1

FERC Staff’s Responses to Discussion Questions from eTariff@FERC.gov 

List of Issue Groups

Business Rules .......................................................................................................................................................................2

Attachment Related Codes ................................................................................................................................................16

Tariff Record Related Codes .............................................................................................................................................22

Type of Filing Related Questions.....................................................................................................................................47

eTariff Viewer.........................................................................................................................................................................53

Company Registration.........................................................................................................................................................62

Maintaining and Changing Tariff Data Bases ...............................................................................................................63
2

Business Rules

Question Answer Date

1 If a record change type of CHANGE is filed 

in a filing for record id 1234 version 2.0.0 

and then is subsequently withdrawn in a 

later filing via a record change type of 

WITHDRAW, can record id 1234 version 

2.0.0 be filed again at some later date?

Upon processing the latter (WITHDRAW) 

filing, is the earlier filed record physically 

delete from FERC's eTariff database?

Neither the Filing Identifier (filing_id) number nor 

the Tariff Record’s Record Version Number 

(record_version_num) can be reused once the 

filing has been accepted by the OSEC. Once the 

OSEC has accepted a filing, the filing is an official 

document with the Commission. A withdraw filing 

initiates a set of FERC processes. Neither the 

WITHDRAW filing type nor the WITHDRAW 

Record Change Type results in the removal of the 

tariff filing or the Tariff Record data being from the 

FERC’s databases.

1/15/10

2 Under what circumstances will a filing 

include tariff record versions that do not 

contain tariff content?

• Withdrawal filings?

• Cancellation filings?

• Motion filings?

• Are there other filing types?

The Record Version Number 

(record_version_num) is not used in any 

automated fashion. It is not required for the Type 

of Filing (filing_type) identified as a Motion, 

Withdraw or Cancellation category. All other 

categories of Type of Filing that require Tariff 

Record Content Data require a Record Version 

Number.

12/19/08

3 For which types of filings is an 

associated_filing_id required in a filing?

Amendment? Compliance? Motion?

Withdraw? Report? Other?

The Baseline, Normal and Cancellation Type of 

Filing categories do not require an Associated 

Filing Identifier (associated_filing_id). 

Compliance may require an Associated Filing 

Identifier depending on the circumstance. All 

other Type of Filing categories require an 

Associated Filing Identifier.

12/19/08

5/25/10
3

Question Answer Date

4 Which types of filings can BE the associated 

filing for a filing being filed?

The Commission’s program specific regulations 

and business rules specify which types of filings 

may be associated with which filings. For 

example, Withdraw and Amendment Type of 

Filings can only be associated with tariff filings 

that the Commission has not acted upon. 

12/19/08

5/25/10

5 In the FERC documentation there are 

references to automated actions 

(amendment type filings, suspension 

motions, status_change_timeout) to update 

the status of filings and tariff records. Are 

these things that happen automatically 

within FERC’s tariff software? Are the 

owners of the affected tariffs notified? Will 

every tariff filing result in a FERC order?

The referenced Amendment and Motion Type of 

Filing categories will in many cases automatically 

update the status of filings. An amendment filing 

for example will automatically change the filing 

date for the proceeding (defined as all open tariff 

filings within the root docket number set) after the 

30th or 60th day which the Commission is required 

to act. In some cases, the Commission may issue 

a notice indicating that the filing has been made, 

but no explicit notification of the status tariff filing 

or tariff record change will be issued. The filer 

needs to be aware of the regulatory implications 

of its actions.

12/19/08

1/15/10

8/12/13

6 Currently, there is no way for software to 

understand and enforce the quantity of each 

type of attachment that may be placed into a 

filing. For example, it wouldn’t make sense 

for a filing to have two transmittal letters, but 

it would make sense for a filing to have two 

“Other Support not otherwise specified”

attachments. Is FERC willing to add a 

column to the attachment-referencecode.csv file that specifies whether multiple 

Attachments are governed by the current 

Secretary’s filing rules and in many cases, 

multiple documents and filing types are used for 

almost all types of documents. For example, a 

transmittal letter may consist of a Word document 

with an Excel spreadsheet as an appendix. Also, 

confidential information with redacted and 

unredacted copies may require the same 

attachment type be used more than once. Thus, 

designating which documents can be used 

12/19/08
4

Question Answer Date

attachments of a particular type are allowed 

in a filing?

multiple times is not worthwhile.

7 Can there be only one baseline filing 

(new_type=Y) for a tariff/database?

Yes. The Baseline Type of Filing category is a 

special case used to establish a new Tariff 

Identifier (tariff_id) for a company. Once the Tariff 

Identifier has been established, then all 

subsequent modifications to that tariff_id’s 

database must be performed by one of the other 

Type of Filing categories. For example, an 

applicant may file in its Baseline Type of Filing 

filing only one record_id: the first section of its 

tariff. That would establish the Tariff Identifier. 

Subsequently, and for the first time, the applicant 

could file 1,000 record_ids that compose the rest 

of the tariff and do not yet exist in the database. 

This second filing must use a Type of Filing 

category other than Baseline.

12/19/08

1/15/10

8 Under what circumstances can a filing of

refiled_type=Y be filed?

Many FERC programs’ regulations require 

different business rules depending on whether a 

tariff is filed with the Commission for the first time 

(for example, a new company: refiled_type = N), 

or is simply a restatement of what the

Commission has already reviewed and accepted 

(refiled_type = Y).

12/19/08

9 Are there rules regarding the filing of root 

tariff records (those without a parent) within 

such a filing? Or are they treated the same 

as tariff records that do have a parent?

A Tariff Identifier database can have multiple 

parent (root) Tariff Record Identifiers (record_ids). 

For example, Part 154 requires pipelines to 

maintain Volume No. 1 for their open access 

transportation and sales services, and a Volume 

12/19/08
5

Question Answer Date

I suppose at the crux of this topic is the 

difference in FERC’s eyes between a single 

tariff/database that contains multiple root 

tariff records VS multiple tariffs/databases 

each of which containing a single root tariff 

record.

No. 2 for their traditionally certificated services. 

Both of these Volumes can be placed in a single 

Tariff Identifier database under different parent 

Tariff Record Identifiers.

10 How does the “Etariff Filing Rules Table” 

PDF relate to the type-of-filing.csv? Are 

these supposed to convey the same 

information, the former in human readable 

format and the latter in machine readable 

format? When is the next time that these 

resources will be updated with the latest 

information?

The Etariff Filing Rules Table in PDF format is the 

human readable format of the type-of-filing.csv 

and att_ref_code.csv documents. The table and 

related CSV files may be updated to reflect 

business and regulatory changes. 

12/19/08

3/6 /09

5/25/10

11 The Type of Filing list posted on FERC’s 

web site contains a lot of information that 

does not appear to be directly relevant to 

the eTariff process (e.g. amendment type, 

withdrawal type, refiled type). Why are these 

included?

The Type of Filing data shows the business rules 

eTariff applies to each and every Type of Filing 

Code (filing_type) available to applicants. The 

data provides information on how a tariff filing and 

the attached Tariff Records are processed. The 

information is provided to enhance applicants’ 

tariff filing and tariff maintenance software. 

12/19/08

1/15/10

5/25/10

12 If Companies A, B and C have a joint rate 

schedule, and Company A has agreed to be the 

party responsible to maintain the rate schedule, 

and Companies B and C have tariff records for 

the rate schedule which incorporates by 

reference Company A’s rate schedule, must 

Companies B and C make a tariff filing to 

modify their tariff records when Company A 

No. However, Order No. 714 did not change 

Companies B’s or C’s responsibilities for service and 

supporting any changes to the joint rate schedule as 

required by the statutes and Commission regulations. 

3/6 /09
6

Question Answer Date

makes a tariff filing affecting the joint rate 

schedule?

13 Companies A, B and C have a joint rate 

schedule, and Company A has filed a proposed 

change to that rate schedule. Companies B and 

C wish to file additional material to the record to 

support their parts of the proposed change. How 

can they do this?

Companies B and C can file through eTariff utilizing a 

REPORT filing type, such as FPA program’s Type of 

Filing Code (filing_type) 150. When Companies B 

and C make such a filing, they must use Company A’s 

Company Identifier (company_id) and Filing Identifier

(filing_id) to ensure their material is properly routed to 

Company A’s tariff filing proceeding.

3/6 /09

1/15/10

14 Companies A, B and C have a joint rate 

schedule, and Company B wishes to make a 

change to the joint rate schedule that only affects 

them. Can Company B make the tariff filing?

The responsibilities of Companies A, B and C with 

regard to filing and maintaining the joint rate schedule, 

and responsibilities for satisfying all other statutory 

and regulatory requirements related to proposed 

changes and compliance, are a matter of the certificate 

of concurrence agreement. If Companies A, B and C 

wish to treat Company A’s joint rate schedule as a 

shared rate schedule (see Order No. 714 at P 65-73), 

the Tariff Filing XML schema will support such tariff 

filings.

If Company B makes such a filing, it must use 

Company A’s Company Identifier (company_id), 

Tariff Identifier (tariff_id) and an appropriate Filing 

Identifier (filing_id).

NOTE: Certificates of concurrences are NOT tariff 

records. Certificates of concurrence are agreements 

between the companies with tariffs defining who is 

responsible for tariff maintenance, identifying the 

3/6 /09

1/15/10

1/6/14
7

Question Answer Date

tariffs subject to the agreement, and memorializing any 

limitations. Certificates of concurrence should only be 

filed as a supporting document – NOT as a tariff 

record. 

15 Regarding the first two lines of the XML 

Schema, can anything be removed, edited or 

added to these lines without resulting in an 

error?

No. The first two lines of the XML Schema must be 

provided exactly as shown. If they are not provided 

exactly as shown, the OSEC cannot process the filing 

and it will be rejected.

1/15/10

16 My type of filing does not require all the data 

elements provided in the XML Schema. May I 

omit that row of information?

No. Every row of information for every sequence must 

be provided, even if there is no information to convey. 

If all the data elements are not provided exactly as 

shown, the OSEC cannot process the filing and it will 

be rejected.

1/15/10

17 What is the proper format for data elements that 

are not populated? 

Depending on the Type of Filing definition, different 

data elements need not be populated. For example, a 

BASELINE type of filing should not have an 

associated_filing_id. However, the XML Schema 

requires that all tariff filings provide that data element: 

<xs:element name=”associated_filing_id”

type=”xs:integer” nillable=”true”/>

The tariff filing’s XML code for this data element should 

appear as follows: 

< associated_filing_id xsi:nil=”true” />

Please note the guidance provided at the XML Schema’s 

note in the OSEC Implementation Guide with regard to 

known issues for certain XML software tools.

1/15/10

18 If 0 (zero) is used to populated an XML Schema No. Zero and null are different. Zero is read as 1/15/10
8

Question Answer Date

data element, will it be read by the 

Commission’s software the same as “null”?

populating the data element. Null is read as not 

populating the data element.

19 Can the order of the XML Schema’s data 

elements be changed?

No. The data elements must be provided in the same 

order as given in the XML Schema.

1/15/10

20 My filing had an ERROR and was rejected by 

the OSEC. May I correct the filing, use the same 

filing_id and resubmit it to the Commission?

Yes. 1/15/10

21 Can the clean tariff have headers and footers? Yes. Order No. 714 removed the regulations that 

required some program’s tariffs to include headers and 

footers. Headers may be included in the tariff text, or 

left as part of the RTF file’s page definition. However, 

information in the headers or footers cannot be 

contrary to any Commission finding, such as effective 

date, or contrary to other meta data provided by the 

company, such as section titles.

Headers that do not identify the proper tariff program 

may also result in the Commission requiring the 

applicant to refile the tariff records. The Commission 

is responsible for five different tariff programs, 

including two different electric and two different gas 

tariff programs. “FERC Electric Tariff” and “FERC 

Gas Tariff” are not adequate to identify the tariff 

program. See 149 FERC ¶ 61,283, at P 89. If headers 

are used, they should use the program identifiers 

provided in the OSEC Implementation Guide.

6/25/10

1/6/14

22 Must the tariff or rate schedule have a table of 

contents? 

If the Commission’s regulations or order requires a 

table of content for a tariff, rate schedule or any other 

tariff document, it must be included.

