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.

TariffShark’s Intelligence

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
contact Support.

The need to move the TariffShark client application from one PC to another usually occurs when a TariffShark user has been issued a new computer. The process to be followed is similar to the upgrade process and is outlined here.

1. On the new PC, follow the TariffShark Desktop Client Installer Guide until you get to the step called “Complete Page”, which is the final step of the installation wizard. Do not run TariffShark just yet.
2. On both the old and new PCs, open TariffShark’s global application settings folder (C:\ProgramData\Links Technology Solutions\). Note that this is a hidden folder and, depending on Windows settings, may not be visible.  One way to get to it is to type the path in the Windows Explorer address bar.
3. Find the “TariffShark Tiger” or “TariffShark Tiger SP1” folder on the old PC and copy its contents to the same folder on the new PC.
4. If you use proxy configuration settings other than the default ones…
   • On the old PC, locate the proxy.config file located in the TariffShark installation folder (usually in C:\Program Files).
   • Copy the proxy.config file identified into the TariffShark installation folder on the new PC.
5. There is no need to register the TariffShark client on the new PC with a TariffShark server, unless the TariffShark server has changed.

If you have questions or would like to discuss the new PC installation process in greater detail, we’d love to hear from you. Comment below or contact TariffShark Support.

[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.