FERC Electronic Filing Strategic Plan

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Table of Contents

SECTION 1 – INTRODUCTION

1.1 PURPOSE.............................................................................................................. 1-1

1.2 BACKGROUND ...................................................................................................... 1-1

1.3 DOCUMENT ORGANIZATION.................................................................................. 1-2

1.4 REFERENCES ........................................................................................................ 1-3

SECTION 2 – CORE FILING REQUIREMENTS

2.1 OVERVIEW ........................................................................................................... 2-1

2.2 SUPPORTED BUSINESS FUNCTIONS ........................................................................ 2-1

2.3 PRIMARY INFORMATION FLOWS............................................................................ 2-2

2.3.1 Process 1 – Electronic Filing Pilot Program (Internet).................................. 2-2

2.3.2 Process 2 – Manually Received Documentation ............................................. 2-3

2.4 E-FILING REQUIREMENTS...................................................................................... 2-6

2.4.1 Functional Requirements............................................................................... 2-7

2.4.2 Performance Requirements............................................................................ 2-9

2.4.3 Electronic Document and Records Management Requirements...................... 2-10

SECTION 3 – INFORMATION TECHNOLOGY INFRASTRUCTURE

3.1 CURRENT ENVIRONMENT...................................................................................... 3-1

3.1.1 The FERC Organization ................................................................................ 3-1

3.1.2 Systems.......................................................................................................... 3-4

3.1.3 Applications .................................................................................................. 3-6

3.1.4 Communications............................................................................................ 3-10

3.2 FUTURE INFRASTRUCTURE.................................................................................... 3-13

3.2.1 Fundamental Architecture Implementation Considerations/Alternatives......... 3-13

3.2.2 Client/Server Implementation Considerations/Alternatives............................. 3-17

3.2.3 Storage Implementation Considerations/Alternatives..................................... 3-20

3.2.4 Security Implementation Considerations/Alternatives..................................... 3-23

3.2.5 Information Exchange Implementation Considerations/Alternatives............... 3-25

3.2.6 Document Management ................................................................................. 3-28

SECTION 4 – E-FILING INFORMATION TECHNOLOGY ARCHITECTURE

4.1 INFORMATION INFRASTRUCTURE.......................................................................... 4-1

4.2 COMMUNICATIONS INFRASTRUCTURE................................................................... 4-2

4.3 PROCESSING INFRASTRUCTURE............................................................................. 4-3

4.4 SECURITY INFRASTRUCTURE ................................................................................ 4-3

4.5 STANDARDS OVERVIEW........................................................................................ 4-4

4.5.1 Overview ....................................................................................................... 4-6

4.5.2 Information Infrastructure Standards............................................................. 4-7

4.5.3 Communication Infrastructure Standards ...................................................... 4-10

4.5.4 Processing Infrastructure Standards.............................................................. 4-11

4.5.5 Security Infrastructure Standards .................................................................. 4-14
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Table of Contents (continued)

4.6 E-FILING STANDARDS PROFILE .................................................................... 4-15

4.7 MANAGING THE E-FILING TRM AND STANDARDS PROFILE............................... 4-16

4.7.1 The TRM Change Process......................................................................... 4-16

4.7.2 Obtaining a TRM Waiver.......................................................................... 4-17

SECTION 5 – THE FUTURE OF E-FILING AT FERC

5.1 GOALS ............................................................................................................5-1

5.2 BENEFITS ........................................................................................................5-2

5.3 IMPLEMENTATION CONSIDERATIONS...............................................................5-2

5.3.1 Business/Process Considerations..............................................................5-2

5.3.2 Technical Considerations .........................................................................5-5

5.3.3 Industry/Government “Best Practices” .......................................................5-9

5.4 TRANSITION STRATEGY ............................................................................... 5-10

APPENDIX A — REQUIREMENTS SUMMARY

APPENDIX B — GLOSSARY

APPENDIX C — RETENTION SCHEDULE

APPENDIX D — FERC STANDARDS PROFILE SUMMARY

APPENDIX E – FERC COMPREHENSIVE RECORDS DISPOSITION SCHEDULES

APPENDIX F - TRANSFER OF ELECTRONIC RECORDS TO NARA
Federal Energy Regulatory Commission

Electronic Filing Strategic Plan

and

Information Technology Architecture

4 August, 2000
The Federal Energy Regulatory Commission

Electronic Filing Strategic Plan

and

Information Technology Architecture

4 August, 2000

prepared for

The Federal Energy Regulatory Commission

by

SIGNAL Corporation
and

PEC Solutions, Inc.
FERC Electronic Filing Strategic Plan

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Section 1 – Introduction

1.1 Purpose

The purpose of the Federal Energy Regulatory Commission (FERC)

Electronic Filing (E-Filing) Strategic Plan is to provide guidance to the

Commission as it moves forward with its E-filing initiative. The heart of

the Strategic Plan is an E-filing Information Technology Architecture

(ITA) that specifies a Technical Reference Model (TRM) and a Standards

Profile to guide the initiative.

The Information Technology Management Reform Act (ITMRA), or

“Clinger-Cohen” Act of 1996, requires Federal agencies to develop

information technology (IT) architectures that provide guidance and

direction to IT programs. The E-filing ITA TRM and Standards Profile

provide E-filing project managers and system designers with the

information they need to successfully build an E-filing system and

architecture and evaluate the conformance of the architecture to E-filingrelated standards.

