Category: How To

How to Change Company Name

[Updated 9/5/2019]

Companies who are subject to FERC Order 714 sometimes change their names. In our experience, this is usually the result of an acquisition or restructuring. In any event, when this happens, the name of the licensed Company in TariffShark must be changed and TariffShark’s automated features must be considered when doing so.

Background

TariffShark has the ability to automatically insert headers and footers into your Tariff content. This feature allows you to focus on the content your tariffs while providing contextual tariff information (Company name, Tariff name, section name, sheet number, effective date, etc.) to your readers. TariffShark does this by placing actual Tariff metadata into the headers and footers of your tariff content. For example, if you configured TariffShark to insert the effective date in the footer of your tariff provisions and you were to change the effective date of a tariff provision, TariffShark would automatically update the provision’s PDF(s) to reflect the new effective date.

TariffShark provides this ability flexibly by allowing you to define different headers and footers for different tariff provisions. For example, you might want your tariff’s title page to not have a header or footer, your tariff’s rates to be formatted with landscape-style headers and footers, and the rest of your tariff’s content to have portrait-style headers and footers. So, even within a single Tariff, different Header and Footer combinations could be present.

Some companies, especially those in FERC’s NGA Gas program and electric industry companies with Open Access Transmission Tariffs, use TariffShark to publish their effective tariff provisions. Publishing is a process whereby the various tariff provisions that are in effect at a point in time are brought together into a single document. When publishing, TariffShark can generate and include a table of contents at the beginning of the published document and also an index at the end of the published document. These automatically generated elements include the name of the Company at the top of each page.

Finally, TariffShark is licensed by Company. The names of the Companies licensed to use TariffShark are listed in a license file on the TariffShark Application Server. When updating the name of a licensed Company, it may be necessary to update the license file.

Changing Company Name in TariffShark

There are three alternative methods to effect a Company name change in TariffShark.

Method #1: New Company

The first method involves cancelling all Tariffs under the old Company name and submitting baseline Tariffs under the new Company name. The automated processes described under the “Background” heading above are unaffected by this approach, however, it requires an updated TariffShark license file that adds a license for the Company under its new name. Also, because the FERC Company Id doesn’t change, when creating the new Company in TariffShark, it is necessary to set the “Next FERC Filing Id”, the “Next FERC Tariff Record Id”, and the “Next FERC Tariff Database Id” to values that are higher than the values shown for the same fields in the current Company.

This method is the most natural fit from a software perspective, but may inflict the most regulatory pain as it requires entire Tariffs to be refiled. In addition, FERC Staff does not recommend cancelling Tariffs just because of a Company name change.

Method #2: Don’t Update the Company Name At All

The second method is a “trick” of sorts as the Company name isn’t updated at all. If the automated TariffShark features described under the “Background” heading above aren’t used for the Company, then there is no compelling reason to update the Company name in TariffShark.

If the Company name appears in Header/Footer Templates, Method #2 can still be used. Create separate Templates for the old Company name and the new Company name by following these steps:

(2a) Make copies of all Header Templates or Footer Templates where the [Company Name] symbol is used to insert the Company name.

(2b) In the copies, replace the [Company Name] symbol with the new name of the Company.

(2c) Next, make new Document Layouts as copies of existing Document Layouts that use the new Header/Footer Templates created in steps (2a) and (2b).

(2d) At the Tariff Database level, use the “Replace Document Layouts” command to select the current Document Layouts, and specify that they be replaced with the new Document Layouts created in step (2c). From this point forward, all new Tariff Record Versions will use the new Document Layouts and, therefore, the new Company name will appear in the Headers/Footers.

If the publishing features to automatically generate Tables of Contents and/or Indices are used for the Company, then Method #3 is likely the best fit.

Method #3: Update Company Name

The third and final method requires that the Company name is updated in TariffShark. If the automated TariffShark features described under the “Background” heading above are used for the Company, then the best course of action is to update the name of the Company in TariffShark.

If the Company name appears in Header/Footer Templates, then separate Templates are needed for the old Company name and the new one. Create these Templates by following these steps:

(3a) Make copies of all Header Templates or Footer Templates where the [Company Name] symbol is used to insert the Company name.

(3b) In the original Templates (not the copies), replace the [Company Name] symbol with the old name of the Company. When the Header/Footer Templates are updated in TariffShark, all Tariff Record Versions that use them will be reprocessed. However, because the [Company Name] symbol was replaced with the current Company name, the resulting PDFs will appear unchanged.

(3c) Next, make new Document Layouts to parallel the existing Document Layouts, only use the copied Header/Footer Templates created in step (3a).

(3d) Update the Company name in TariffShark. In order to complete this task, you will need an updated TariffShark license file and a SQL script. Contact TariffShark Support to complete this step.