6/25/10
9

Question Answer Date

23 Can a company continue use of the old 

designation system? 

Yes. However, if a company chooses to use its old 

system, it still must abide by the general rule that the 

designations must be unique so as not to create 

confusion. See RP10-563-000.

6/25/10

24 Order No. 714 permits companies sharing joint 

tariffs to incorporate a tariff by reference. Joint 

tariffs are most common in the FPA program. 

May other programs incorporate tariffs by 

reference?

Yes, Order No. 714’s findings apply to all the tariff 

programs, not just the Part 35 program.

6/25/10

25 As a non-designated party to a joint tariff, what 

should be included on the tariff section 

incorporating the designated filer’s tariff?

Generally, the non-designated tariff section should 

have an informative section title, the name of the 

designated party, tariff and, as necessary, section title, 

and any other information or limitations applicable to 

the tariff and non-designated party. See Portland 

General Electric Company for an example of a 

designated party filing, and Puget Sound Energy, Inc.

for an example of a non-designated filing, especially 

the accepted tariff record.

6/25/10

10/11/13

26 Company A’s paper version of the OATT was 

maintain and filed with the Commission under a 

Service Company B designation. That OATT 

will now be in another Company C’s tariff. Can 

Company A’s Order No. 714 baseline tariff 

filing incorporate Company C’s OATT by 

reference? 

This is similar to a Joint tariff situation. Yes, Company 

A can provide a single tariff record incorporating 

Company C’s OATT by reference in the baseline 

filing. The Transmittal Letter of Company A must 

clearly explain that Company C will be the location of 

the OATT in place of what used to be Service 

Company B’s tariff, and confirm that no other 

significant changes are in the baselined Company C 

incorporated tariff.

6/25/10

27 Company A’s paper rate schedule is identical to 

Company B’s paper rate schedule. Can 

If the rate schedules are clearly marked as a joint tariff 

and are identical in all respects, Company A can 

6/25/10

10/11/13
10

Question Answer Date

Company A incorporate Company B’s rate 

schedule as part of its Order No. 714 compliance 

filing?

incorporate Company B’s rate schedule provided the 

appropriate letters of concurrence are provided. The 

Transmittal Letter must clearly state the nature of the 

incorporation by reference. See also answers to Qu. 12 

and 14 above.

If Company A’s incorporation by reference is limited 

or conditional, any proposals by either Company A or 

B to change the incorporated rate schedule imply that 

the rate schedules, or their application, are not 

identical. In that case, Company A needs to make a 

Normal/Statutory filing with its proposal for the

incorporated by reference rate schedule.

28 In a contested proceeding before an ALJ, the 

parties wish to file a settlement with the ALJ. 

Can eTariff be used to file the Settlement?

eTariff must be used to file Settlements. Parties should 

follow the instructions of the ALJ. Public, Procedures 

Governing Rule 602 Settlement Filings (Oct. 13, 2017) 

(Accession Number 20171013-3043).

Any Settlement that claims to have real tariff records 

as part of the Settlement and those tariff records are not 

filed through eTariff must be followed up with an 

eTariff Compliance filing to enter the tariff records into 

the eTariff data base. 

6/25/10

4/11/19

29 A Settlement contains tariff records. Can eTariff 

be used to file the Settlement?

Any filing that contains real tariff records must be filed 

in eTariff. 

Any Settlement with real or pro forma tariff records 

must be filed in eTariff. Further, pro forma Tariff 

Records must be filed as Tariff Records using Record 

6/25/10

4/11/19
11

Question Answer Date

Change Type Pro Forma. Blackstone Wind Farm, 

LLC, 167 FERC ¶ 61,004, at P 5 (2019).

30 A Settlement contains tariff records and provides 

that the agreed upon tariff records will go into 

effect upon Commission approval. What date 

should be used to populate the Tariff Record 

Proposed Effective Date?

When an applicant does not know or have a proposed 

effective date, the Tariff Record Proposed Effective 

Date should be populated with 12/31/9998. Note 

special case when establishing a new Tariff Identifier: 

Tariff Record Related Codes, Qu. 32.

6/25/10

10/4/2011

31 The ISO has, under one of its tariffs, tariff 

documents of its members. As the eTariff XML 

schema only contains the Company Identifier of 

the owner of the Tariff Identifier, how can the 

other party to the shared tariff be made a coapplicant to the proceeding?

eFiling provides functionality to add co-applicants to 

an eTariff filing. eFiling’s instructions are located at 

https://ferconline.ferc.gov/efiling-help.asp. 

1/27/2011

32 My Transmittal Letter requested that several 

names be added to the Commission maintained 

service list in my proceeding. However, only the 

name on the service list is the one associated 

with the Company Profile. Why are the names 

in the Transmittal Letter not on the service list? 

Since Order No. 703, eFiled material is not read by 

staff to transcribe names to the Commission service 

list. Populating the Commission’s service list is 

performed by the applicant as part of the eFiling 

process. eFiling’s instructions on how to add names to 

the Commission’s service list are located at 

https://ferconline.ferc.gov/efiling-help.asp. If a party 

wishes to add more names to the Commission’s service 

list, they may do so by using the electronic 

Documentless Intervention function. Those 

instructions are available at 

https://ferconline.ferc.gov/efilinghelp.asp#intervention.

1/27/2011

33 I ZIPped my XML tariff filing using Apple’s OS 

X’s embedded compression software. However, 

upon making the filing with the Commission, I 

Apple’s OS X’s embedded compression software is 

known to include a sub-folder and a file in that sub 

folder that is usually hidden from OS X users. The 

4/18/11
12

Question Answer Date

received and error message that the eTariff Zip 

file contains more that one file. I looked at the 

file and I do not see anything other than the 

XML file. What is happening?

subfolder contains another file with the identical name 

as the file at the parent level, but whose content is 

different. eFiling screens ZIP files to ensure that only 

one file is included, and that the file is an XML file. 

The subfolder is considered by eFiling as a second file. 

eTariff filers should not use compression software that 

uses proprietary formats.

34 I made a Normal/Statutory filing in the NGA 

Gas program. I entered “Y” in the 

Suspension Motion data element. The 

Transmittal Letter stated that the pipeline 

was motioning into effect the tariff record if 

the Commission suspended the tariff record. 

The Commission suspended the tariff record 

for more than one day. Why does the 

Public Viewer show the tariff record as 

Suspended after the end of the suspension 

period?

The Suspension Motion data element is only to 

reflect the NGA pipeline’s motion proposal in the 

event of minimal suspension consistent with the 

filing requirements of section 154.7(a)(9) of the 

Commission’s regulations. A Transmittal Letter 

statement that the pipeline motions tariff records 

suspended for more than the minimal period does 

not comport with the Commission’s electronic tariff 

filing requirements to place suspended tariff 

records into effect. If the tariff records were: 

1. suspended for more than the minimal 

period, 

2. for which the Suspended Motion data 

element was populated with “N”, or 

3. the Commission rejected the pipeline’s 

minimal suspension motion into effect,

neither a Suspension Motion data element 

populated with “Y” nor a statement in the 

Transmittal Letter is adequate to place the 

suspended tariff records into effect. 

If the NGA pipeline wishes to motion into effect 

11/13/13

1/6/14
13

Question Answer Date

tariff records that remain in Suspended status, it 

must do so pursuant to section 154.206 of the 

Commission’s regulations. Such filings require a 

TOFC 610 Motion category filing with a proposed 

effective date for each record equal to or later 

than the end of the suspension period. Motion 

filings cannot propose a retroactive effective date. 

Motions filings can be made any time after the 

tariff record is suspended and before the end of 

the Commission’s suspension period or later 

effective date as proposed by the pipeline in its 

TOFC 610 Motion filing. See 149 FERC ¶ 61,123,

at P 30.

35 I need access to the eTariff XML file that 

was filed with the Commission. Can I 

request a copy of that file from the 

Commission?

The Commission does not retain a copy of the 

eTariff XML file once the data within the file has 

been extracted.

5/12/16

36 I, as an eTariff filing agent, made an eTariff 

filing. However, I forgot to select the coapplicants of the filing. How do I correct this 

mistake and add co-applicants to the 

proceeding?

eLibrary and the Commission’s Notices are 

dependent upon eTariff filing agents properly 

identifing all co-applicants as part of the eFiling 

process. If co-applicants are not properly 

identified in the eFiling process, they will not 

appear as co-applicants in eLibrary, the Notice 

and, possibly, the Commission order. 

To add co-applicants to an Open eTariff 

proceeding, prepare a new eTariff filing under the 

same CID as the one initially used. Select a Type 

of Filing category of AMENDMENT or 

5/12/16
14

Question Answer Date

COMPLIANCE as appropriate for the Associated 

Filing Identifier. File as a normal eTariff filing 

through eFiling, this time selecting the appropriate 

co-applicants.

NOTE 1: Type of Filing category AMENDMENT 

eTariff filings must have at least one Tariff 

Record. Type of Filing category COMPLIANCE 

eTariff filings do not have to have a Tariff Record. 

Both type of filings will receive a new sub-docket.

NOTE 2: The eTariff filing agent must also be 

listed as an eTariff filing agent in each coapplicant’s CID profile. If the agent is not listed in 

a company’s CID, eFiling will not list that company 

for the agent to select as a co-applicant.

37 The company wishes to file a 

NORMAL/STATUTORY filing without a 

Tariff Record and still achieve a statutory 

action date. Is that possible?

No. Order No. 714-A provides that applicants 

may only make tariff filings designated as a 

statutory filing through eTariff. Designating a tariff 

filing as a statutory filing is accomplished through 

the applicant choosing a NORMAL/STATUTORY 

or AMENDMENT Type of Filing Code appropriate 

for the program. Statutory action dates are a 

function of the date of filing and the Tariff 

Record’s Tariff Record Proposed Effective 

Date(s). A Tariff Record’s Tariff Record Proposed 

Effective Date metadata is part of a proposed 

Tariff Record. If there is no Tariff Record, the will 

be no Tariff Record Proposed Effective Date and 

5/12/16
15

Question Answer Date

a statutory action date cannot be calculated.
16

Attachment Related Codes

Question Answer Date

1 Is FERC willing to add the valid file 

extensions for each type of file identified in 

the attachment-content-type.csv file? This 

would enable software to automatically 

identify the attachment type based on the 

file's extension. In the event that the file 

extension is not unique to an attachment 

type, software could present users with a 

short list of file types from which they could 

choose.

The extension information is now provided in the 

att_content_type_code.csv file.

12/19/08

1/15/10

2 The "Record Content Type Code" file 

(record-content-type-code.csv) provides a 

"security_level" column but no 

"record_content_type_code" column. The 

"security_level" column should be changed 

to "record_content_type_code," right?

This error has been corrected. 12/19/08

3 Concerning the various software packages 

used for Attachments: how best can the 

acceptable software versions be 

determined? If software versions are too 

new will this create problems in the upload 

of the electronic tariff package?

The Secretary of the Commission determines 

which electronic document formats may be 

electronically filed with the Commission. OSEC

posts this information on the www.ferc.gov web 

site, and OSEC is delegated the responsibility of 

maintaining the Attachment Content Type Codes 

(att_content_type_code).

12/19/08

4 The Attachment Reference Code list posted 

on FERC’s site contains a cross-reference 

to Filing Type. Will this list be normalized 

The Attachment Reference Codes for Transmittal 

Letter, Tariff, Marked Tariff and Other have been 

normalized across Types of Filings as of 

12/19/08

1/15/10
17

Question Answer Date

across Filing Types? 12/7/2009. 

5 RTF was chosen as one of the “standards”. 

Was SGML (Standard Generalized Markup 

Language) considered?

RTF was one of two Record Binary Data 

(record_binary_data) versions of software 

recommended to the Commission by NAESB and 

accepted by Order No. 714. As noted by Order 

No. 714, the standards are the result of a 

consensus after a long process starting in 2001.

12/19/08

6 Since Office 2007/Word 2007 supports 

many more features than RTF, is there any 

guideline on how to translate these features 

to RTF?

Microsoft provides compatibility documentation for

various versions of Word 2007 with RTF entitled Rich 

Text Format (RTF) Specification. 