1.2 Background

The Federal Energy Regulatory Commission is an independent

regulatory agency that regulates essential aspects of the electric, natural

gas and oil pipeline, and nonfederal hydropower industries. It ensures

that the rates, terms and conditions of service for segments of the electric

and natural gas and oil pipeline industries are just and reasonable. It

authorizes the construction of natural gas pipeline facilities. It ensures

that hydropower licensing, administration, and safety actions are

consistent with the public interest. The Commission’s main areas of

responsibility are:

Energy Markets:

• transmission and sales for resale of electric energy in interstate

commerce;

• transportation of natural gas in interstate commerce;

• transportation of crude oil and petroleum products by pipeline in

interstate commerce;

• corporate transactions, mergers, interlocking directorates, and

security issues of electric public utilities; and
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• certification of exempt wholesale generators and qualifying

facilities.

Energy Projects:

• licensing and safety inspection of nonfederal hydropower

projects;

• construction and operation of natural gas pipelines; and

• oversight of related environmental matters.

The industries that the FERC regulates are required to file numerous

types of legal and regulatory documents with the Commission. Currently,

virtually all of these filings are submitted, processed, and retained in

their native paper format. The FERC has put into motion an Electronic

Filing Initiative designed to provide an electronic submission option to

traditional paper filings, in accordance with the requirements of the

Government Paperwork Elimination Act of 1998. The initiative is also

driven by the Commission’s strategic objective of improving information

availability and exchaenge by increasing reliance on electronic filing and

data bases and by making greater use of appropriate information

technology tools.

According to the Office of the CIO, the vision statement for FERC’s Efiling Initiative reads:

“We will provide Commission staff and our customers (regulated

entities and the general public) with efficient, cost-effective

access to the information they need—when they need it—and in a

format that is useful to them.”

Similarly, FERC’s E-filing Initiative goal statement is:

“To provide more information to Commission staff, regulated

entities, and the public in a more flexible, practical, and efficient

way and to improve our regulatory processes by reducing the

cost and volume of paper filed by applicants and intervenors

with FERC and each other.”

E-filing presents many challenges to the FERC. The Commission must

not only change the way it does business, it must change the way it

interacts with the entities it regulates. The IT-based E-filing system must

meet evolving federal requirements for new technology investments—

including proper planning facilitated by an ITA, adherence to nonproprietary industry standards, and the use of Commercial-Off-The-Shelf

(COTS) products—while keeping within budget constraints that are

established to help maximize benefit to the American tax payer.
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1.3 Document Organization

The FERC Electronic Filing Strategic Plan is organized into five

sections.

• Section 1 – Introduction. This section provides the necessary

background information.

• Section 2 – Core Filing Requirements. This section presents the

functional, performance, and electronic document and records

management requirements of E-filing.

• Section 3 – Information Technology Infrastructure. This section

outlines the current IT environment and identifies relevant

technologies.

• Section 4 – E-filing Information Technology Architecture. This

section uses Sections 2 and 3 as a foundation to build the ITA—

which defines the Technical Reference Model and the Standards

Profile for the E-filing infrastructure. Also included are

guidelines for managing the ITA.

• Section 5 – The Future of E-Filing at FERC. This section

discusses the goals and benefits of E-filing. It also addresses the

implementation considerations of transitioning to a totally

paperless environment.

• Appendices – The Appendices include a Glossary and an

overview of the FERC E-Filing Pilot Project.

1.4 References

The following were used in the preparation of this document:

• Federal Energy Regulatory Commission Strategic Plan FY1997–

FY2002

• Electronic Filing: Major Issues Summary

• FERC Website: http://www.ferc.fed.us

• FERC Electronic Filing Initiative Website:

http://www.ferc.fed.us/efi/efi.htm

• National Archives and Records Administration Information

Server: http://webgopher.nara.gov/
FERC Electronic Filing Strategic Plan

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• Federal Energy Regulatory Commission – FY2000

Congressional Budget Request

• Federal Energy Regulatory Commission – FY2001

Congressional Budget Request
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Section 2 – Core Filing Requirements

2.1 Overview

As regulated industries become more competitive, FERC Strategic Plan

FY1997 - FY 2002 Strategic Vision recognizes the importance of

flexibility and innovation in meeting the FERC’s business needs. The

FERC is committed to making changes that will allow it to “...respond in

real time to industries and intervenors...” and will “...include better use

of electronic technology to facilitate the regulatory process.” The E-filing

initiative is a direct response to the FERC’s strategic vision. The FERC’s

long-term goal is a primarily “paperless” filing environment with a

specific target of reducing paper filings by 90% by 2002.

This section addresses the business functions that E-filing supports, the

goals and requirements of the initiative, information flows, data entities

and their relationships, and document and records management

requirements.

2.2 Supported Business Functions

As mentioned, the FERC’s long-term goal is a primarily “paperless”

filing environment. To that end, E-filing must support all business

functions currently related to filing activities. At the highest level, this

includes receiving, processing, storing, and retrieving all documents filed

with the FERC.

In the Commission’s four program areas (gas, oil, electric, and

hydropower), regulated entities collectively file more than 400 different

types of pleadings, comments on rulemakings and offers of settlement,

forms, and reports. The major filings include:

• Motion/Notice of Intervention

• Comments on a filing, rulemaking, or offer of settlement

• Electric, gas, and oil rate applications

• Gas pipeline certificate (construction) applications

• Hydropower Licensing/Relicensing Applications

• Annual and periodic reports and forms filed by regulated entities

• Briefs and Testimony
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• Complaints, petitions, protests, other motions, and answers to

such pleadings

While many documents are text-only, others may contain maps of

various sizes, CAD drawings, photographs, spreadsheets, or other

structured data or text formats.

