Author: TariffShark

eTariff RTF Document Compliance

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 support@tariffshark.com if you have any questions or concerns regarding this notice and ensuring that your FERC eTariff submissions through TariffShark comply with it.

Figures

Marked Word Doc
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.

Clean PDF
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.

Clean RTF 2
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.

Clean RTF
Figure 4 TariffShark’s RTF rendering of Figure 1 for TRV with Document Layout that includes TariffShark Header Template and Footer Template.

TariffShark Tiger Now Available

July 10, 2017

Thanks to our customers, TariffShark has been the leading eTariff filing solution since its release in 2010.  We have not taken the honor sitting down, however.  We’ve spent the last two years listening to our customers and building an even better experience.  Introducing TariffShark Tiger, the third major TariffShark software release!  The most advanced eTariff filing solution in the industry is better than ever.

With loads of new features and enhancements, including an updated user interface, Tiger will take your eTariff filing experience to a whole new level!

Learn more.

TariffShark Updated with New "Settlement" Filing Types

For our enterprise TariffShark customers, software updates are available NOW for all TariffShark Hammerhead releases (4.0.1 and higher) on TariffShark.com.

Hosted customers, we will update your hosted servers prior to the January 3, 2017 effective date of the FERC Notice. No action is required on your part.

Background and Details

On December 1, 2016, FERC issued a notice that requires all settlements in Parts 35, 154, 284 and 341 proceedings set for trial-type evidentiary hearing and/or settlement judge procedures before a Presiding Judge or Settlement Judge must be filed in eTariff, effective January 3, 2017.

The following new Filing Types have been added to TariffShark:

TOFC (Code) Filing Title (Description) Filing Category Description of Change
1380 ALJ Settlement Compliance Settlement in a Part 35
FPA Traditional Cost of Service and
Market Based Rate Program proceeding
1390 ALJ Settlement Compliance Settlement in a Part 35
FPA Market Based Rate Program proceeding
1400 ALJ Settlement Compliance Settlement in a Part 154
NGA Gas Pipelines Program proceeding
1410 ALJ Settlement Compliance Settlement in a Part 284
NGPA 311 Gas Pipelines Program proceeding
1420 ALJ Settlement Compliance Settlement in a Part 341
Oil Pipelines Program proceeding

Today we are announcing the availability of TariffShark software releases that accommodate these Filing Type additions. Updated software, upgrade guides, and installation instructions are available NOW on the TariffShark website.

If you are already running a recent TariffShark release, it’s likely that only your TariffShark database is affected by this update. Consult the TariffShark Releases page to assess the impact to your installation. If only your TariffShark database requires update, simply download and run the appropriate database installer to bring your TariffShark installation up to the latest release.

Please contact TariffShark Support at 847-252-1611 or at support@tariffshark.com if you have any questions or concerns.

TariffShark Software Updates Available for FERC Compliance

For our enterprise TariffShark customers, software updates are available NOW for all TariffShark Hammerhead releases (4.0.1 and higher) on TariffShark.com.

Hosted customers, we will update your hosted servers prior to the November 7, 2016 effective date of the Filing Type changes. No action is required on your part.

Background and Details

On September 6, 2016, FERC issued a notice that identifies changes to filing types that affect the Part 284 program. Subsequently, on October 21, FERC provided updated Filing Type and Attachment CSV files on the eTariff web page to align them with the notice.

Today we are announcing the availability of TariffShark software releases that accommodate these Filing Type changes. Updated software, upgrade guides, and installation instructions are available NOW on the TariffShark website.

Note that only the following FERC program is affected:

  • NGPA 311 Gas Pipelines 

If you are already running a recent TariffShark release, it’s likely that only your TariffShark database is affected by this update. Consult the TariffShark Releases page to assess the impact to your installation. If only your TariffShark database requires update, simply download and run the appropriate database installer to bring your TariffShark installation up to the latest release.

Please contact TariffShark Support at 847-252-1611 or at support@tariffshark.com if you have any questions or concerns.

Resolving Failed TRV Document Processing

From time to time, TariffShark may struggle to process a Tariff Record Version (TRV) document. When a TRV has failed document processing, the Failed Processing tab on the Dashboard will appear pinkish.

The rightmost column, titled Action in the image above, contains two buttons, Requeue and View, that can help you to complete processing of the TRV document.

Requeue Button

Click the Requeue button to resubmit the TRV for document processing. This action essentially moves the TRV from the Dashboard’s Failed Processing tab over to its Processing Queue tab. If TariffShark is still unable to process the TRV’s content, it will turn up on the Failed Processing tab once again. If this happens, try the View button (described below).

View Button

Click the View button to open the marked content of the TRV that failed processing. The document will open in Microsoft Word.

TariffShark is often unable to process documents that contain section breaks. If your document contains section breaks, follow these steps to resolve:

  1. Using Microsoft Word, find and remove all section breaks (often times it’s best to replace them with page breaks).
  2. Save the document to your computer or network.
  3. Use the Build Content command for the TRV in TariffShark to import the document that you saved in the prior step.