There are no OSEC guidelines at this time. Each 

company needs to asses the use of its word processing 

capabilities with respect to creation of RTF files. Our 

guidance would be that tariff provisions should not use 

complex formats. A reasonable test is to view the 

document after it has been saved in RTF in an 

alternative software reader than what was used to create 

the RTF, such as WordPad.

12/19/08

5/25/10

8/12/13

7 A Word 2007 DOCX saved as a RTF may 

expand tremendously. There may be a problem 

with size of files once translated to RTF from 

DOCX. E.g. I saved a 10mb DOCX as a RTF 

and it became 243 MB. However zipping that 

same file it became 23 MB while the DOCX 

zipped yielded 8MB (a resulting 3x difference).

Each company needs to asses the use of its word

processing capabilities with respect to creation of RTF 

files. Our guidance would be that tariff provisions 

should not use complex formats. There is a 10MB limit 

to the Record Binary Data (record_binary_data). Tariff 

creation software should be chosen and configured to 

conform to the technological limits of RTF and the 

OSEC Implementation Guide.

See also the response to Question 12 below.

12/19/08

4/18/11
18

Question Answer Date

8 A map/line drawing/diagram greatly increased 

the size of the RTF versions of the Record 

Binary Data file. What are the alternatives 

means of creating this data?

Maps/line drawings/diagrams in JPG format can 

significantly increase the RTF file size. Try converting 

from JPG to GIF format, and saving in grey scale. An 

alternative is to file the Maps/line drawings/diagrams as 

a separate tariff section in PDF format. 

See also the response to Question 12 below.

5/25/10

4/18/11

9 My eTariff filing was rejected by the 

Commission as it failed to include a Clean 

Tariff. However, the att_ref_code.csv table 

indicates that a Clean Tariff is not required. 

Why was my filing rejected?

Order No. 714 did not change the documentation 

requirements for a complete tariff filing. The 

convention for eTariff filings permits the Clean Tariff 

to be part of the Transmittal Letter or attached as a 

separate document. The flexibility eTariff provides 

users to satisfy the attachment requirement does not 

change the requirement that the documentation must be 

provided. 

Note that the OSEC and the Commission have the 

ability to change the eTariff attachment filing 

requirements to mandate the attachment of a separate 

Clean Tariff document as a means of ensuring the 

regulatory requirement is satisfied.

5/25/10

10 My formula rates tariff sheets are creating large 

tariff sections when converted into RTF files. 

What can I do?

Many formula rate paper tariff sheets were constructed 

by printing directly from the spreadsheet software or 

copying spreadsheets into a word processor and saving 

in the native file format before printing. 

RTF is capable of receiving some forms of embedded 

objects and rendering tables. However RTF is not as

efficient as native file formats for tables and styles. 

6/10/10

4/18/11
19

Question Answer Date

When converting formula rate tariff sheets to RTF, 

review the tariff sheets to ensure that the existing tariff 

sheets are compliant with the minimum font size 

required by the Commission’s regulations (10 point 

font: sec. 385.2003(a)(4) (10)).

Review whether a table structure is required, or whether 

columns or tabs will suffice.

Review whether tables contain unnecessary rows or 

columns.

Consider converting the formula rate into a plain-text 

format to remove most table and style codes. For 

example, Excel provides Save As|MS –DOS text 

format. For an example of this technique for rendering

large rate designs, see 

http://www.ferc.gov/industries/gas/gen-info/ratefilings/rate_fnl.pdf.

See also the response to Question 12 below.

11 Can I leave active hyper-links in my tariff

sections?

No. Leaving hyper-links in a tariff creates a security 

risk for both FERC and site that the link is directed.

6/10/10

12 My Microsoft Word file has graphics in it, and 

RTF conversion file size is large. Can I set 

some default in Word to reduce the file size? 

Yes. However, it should only be done with great 

caution and some companies may limit access to the 

necessary files to IT support personnel only. The 

Microsoft information and instructions are located here: 

http://support.microsoft.com/kb/224663

4/18/11
20

Question Answer Date

13 How can I improve the attachment descriptions 

that appear in eLibrary?

eLibrary prominently displays the hyperlinked 

Attachment Document File Name as the lead item, 

followed by the Attachment Description. As a result, 

many applicants believe that the Attachment Document 

File Name is the attachment’s description. However, it 

is not. Further, many applicants who try to name their 

attachment file names with complete descriptions 

quickly run into the 60-character limit for the 

Attachment Document File Name data element. The 

effective available Attachment Document File Name 

character limit is really about 55, as the remaining 

characters must be reserved for the extension (“dot” and 

the extension characters). 

eLibrary’s description of the attachment follows the 

hyperlinked Attachment Document File Name. 

Applicants should use the Attachment Description to 

pass the attachment’s description to eLibrary. The 

Attachment Description data element has an 80 

character limit. Many applicants do not change their 

software’s default Attachment Description of “Other”, 

and thereby miss an opportunity to provide eLibrary 

and the public a more informative description of the 

attachment’s content. 

5/25/11

14 I made a mistake and did not identify a 

document as Privileged/CEII in the Attachment 

Security Code. What should I do to correct this 

mistake?

All documents that are part of an eTariff filing are, upon 

acceptance by OSEC as a tariff filing, automatically and 

immediately uploaded into eLibrary and made part of 

the public record with the security status provided by 

the Applicant. FERC is not responsible for detecting 

1/6/14
21

Question Answer Date

and correcting filer errors.

Applicants cannot change the security status of a 

document once in the public record through an eTariff 

filing. When such an error occurs:

1. The Applicant should email 

FERCOnLineSupport@ferc.gov. The email should

identify the Applicant, docket number, date of filing 

and accession number of the specific document at 

issue, and request FERC staff to change the status of 

the document to either privileged or CEII, as 

appropriate. 

2. The Applicant is responsible for correcting their 

filing. The Applicant should modify their filing 

using the appropriate TOFC to ensure the proper set 

of documents are before the Commission and the 

public consistent with 18 C.F.R. 388.112 (2014). 

This regulation requires:

a. A redacted pubic version of the document

b. An unredacted non-public version of the 

document, and 

c. A proposed form of protective agreement.

Alternatively, instead of modifying the filing, the 

Applicant may Withdraw the filing and start over. Note 

that Withdraw of a tariff filing does not remove the 

filing or any of its documents from eLibrary or change 

the security status of any document.
22

Tariff Record Related Codes

Question Answer Date

1 Discuss "PRO FORMA" record 

change type relative to version 

numbers. It seems that "PRO 

FORMA" tariff records will "use up" 

a version. Could PRO FORMA 

tariff record versions use version 

numbers in the 1000’s, for example, 

so that they do not collide with the 

natural progression of version 

numbers? Are there any tariff 

record filing rules that are relaxed 

for records filed with a "PRO 

FORMA" change type?

Order No. 714 gave applicants some discretion in 

creating Record Version Number (record_version_num) 

entries, and the application of such discretion to Pro 

Forma Tariff Records would be reasonable. As 

applicants usually file Pro Forma tariff sections as part of 

a request for a full review of the proposed tariff changes, 

all the Tariff Record Content Data should be filed for 

each Pro Forma Tariff Record.

12/19/08

2 Tariff Record Proposed Effective 

Date: this XML field is marked as 

required in the "OSEC

Implementation Guide," however, it 

wouldn't be needed for a withdrawal 

filing, for example. Is this right?

Aside from withdrawal filings, are 

there other types of filings for which 

Tariff Record Proposed Effective 

Date would not be required?

Currently, there is no Withdraw category Type of Filing 

Code (filing_type) that requires a Tariff Record Proposed 

Effective Date (proposed_effective_date) to implement 

the Commission’s regulatory business rules. However, 

that may not be the case in the future.

12/19/08

3 When filing a tariff record with 

multiple options, do all tariff records

in the filing have to have the same 

number of options? For example, if 

The Commission’s normal business practice, and 

adopted in the OSEC Implementation Guide, is to accept 

one option in its entirety, reject the others, and require a 

compliance filing to include proposals in other options 

12/19/08
23

Question Answer Date

tariff record #12 was being filed with 

option codes "A" and "B," would 

tariff record #23 also need to be 

filed as an option "A" and an option 

"B" even if only one version of 

record #23 was desired?

where accepted. Given this business practice, 

applicants proposing different Option Code sets may 

choose to file complete sets to reduce the likelihood of a 

subsequent compliance filing or the number of Tariff 

Records that must be included in a subsequent 

compliance filing.

4 Under eTariff, when filing a new version of a given tariff record, in addition to the content of the record 

being updated, the organization of tariff can also be changed. Specifically, the "Tariff Record Collation 

Value" and the "Tariff Record Parent Identifier" can also be changed. I present here an example filing 

scenario followed by some questions.

Scenario

Given the following tariff records which represent only a portion of the overall tariff:

#17 v0.0.0 General Terms & Conditions

|

+---#1120 v3.0.0 Gas Quality

Record id 17 is the "General Terms & Conditions" section. Record id 1120 is the "Gas Quality" section, 

which has some history as it is on version 3.0.0. Record 1120 is a child of record 17.

Filing scenario: Two new sections are being added: "Rate Guarantees" and "Issue Resolution Response".

Like "Gas Quality," these sections speak to "Pipeline Performance." As such, a new section called 

"Pipeline Performance" will also be added. Its parent will be "General Terms & Conditions" (record 17).

"Gas Quality," "Rate Guarantees," and "Issue Resolution Response" will all be children of "Pipeline 

Performance". Therefore, the new structure of the tariff will be as follows:

#17 v0.0.0 General Terms & Conditions

|

+---#???? v?.?.? Pipeline Performance

 |
24

Question Answer Date +---#???? v?.?.? Gas Quality

 |

 +---#9217 v0.0.0 Rate Guarantees

 |

 +---#9218 v0.0.0 Issue Resolution Response

There are 3 ways to file these changes to the tariff that all have roughly the same results. They are 

presented below:

(1) File 3 new records for "Pipeline Performance," "Rate Guarantees," and "Issue Resolution." File "Gas 

Quality" as v4.0.0. of record id 1120 and change its parent to be the "Pipeline Performance" record.

(2) File v4.0.0 of record id 1120 changing it over to be the "Pipeline Performance" record, which obviates 

the need to change its parent. In addition, file 3 new records for "Gas Quality," "Rate Guarantees," and 

"Issue Resolution."

(3) Cancel record id 1120. In addition, file 4 new records for "Pipeline Performance," "Gas Quality," "Rate 

Guarantees," and "Issue Resolution."

4a For industry members: How often 

does such a filing scenario occur?

Some of this data is available from the Commission’s 

FASTR data, available at 

http://www.ferc.gov/industries/gas/geninfo/fastr/htmlall/index.asp. Every Volume No. 1 with a 

revision above “Original” constitutes a reorganized tariff. 

Adding sections to existing tariffs most frequently is 

associated with the Commission imposing new tariff 

requirements. 

12/19/08

4b For FERC: What is the preferred 

filing method (1, 2, or 3) for such a 

filing?

All the proposed filing methods require the use of a Tariff 

Record Collation Value (collation_value) to organize the 

Tariff Records in the proposed fashion. Filing method 1 

is preferred: retain the use of Tariff Record No. 1120, 

and relocate its position in the tariff through a new Tariff 

Record Collation Value. This method preserves the 

history of Tariff Record No. 1120.

12/19/08
25

Question Answer Date

5 How are the energy companies to 

use the parent relationship in a 

sheet-based tariff to meet the 

needs of the eTariff process and 

FERC's eTariff Viewer?

At NAESB’s public web site is a Draft Implementation 

Guide 01/25/08 (Redline) 

(http://www.naesb.org/pdf3/etariff012308a2.doc). It has 

an extensive set of Use Case Descriptions starting at 

approximately page 44. The Use Cases show 

examples of how to use the Tariff Record Identifier 

(record_id) and Tariff Record Parent Identifier 

(record_parent_id) that will be used by the FERC’s 

eTariff Viewer to show the structure of the Tariff Records 

in the Table of Contents pane.

12/19/08

10/8/10

6 Should the Title Sheet of Volume X 

be the parent and all the tariff 

sheets in Volume X be its children?

This suggestion would work. See response to Business 

Rules, Question No. 9.