2.3 Primary Information Flows

In an effort to support the Strategic Plan and Information Technology

Architecture for the FERC Electronic Filing Initiative, two process flows

are defined in this section. Currently FERC documentation is received in

two ways, via the Electronic Filing Pilot Program (Internet), and

manually. Although manual entry of documentation information is not

the preferred method, to define this process further supports the

requirement of the Electronic Filing Initiative for this project. See

Exhibit 2-1.

2.3.1 Process 1 – Electronic Filing Pilot Program (Internet)

1. Filings (Forms, Comments, Protests, and Interventions) are

processed through FERC via Internet (web browser, client/server

applications, distributed executables or e-mail). Once FERC

receives the document, the sender receives an HTML

acknowledgement of receipt, followed by an e-mail confirmation

with a page link to the document in the FAMIS database.

2. The electronic submission goes through OSEC for quality

control, including verification that the docket and sub-docket

numbers are correct.

3. If the document is approved, OSEC forwards electronic

submission to the RIMS database for customer retrieval and

viewing.

4. If the document is not approved, OSEC sends a notification to

the filer with an explanation as to why to document was not

accepted.

5. After docket or sub-docket number is verified, OSEC sends the

the paper copy of the filing (required only during the Pilot) to the

RIMS database to create TIFF images, indexed, and stored.

6. Through FAMIS a workflow is initiated.
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2.3.2 Process 2 – Manually Received Documentation

1. Customer submits filings to the FERC (e.g., via courier, express

mail and regular mail.)

2. The document is sent to OSEC and quality controlled using

paper acceptance criteria, if approved, depending on the type of

submittal (new or existing), OSEC assigns a docket or subdocket number.

3. If rejected, OSEC notifies the customer with the rejection reason.

4. The filer is required to submit an original and the required

number of copies. For comments, interventions, and protests, the

required number of copies is 14. For other submissions, the

number of copies may be less, depending on the requirement in

the regulations. In a few cases, OSEC will make copies, but they

do not normally have to do this. They distribute the copies that

are filed with the original.

5. The document is quality controlled again at the same time it is

sent to RIMS to create TIFF images, indexed, and stored.
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Customer

Submits

Filing

Customer Electronic

Filings

Paper

Filings

Passes

Applic.

Edits?

No

Electric: Form 1, Form 1F

Gas: Form 2, Form 2A

Oil: Form 6

 Tarriff And Rate Forms

FERC Forms

Structured

Data

(Forms)

Forms Application Data Entry

Customer OSEC Doorway

Yes

Electronic

Filings flow

path

To Paper Filings

flow path

Structured

Data

(Forms

applications)

flow path

From Rejected

Submittal (Paper

and Electronic

Filings)

To

Customer

(E-Mail )

Exhibit 2-1. Present E-Filing Process
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Evaluate Submittal

using Electronic

Filings acceptance

criteria

Receive

Submittal

Electronic File

Yes Accepted?

Evaluate Submittal

using Paper

acceptance criteria

Receive

Submittal

Documents

Perform

Document

Prep

No

Yes

Accepted?

No

To

Forms Data

Database

Receive

Forms-based

Submittal

Data

Send Receipt

Confirmation

Store Form

Data

To

Customer

(E-Mail )

Stored

Forms

Data

From Paper

Filings

Electronic

Filings

Forms

applications

Rejected Submittal (Paper

and Electronic Filings)

OSEC

Validates

Filing

OSEC

Receives

Filing

 OSEC Accepts

Filing, Sends

Submittal

Documents To

Dockets For Prep.

Electronic

Filings flow path

To Paper

Filings flow

path

Forms Application

Filing flow path

OSEC Doorway (Segment 1)

E-Mail

Confirmation

Customer

Exhibit 2-2. OSEC Doorway (Segment 1)
FERC Electronic Filing Strategic Plan

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Dockets

Sends

Documents

To RIMS

Ops.

Source Documents Electronically

Scanned (TIF Images And ASCII

Text Files Created), Indexed, And

Stored

 (If New, Assign

Docket

Number, Else

Associate With

Existing Docket)

Identify

Document

Index

Master

Document

Create TIF

Images

To

RIMS

Database

Index

Source

Document

Image Document

(Create TIF

Images)

Perform

Image

Quality

Control

Store TIF

Images

Perform

Index

Quality

Control

To

RIMS

Database

Identify

Document

To

RIMS

Database

To

RIMS

Database

Image Files

Index Data

Store TIF

Images

Store Index

Data

Index Data

Stored

Index

Data

Stored

Image

Data

Paper Filings

Electronic Filings

Image Files

Index Data

Store Index

Data

Paper Filings

Electronic Filings

To

RIMS Database

Image Files

OSEC Doorway (Segment 2)

Exhibit 2-3. OSEC Doorway (Segment 2)

2.4 E-filing Requirements

E-filing goals and requirements are shaped by the business functions that

E-filing supports. E-filing requirements are broken into two types—

functional requirements and performance requirements.

The functional and performance requirements for E-filing are driven by

strategic goals that will be attained by moving to a paperless

environment. As stated in the FERC Strategic Plan, these strategic goals

are:

• To provide stable and timely regulatory treatment to regulated

companies and their customers. Expedite decisions where

practical, while considering the due process rights of others

• To provide both staff and the public with information in a timely

manner and in formats with more utility than native paper or

electronically scanned documents
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• To reduce the Commission’s overhead costs for administration

and the costs of treating similar issues in similar cases.