(3e) At the Tariff Database level, use the “Replace Document Layouts” command to select the current Document Layouts, and specify that they be replaced with the new Document Layout(s) created in step (3c). From this point forward, all new Tariff Record Versions will use Document Layouts that leverage the original Header/Footer Templates. Therefore, the new Company name will appear in the Headers/Footers.

Summary

Depending on how you use TariffShark, choose the method for changing Company name that’s the best fit.

	Updated License File Needed	Document Layout and Header/Footer Template Work Required	Auto-Generated Publishing Content Affected	Tariffs Must Be Cancelled and Re-Baselined	SQL Script Required to Update Company Name
Method #1	✔			✔
Method #2		✔	✔
Method #3	✔	✔	✔		✔

If you have questions or would like to discuss these options in greater detail, we’d love to hear from you. 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.

View Your FERC eTariff XML

After validating your Filing in TariffShark and downloading the zipped XML file, have you ever wanted to look at the XML before you ship it off to FERC? This blog article describes one method for doing so.

An eTariff filing’s data is coded in XML format. XML is a plain text format, so it may be viewed using any number of file editors that can open and display plain text. Because eTariff XML files can be VERY large, the XML file is compressed into a ZIP file. The ZIP file is what actually gets submitted to FERC when making an eTariff filing.

1. Open ZIP File

Windows knows how to open a ZIP file, so special software is not needed. Simply double-click the ZIP file downloaded from TariffShark and Windows will open it. Looking at the open ZIP file is almost exactly like looking at the contents of a folder. The difference is that folder contents are ready to be used and ZIP file contents must be extracted from (or copied out of) the ZIP file first.

2. Extract XML File

Extracting the XML file from the ZIP file is as easy as dragging it out of the ZIP window and dropping it on your Windows desktop. This is how we typically do it.

3. Open XML File

There are many programs that can read and display XML files. Some do a better job of it than others. The biggest concern is that you use a program that is able to handle very large files because FERC eTariff XML files can be VERY large…sometimes many, many megabytes.

Our tool of choice is Notepad++, which is a free text file editor. A standard Windows installer version is available for download from the developer’s website here.

Start Notepad++ and select “File | Open…” from the menu to open the XML file that you copied to your desktop in Step 2 above.

About the XML

The XML file contains tags and data. The tags appear within angle brackets and the data appears between the tags.

In the example above, “” is a tag that indicates the beginning of the Record Id data and “” signals the end of the Record Id data. Between the tags is the actual data, which is “1234” in the example.

There are a couple of tags in a typical eTariff XML file that you will not be able to read. These tags contain binary data that can only be read and understood by a computer:

4. Delete XML File

When you’re done viewing the XML, find the XML file that you placed on your desktop in Step 2 above and delete it.

If you have questions about viewing eTariff XML or if you use a different procedure for opening and viewing it, we’d love to hear from you. Please comment below or contact TariffShark Support.

"Pro Forma" Record Change Type

What Is Pro Forma in eTariff?

According to FERC’s eTariff implementation guide, Pro Forma proposals submit a tariff record without invoking statutory processing timelines. Pro Forma tariff records cannot be converted to effective tariff records by FERC, and should be resubmitted as actual tariff records.

In other words, a Pro Forma submission is a way of gaining preliminary feedback from the commission on contemplated tariff changes.

How to Create a Pro Forma Request in TariffShark

In order to send Pro Forma content to FERC in an eTariff filing, the Record Change Type field must be set to “Pro Forma”. In TariffShark, when you add a Tariff Record Version (TRV) to a Filing, a Filed Tariff Record Version (FTRV) results. TariffShark will automatically assign this FTRV a Record Change Type of either “New” or “Change”. Use the Update FTRV command…

…to change the Record Change Type to “Pro Forma”, as shown below.

TariffShark Life Cycle of a Pro Forma FTRV

In TariffShark, all FTRVs start with a “Draft” FERC Response. Once a Filing has been submitted to FERC, all of its FTRVs become “Pending”. So, the first two stages of a Pro Forma FTRV’s life cycle are “Draft” and “Pending”, which is the same as any other FTRV. However, that is where the similarities end. Because a Pro Forma submission does not represent a true proposal before the commission, many of the typical FTRV FERC Response values (such as “Approved” and “Rejected”) do not apply. So that Pro Forma FTRVs do not end their life cycle as “Pending”, TariffShark provides a FERC Response of “Pro Forma Ordered”. This FERC Response represents the end of the life cycle for Pro Forma submissions.

NOTE: If the changes proposed in a Pro Forma submission need to become part of an official tariff, the changes must be resubmitted in a new Filing with a Record Change Type of “Change”.

If you have questions about Pro Forma eTariff requests, we’d love to hear from you. Please comment below or contact TariffShark Support.