12/19/08

7 Would this solution cause problems 

in generating the Table of 

Contents?

No. 12/19/08

8 These questions all relate to filings having associated filings and tariff records having associated tariff 

records.

8a When a filing has an associated 

filing, is it necessarily true that 

every tariff record contained within 

will be associated with the same 

filing?

The Associated Filing Identifier (associated_filing_id) is 

the Filing Identifier (filing_id) for the previous Tariff Filing 

to which the subject Tariff Filing or Tariff Record 

pertains. The Filing Data’s Associated Filing Identifier 

does not necessarily determine the appropriate Tariff 

Record Content Data’s Associated Filing Identifier. See 

8(d) for examples.

12/19/08

8b When a tariff record being filed is 

associated with a previously filed 

tariff record, the Associated Filing 

Identifier, Associated Record 

Identifier, and Associated Option 

True. However, if a set of several tariff records with the 

same Tariff Record Identifier and Option Code are in the 

associated tariff filing, the action will be against the 

whole Tariff Record Identifier set.

12/19/08

8/12/13
26

Question Answer Date

Code work together to uniquely 

identify the associated record.

True?

8c When a tariff record being filed is 

associated with a previously filed 

tariff record, must the filing within 

which it is being filed also be 

associated with a previously filed 

filing? Must they be the same 

filing?

No. 12/19/08

8d Can you provide an example where 

the Associated Fling ID at the Filing 

level would differ from the 

Associated Filing ID at the Tariff 

record level?

Example A: A COMPLIANCE Type of Filing that 

CHANGEs Tariff Records from a NORMAL Type of 

Filing category filing (e.g., RP01-234-000) and Tariff 

Records from two subsequent and associated 

AMENDMENT Type of Filing category filings (RP01-234-

001 and RP01-234-002).

Example B: A Compliance Type of Filing that CHANGEs 

a Tariff Record from a NORMAL Associated Filing, 

which would have the association data, and introduces a 

NEW Tariff Record, which would have no association 

data.

Example C: A Motion Type of Filing that moves into 

effect suspended Tariff Records from a NORMAL and its 

AMENDMENT Tariff Filings.

12/19/08

8e Could there be multiple Associated 

Filing IDs at the Tariff record level?

Multiple Tariff Records can have different Associated 

Filing IDs, but any given Tariff Record Identifier can have 

no more than one Associated Filing ID.

12/19/08

9 Under what circumstances will a The MOTION, WITHDRAW and CANCELLATION Type 12/19/08
27

Question Answer Date

filing include tariff records that do 

not contain tariff content such that 

fields record_content_type_code, 

record_binary_data, and 

record_plain_text will be blank.

>Withdrawal filings?

>Cancellation filings?

>Motion filings?

Are there other filing types?

of Filing categories (filing_type) do not require content 

for the record_content_type_code, record_binary_data, 

and record_plain_text fields. Further, regardless of the 

Type of Filing, Tariff Records with a Record Change 

Type (record_change_type) populated with CANCEL or 

WITHDRAW do not require content for the 

record_content_type_code, record_binary_data, and 

record_plain_text fields.

In addition, no tariff text may be required for some tariff 

organization. For example, a parent record may only 

have text in the Record Content Description and/or Tariff 

Record Title.

10/8/10

10 Could record binary data in .rtf 

format contain a page break? For 

instance, because there appears to 

be no limitation of content on a tariff 

sheet, one could presumably have 

the content run over to the next 

sheet but continue to name that 

Sheet No. 200, thus one would 

need to have a break to make it 

work.

Yes. The eTariff software system will not be altering any 

of the binary content of the tariff record. If the material is 

retrieved as an rtf file, then the page break codes should 

show up as they were entered. However, in a web page 

viewer, or any other conversion to other formats, page 

breaks may or may not be recognized.

12/19/08

11 Consider the following scenario: 

(A) An eTariff record is filed with 

FERC.

(B) FERC accepts the changes 

subject to conditions.

(C) The record is filed again in a 

compliance filing (like today's 

Yes, the Record Effective Priority Order (priority_order) 

is required: Tariff status is largely controlled by dates 

(think of the statutory clock and notice periods as 

examples). The problem becomes what happens for the 

same tariff record of a single date with multiple tariff 

record changes hitting on the same date? 

1) Two tariff record changes: In this scenario, which is 

3/6 /09
28

Question Answer Date

Substitute tariff sheets) with the 

same effective date as in (A) above.

Is it necessary that the two filed 

records (in (A) and (C) above) have 

different Record Effective Priority 

Order values?

the same as in the question for date 1/1/2020, the 

“substitute” record is likely to take precedence over the 

“original” record, and the objective is to show as 

“effective” the substitute record for the whole day.

Section Revision Priority Order Disposition Tariff Record 

Status

Section 156 6.0.0 500 Minimal Suspension Superceded

Section 156 6.1.0 520 Accepted Effective

2) But scenario 1) is simplistic, and there are often 

more complex issues. Suppose the example below for a 

given date 1/1/2020:

Section Revision Priority Order Disposition Tariff Record 

Status

Section 156 6.0.0 500 Minimal Suspension Superceded

Section 156 7.0.0 600 Accepted Effective

If a change in the tariff record text was required to 

v6.0.0, but not 7.0.0, then the compliance filing would 

be:

Section Revision Priority Order Disposition Tariff Record 

Status

Section 156 6.0.0 500 Minimal Suspension Superceded

Section 156 6.1.0 520 Accepted Superceded

Section 156 7.0.0 600 Accepted Effective

If a change in the tariff record text was required to 

v6.0.0, and if affected the tariff text of 7.0.0, then the 

compliance filing would be:

Section Revision Priority Order Disposition Tariff Record 

Status

Section 156 6.0.0 500 Minimal Suspension Superceded
29

Question Answer Date

Section 156 7.0.0 600 Accepted Superceded

Section 156 7.1.0 620 Accepted Effective

12 What are the status conditions for 

Natural Gas Act (natural gas 

pipeline) tariff records?

Status conditions vary over time and in accordance with 

a variety of statutory, regulatory and business rules. The 

combination of the meta data required by the XML 

schema and the business rules permit at least the 

following tariff record status conditions:

Pending

Accepted

Effective

Suspended

Superceded

Rejected

Withdrawn

Overtaken by events

Pro Forma

3/6 /09

13 What are the status conditions for 

Federal Power Act (public utility) 

tariff records?

Status conditions vary over time and in accordance with 

a variety of statutory, regulatory and business rules. The 

combination of the meta data required by the XML 

schema and the business rules permit at least the 

following tariff record status conditions:

Pending

Pending (Tolled)

Accepted

Effective

Suspended

Superceded

Rejected

Withdrawn

Overtaken by events

3/6/09
30

Question Answer Date

Pro Forma

14 What are the status conditions for 

Interstate Commerce Act (oil 

pipeline) tariff records?

Status conditions vary over time and in accordance with 

a variety of statutory, regulatory and business rules. The 

combination of the meta data required by the XML 

schema and the business rules permit at least the 

following tariff record status conditions:

Conditionally Accepted

Conditionally Effective

Accepted

Effective

Suspended

Superceded

Rejected

Withdrawn

Overtaken by events

Pro Forma

3/6 /09

15 What are the status conditions for 

Part 284 program (NGPA intrastate 

and NGA Hinshaw gas pipelines) 

tariff records?

Status conditions vary over time and in accordance with 

a variety of statutory, regulatory and business rules. The 

combination of the meta data required by the XML 

schema and the business rules permit at least the 

following tariff record status conditions:

Conditionally Accepted

Conditionally Effective

Pending (Tolled)

Accepted

Effective

Superceded

Rejected

Withdrawn

Overtaken by events

3/6 /09

11/13/13
31

Question Answer Date

Pro Forma

16 What are the status conditions for 

Power Administration tariff records?

Status conditions vary over time and in accordance with 

a variety of statutory, regulatory and business rules. The 

combination of the meta data required by the XML 

schema and the business rules permit at least the 

following tariff record status conditions:

Conditionally Accepted

Conditionally Effective

Accepted

Effective

Superceded

Rejected

Withdrawn

Overtaken by events

Pro forma

3/6 /09

17 What is the tariff record status 

condition of “Overtaken by events”?

The tariff record status condition of “Overtaken by 

events” indicates the disposition of a tariff record whose 

status before the Commission is moot because it has 

been overtaken by some other filing. Currently, if an 

applicant files a correction to an initial filing’s tariff record 

or a correction to a compliance filing’s tariff record, the 

applicant should indicate that the underlying record is 

withdrawn. If it fails to do so, the Commission should 

reject the tariff record as moot. 

In eTariff, AMENDMENTS to a NORMAL/STATUTORY

or another AMENDMENT, or COMPLIANCE to a 

COMPLIANCE Type of Filing should target the 

underlying tariff record utilizing the associated date 

elements: Associated Filing Identifier, Associated 

3/6 /09

1/15/10

5/25/10

1/27/11
32

Question Answer Date

Record Identifier and Associated Option Code. Upon 

OSEC acceptance of the later tariff filing, the associated 

tariff record’s status will convert to “Overtaken by events” 

without further action by the applicant or the 

Commission.

18 What is the FPA and NGPA 

programs’ tariff record status 

condition of “Pending (tolled)”?

The “Pending (tolled)” status condition indicates that the 

Commission has issued an order finding a 

NORMAL/STATUTORY or AMENDED FPA or NGPA 

program type of filing (a filing type for which there is a 

statutory or regulatory time the Commission must act) 

tariff filing deficient (FPA and NGPA programs) or 

protested (NGPA program) and cannot be processed

within the time-line. The statutory or regulatory time for 

the Commission to act is no longer applicable. The tariff 

filing and tariff records will remain in this status until (a) 

an AMENDMENT type of filing is filed, which will reset 

the filing date for the statutory or regulatory clock to the 

date of the AMENDMENT filing; (b) the Commission 

rules upon the tariff record; or (c) the filing is withdrawn.

Note that in the NGPA program, the optional procedures 

of 284.123(g) provide for regulatory tolling (without 

Commission order) of the tariff records in the event the 

filing remains protested by the 60th day from the date of 

filing, and the tolling status may be removed by 

regulation (without Commission order) if the protest is 

withdrawn within the reconciliation period.

3/6 /09

1/15/10

5/25/10

11/13/13

19 What is the difference between the 

tariff record status conditions of 

“Accepted” and “Effective”?

The tariff record status condition of “Accepted” indicates 

that the tariff record has been accepted by the 

Commission or pursuant to some other statutory or 

3/6 /09
33

Question Answer Date

business rule, and may become effective some date in 

the future. The tariff record status condition of 

“Effective” indicates that the tariff record has been 

Accepted and is in effect. 

20 What is the tariff record status 

condition of “Conditionally 

Accepted”?

Certain programs’ statutory, regulatory or business rules 

permit a tariff record to become effective before 

Commission action is required. Conditionally Accepted 

indicates a tariff record change is proposed to be 

effective on a specified future date. 

3/6 /09

21 What is the tariff record status 

condition of “Conditionally 

Effective”?

Certain programs’ statutory, regulatory or business rules 

permit a tariff record to become effective before 

Commission action is required. The tariff record status 

condition of “Conditionally Effective” indicates that the 

tariff record is effective, but that final Commission action 

is still pending.

3/6 /09

22 NGA section 7 certificate filings 

commonly contain “Pro Forma” tariff 

records. Are NGA section 7 

certificate filings’ “Pro Forma” tariff 

records required to be filed utilizing 

eTariff.

Not at this time. If the Commission decides to require 

NGA section 7 certificate filings to be filed utilizing the 

eTariff gateway of eFiling, that requirement will be the 

subject of a separate Notice and/or rulemaking. 

All NGA section 4 compliance filings to Commission 

orders on NGA section 7 certificate filings must utilized 

eTariff. These compliance filings may contain Pro 

Forma, New or Changed tariff records.

3/6 /09

23 If a Conditionally Accepted or 

Conditionally Effective tariff record 

is Suspended or Rejected, must the 

applicant refile the tariff record that 

was formerly effective? 

No. The status of the tariff record that was superceded 

by the Conditionally Accepted or Conditionally Effective 

tariff record will revert to tariff record status of Effective. 