2.4.1 Functional Requirements

2.4.1.1 Paperless Filing Environment

The core functional requirement of E-filing is that it must provide a

paperless environment for “all” filings made with the Commission. A

key success factor of this requirement is a well-planned, phased

implementation. The FERC must be able to concurrently support paper

filing until the transition is complete. Filing components such as maps

and sensitive information are candidates for later phases—as

technologies emerge and standards are established.

It is likely that paper will always be involved in some part of the filing

process. For example, some information might be considered too

sensitive to transmit over public communications media. Continued

advances and wide-spread acceptance of technologies like Public Key

Infrastructure (PKI) and Virtual Private Networks (VPN) could

eventually obviate concerns in this area.

2.4.1.2 Workflow

Stable and timely regulatory treatment of regulated companies and their

customers is a strategic goal of the FERC’s E-filing initiative.

Automating the workflow of the filing process to provide an E-filing

infrastructure is an important factor in achieving this goal. Workflowrelated functional requirements for E-filing include both current, manual

procedures (e.g., docketing of filings) and procedures that are new to the

process (e.g., virus checking). E-filing automated workflow requirements

include the following procedures:

a) Receive Electronic Document – The FERC must be able to

receive, view, and process all electronic document formats used.

b) Validation – The FERC must be able to validate documents and

authenticate their origin. They must also be able to automatically

inspect submitted documents for adherence to business rules,

proper numbering schemes, completeness, and accuracy.

c) Virus Checking – The FERC must be able to automatically scan

for and clean infected submissions. Also included in this process

are automatic updates of virus patterns for detection of new

viruses and automatic notice to the submitter that an electronic

document was infected.

d) Acknowledgement of Receipt – The FERC must be able to

electronically acknowledge receipt of documents and either
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confirm validation of filing or reject submittal with adequate

explanation for rejection.

e) Docketing of Electronic Filings – The FERC must be able to

automatically docket electronic filings based on meta-data

included with each filing.

f) Notify Staff – The FERC must be able automatically notify the

staff assigned to a specific case that related filings have been

received.

g) Access for Staff and Public – The FERC must provide access to

filed materials for the Staff and Public in a timely and reliable

manner.

h) Perform Quality Assurance (QA) on E-filing – The FERC must

be able to automatically check filings against business rules, Efiling standards, and accepted formats. Filers shall be notified if

E-files do not meet QA standards.

i) Accept waivers – The FERC must have an evaluation process for

reviewing and accepting or denying waivers for late filings due

to IT technology issues and non-standard submissions.

The functional requirements listed above outline the process for

accepting electronic submissions at the Commission. The timeframe for

this process is discussed in Section 2.3.2, Performance Requirements.

2.4.1.3 Digital Signatures

In May of 1998, the Commission solicited comments from industry on

the E-filing initiative. One of the questions dealt with the authentication

of submissions by physical signature. The FERC not only solicited

suggestions for the method used for electronic authentication but also

asked if signatures should still be considered as a requirement. Industry

replies were mixed—some felt that a “signature” in some form should be

required, others did not. Digital signatures will be required for some, but

not all, filings. A risk assessment for each type of submission will be

required to determine the method of authentication/validation/signature

(if any) used for that type of submission.

FERC shall follow the procedure and guidance for implementing the

Government Paperwork Elimination Act issued by the Office of

Management and the Budget and published in the Federal Register (65

FR 25508 (May 2, 2000)).

2.4.1.4 Digital Maps and Large-format Graphics

Maps and photo-alignment sheets (normally included with natural gas

pipeline certificate applications, hydropower licensing/relicensing
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applications, and reports submitted to the Commission) are currently

submitted on paper. Applicants do not normally serve this information to

all parties. Currently, the FERC digitizes large-format graphics by

scanning paper source maps into electronic format. The large file sizes of

the resulting digital maps make it difficult to disseminate this

information to the public. Eventually, the FERC should be able to

receive, process, store, and disseminate maps that are produced in digital

form. Digital maps will be part of a practical solution that allows

interested parties to easily and quickly access required portions or areas

of maps.

2.4.1.5 Secure Transmission and Storage of Proprietary Data

Some filings, such as annual reports, contain proprietary information that

regulated companies need to protect—especially as industries move

towards an unregulated, competition-based environment. The FERC

must ensure that all electronic submissions containing sensitive

information are transmitted and stored in a secure manner. Furthermore,

the FERC must provide defined procedures for filing, receiving, and

posting documents of mixed proprietary and non-proprietary content.

2.4.1.6 Web-enabled

The FERC understands that the Internet is a valuable tool in meeting its

strategic goal of providing both staff and the public with information in a

timely manner. The E-filing solution must be capable of interfacing with

the current Internet, Intranet, and other web-enabled systems at FERC

(i.e., CIPS, RIMS, and FAMIS).

2.4.1.7 Administration of E-Filing Process

The administration of the E-filing process shall be controlled by FERC.

Specific requirements concerning the E-filing process shall not inhibit

the ability of a system administrator to over-ride any specific business

process. As an example, the administrator will need the ability to override filing dates that are generated automatically in order to deal with

exceptions to business rules.

2.4.2 Performance Requirements

2.4.2.1 Timely and Accurate Information

The E-filing system must provide timely and accurate information to the

FERC staff and the Public.

