Category: FERC

Why Is December 31, 9998 Significant to eTariff

The OSEC Implementation Guide for eTariff contains a somewhat odd rule about proposing effective dates for tariff records.  Under the heading “Tariff Record Proposed Effective Date”, it says…

“If the effective date is not known at the time of the filing, such as the effective date is contingent on FERC approval, the closing of a plant sale, etc., the date of 12/31/9998 must be used.”

One of the highest priority goals for TariffShark is ease of use.  To that end, if there is ever uncertainty around the proposed effective date for a Tariff Record Version, simply leave it blank in TariffShark.  TariffShark has your back; it understands the 12/31/9998 rule and will put the appropriate value in the XML for submission to FERC.  With TariffShark, you don’t have to know the 12/31/9998 rule.

An unknown effective date is a rather uncommon situation.  In order to help prevent data entry errors, TariffShark will generate a filing validation warning any time it encounters a blank proposed effective date.  If you have left a proposed effective date blank intentionally, simply disregard the warning.

As always, if you have questions or comments, you may post them below or contact TariffShark Support.

Changing a Filing’s Type After It Has Been Submitted

Several months ago we posted a blog article that described how to change the Filing Type of a Filing, which is helpful for Filings that have not yet been submitted to the Commission.  But, what do you do if you submitted a Filing and FERC has instructed you to submit the Filing again under a different Type of Filing?

The first thing you need to understand is that once a Filing has been submitted to FERC and accepted by FERC, it cannot be changed and submitted again.  This means that in order to “change” the Type of Filing, you actually need to make two additional Filings. The first of these is a Filing to withdraw the incorrect Filing and the second is a Filing with the correct Filing Type.

Preparing a Filing’s Tariff Record Versions’ (TRVs’) marked content and clean content for submission to FERC can take a fair amount of work.  It would be a shame to have to repeat that work simply because a Filing needs to be resubmitted with a different Filing Type.  By following the steps below, the replacement Filing can have all of the same content as the original Filing.  For each TRV in the original Filing…

  1. Open the Filing Details screen for the original Filing.
  2. On the “Tariff Record Versions” tab, select a TRV.
  3. Click the “Download Content” command in the SmartBar.  On the resulting form, download the TRV’s “Marked Document” and save the file somewhere temporarily (such as your desktop).
  4. Create a TRV for the replacement Filing.
    1. We recommend incrementing the Version by 1.  For example, if the TRV in
      the original Filing was Version 2.0.0, use Version 3.0.0 for the new
      TRV.
    2. On the Create Tariff Record Version form, place the new TRV into the replacement Filing.
  5. Open the Filing Details screen for the replacement Filing.
  6. On the “Tariff Record Versions” tab, select the TRV that was created in step 4 above.
  7. Click the “Build Content” command in the SmartBar.
    1. When the Build Content wizard asks “How would you like to build the content?” select the “Import Microsoft Word document” option.
    2. On the wizard next step, when prompted to “Select Microsoft Word file to import:”, select the file saved in step 3 above.
    3. Finish the wizard.
  8. TariffShark will open Microsoft Word with the content of the file selected in step 7b above.  Close Word and save the document when prompted.

Simply repeat this process for every TRV in the original Filing and the TRVs in the replacement Filing will have identical content.

If you have questions about this article, we’d love to hear from you.  Please comment below or contact TariffShark Support.

Submit Your eTariff XML to the FERC eTariff Sandbox

After validating your Filing in TariffShark and downloading the zipped XML file, have you ever wanted to submit the XML to FERC’s eTariff Sandbox for further validation?  This blog article describes one method for doing so.

1. Open “My Computer” or “Windows Explorer”.














2. Type “ftp://etariff-ftp.ferc.gov” into the address bar (without the quotes) and press Enter.

3. You are connecting to the FERC Sandbox FTP site and will be prompted to login.  The user name and password to use are “etsuser” and “testxml#”, respectively, both without the quotes.

4. After successfully logging into the FERC Sandbox FTP site, your screen should look similar to the following.

5. Copy your zipped XML file (that you downloaded from TariffShark) and paste it into the folder named “ets_receive_files” (circled in the image above).  Once you’ve placed your file in the “ets_receive_files” folder, you may find that it has disappeared.  This is normal.  When FERC’s software detects that a new file has been uploaded, the file is moved to another location for processing.

6. That’s all there is to it.  Now, just sit back and wait for an email to arrive from FERC with your validation results.  The email will come from NoReply@ferc.gov and will have a subject line of “SandBox FERC ETariff Validation”.

TariffShark Hammerhead Tip

Submitting eTariff XML to FERC’s Sandbox is built right into TariffShark Hammerhead and takes just a couple of clicks. See it in action.

If you have questions about using FERC’s eTariff Sandbox or if you use a different procedure for submitting your eTariff filings to the sandbox, we’d love to hear from you.  Please comment below or contact TariffShark Support.

FERC Uniqueness Requirement for Description, Title, and Version

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.

R011

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.

R044

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.

TariffShark’s validations are there to help you avoid rejected and erroneous Filing submissions.  For your reference, the v1.1 online documentation includes a complete list of Filing Validation Rules.

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.