3/6 /09

24 Can the Associated Filing Identifier No. The Associated Filing Identifier 3/6 /09
34

Question Answer Date

(associated_filing_id) reference a 

Filing Identifier (filing_id) other than 

the filer’s?

(associated_filing_id) must reference only Filing 

Identifiers (filing_id) made by the filer as identified by the 

Company Identifier (company_id).

25 Can the Associated Record 

Identifier (associated_record_id) 

reference a Tariff Record Identifier 

(record_id) of another Company

Identifier (company_id) or Tariff 

Identifier (tariff_id)?

No. The Associated Record Identifier 

(associated_record_id) must reference only a Tariff 

Record Identifier (record_id) that exists in the Tariff 

Filing’s Tariff Identifier (tariff_id) for the of the Tariff 

Filing’s Company Identifier (company_id).

3/6 /09

26 In a situation of multiple option sets 

– Options A, B and C, and a new 

Tariff Record Identifier (record_id) 

is being created, what should the 

different option sets’ Record 

Change Type 

(record_change_type) contain?

There must be at least one Record Change Type 

(record_change_type) of NEW in the first option the 

proposed new Tariff Record Identifier (record_id)

appears. Thereafter and within the tariff filing’s option 

sets, Tariff Record Identifier (record_id) of either NEW or 

CHANGE are acceptable. Acceptable examples for a 

new Tariff Record Identifier (record_id) of “1234”:

Example 1:

Option Record Change Type 

 A NEW

 B CHANGE

 C CHANGE

Example 2:

Option Record Change Type 

 A NEW

 B NEW

 C CHANGE

Example 3:

5/25/10
35

Question Answer Date

Option Record Change Type 

 A null

 B NEW

 C CHANGE

27 For tariff records with a Record 

Change Type 

(record_change_type) of PRO 

FORMA, must the Option Code 

(option_code) be populated?

Yes. There can be multiple PRO FORMA option sets. 

However, PRO FORMA option sets should avoid Option 

Code (option_code) “A”, as that code designates the 

applicant’s primary real (as opposed to pro forma) tariff 

change proposal. 

5/25/10

28 I found a mistake in a tariff record in 

a tariff filing that is still pending 

before the Commission. How do I 

correct the tariff record?

If the pending tariff filing is a Normal/Statutory filing, then 

file an Amendment category type of filing; or if the 

pending tariff filing is a Compliance filing, then file a 

Compliance category type of filing. The corrected tariff 

records should contain all the associated tariff record 

information (associated_filing_id, associated_record_id, 

and associated_option_code) to properly target the 

incorrect tariff record. Providing the associated tariff 

record information informs the Commission that the 

targeted tariff record is replaced. The Commission will 

reflect the targeted tariff record’s status as OBE 

(Overtaken By Events).

6/10/10

29 I found a mistake in tariff record 123 

in a tariff filing that is still pending 

before the Commission. Tariff 

record 123 had several child 

records with Record Change Type 

NEW. I filed a single tariff record 

consisting of (a) a correction to tariff 

record 123 with a Record Change 

Type WITHDRAW to withdraw the 

Any proposal to withdraw or OBE a pending tariff record 

with pending child records, regardless of whether the 

child records are in the proceeding or another 

proceeding, will be deemed either withdrawn or OBE, 

as there is no longer a parent record for the child records 

to attach. All tariff records must have a parent to provide 

the tariff with structure and continuity. Tariff records 

cannot “float” in a tariff, and must be “anchored.”

6/25/10
36

Question Answer Date

record or (b) an associated tariff 

record 567 with tariff record 123 to 

OBE tariff record 123. Now all the 

child records with Record Change 

Type NEW to tariff record 123 are 

no longer visible in the Public Tariff 

Viewer and appear to have been 

either (a) withdrawn or (b) OBE. 

What happened?

Another analog to visualize the situation: imagine a NEW 

section to an outline, and the section has several subsections. If the highest level of the section is removed, 

all the subsections will be removed at the same time. 

30 My filing was rejected by the 

Commission as it failed an eTariff 

validation test. I corrected the 

error. However, the filing was 

rejected again as it failed another 

test not previously identified. How 

can this happen?

Many of the Secretary’s validation tests are complex, 

requiring use of several data elements from the XML file 

and comparing to several other data elements in the 

Commission’s eTariff data base. If the expected data 

from the XML filing are not available or unexpected, the 

validation test results will find that there was an error and 

reject the filing. The complex validation tests will not

run. Once the filing has been refiled with the previously 

noted errors corrected, then the complex tests can run. 

The result of those complex tests can be other error 

messages and rejection of the filing. It is always a good 

idea to first test your XML filing in the Sandbox to ensure 

the filing will pass all validation tests.

1/27/2011

31 I tried to upload my test tariff filing 

into the Sandbox, but I received an 

error message that the site is 

unavailable, that I do not have 

rights to the site, or nothing 

happens. What is wrong with your 

Sandbox site?

In most instances the problem is with the user’s internet 

browser’s security settings with regard to access to and 

use of an FTP site. Either use your browser’s HELP 

feature to research the appropriate settings or discuss 

your requirement to access the Sandbox’s FTP site with 

your IT personnel.

Frequently, browser settings permitting access to the 

5/25/11
37

Question Answer Date

Sandbox are lost when browsers are upgraded. If you 

formerly had access to the Commission’s Sandbox but 

have lost access, check your FTP security settings. 

32 A new company is creating a new 

tariff, but does not know when it will 

go into service. What Tariff Record 

Proposed Effective Dates should 

the Baseline filing contain?

Baseline tariff filings with “to be determined” proposed 

effective dates of 12/31/9998 need to include at least 

one tariff record with a Tariff Record Proposed Effective 

Date in the near future – date of filing is acceptable. The 

reason is that the earliest Tariff Record Proposed 

Effective Date in a Baseline filing becomes the 

establishment date for the Tariff Identifier. No Tariff 

Record can have an effective date that predates the 

Tariff Identifier’s establishment date. Therefore, if a 

Tariff Identifier has an establishment date of 12/31/9998, 

once the company goes into service and informs the 

Commission of its in-service date, it will not be able to 

provide a Tariff Record Proposed Effective Date earlier 

than 12/31/9998. The company will have to file a 

Cancellation of the Tariff Identifier with the 12/31/9998 

establishment date and file a new Baseline filing to 

create a new Tariff Identifier with the in-service date.

10/4/11

33 The company needs to make a 

Normal/Statutory, Amendment or 

Compliance filing that requires several

tariff records to reflect intermediate 

changes; or, the company wishes to 

propose several different changes to a 

tariff record, each change with a 

different prospective effective date. 

How can this be done?

There are two methods to make tariff filings that involve a set 

of tariff records with the same Tariff Record Identifier. 

Assume an example were one tariff record needs 4 versions.

Method 1: This method requires 4 tariff filings, each tariff 

filing containing one tariff record. Do NOT associate at the 

Tariff Record Content Data Level, as that will result in the 

target tariff record or record set becoming OBE if that record 

or record set is in a Pending, Tolled, Conditionally Accepted 

or Conditionally Effective status.

2/3/14
38

Question Answer Date

Method 2: Multiple tariff records with the same Tariff 

Identifier and multiple Tariff Record Proposed Effective Dates 

(a Tariff Record ID set) can be filed in a single tariff filing. 

All the proposed tariff records with the same Tariff Identifier 

must have the same Option Code. However, each tariff record 

must have a different Record Effective Priority Order. Do 

NOT associate at the Tariff Record Content Data Level, as 

that will result in the target tariff record or record set 

becoming OBE if that record is in a Pending, Tolled, 

Conditionally Accepted or Conditionally Effective status.

Example:

Tariff Record ID Priority Order Option Code P. Eff. Date Ass. Tariff Record 

 1589 1085 A 1/8/10 Null

 1589 1258 A 2/8/10 Null

 1589 1565 A 3/8/10 Null

 1589 1566 A 3/8/10 Null

Under Method 2, make sure the Record Effective Priority 

Order is valid for each Tariff Record Proposed Effective Date. 

Method 1 is the best method for those who have limited 

experience with eTariff and/or whose eTariff software does 

not validate associations at the Tariff Record Content Data 

Level.

Method 1 also will establish different statutory effective 

dates (in the example above, 3 different dates), while 

Method 2 will establish a statutory date based on earliest 

proposed effective date.

34 I made a filing following Method 2 If the tariff records in the subject tariff filing are Pending, 2/3/14
39

Question Answer Date

describe in Qu. 33 above, with a Tariff 

Record ID set containing 4 tariff 

records. One of those records has a 

mistake that needs to be corrected. 

How can I correct that record?

Tolled, Conditionally Accepted or Conditionally Effective, 

then an Amendment or Compliance filing (as appropriate) 

may be filed to correct the tariff record. However, the whole 

Tariff Record ID set of 4 tariff records must be refiled. 

Remember to increment the Record Effective Priority Order. 

With at least one of the tariff records in the tariff record set, 

associate at the Tariff Record Content Data Level. This 

association at the Tariff Record Content Data Level will OBE 

ALL the proposed tariff records in the set in the targeted tariff 

filing.

35 I made a filing following Method 2 

describe in Qu. 33 above, with a Tariff 

Record ID set containing 4 tariff 

records. Why is it not possible to 

correct only select records in the Tariff 

Record ID set?

eTariff’s XML Schema Version 1 does not provide enough 

data elements to correctly target a single tariff record in a 

Tariff Record ID set.

For example, Filing Identifier 687 proposed and has pending:

Tariff Record ID Priority Order Option Code P. Eff. Date 

 1589 1085 A 1/8/10 

 1589 1258 A 2/8/10 

 1589 1565 A 3/8/10 

 1589 1566 A 3/8/10 

If Line 3 (Tariff Record ID 1589, Priority Order 1565, Option 

Code A with a Tariff Record Proposed Effective Date of 

3/8/10) is in error, the eTariff XML schema, at the associated 

Tariff Record Content Data Level, only request data elements 

the Tariff Record ID and the Option Code. These are not 

enough data to select the proper tariff record in the Tariff ID 

set that is in error.

36 I made a Normal/Statutory or 

Compliance filing following Method 2 

describe in Qu. 33 above. What other 

Any Type of Filing Code or Record Change Type that requires 

providing associated tariff record data at the Tariff Record 

Content Data Level should be treated with extreme caution.

2/3/14
40

Question Answer Date

limitations are there to the use Tariff 

Record ID sets? Normal/Statutory filings may be revised using Amendment

category Type of Filing Codes, and Compliance Statutory 

filings may be revised using Compliance category Type of 

Filing Codes. See Qu. 34 above.

Record Change Type Withdraw that targets any tariff record 

within a filing’s Tariff Record ID set will withdraw the 

complete Tariff Record ID set.

37 I made a tariff filing with a Tariff 

Record ID set that the Commission 

suspended. How do I move the 

suspended tariff records into effect or 

change their effective dates?

The Motion category of Type of Filing Codes is used to 

motion tariff records into effect and/or change their effective 

date, as permitted by Commission regulation. Motion filings 

can only be directed to tariff records that are in Suspended 

status. 

The use of a Motion filing targeting a suspended Tariff Record 

ID set will result in all the tariff records in the Tariff Record 

ID set going into effect on the same date (see Qu. 35). If 

multiple tariff records with different Tariff Record Proposed 

Effective Date in a Tariff Record ID set are provided in the 

Motion filing, the actual Effective date that will appear in the 

Commission’s records is unpredictable.

The proper method to change the date of Suspended tariff 

records in a Tariff Record ID set is to file a Compliance (FPA 

Program) or Normal/Statutory (Oil Program) filing that 

contain a new Tariff Record ID set with the new Tariff Record 

Proposed Effective Dates. Such filings in the FPA and Oil 

Programs should state in the Transmittal Letter that the 

Commission should act before the automatic end of the 

2/3/14
41

Question Answer Date

suspension period when Suspended tariff records 

automatically change status to Effective. 

38 My filing was rejected because of 

OSEC Validation Rule 80: A tariff 

record's Record Effective Priority 

Order in the filing duplicates an 

effective or pending Record Effective 

Priority Order. Which records need to 

be checked to eliminate this error?