At a deeper level, this requirement establishes performance metrics for

the workflow defined in Section 2.1.3.2. The FERC must establish

acceptable process duration times for receiving, processing, and posting

electronically filed documents. These metrics should complement FERC
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business rules for meeting filing deadlines and should align with Industry

expectations.

For the FERC to ensure that information is accurate, the E-filing process

must also include error checking and correction procedures. Just as in the

current paper environment, the FERC must ensure that electronic filings

are available As-Filed and adhere to established filing conventions.

2.4.2.2 System Availability

The E-filing system must always be available to the FERC staff and the

Public during prime filing periods to accept time-sensitive filings. The

system will be subject to peak filing periods driven by the deadlines for

making certain filings. System availability shall consider these "busy

hours" as a critical time period.1

This requirement establishes performance metrics for availability. These

metrics will define acceptable parameters for system uptime, periods of

availability, and the overall level of service the FERC will provide.

System availability also establishes requirements for infrastructure issues

like bandwidth and connection speeds.

2.4.3 Electronic Document and Record Management Requirements

This section outlines the electronic document and records management

requirements for E-filing at the FERC. The National Archives and

Records Administration (NARA) requires that the Commission establish

record retention schedules for all agency business records. This record

retention requirement applies to records in any format. Records fall into

two general categories: permanent and temporary. Permanent records

include those appraised as having sufficient historical or other value to

warrant continued preservation beyond the time they are needed for an

agency's administrative, legal, or fiscal purposes. NARA becomes the

legal owner of any permanent records transferred to NARA.

Temporary records have defined retention schedules. Most filings with

the Commission are classified as temporary records, even though the

retention period may be 50 years or more. The agency has greater

discretion over temporary records because it retains legal custody.

The Commission must retain official records in a format that accurately

renders a document for the duration of the retention period. For paper

records, scanned image formats always reproduce the document As-filed.

 

1

 The telecommunications industry traditionally designs for the "busy hour" for

the phone system. A comparative approach should be pursued for system

availability by utilizing historical reports showing system utilization.
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For electronic submissions, the ability to render a document As-filed

may be hindered by the proprietary software application used to create

the electronic submission. At present, only paper documents are

considered official.

The Electronic Document and Records Management requirements are

discussed below.

2.4.3.1 Ensure compliance with NARA

Electronic filing shall ensure compliance with NARA and other Federal

Regulations for Records Management.

2.4.3.2 Public Access to Electronic Documents

Documents submitted in electronic format must be available to the public

in electronic format. Additionally, it is required that document retrieval,

via the Internet, not require a proprietary for-purchase software solution

to enable viewing by the public. All documents filed electronically must

be capable of being printed as paper documents without loss of content

or appearance.

The Commission’s Records Management System will retain the original

submission “as-filed”. The original document cannot be altered and will

be retained in its original format. Processing of the document for web

viewing will render the document in a new format but no additional

alteration of the document will occur.

2.4.3.3 Document Retention

Document retention requires that the electronic document be viewable

for the duration of its legal retention schedule. As a consequence of this,

and other issues, a Pilot Project was initiated which has adopted a multiphased or evolutionary approach to the Electronic Filing Initiative. This

will require that document content standards be defined to ensure that the

electronic documents can be accepted, disseminated and distributed in a

timely manner. Presently, the most popular format used for document

viewing is Adobe’s Portable Document Format (PDF). PDF files

typically require a proprietary document viewer; however, this is

distributed free of charge from Adobe. Document creation, in a PDF

format, requires either the proprietary Adobe Acrobat application or a

separate application that has implemented the PDF standard.2

 

2

 Adobe has released the PDF specification that provides other vendors the

opportunity to create their own PDF writer. For example, Corel’s WordPerfect

(V 9.0) can generate a PDF output.
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In addition to PDF, there are other non-proprietary solutions could be

implemented. Other phases of the E-filing initiative will require

investigating XML (Extensible Markup Language), SGML (Standard

Generalized Markup Language), as well as other emerging nonproprietary technologies.

2.4.3.4 File Format and Retention

The FERC receives documents that can be classified into two categories:

1. Structured Data, typically contained in forms, and

2. Unstructured Data, from Comments, Protests, and Interventions.

For accountability purposes, the Commission shall retain submitted

unstructured data (i.e. documents) in both the original file format as well

as the converted non-proprietary file format.

2.4.3.5 File Format Standards

The Commission shall endeavor to support standard file formats that

obviate single vendor software applications. Standard file formats are

developed and ratified by nationally or internationally recognized

standards bodies. (See File Format Retention.) There are certain

situations, however, where the Commission will have to accept

proprietary formats. In natural gas pipeline and electric transmission rate

cases, the formulas underlying the spreadsheet entries for certain

schedules are of interest to staff. So rate case filers may be required to

submit that information in one of several proprietary spreadsheet

formats. It will also be necessary to accept certain filings in proprietary

formats from people who are not able to create a filing in a nonproprietary format without incurring additional expense.
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The Electronic Filing Pilot project is presently accepting the following

file formats:

EXTENSION APPLICATION

wpd Corel WordPerfect

doc Microsoft Word

pdf Adobe Acrobat

txt ASCII3

Particular emphasis should be placed on the Portable Document File

format as it provides a platform and vendor independent solution.4 An

inter-agency group within the federal government has recommended that

the National Institute of Standards and Technology (NIST) develop a

Federal Information Processing Standard (FIPS) for PDF; efforts are also

under way to develop national (American National Standards Institute,

ANSI) and international (International Standards Organization, ISO)

standards for PDF based on this published specification. ANSI approved

a PDF standard in October of 1999. This specific standard, CGATS.12/1,

relates to digital pre-press. Digital pre-press and publishing is defined as

"the process of preparing images for reproduction and/or dissemination

by print or alternative media, including such options as multimedia, CDROM, on-demand printing and digital databases." The Committee for

Graphic Arts Technologies Standards (CGATS) is continuing to study

additional PDF standards. The ISO has assigned number 15930 to the

PDF proposed standard. It is presently in review and comment phase and

is expected to be classified as an official ISO standard in the year 2000.

