When to Associate at the Record Level - And Make it OBE

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When to Associate at the Record Level - And Make it OBE
Compliance Filing Type
If the section is already acted on by FERC and you are filing a compliance filing to either change language or to change an effective date from 9998 to an actual date, you want to associate the record at the record level in order to show the association (in the compliance instance) or to remove the 9998 date (in the effective date instance).
Amendment Filing Type
When you associate a record to a pending record in eTariff in the same docket, you are replacing the pending record with the one you are associating, thus you want the original version to become “moot” or OBE. This means that FERC will not have to act on this section; they will look only at the associated version. A good way to think of this: when you file an amendment type filing (to correct or change a pending filing), you would submit the same redline as you did in the initial filing, but with corrections, so FERC will only rule on the amended version of the record, making the first version moot/OBE, because the first version was incorrect and you do not want FERC to act on it.
Filing Type: 10 New 205 Filing
In this scenario, you would NOT want to associate at the record level because you do not want to replace any version of a section that is still pending at FERC in a different docket. A new type 10 filing means that this is unrelated to other pending changes at FERC. This type of filing is why we have the option in Systrends to pull in a section from a filing (and not the Master Tariff) and NOT use the OBE box. You would use this when a new section was added to the Tariff in a filing and it is not yet merged into the Tariff for access for you to pull into a filing to make changes to. If you associate at the record level in a type 10 filing and file, it will turn the pending version of the record to OBE and not allow FERC to act on it in the other pending proceeding. You do not want to do this.
Please see more details in Systrends News Blog

By: Sara Gordon, Wright & Talisman, P.C.