The most common reason eTariff filings are rejected by the 

Secretary is OSEC Validation Rule 80. The Secretary’s 

rejection email provides the Tariff Record Identifier that 

caused the error to assist filers in identifying and correcting 

the problem. Each Tariff Record Identifier’s Record Effective 

Priority Order in a proposed tariff filing should be checked

two ways:

1. If there are multiple identical Tariff Record Identifiers in 

the same Option Set in the same filing, all Record 

Effective Priority Order numbers must be unique within 

the filing.

2. If the proposed tariff record in the filing has an identical 

Tariff Record Proposed Effective Date as another version 

of the tariff record filed with the Commission, the Record 

Effective Priority Order numbers must be unique. If the 

tariff record with the Commission has the status condition 

of Pending, Tolled, Conditionally Accepted or 

Conditionally Effective, check the Tariff Record Proposed 

Effective Date of that pending record. If the status 

condition is Accepted, Suspended or Superceded, then 

check the Commission’s effective date for that record.

1/6/14

39 The Commission changed the effective 

date for a tariff record. Now the 

Record Effective Priority Order 

conflicts with another tariff record that 

has the same effective date or the same 
42

Question Answer Date

Tariff Record Proposed Effective Date.

39A Which tariff record will appear in the 

Commission Public eTariff Viewer and 

eTariff data base as Effective and 

which will appear as Superceded?

Because the tariff records’ Record Effective Priority Order

numbers are identical for the same effective date, there is no 

basis that the software can determine what was the intent of 

the Commission or the applicant as to which tariff record 

should be Effective and which tariff record should be 

Superceded. The Commission’s eTariff data base and Public 

eTariff Viewer will randomly select one of the tariff records as 

Effective and place the other tariff record into the Superceded 

status category.

1/6/14

39B How should conflicting Record 

Effective Priority Order situations be 

corrected?

If the proposed tariff record is still Pending before the 

Commission, then the applicant should file an 

Amendment/Compliance filing, as appropriate, with a revised 

tariff record with an appropriated Record Effective Priority 

Order. The tariff record should be associated with the 

underlying Pending tariff record such that that record will 

become OBE.

If the tariff record has been accepted, then the applicant should 

file a Compliance filing with a revised tariff record with an 

appropriated Record Effective Priority Order. 

1/6/14

39C What are the most common situations 

that Commission orders may change an 

effective date and thus increase the risk 

that there may be identical Record 

Effective Priority Order numbers?

The most common situations involve Commission orders 

suspending tariff records for more than the minimal 

suspension period and orders on Compliance filings were the 

Commission requires an Effective date different from the 

Tariff Record Proposed Effective Date. 

1/6/14

40 In our supporting documents we often 

cite to a specific section of our tariff. 

However, Commission orders often use 

a different citation for the same section. 

Commission orders do not use a uniform tariff citation style. 

However, most citations attempt to identify the tariff section 

using terms provided by the applicant and are readily available 

to the public if the public wishes to follow the citation’s 

1/6/14
43

Question Answer Date

How does the Commission compose 

tariff citations? 

direction. Thus many Commission order citations follow the 

following style:

Company Name + “, ” + Program “, ” + Tariff Title “, ” + 

Section Title “, at ” + (additional references as appropriate for 

the tariff record’s content)

Company Name = The Company Name in the Company 

Identifier’s (CID) profile.

Program = As provided by the OSEC Implementation Guide at 

p. 7. This is optional if the company does not have 

tariffs in more than one Program.

Tariff Title = Tariff Title as provided by the Company in the 

tariff’s Baseline filing’s Tariff Title data element.

Section Title = See Qu. 41.

An example:

Texas Eastern Transmission, LP, FERC NGA Gas Tariff, 

Texas Eastern Database 1, 3.18, Materially Non-Conforming 

Agreements, 19.0.0, A

41 Commission orders often refer to a 

“Section Title” when referencing a 

tariff record and the term also appears 

in the eTariff Public Viewer when 

viewing a tariff record. What is a 

Section Title?

A full Section Title is composed of four data elements from 

the eTariff filing as provided by the applicant:

Record Content Description + “, ” + Tariff Record Title + “, ” 

+ Record Version Number + “, ” + Option Code

1/6/14
44

Question Answer Date

Option Code is often omitted, as most tariff records are Option 

Code “A”.

From the example in Qu. 40, the Section Title is:

3.18, Materially Non-Conforming Agreements, 19.0.0, A

42 I made a mistake whereby

privileged/CEII material was included 

as part of the Record Binary Data. 

What should I do to correct this 

mistake?

All Record Binary Data that are part of an eTariff filing are, 

upon acceptance by OSEC of the tariff filing, automatically 

and immediately uploaded into eLibrary and the eTariff Public 

Viewer and made part of the public record. FERC is not 

responsible for detecting and correcting filer errors.

Applicants cannot, though eTariff metadata, propose a nonpublic tariff record. When such an error occurs: 

1. The Applicant should email 

FERCOnLineSupport@ferc.gov. The email should

identify the Applicant, docket number, date of filing, 

accession number of the specific document at issue and the 

complete metadata of the tariff record at issue, and request 

FERC staff to change the status of the document in 

eLibrary to either privileged or CEII, as appropriate and to 

remove the companion tariff record or Record Binary Data

from the eTariff data base. 

2. The Applicant is responsible for correcting their filing. 

The Applicant should amend or modify their filing using 

the appropriate TOFC to ensure the proper set of 

documents and tariff records are before the Commission 

and the public consistent with 18 C.F.R. 388.112 (2014). 

This regulation requires: 

1/6/14
45

Question Answer Date

a. A redacted pubic version of the document (for a tariff 

record, this would be Record Binary Data and the 

“Clean Tariff” document);

b. An unredacted non-public version of the document, and 

c. A proposed form of protective agreement.

Alternatively, instead of modifying the filing, the Applicant 

may Withdraw the filing and start over. Note that Withdraw 

of a tariff filing does not remove the filing or any of its 

documents or tariff records from eLibrary or eTariff, or 

change the security status of any document.

The Applicant should take great care to ensure that the 

Applicant’s version of the tariff data base matches the 

Commission’s version. If the two data bases do not match, the 

Applicant may generate incorrect eTariff filings, and OSEC 

may inappropriately accept or reject eTariff filings. 

43 The company proposed/the 

Commission Accepted and gave an 

effective date of 12/31/9998 to a tariff 

record. The real Effective date is now 

known. How can the company change 

the Effective date from 12/31/9998 to 

the real Effective date?

If a Tariff Record is Accepted by the Commission with a 

12/31/9998 effective date, there are two methods by which the 

Effective date can be changed to the real effective date. 

1. The applicant may file a Type of Filing category 

REPORT using the Type of Filing Code appropriate for 

the program informing the Commission of the real 

Effective date. The Commission will update the 

Effective date of the Tariff Record without further 

notice or order. The applicant should update its tariff 

database consistent with the date the applicant provided 

in the Report. (NOTE: the Commission will inform all 

parties and individuals on the service list and the 

5/12/16
46

Question Answer Date

eSubscription list that this eTariff filed Report has been 

made with the Commission.) 

2. The Applicant may file a Type of Filing category 

COMPLIANCE using the Type of Filing Code 

appropriate for the program with a revised Tariff 

Record and including the real effective data in the 

Tariff Record’s Tariff Record Proposed Effective Date. 

The Transmittal Letter should also request that the 

Commission reject as moot the Tariff Record accepted 

effective 12/31/9998. The Commission will issue 

Notice this filing and issue an order in due course. 

The Commission order Accepting a Tariff Record effective 

12/31/9998 will normally instruct the applicant which method 

to use. If the Commission order does not specify a specific 

method to update the effective date, either option is 

acceptable. If there have been intervening changes to the 

Tariff Record’s tariff text that must be reflected, a Type of 

Filing category COMPLIANCE tariff filing must be made

regardless of the Commission’s instruction.
47

Type of Filing Related Questions

Question Answer Date

1 Can a column be added to the ‘Type 

of Filing’ csv that provides a shorter 

name for each type of filing? From a 

software display standpoint, the 

description column provided is too 

long for some display scenarios.

There does not appear to be any benefit to providing 

another column with essentially identical information. The 

names for each Type of Filing can be discussed at a 

technical conference to be held later.

12/19/08

2 Is the Tariff Record key = Tariff 

record Identifier + Option Code + 

Tariff Record Effective Date Record 

+ Effective Priority Order as shown 

on page 11 of the NAESB 

Implementation Guide?

And 

Is the Tariff Filing key = Company

Identifier + Filing Identifier + Tariff 

Identifier as shown on page 11 of the 

NAESB Implementation Guide?

Unique identifier keys will likely be data base specific. A 

“Tariff Record key” is not a required XML filing package 

data element.

See also Tariff Record Related Codes, Qu. 35.

12/19/08

2/3/14

3 Is the Associated Filing Identifier 

required for every COMPLIANCE 

type of filing?

No. Many COMPLIANCE type of filings will be required 

for which there is no Associated Filing Identifier. For 

example:

 Compliance tariff filings pursuant to a Commission 

rule making;

 During the transition from paper tariff filings to 

3/6 /09

2/3/14
48

eTariff filings, all compliance filings referencing 

paper tariff filings. For the FPA and NGA 

programs, this transition period may last many 

years as all Order No. 714 grandfathered but 

effective paper tariff documents do not have to be 

placed into the eTariff format until their first tariff 

change.

4 I forgot to include an attachment in a 

tariff filing. How do I correct this 

mistake?

File the omitted attachment using a Report category Type of 

Filing. This Type of Filing requires the Associated Filing 

Identifier at the filing level.

5/25/10

5 I made a mistake with a tariff record in a 

COMPLIANCE Type of Filing. How do 

I correct this mistake?

Use a COMPLIANCE Type of Filing to correct a tariff record. 

Including the Associated Filing Identifier at the filing level to 

ensure proper docketing and posting in eLibrary. Include the 

Associated Filing Identifier, Associated Record Identifier, and 

Associated Option Code at the tariff record level to reflect the 

fact that the targeted tariff record should be OBE’d if the tariff 

record is Pending, Tolled, Conditionally Accepted, or 

Conditionally Effective.

NOTE that AMENDMENT Type of Filings ARE NOT used to 

correct COMPLIANCE Type of Filings.

5/25/10

8/12/13

6 I made a mistake on my COMPLIANCE 

category Type of Filing – it should have 

been a NORMAL/STATUTORY filing. 

How do I correct this mistake? 

The COMPLIANCE filing will have to be withdrawn using a 

WITHDRAW filing, and refiled using a 

NORMAL/STATUTORY filing code. 

An alternative method of closing the mistaken COMPLIANCE 

filing: If the tariff records in the COMPLIANCE filing are 

Pending, Tolled, Conditionally Accepted, or Conditionally 

Effective, then the NORMAL/STATUTORY tariff filing can 

close the COMPLIANCE filing by associating and OBE’ing 

every pending tariff record in the COMPLIANCE filing. No 

5/25/10

10/8/10

8/12/13
49

WITHDRAW filing is necessary. 

7 I am making a Compliance filing to a 

proceeding that predates the Baseline 

filing of my company. How do I ensure 

that the old docket number will be 

assigned to this Compliance filing?

The Commission has converted, for tariff filings, to automatic 

docketing. Compliance filings that are to tariff filings that 

predate a company’s Baseline filing will lack the Filing 

Identifier necessary to populate the eTariff XML schema. The 

Commission will issue Compliance filings that lack an 

Associated Filing Identifier a new docket number. The 

Commission, in its January 21, 2010 order, advised applicants

in this situation to put the source docket number in the Filing 

Title/Description.

6/10/10

8 I wish to extend the date by which the 

Commission must act on a 

NORMAL/STATUTORY, 

AMENDMENT, BASELINE/NEW or 

CANCELLATION filing. How do I do 

it?

File an AMENDMENT filing with at least one tariff record. As 

with any statutory type of filing, the new statutory period 

depends on the proposed effective date(s) in the 

AMENDMENT filing.

10/8/10

9 Must a motion to extend the date by 

which the Commission may act be filed 

through eTariff?

Yes. See Order No. 714 at P 83. 

