TariffShark is mostly compliant with these restrictions; however, it does have limitations depending on how its users choose to file their tariffs and the options that they select.
Tariff Record Versions (TRVs) in Section-based or Sheet-based Record Formats…
With Document Layouts that include TariffShark Header and Footer Templates
If eTariffs are submitted via TariffShark in either Section-based or Sheet-based Record Formats, filers can choose to take advantage of Document Layouts that include TariffShark-generated headers and/or footers. This feature will inject TariffShark metadata on each page as TariffShark-generated headers and/or footers but will NOT include them in the resulting RTF (just as FERC requires).
In this scenario, TariffShark does NOT include the Microsoft Word-style header and footer in either the PDF (Figure 2) or the RTF (Figure 4).
With Document Layouts that omit TariffShark Header and Footer Templates
If a filer chooses to use Document Layouts without TariffShark-generated headers or footers, then they need to be careful of how they work in Microsoft Word. A filer has full control of all aspects of such TRVs’ tariff content, so they must not insert headers or footers in Microsoft Word.
Refer to Figure 3., and note that this RTF includes a Microsoft Word-style header and footer.
Without Document Layouts
Once again, if a filer chooses to NOT use Document Layouts, then they need to be careful of how they work in Microsoft Word. A filer has full control of all aspects of such TRVs’ tariff content, so they must not insert headers or footers in Microsoft Word.
Here TariffShark includes the Microsoft Word-style header and footer (Figure 3).
TRVs in Whole Document Record Format…
If eTariffs are prepared in TariffShark using Whole Document Record Format, users do not have the option to include Document Layouts thus TariffShark-generated headers and footers are also not available. As in the examples above, a filer has full control over all aspects of the tariff content. When filing in RTF format, they must take care to not insert headers or footers.
And TariffShark’s RTF rendering of the TRV again looks like Figure 3., with a Microsoft Word-style header and footer included.
FERC Guidance: Do NOT use Microsoft Word footnotes when submitting RTF files.
The Record Format selected for your Tariff (Section-based, Sheet-based, or Whole Document Record Formats) does NOT matter since TariffShark will include any footnotes inserted with the Microsoft Word footnote tool. Therefore, it is up to the filer to be careful not to violate this FERC notice by avoiding programmed footnotes when submitting eTariffs as RTF files.
We have purposely included a Microsoft Word footnote in all the scenarios discussed since no matter the TariffShark Record Format or Document Layout option, Microsoft Word footnotes will be rendered in the RTF (Figures 3 and 4).
Generalizations Regarding FERC’s eTariff system and compatibility with RTF files
In general, Microsoft Word is a very powerful word processor and can save all kinds of content in an RTF file. However, 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. In 2011, FERC staff guided that Microsoft Word 2007 saves such files as much smaller RTFs. If you’re running modern Microsoft Word software, RTFs submitted with embedded images 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. In 2011, FERC staff reported that it 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.
- Advanced Word Features to Avoid
- Avoid automatic content (paragraph numbering and footnotes are two examples).
- Never use text boxes.
- Avoid complex tables (fancy styling, cell merging and splitting, font orientation). Keep tables simple.
- Keep Word styles simple. Use WordPad to view your RTF content to help identify potential issues.
- Do not use drawing/diagramming objects. Instead, insert drawings as images.
- Do not embed Excel worksheets (insert them as images).
Please contact TariffShark Support at 847-252-1611 or at email@example.com if you have any questions or concerns regarding this notice and ensuring that your FERC eTariff submissions through TariffShark comply with it.
Figure 1 Editing TRV content in TariffShark Microsoft Word with a TariffShark Header and Footer and a Microsoft Word-style header and footer and a Microsoft Word footnote.
Figure 2 TariffShark’s PDF rendering of Figure 1 for a Section-based TRV with Document Layout that includes TariffShark Header Template and Footer Template.
Figure 3 TariffShark’s RTF rendering of Figure 1 for TRV with Document Layout that omits TariffShark Header Template and Footer Template. The same result is achieved for a TRV without a Document Layout and for a TRV in Whole Document Record Format.
Figure 4 TariffShark’s RTF rendering of Figure 1 for TRV with Document Layout that includes TariffShark Header Template and Footer Template.