On June 11, the Federal Energy Regulatory Commission (FERC) released a notice detailing revisions to the eTariff program in docket RM01-5-000. These changes aim to enhance clarity and streamline the filing process and provide greater flexibility for filers. The two primary updates are the introduction of a "Lead Applicant" field and the acceptance of Word and Excel files for tariff records.
Lead Applicant Field
The new "Lead Applicant" field is designed to clarify the distinction between the lead applicant for the agreement and the company submitting the filing. This change addresses issues that arise when an Independent System Operator (ISO) submits a filing on behalf of a market participant, causing confusion in the FERC database and staff who might address concerns with the agreement. To utilize the new Lead Applicant field effectively:
Enter the Lead applicant's FERC Company Identifier (CID) in the field
Only one Lead applicant CID is permitted
If multiple entities share the lead applicant role, select the most appropriate as the lead and add the others as co-applicants when filing through eFile.
The Lead Applicant field is mandatory; if no lead applicant exists, enter your own company's CID
Word and Excel Tariff Records
Previously, FERC required Tariff Records to be submitted in RTF format only. This change allows Word and Excel files as an additional option to the RTF requirement. RTF was originally chosen as the preferred format over a decade ago when FERC viewer was in development. The change to allow Word and Excel should not be mistaken as the documents loaded as attachments in a filing. Attachments have always been allowed in any format because they are displayed in the eLibrary.
Benefits of Word and Excel in Tariff Records
Allows for larger Word files in the tariff record. When converting any files to RTF it would increase in size. This meant you had to start with smaller files to stay within the FERC limit when converted to RTF.
Word documents can include headers and footers, which were not allowed in RTF
Excel files must have margins within an 11x17 range and render to PDF without data loss
Implementation and Testing
These revisions take effect on September 30, 2024. Only the updated XML schema will be accepted in eFile starting on this date. FERC has provided a special Sandbox site to test the new XSD before it goes into production. Systrends customers with Sandbox servers can begin testing the new XSD now. All other eTariff production servers will be updated with the latest changes the weekend preceding the effective date. Submissions using the old XSD after September 30 will result in validation errors.
For questions on navigating these changes, contact Systrends.
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