Such a filing should use an AMENDMENT category Type of 

Filing Code, as such a motion is a proposal to amend the 

proceeding’ action dates. The company has a choice as to how 

long the Commission action date may be extended:

A) A simple statutory extension (30 or 60 days): Refile any 

tariff record from the underlying filing with the same proposed 

effective date (Tariff Record Proposed Effective Date) and 

content, but increase the Record Effective Priority Order and 

Record version number, and populate the associated tariff 

record information to OBE the underlying and duplicative 

record;

B) To extend the Commission action date to a given date 

beyond the statutory date (beyond the 30 or 60 days): Refile 

10/8/10

10/4/11
50

any tariff record from the underlying filing with the proposed 

effective date and content, but increase the Record Version 

Number, and populate the associated tariff record information 

to OBE the underlying and duplicative record. The proposed 

effective date should be the day after the company wishes the 

Commission to act. If the company wishes to maintain the 

proposed effective date(s) of the underlying filing, the tariff 

record in the amendment filing should not have the associated 

tariff record information.

C) To extend the Commission action date indefinitely: Refile 

any tariff record from the underlying filing with a well into the 

future proposed effective date and content, but increase the 

Record Version Number, and populate the associated tariff 

record information to OBE the underlying and duplicative 

record. The proposed effective date should be the day after the 

company wishes the Commission to act. If the company wishes 

to maintain the proposed effective date(s) of the underlying 

filing, the tariff record in the amendment filing should not have 

the associated tariff record information. When the company 

decides to restart the proceeding, it should file another motion 

through the AMENDMENT category Type of Filing Code with 

another tariff record, and populate the associated tariff record 

information to OBE the underlying and duplicative record with 

the indefinite date.

10 I need to motion suspended tariff records 

into effect. However, there have been 

intervening changes. How do this?

File all the records that the company wishes to move into effect 

(both changed and unchanged) using a COMPLIANCE filing. 

The Tariff Record Proposed Effective Date for each of the 

record should conform with the motion filing rules.

4/18/11

11 Should my MOTION category filing’s

tariff records contain tariff text or 

modified Record Version Number?

No. MOTION category filings’ tariff records should not 

contain tariff text or a revised Record Version Number, as the 

applicant is not supposed to be proposing any change to the 

5/25/11
51

suspended tariff records’ tariff text. A Motion filing is only for 

the purpose of changing a proposed effective date for a 

suspended tariff record.

12 In the FPA and Oil Program, Suspended 

tariff records go into effect automatically 

at the end of their suspension periods. 

What should be filed to move the 

effective date out?

Companies in the FPA and Oil Programs with suspended tariff 

records who wish to move the effective date of their suspended 

tariff records further into the future should file a MOTION 

filing that identifies, for each of the suspended tariff records

they wish to push out the effective date, the new Tariff Record 

Proposed Effective Date. This filing must be made before the 

end of the suspension period.

8/12/13

13 I made a Normal/Statutory filing in the 

NGA Program and entered the incorrect 

information for Suspension Motion 

(suspend_motion). How do I correct that 

mistake?

The Suspension Motion data element can be populated with 

either “Y” or “N”. If the incorrect information is provided, the 

information is applied to the tariff filing as a whole – including 

each proposed tariff record. If the mistake is found while the 

filing is still pending, it may be WITHDRAWN. Alternatively, 

while the filing is still pending, file an AMENDMENT with all 

new records and associated at the record level such that all the 

records in the tariff filing with the incorrect information are 

OBE’d and the tariff filing Closed.

A mistake in the Suspension Motion data found after the 

issuance of the Commission order cannot be corrected in 

eTariff. As a result, tariff records that could have gone into 

effect will not without a MOTION filing; or tariff records will 

go into effect that the company may not wish to have in effect. 

MOTION filings cannot propose a retroactive effective date.

8/12/13

14 I made a Normal/Statutory filing under 

284.123(b)(2) in the NGPA program 

under one of the two time-line options 

(60- or 150-days) that is still Pending 

before the Commission. I now want to 

The applicant with a Pending Normal/Statutory NGPA program 

filing can propose to change the applicable time-line by filing 

an Amendment with the desired time-line. The Amendment’s 

time line will change the underlying Pending filing’s time-line. 

For example:

11/13/13
52

change the time-lines. How can I do 

that? TOFC Category Time-line

760 Normal/Statutory 150 days

1270 Amendment 60 days

Or:

1300 Normal/Statutory 60 days

1350 Amendment 150 days

15 I made an initial filing under 

284.123(b)(1) (TOFC 980), which has no 

time line. I would like to change to a 60-

day time-line; however my Amendment 

TOFC 1270 was rejected. How can I 

change the time-line for my filing?

TOFC 980 actually follows the Compliance business process 

category business. As such, Amendment business process 

categories will not amend Compliance category TOFCs. 

To change the time-line of a TOFC 980 filing, file a TOFC 

1300 tariff filing and associate with all the records of the TOFC 

980 filing. The association of the tariff records will OBE all 

the records in the TOFC 980 and close the TOFC 980 tariff 

filing. OSEC will assign the TOFC 1300 filing a new docket 

number.

11/13/13
53

eTariff Viewer

Question Answer Date

1 In the OSEC Implementation Guide

under Tariff Record Content Data --

Tariff Record Title (record_title) and 

Record Content Description 

(record_content_desc), it states that 

"this field may be used in a database 

generated Table of Contents." Can 

FERC commit that these are the 

fields they will use in an automated 

table of contents?

Tariff Record Title (record_title) will definitely be used in 

an automated table of contents. How the Record Content 

Description (record_content_desc) will be displayed has 

not been determined. At the April 28, 2009 technical 

conference, Record Content Description, Tariff Record 

Title and Record Version Number, in this arrangement,

were identified as the data elements to be used. 

Commission orders commonly refer to this set of data 

elements as the “section title.”

12/19/08

1/15/10

10/8/10

10/4/11

2 If leading spaces are placed in Tariff 

Record Title (record_title), Record 

Content Description 

(record_content_description), Record 

Version Number 

(record_version_num) or Record 

Narrative Name 

(record_narrative_name), how will the 

spaces appear in the eTariff Viewer?

Leading spaces will likely be removed for the eTariff 

Viewer’s display. ETariff will not modify the data 

submitted to the Commission, including leading spaces.

2/9 /09

3 When a tariff filing is made, how long 

does it take for the new tariff records to 

appear in the eTariff Viewer?

The new tariff records should appear within a few minutes of 

the Secretary accepting the tariff filing for filing before the 

Commission.

10//8/10

4 When the Commission acts on a tariff 

filing, how long does it take for the 

Commission’s actions to be reflected in 

the eTariff Viewer?

There may be up to a 5-day delay between the time the 

Commission order issues and the time the actions are reflected 

in the eTariff Viewer.

10/8/10

5 My RTF tariff text does not appear the There are many reasons why the RTF representation of the 10/8/10
54

Question Answer Date

same as the Clean Tariff I provided as an 

attachment. Why are they different?

tariff text in the eTariff Viewer does not match the Clean Tariff. 

Users should be aware that the Commission did not promise it 

could render tariff material in the eTariff Viewer with the same 

fidelity intended by the applicant. The Clean Tariff 

requirement is the applicant’s rendition of its tariff.

Reasons for the lack of fidelity include one or more of the 

following possible explanations:

 Creating the tariff document in a format other than RTF 

and converting to RTF (note Discussion items above 

regarding incompatibilities between Microsoft Word 

formats and RTF);

 Creating the tariff document in a format other than RTF, 

creating the Clean Tariff document from that document, 

then converting to RTF, instead of creating the Clean 

Tariff document from the RTF document.

 Use of conversion software (including word processing 

conversions, binary64 conversions and XML generators) 

that do not recognize the same character sets or features. 

These conversion issues can be located with the tariff 

creators or with FERC.

 Using Tracked Changes and creating the RTF file before 

removing all tracked changes and/or before saving the 

file in native format. 

1/6/14

6 I have lost access to the company’s tariff 

data base and I need to restore it to 

continue making filings. How can I do 

that?

The eTariff Viewer provides a feature that permits any person 

to download in an XML format enough of the tariff to continue 

business. The instructions on how to use this feature are 

located under Help on the eTariff Viewer home page.

4/18/11

7 I have lost access to the company’s past 

XML and ZIPped eTariff filings. Can I 

No. The Commission does not retain a copy of the XML or 

ZIPped tariff filings. All the material from these tariff filings, 

4/18/11
55

Question Answer Date

obtain a copy from the Commission? including the meta data, are available on eLibrary.

8 I only need access to a couple of 

companies’ tariffs. Do I have to go 

through the eTariff Viewer’s menu each 

time to find and bring up those tariff’s?

Most internet browsers permit the creation of shortcuts or 

favorites to websites. In the eTariff Viewer, bring up the tariff 

of interest, and then create a shortcut or favorite consistent with 

the instructions on your browser. 

8/12/13

9 I cannot find a tariff record in the eTariff 

Viewer’s Table of Contents. Why cannot 

I see certain tariff records?

There are several reason why certain tariff records do not 

appear in the eTariff Viewer’s Table of Contents:

1. The tariff record is Rejected or Cancelled as of the Effective 

Date the user selected for viewing the tariff, and there were no 

Effective versions of the tariff record. To see these records, 

select a view Effective date prior to the date the tariff record 

was Rejected or Cancelled.

2. A version of the tariff record is Suspended, and there were 

no Effective versions of the tariff record as of the Effective 

Date the user selected for viewing the tariff. To see these 

records, select a view Effective date after the end of the 

suspension period.

3. On rare occasions, there is an eTariff updating error that 

results in no Effective tariff record (a condition known as 

Superceded<>Superceded). To see these records, select a view 

Effective date prior to the date the tariff record was superceded. 

If these errors are found, please inform 

ferconlinesupport@ferc.gov, and provide the Company ID, 

Tariff Identifier and Tariff Record Identifier.

8/12/13

10 I cannot find a tariff record in the eTariff 

Viewer’s Table of Contents. How can I 

find tariff records that are not in eTariff 

Viewer’s Table of Contents? 

On the Tariff Browser screen, use the “List All Sections” 

button. This will list all tariff records, including those that have 

only Rejected, Suspended, Cancelled and no Effective status. 

Rejected and Cancelled tariff records may appear misplaced in 

8/12/13

5/12/16
56

Question Answer Date

the Table of Contents. This may occur because the tariff 

records’ Tariff Record Collation Values and Parent Identifiers

may have no continuing relationship to their location relative to 

other tariff records in the eTariff Viewer’s Table of Contents.

See also Maintaining and Changing Tariff Databases, Qu. 8.

11 Many recent Commission orders contain 

hyperlinks to the eTariff Viewer’s 

version of the Company’s tariff or 

specific tariff records in the tariff. How 

can I find these links for use in my 

filings?

For the link to the tariff, go to the eTariff Viewer and either:

(a) go to the Tariff Browser to find the company’s tariff, place 

the cursor over the hyperlink to the tariff, and copy the link 

address (usually the option to copy the link address appears 

with a right-click of the mouse); or

(b)go to the company’s Tariff Browser, and copy the URL from 

the address line at the top of your browser.

For the link to the tariff record, in the Tariff Browser, select the 

tariff record of interest from the Table of Contents. Then, in 

the tariff section activity box on the upper right of the screen, 

place the cursor over the hyperlink to the version of the tariff 

record of interest, and copy the link address (usually the option 

to copy the link address appears with a right-click of the 

mouse).

If the document is to be converted to PDF and has hyperlinks, 

remember to print-to-PDF to retain the hyperlinks. All PDF 

documents filed with the Commission are required to be either 

print-to-PDF or OCR’ed.

8/12/13

12 The eTariff Viewer’sTable of Contents 

does not show the correct tariff record 

section title for the chosen effective date. 

This is a known error of the eTariff Viewer. 1/6/14

13 Two tariff records with the same Tariff 

Record Identifier became effective on the 

If two or more tariff records with the same Tariff Record 

Identifier became effective on the same day and have the same 

1/6/14
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Question Answer Date

same day. However, the eTariff Viewer 

shows the wrong tariff record as 

effective. What is the problem?