If TariffShark still cannot process the document, let the TariffShark Support team help. If the TRV’s content isn’t confidential, please share the document with Support. To do so, click the View button in TariffShark’s Dashboard, save the document, and send it to support.

Remove Warning When Saving Tariff Content That Contains Tracked Changes

For reasons of privacy, there is a setting in Microsoft Word that tells Word to warn you any time you save or print a document that contains tracked changes.  TariffShark saves a lot of documents that contain tracked changes, so having to deal with the confirmation dialog can be rather tiresome.

The setting can be found under Privacy Options and, depending on the version of Microsoft Word you use, looks exactly or something like this:

Some TariffShark users have reported that after unchecking the “Warn before printing…” privacy option, it appears checked the next time they go into Microsoft Word.  It turns out that this option can be established by software policy, thus disabling users’ ability to change it.

For some users, we have found that a registry entry can be used to uncheck the “Warn before printing…” box.

For Microsoft Word 2010, create or update the REG_DWORD entry named fWarnRevisions_1125_1 setting it to 0 (meaning unchecked) which can be found under registry key HKCU\Software\Policies\Microsoft\Office\14.0\word\options\vpref.

For Microsoft Word 2013, create or update the REG_DWORD entry named fWarnRevisions_1125_1 to 0 (meaning unchecked) which can be found under registry key HKCU\Software\Policies\Microsoft\Office\15.0\word\options.

If you need assistance applying this fix or are interested in more details, contact TariffShark Support.

eTariff Terminology

When speaking with FERC staff about eTariff matters, you will commonly hear terms like the following:

  • Company Identifier, Company Id, or CId
  • Tariff, Tariff Identifier or Tariff Id
  • Filing
  • Type of Filing Code or ToFC
  • Tariff Record
  • Attachment

Similar terms are used within TariffShark, but the terms are not identical and can have slightly different meanings. This article will outline TariffShark’s terminology and draw parallels to FERC’s eTariff terms.

Company

A Company in TariffShark is a FERC-regulated entity for which electronic tariff filings are made.

FERC Term(s): Company Identifier, Company Id, or CId

Tariff Database

A Tariff Database is a repository into which your tariff work (Filing, Tariffs, Tariff Record Versions, etc.) is stored. A Tariff Database has associated with it a unique identifier which is assigned by TariffShark when the Tariff Database is created. In TariffShark, this ID is known as the Tariff Database ID and it gets sent to FERC in every eTariff filing you submit.

FERC Term(s): Tariff, Tariff Identifier, or Tariff Id

Filing

A Filing in TariffShark is a proposal to FERC to affect one or more changes to a company’s electronic tariff(s). Changes to the Tariff Record Versions that represent the content of your tariff(s) are included in a Filing as Filed Tariff Record Versions (or FTRVs) and supporting materials (such as a transmittal letter) are included as FERC Attachments.

FERC Term(s): Filing

Filing Type

A Filing Type in TariffShark describes the type of filing being made as defined by FERC regulations.

FERC Term(s): Type of Filing Code or ToFC

Tariff

A Tariff in TariffShark represents a tariff, rate schedule, service agreement, or similar document that must be filed electronically as a result of FERC Order 714. Large Tariffs, such as gas industry open access tariffs and electric industry open access transmission tariffs, must be managed and filed as a series of smaller documents. Small Tariffs, such as oil industry tariffs and electric industry market based rates, may be managed and filed in their entirety.

FERC Term(s): Tariff Record

Tariff Record

A Tariff Record is a portion of a Tariff in TariffShark. Large Tariffs, such as gas industry open access tariffs and electric industry open access transmission tariffs, must be managed and filed as a series of smaller documents (Tariff Records). In a Tariff that is composed of multiple Tariff Records, the top-most (or “root”) Tariff Record commonly represents the Tariff title page.

FERC Term(s): Tariff Record

Tariff Record Version

A Tariff Record Version (TRV) is a version of a Tariff Record. TRVs are where the content of your tariffs is stored. TRVs can exist independent of a Filing or they can be part of a Filing. Placing a TRV into a Filing causes a Filed Tariff Record Version (FTRV) to be created.

FERC Term(s): Tariff Record

Filed Tariff Record Version

A Filed Tariff Record Version, or FTRV, represents a Tariff Record Version (TRV) in a Filing. When a TRV is placed into a Filing, the result is the creation of an FTRV. When a TRV is in a Filing, it is there for a reason … and that reason is known as a Record Change Type. The valid Record Change Type values are “New”, “Change”, “Cancel”, “Withdraw”, and “Pro Forma”.

FERC Term(s): Tariff Record

FERC Attachment

A FERC Attachment in TariffShark is supplemental information above and beyond the content of your Tariff Record Versions that are sent to FERC when making an electronic Tariff filing. A transmittal letter is the most common example of a FERC Attachment.

FERC Term(s): Attachment