2.4.3.6 File Format Virus Scanning

All documents submitted electronically must be in an approved file

format so as to enable virus scanning by the FERC IT architecture. At

present, no files can be submitted in a compressed or zipped format. It is

 

3

 ASCII provides the least usability for electronic processing applications. It

should be anticipated that ASCII will eventually be removed from the accepted

formats list.

4

 PDF, although created by Adobe, has been released into the public domain.

Adobe's reader is freely downloadable. It is possible to generate PDF files

without purchasing an Adobe product; e.g. WordPerfect Version 9.0 can

generate PDF. Previous versions must install new print drivers.
FERC Electronic Filing Strategic Plan

SIGNAL Corporation 2-14 PEC Solutions

anticipated that future phases of electronic filing, that include larger

filing of multiple files, will have to accommodate compressed files.

2.4.3.7 File Format Paragraph and Page Numbering

Paragraph numbers are not required for files submitted in unalterable

format i.e. PDF; paragraph numbers are recommended, but not required,

for other file formats.

2.4.3.8 File Naming Conventions

Files name must be limited to a maximum of 25 characters, excluding the

extension.

File extensions must follow an approved format. The following table

defines the approved extension names identified for the pilot:

EXTENSION APPLICATION

wpd Corel WordPerfect

doc Microsoft Word

pdf Adobe Acrobat

txt ASCII

2.4.3.9 File Size

Submitted documents are presently limited to five megabytes. Any

system upgrades should include proper sizing of the system to include

anticipated storage of approved file formats; e.g., maps converted to

standard GIS formats.

2.4.3.10 Hyperlinks and other Embedded Code

Hyperlinks embedded within an electronic filing should refer only to

information within the same document. Hyperlinks should not be used to

refer to external documents or information sources which are likely to

change. (i.e. web sites).

Documents must not contain auto-text generating features. As an

example, most word processors have the ability to insert “Today’s Date”;

this feature initiates a “Save” request whenever the document is reviewed

at a later date. Setting the document’s properties to “read-only” will

inhibit the document being overwritten but can still confuse the reader.

Not implementing auto-text generating features will obviate this

confusion.
FERC Electronic Filing Strategic Plan

SIGNAL Corporation 2-15 PEC Solutions

2.4.3.11 Adherence to Regulations

• Government Paperwork Elimination Act

The Government Paperwork Elimination Act (GPEA), which takes effect

in FY 2004, provides a strong impetus for agencies to develop the

capability of managing records electronically for their full legal retention

period. Under the GPEA (Pub. L. 105-277), by October 2003, agencies

must give persons and entities that are required to maintain, submit, or

disclose information to the Federal Government the option of doing so

electronically when practicable as a substitute for paper, and to use

electronic authentication (electronic signature) methods to verify the

identity of the sender and the integrity of electronic content.

As a consequence of this, the Commission shall review all document

filing requirements and propose which documents meet the "practical"

parameter as stated by GPEA. A phased implementation schedule shall

be developed that reflects the milestone dates, as established by the

GPEA, which can be implemented within the constraints of the

supporting Information Technology Architecture. (ITA)

• U.S. Code of Federal Regulations

The regulations in 18 CFR 385 (U.S. Code of Federal Regulations, Title

18: Conservation of Power and Water Resources) that may need to be

revised to accommodate electronic filing in general, and Phase 1 filings

(Interventions, Comments, Protests, and Answers) in particular include:

• Rule 2001 (18 CFR 385.2001): Filings with the Commission.

Expand to include method for electronic submission.

• Rule 2002: Caption of filings. Modify to include caption or

description requirements for electronic filings.

• Rule 2003: Specifications. Modify to include any specifications

that should apply to electronic filings, including those relating to

citation.

• Rule 2004: Original and copies of filings. Modify to delete

requirement to file paper copies with electronic submissions.

• Rule 2005: Subscription and verification. Expand to address

signatures for electronic filings.

• Rule 2007: Time. Modify to include rules for establishing the

filing date of an electronic submission.

• Rule 2010: Service. Clarify Certificate of Service procedure for

electronic filings.
FERC Electronic Filing Strategic Plan

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• Rule 2011: Procedures for filing on electronic media. Revise as

additional filings are added to the filings that FERC can accept

in electronic format.

• Rules specific to Motions, Protests, Answers, Interventions,

Amendments and Withdrawal of Pleadings:

• Rule 203: Content of pleadings (and tariff or rate filings)

• Rule 208: Notice of protest to tentative oil pipeline valuations

• Rule 211: Protests other than under Rule 208

• Rule 212: Motions

• Rule 213: Answers

• Rule 214: Interventions

• Rule 215: Amendment of pleadings (and tariff or rate filings)

• Rule 216: Withdrawal of pleadings

2.4.3.12 Auditing Electronic Documents

FERC shall follow the legal guidelines for auditing electronic documents

as defined by the OMB5 and the Justice Department.