Record Effective Priority Order, then the eTariff software 

cannot determine the intent of the Commission or the applicant 

as to which tariff record should be effective and which tariff 

record(s) should be Superceded. The applicant should make a 

tariff filing to correct the Record Effective Priority Order. See

Tariff Record Related Codes, Qu. 39.

14 I looked at my company’s tariff on the 

eTariff Public Viewer. The effective 

tariff records are out of order and/or not 

in the proper hierarchical structure. What 

is wrong, and how can it be corrected?

Effective tariff records not in the proper order mean that the 

records’ Tariff Record Collation Values are incorrect. Tariff 

record order is determined by each tariff record’s Tariff Record 

Collation Value. Tariff records are ordered with the smallest 

Tariff Record Collation Value at the top of the Table of 

Contents through the highest Tariff Record Collation Value at 

the bottom of the Table of Contents. Every effective tariff 

record’s Tariff Record Collation Value must be unique. 

Duplicative effective Tariff Record Collation Values are 

ordered randomly relative to each other on the eTariff Public 

Viewer.

Effective tariff records that are misplace in the hierarchy may 

mean that the either that record’s or one of its parent’s Tariff 

Record Parent Identifier is incorrect. 

A tariff record that appears in the eTariff Public Viewer to be a 

child of the wrong parent may have the proper Tariff Record 

Parent Identifier, but the wrong Tariff Record Collation Value.

Incorrect Tariff Record Collation Values and Tariff Record 

Parent Identifiers should be corrected through a 

Normal/Statutory or Compliance filing.

1/6/14

15 Different companies have very different tariff organization. Are there any guidelines? 1/6/14
58

Question Answer Date

The Commission provides limited guidance on how to structure tariffs at Parts 35, 154, 284 and 341.

Business practice and staff experience suggest the following guidelines:

1. Do not have too many Tariff IDs. Rather, group classes of tariff documents into a single Tariff Identifier:

i. Example of excess Tariff IDs:

2. Don’t include the Company Name as part of the Tariff Title – it unnecessarily adds character space that is better used 

to describe the tariff, and creates duplicative text in properly formatted tariff citations:
59

Question Answer Date

3. Some companies use tariff structures that lack organization.

i. Some common mistakes or practices that produce poor tariff structure:

1. Mixing up correlation values

2. Placing different types of agreements together

3. Not using parent/child relationships to facilitate viewing and researching

ii. Example of disorganized tariff structure:
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Question Answer Date

iii. Example of disorganized tariff structure: 

Mixing sections, sheets and pages in a single tariff:

4. Example of good tariff structure:

i. Has standardized Section Titles

ii. Has informative Section Titles

iii. Maximizes use of sectionalized outline formatting, at least 3 Levels deep

a. Consistent use of Record Content Description for outline format

b. Consistent use of Tariff Record Title for the description
61

Question Answer Date
62

Company Registration

Question Answer Date

1 I manage several company registrations

(CIDs). The same agents make filings 

on behalf of these companies. Is there 

some way that I can manage just one 

company profile’s agents and have those 

changes carry over to the other company 

profiles?

Yes. Create a Delegated Filer DID at the Commission’s 

Company Registration site. Assign agents to each of the forms. 

Then, edit each of the CIDs by designating the DID for each 

form. Thereafter, if you need to make any changes to your 

agents, make the change in the DID profile, and those changes 

will automatically carry over to every CID form that has that 

DID designated as an agent. 

8/12/13

2 I would like to create several DIDs for 

my business purposes. Will Company 

Registration permit that?

Yes. However, the Commission provides no service to find lost 

DIDs or correct information in the DID profile other than 

through Company Registration.

8/12/13

3 I am a person eRegistered with the 

Commission. How do I find out whether 

I am an agent for a company for the 

purpose of filing a form with the 

Commission?

You should contact the company’s CID Account Manager. If 

the Account Manager does not find your name as an agent, the 

Account Manager may add your name. If the Account Manager 

does not find your name but finds that a DID listed as an agent 

for the form, you should contact DID’s Account Manager.

Staff does not review, approve or have access to a CID profile’s 

list of agents.

2/3/14

4 The company retroactively changed its 

name and/or other information. Can I 

request that the CID profile information 

be changed with a retroactive effective 

date?

No. 5/12/16
63

Maintaining and Changing Tariff Data Bases

Question Answer Date

1 My company is changing its name/was 

acquired by another entity, but will 

otherwise continue to operate as it did in 

the past. Does the old company’s tariff 

database need to be Cancelled and a new

Baseline tariff data base filed? 

If the company is simply changing its name, was acquired by 

another entity, or both, then there is no need to Cancel the 

existing tariff data base and file a new Baseline tariff. Simply 

update Company Registration and, as of the effective date of the 

change, revise any Tariff Records as necessary through an 

eTariff filing.

5/12/16

2 The company wishes to change tariff 

data bases. However, there are many 

tariff records that are in different status 

conditions. How should the tariff 

records with different status conditions 

be filed?

Tariff records may have many different status conditions (see

Tariff Record Related Codes, Qus. 12-17, above). In general, 

refiled tariff data bases should reflect only Effective or 

Conditionally Effective tariff records. Tariff records that are 

Pending, Pending (Tolled), Accepted, Conditionally Accepted, 

and Suspended should be filed at a later date in a 

COMPLIANCE filing as action dates approach or Commission 

findings require. An accepted set of procedures for managing 

tariff records with statuses other than Effective or Conditionally 

Effective are listed at Transmittal Letter, Docket No. ER15-

2244.

5/12/16

3 The company Cancelled a tariff data 

base effective a certain date. The 

Commission accepted a Pending tariff 

record with an effective date that 

predates the date the tariff database was 

Canceled. Can the cancelled tariff data 

base tariff records’ metadata be modified 

to reflect the change in status, effective 

date and Commission action? 

Cancelled tariff databases may be revised for changes that occur 

prior to the date of cancellation. For example, tariff records 

Pending as of the date of cancellation may become Accepted 

and Effective with effective dates prior to the date of 

cancellation. The Commission will revise its “cancelled” tariff 

data base to reflect changes to Pending tariff records’ statuses

and effective dates. It remains the responsibility of the 

company to reflect these changes in its proprietary tariff 

database. An accepted set of procedures for managing tariff 

records with statuses other than Effective or Conditionally 

5/12/16
64

Effective are listed at Transmittal Letter, Docket No. ER15-

2244.

4 The company Cancelled a tariff data 

base effective a certain date. The 

Commission required a change to a tariff 

record with an effective date that 

predates the date the tariff database was 

Canceled. Can the company make an 

eTariff filing that revises a cancelled 

tariff data base tariff records’ metadata 

and Record Binary Data with an 

effective date prior to the date the tariff 

data base was cancelled?

Yes. Cancelled tariff databases may be revised through an 

eTariff filing for changes that occur prior to the date of 

cancellation. An accepted set of procedures for managing tariff 

records with statuses other than Effective or Conditionally 

Effective are listed at Transmittal Letter, Docket No. ER15-

2244.

5/12/16

5 What Type of Filing Code should be 

used to file a new tariff data base?

Tariff data base filings are generally at the initiative of the 

company. As such, a statutory type of filing code as appropriate 

for the Program should be used: Baseline-New. 

If the Commission required a company to refile its tariff data 

base or the tariff database must be refiled in compliance with 

some other directive, such as a Commission approved 

settlement, a compliance type of filing code as appropriate for 

the Program should be used: Baseline-Refile.

5/12/16

6 The company proposed a name change 

in Company Registration with a 

prospective effective date. Various tariff 

records must be revised to reflect this 

and related changes. What name will be 

reflected as the “applicant” in eLibrary 

and the Commission’s Notice if the 

company makes this eTariff filing prior 

to the proposed effective date of the CID 

eLibrary and the Commission’s Notice will reflect the name of 

the applicant that has the status of Effective as reflected in the 

Company Registration data base as of the date the eTariff filing 

was made. The Filing Title and Transmittal Letter should 

indicate the purpose of the tariff filing.

5/12/16
65

profile change?

7 The company opts to retain the same 

Tariff ID. However, the new eTariff

database vendor requires the existing 

Tariff Record Collation Values be 

changed to their system. Can Tariff 

Record Collation Values be changed 

while retaining the existing Tariff ID?

Yes. However, great care should be taken to ensure that each 

Tariff Record retains its original position relative to the 

preceding and following Tariff Records. A common mistake 

with such re-collation filings is assigning an incorrect Tariff 

Record Collation Values for a child Tariff Record. The results 

are “lost” Tariff Records – both single Tariff Records and 

whole branches. 

5/12/16

8 The company refiled all Tariff Records 

with new Tariff Record Collation Values

and/or Tariff Record Parent Identifiers. 

However, not all Tariff Records appear 

in the Commission’s Public Viewer. 

Did eTariff lose those missing Tariff 

Records?

eTariff has proven to be extremely reliable in retrieving Tariff 

Record data from the eTariff XML. As determining the cause 

of missing/misplaced Tariff Records becomes increasingly 

time-consuming and complex as new versions of Tariff Records 

are filed, these problems are best identified and resolved as 

soon as possible after a filing is made.

If the applicant believes that eTariff may have lost Tariff 

Records, check the following sources:

1. In the eTariff Viewer at ferc.gov, bring up the tariff data 

base in question. Ensure that effective date is within the 

range of the proposed or actual effective date for the 

proposed revisions of the tariff data base. Select the 

“List All Sections” button. That option will reveal Tariff 

Records that may be Effective and/or Pending, but with 

Tariff Record Collation Values and/or Tariff Record 

Parent Identifiers that mis-place those Tariff Records.

2. In eLibrary, bring up the tariff filing that should contain 

the missing Tariff Records. Open the “FERC 

GENERATED TARIFF FILING.RTF” document. 

Search for the missing Tariff Record Identifier(s). 

5/12/16
66

If the missing Tariff Records appear in either the List All 

Sections view of the tariff database or in FERC GENERATED 

TARIFF FILING.RTF, then the problem is most likely incorrect 

Tariff Record Collation Values and/or Tariff Record Parent 

Identifiers provided by the applicant. If the missing Tariff 

Records do not appear in either of these locations, then:

3. Open the company-retained eTariff XML filing filed 

with the Commission with an XML editor or a variety of 

text editor software. Search for the missing Tariff 

Record Identifier(s). [NOTE: the Commission does not 

retain eTariff XML files – the Commission only retains 

the data contained within the files. See Business Rules, 

Qu. 35 above.]

If the missing Tariff Records cannot be found in either the 

Public Viewer or eLibrary’s FERC GENERATED TARIFF 

FILING.RTF, and they are in the company’s eTariff XML, 

please contact ferconlinesupport@ferc.gov and provide a 

Docket No., Submission ID, example missing Tariff Record 

Identifiers and brief description of the problem.

Commission staff provides only minimal technical support in 

diagnosing missing Tariff Record problems not of eTariff’s 

making. 

9 The company’s existing Section Titles 

are on a sheet basis. Can the company 

move to a sectionalized basis as part of a 

refiled tariff database?

Yes. Companies should use such tariff database refilings as an 

opportunity to adopt best tariff formatting practices. See also

eTariff Viewer, Qu. 15 above.

5/12/16

10 Is a redline/strike-out required for refiled 

tariff databases?

Certain Program’s tariff filing requirements require tariff filings 

to provide a redline/strike-out document that identifies all

5/12/16
67

proposed tariff changes. Redline/strike-out is only required for 

identifying changes in tariff text. [NOTE: headers and footers 

are not normally considered tariff text.] Redline/strike-out is 

not required for tariff database cancellations. Redline/strike-out 

is not required for refiled tariff databases if there are no changes 

other than tariff structure and format. The Transmittal Letter 

should clearly state that no redline/strike-out is being provide as 

no changes in tariff text is proposed.

If there are minor clean-up changes or changes due to tariff 

structure or format, either provide redline/strike-out of only 

those Tariff Records with changes, or provide a table that 

identifies the Section Title and the change.

11 May the company propose additional 

changes to its tariff in a refiling of its 

tariff database?

Yes. 

However, proposed changes other than those required to refile a 

tariff database may result in unforeseen protests and 

Commission findings, such as suspension, change in effective 

date, or rejection. Such events could seriously complicate a 

company’s ability to make eTariff filings with the Commission 

and maintain its tariff database.

5/12/16