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FERC's NEW FILING CODE CHANGES How and When to Use Them

FERC issued a notice on June 11th authorizing changes to the eTariff requirements. These changes included adding a new “Lead Applicant” field and allowing Word and Excel file types to be uploaded in tariff records.


The changes were expected to go into effect on September 30th, however on September 9th, FERC issued a notice of extension to November 25th.


Along with the extension, FERC decided to include new filing codes and added a new filing category. To ensure you’re ready for the transition, here is an explanation of the new filing codes and how and when they should be used.

 

Compliance Filing Changes

One major change to eTariff Filing codes is the separation of compliance filings into two categories: “Compliance” and “Compliance_New”.


The filings that fall under the “Compliance” category are used when a sub-docket is needed (pretty much the same setup as compliance today). “Compliance” filings will require an associated filing. More specifically, codes 80, 70, 580, 790, and 40 are now "Compliance Filing – subdocket". These codes need an associated filing ID, or they will not pass FERC validation.


“Compliance_New” category is a compliance filing that will not have an associated filing/sub-docket. These filings will receive a New Docket. More specifically, codes 85, 75, 585, 795, and 45 are the new "Compliance Filing – new docket" codes. These should not have an associated filing, and if you try to add one, they will fail validation.


New Filing Codes:

Along with compliance filing changes, FERC is also updating/adding some baseline codes.


Baseline code that distinguishes between Initial Rate Baseline and Rate Change Baseline


  • Filing code 390 (TCS companies) is being renamed to “New Tariff Database (Rate

    Change Baseline).”This code is to be used for baseline filings to change existing rates

    under FPA 205(d) 35.13(a)(2)(iii).


  • New Filing Code 395 (TCS Companies) is titled “New Tariff Database (Initial

    Rate Baseline),” which will be used for an initial rate baseline (as 390 used to be).


  • Filing code 400 (for MBR companies) is being renamed to “New Tariff Database (Rate

    Change Baseline).” This code is to be used for baseline filings to change existing rates.


  • New Filing Code 405 (for MBR Companies), titled “New Tariff Database (Initial

    Rate Baseline),” is used for initial baseline filings establishing a rate.


FERC wants to provide utilities with options to reflect their intentions when filing their baseline. It seems that “initial” baseline filings will use codes 395 or 405.



Systrends eTariff Software

 Summary of Changes:

  1. Filing Code Name Changes:

       390 – “New Tariff Database (Rate Change Baseline)” – program code E

       400 – “New Tariff Database (Rate Change Baseline)” - program code M

       80 – “Compliance Filing - Subdocket” - program code E

       70 – “Compliance Filing - Subdocket” - program code M

       580 – “Compliance Filing - Subdocket” - program code G

       790 – “Compliance Filing - Subdocket” - program code K

       40 – “Application for Confirmation and Approval (Other than BPA) - Subdocket”

 

  1. New Filing Codes

    395 – “New Tariff Database (Initial Rate Baseline)” – for program code E (TCS companies)

    405 – “New Tariff Database (Initial Rate Baseline)” for program code M (MBR companies)

    85 – “Compliance Filing – New Docket” for program code E

    75 – “Compliance Filing – New Docket” for program code M (MBR Company)

    585 – “Compliance Filing – New Docket” for program code G

    795 – “Compliance Filing – New Docket” for program code K

    45 – “Application for Confirmation and Approval (Other than BPA) - New

docket” for program code F

Note: Attachment types allowed for the compliance_new codes are the same as the compliance codes.


  1. New Requirements bring new Validations:

The following validations FERC Codes have been added to FERC rules:

183

Lead Applicant Company Identifier not found – received when the company ID set for the lead applicant is not valid or in FERCs system 

184

Lead Applicant Company Identifier has not been approved yet – Received when the company ID was been created, but it is pending with FERC still

185

Applicant Company Identifier must be text – (ex: C012345).

186

Lead Applicant Company Identifier required – received when the field was left blank. The field is required, so if there’s no lead applicant, then enter submitting company CID.

187

This type of filing code establishes a new docket; the filing should not include an associated filing identifier. – received when an associated filing ID was set for a compliance_new filing. To fix: remove the associated filing ID.

188

Attachment files have a duplicated file name. – received when the file name is the same for two attachments in the filing.

189

Lead Applicant Company Identifier must start with the letter C (see code 185 for example).


Action Items and Reminders

  • Review FERC Regulations: While this guidance aims to educate, it does not constitute legal advice. Utilities must familiarize themselves with the updated Federal Regulations to ensure appropriate code selection.

  • Familiarize Yourself with Code Changes: Study the new filing codes, renamed codes, and their corresponding program codes. Ensure you understand which codes necessitate associated filings and which initiate new dockets.

  • Prepare for New Validations: FERC has implemented additional validations. Anticipate potential errors related to lead applicant identification, file naming, and associated filings for "Compliance_New" codes.

  • System Updates: Systrends will update servers on November 24. Allocate time prior to November 25 to acclimate to the new filings and validations within the Systrends platform.

 

Support

For questions or concerns regarding the FERC filing code changes and validations, please reach out to Renee Feeney at renee.feeney@systrends.com. Embrace the support available to ensure a smooth transition and maintain uninterrupted compliance.

 


For Reference:

Filing codes that require an associated filing ID are as follows:

40

Application for Confirmation and Approval (Other than BPA)-Subdocket

70

Compliance Filing-subdocket

80

Compliance Filing-subdocket

100

Withdraw Entire Proceeding

110

Withdraw Non-Jurisdictional Filings

120

Amendment of Pending Tariff Filing

130

Amendment of Pending Tariff Filing

140

Data Response/Supplement the record

150

170

Data Response/Supplement the record

Deficiency Filing

180

Deficiency Filing

230

Complaint (ISOs/RTOs)

460

Amendment (BPA)

470

Withdraw (All PMA EFs)

530

Non-Jurisdictional Compliance Filing

550

Data Response/Supplement Record

580

Compliance Filing-subdocket

590

Withdraw

600

Amendment

620

Data Response/Supplement Record

670

Refund Report

780

Data Response or Supplement to the record

790

Compliance Filing-subdocket

810

Withdrawal of entire filing

900

Withdraw of Pending/Non-effective Tariff

950

Data Response/Supplement Record

1000

Amendment to non-statutory filings

1020

Non-Jurisdictional filing Amendment

1040

Non-Jurisdictional filing Amendment

1050

Amendment (Other than BPA)

1060

Non-Jurisdictional Withdraw

1090

Non-Jurisdictional filing Amendment*

1120

Market Based Rate Triennial Review

1130

Refund Report

1150

Market Based Rate Triennial Review

1180

Non-Jurisdictional Compliance

1190

Refund Report

1200

Refund Report

1210

Refund Report

1230

Amendment

1270

OPT-Amendment using optional notice procedure filing

1350

Amendment to statutory filings

1360

Certification of Unchg State Rate Election

1380

ALJ Settlement

1390

ALJ Settlement

1400

ALJ Settlement

1410

ALJ Settlement

1420

ALJ Settlement

 

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