By definition, a document management system (DMS) can track all data

accesses and modifications. A DMS can keep prior versions of records

and maintain an audit trail of the changes and who made them. FAMIS

provides these capabilities for FERC.

2.4.3.13 E-Signature Standards

The Electronic Signature in Global and National Commerce Act (S.761)

or E-Bill, recently signed by President Clinton, will establish a national

standard for electronic signatures. This standard would allow businesses

to replace paper records with electronic records regardless of the format

the consumer used to authorize the transaction.

Digital signature standards based on public-private key encryption

technology may be used both to authenticate filer identity and to ensure

the integrity of a document's content. The Commission shall use different

approaches for signature/authentication, based on the type of filing and

the associated risks.

 

5

see OMB M-97-16.
FERC Electronic Filing Strategic Plan

SIGNAL Corporation 2-17 PEC Solutions

2.4.3.14 Developing and Monitoring Recordkeeping Systems

The FERC shall verify that the Information Technology Architecture will

ensure compliance with NARA regulations.

“Agency records officers should participate in the design and

development of recordkeeping systems to ensure the proper disposition

of recorded information. Such involvement is especially important in the

design of electronic records systems. According to OMB Circular No.

A130, agencies are to create or collect information 'only after planning

for it’s . . . use, storage, and disposition.'”

2.4.3.15 Electronic Document Designation

All electronic documents shall be classified as either Temporary or

Permanent. The transition of Temporary electronic Document into

Permanent electronic documents shall be properly defined with a clear

delineation of responsibility (i.e. FERC versus NARA.)

2.4.3.16 Document Scanning

For paper records, all documents shall be converted (e.g., OCR/ICR) to a

machine-readable format that always reproduces the document As-filed.

2.4.3.17 Information Capture and Duplication of Effort

Information should be captured and saved from e-files such that there is a

minimized opportunity to require duplication of effort and potentially

conflicting information.

2.4.3.18 Time & Date Stamping

All electronically filed documents will be stamped electronically with a

data and time stamp.

2.4.3.19 Web Browser Capabilities and Impositions

Electronic Filing will require the end user to access the FERC systems

via the Internet. As a consequence, a standard web browser will be

required at the filer's facility. All FERC generated documents that detail

the web-enabled systems should clarify that web access is not provided

by FERC; i.e. the end user will require an Internet Service Provider.

2.4.3.20 Search Capabilities

Electronic filing shall conform to an industry standard so as to enable full

text search and indexing as required.
FERC Electronic Filing Strategic Plan

SIGNAL Corporation 2-18 PEC Solutions

2.4.3.21 Digital Pictures

Digital Pictures, such as those submitted for Dam Safety Inspection

Reports, must conform to acceptable imaging standards.

Imaging Standards:

• Tagged Image File Format

• Joint Photographic Experts Group (JPEG)

• GIF (note: this is a proprietary CompuServe format; CompuServe

has pursued licensing requirements for use of this format. An effort

should be made to use an alternative non-proprietary format.)

2.4.3.22 Document Utility

Documents shall provide both staff and the public with information in

formats with more utility than either paper or scanned images.

2.4.3.23 Accessibility

When developing, procuring, maintaining, or using electronic and

information technology, the Commission shall ensure, unless an undue

burden would be placed on the agency, that the electronic and

information technology allows, regardless of the type of medium of the

technology --

(i) individuals with disabilities who are Federal employees to have

access to and use of information and data that is comparable to the

access to and use of the information and data by Federal employees

who are not individuals with disabilities; and

(ii) individuals who are members of the public seeking information

or services from the Commission to have access to and use of

information and data that is comparable to the access to and use of

the information and data by such members of the public who are not

individuals with disabilities .

When development, procurement, maintenance, or use of electronic and

information technology that meets the published standards would impose

an undue burden, the Commission shall provide individuals with

disabilities with the information and data involved by an alternative

means of access that allows the individual to use the information and

data.6

 

6 Adapted from the “Workforce Investment Act of 1998”; Section 508:

Electronic and Information Technology.
FERC Electronic Filing Strategic Plan

SIGNAL Corporation 2-19 PEC Solutions

2.4.3.24 Privacy

The Commission will ensure that the Commission’s use of information

technology sustains, and does not erode, the statutory protections for

personal information. Personal information contained in the

Commission’s systems of records will be handled in compliance with the

Privacy Act of 1974.
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-1 PEC Solutions

Section 3 – Information Technology Infrastructure

3.1 Current Environment

The FERC Information Technology Infrastructure is a snapshot of the

current IT environment at FERC. This section discusses FERC in terms

of the current organizational structure, the functions within FERC, the

applications used to support these functions, and the IT environment.

3.1.1 The FERC Organization

Exhibit 3-1. FERC Organization

The Commission was created by the Department of Energy Organization

Act on October 1, 1977, to replace the Federal Power Commission. It is

made up of five members who serve staggered five-year terms and are

appointed by the President and confirmed by the Senate. No more than

three commissioners may belong to the same political party. The

Chairman, designated by the President, serves as the Commission's

administrative head.

The Commission's legal authority comes from the Federal Power Act of

1935, the Natural Gas Act (NGA) of 1938, the Natural Gas Policy Act

(NGPA) of 1978, the Public Utility Regulatory Policies Act of 1978, and

the Energy Policy Act of 1992. Read more Enabling Legislation

The Commission recovers all of its costs from regulated industries

through fees and annual charges.
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-2 PEC Solutions

FERC comprises several divisions which work together to accomplish

FERC's mission. See Exhibit 3-1. This document shall address the

specific organizational structures, functions and applications that are

specifically effected by the E-filing initiative.

The question “What is FERC?” is best answered by reading the

Commission’s mission statement as stated in the FERC Strategic Plan FY

1997 – FY 2002. FERC’s mission reads:

“The Commission regulates, in the public interest, essential

interstate aspects of four of the nation’s critical energy

industries: electric power transmission and sales for resale,

natural gas transportation and sales for resale, oil pipeline

transportation, and nonfederal hydroelectric power. The

Commission ensures that the rates, terms and conditions of

service for the electric power, natural gas, and oil industries are

just and reasonable and not unduly discriminatory or

preferential, and that licensing, administration, and safety

actions for the hydropower industry and other approvals for all

four industries are consistent with the public interest. It

administers numerous laws and regulations involving key

issues...”

The major components of the FERC organization consist of twelve

program offices. The program offices are:

• The Office of the Chief Information Officer – OCIO enables

and supports the Commission's information technology (IT)

needs and initiatives. The OCIO is responsible for meeting the

requirements of internal and external customers, both to provide

a stable reliable computing environment, and to provide access

to information generated by and maintained by FERC, in a

timely, user-friendly way.

• The Office of the Secretary –The Office of the Secretary

(OSEC) plays a vital role in the FERC's document trail process.

It is an office established by the Commission to serve as a focal

point for filing proceedings before the Commission. In

accordance to the Commission's Rules and Regulations, and as

written in Chapter 18 of the Code of Federal Regulations, the

Secretary issues notices of proceedings to the public in order to

alert and invite them to participate in the proceedings. In

addition, the Secretary is responsible for documenting and

retaining the minutes that require actions taken during the

proceedings. These minutes are taken by vote from the members

of the Commission who are responsible for the issuance of

official Commission rules and orders which includes service of

documents on parties to the proceedings. The Office of the

Secretary is also responsible to respond to inquiries from other
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-3 PEC Solutions

parties concerned with pending proceedings, requests for

interpretations of Commission orders, rules, regulations, and

decisions.

• The Office of Energy Projects – OEP has the engineering and

environmental expertise to certificate new gas pipeline projects

and to authorize and monitor hydroelectric projects. It focuses on

project siting and development, balancing environmental and

other concerns, ensuring compliance, and safeguarding the

public. OEP combined the natural gas pipeline certificate staff

from the Office of Pipeline Regulation with the Office of

Hydropower Licensing. Both deal with environmental issues

related to gas pipeline construction projects and

licensing/relicensing of dams, respectively.

• The Office of Markets, Tariffs, and Rates – OMTR deals with

matters involving markets, tariffs and rates relating to electric,

natural gas, and oil pipeline facilities and services. It plays a lead

role in monitoring, promoting and maintaining competitive

markets and refining compliance auditing. This office combined

the rates function of the Office of Pipeline Regulation, the rates

function of the Office of Electric Power Regulation, and the

Office of Economic Policy, so that analysts now get involved in

both gas and electric rate issues and markets since there is more

competition between the two markets now.

• The Office of Administrative Litigation – The Commission's

trial staff consists of lawyers and expert witnesses from the

Office of Administrative Litigation. The trial staff participates in

cases set for hearing, serving two unique roles. First, it advocates

positions for the public interest. Second, trial staff actively leads

the settlement process in most cases and routinely explores

alternative dispute resolution techniques.

• The Office of Administrative Law Judges – The Office of

Administrative Law Judges resolves contested cases as directed

by the Commission either through impartial hearing and decision

or through negotiated settlement. It also presides over ADR

procedures at the request of the parties in cases assigned for

hearing.

• The Office of the General Counsel – The Office of the General

Counsel provides legal services to the Commission. OGC

represents the Commission in cases before the U.S. Circuit

Courts of Appeal and the U.S. Supreme Court and is responsible

for the legal phases of the Commission's activities. The Dispute

Resolution Service (DRS), which resides under the OGC,

fosters the use of alternative dispute resolution processes (ADR)
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-4 PEC Solutions

within the Commission and for disputes within oil, gas, electric,

and hydroelectric industry.

• The Office of the External Affairs – OEA serves as FERC's

primary source of information regarding energy regulatory

matters for the general public, federal, state, and local

governments, news media, regulated entities, and public and

private interest groups.

• The Office of Strategy and Organizational Management –

OSOM is responsible for defining Commission direction and

anticipating and planning for the future. The Office aligns human

resources with the Commission's strategic plan and goals and

coordinates the processes by which employees are attracted,

retained, and developed in order to best support those goals.

Additionally, OSOM coordinates management review and

change initiatives in accordance with the Commission's strategic

direction.

• The Office of Finance, Accounting, and Operations – The

Office of Finance, Accounting, and Operations oversees and

directs the executive and administrative operations of the

Commission. It also advises the Chairman of potential issues and

concerns in the areas of management studies and related

financial reviews, productivity, and performance audits.

3.1.2 Systems

This section provides an overview of systems at FERC that will be

involved in the E-filing process. Also included are relevant external

systems that interface with FERC. The following information is provided

for each system: its purpose/functionality, its program office, system

platform and OS, primary applications, and primary interfaces.

Applications and communications will be discussed in more detail later

in this section.

The systems include:

• FERC Automatic Management Information System (FAMIS)

– The objective of the FAMIS system is to store all filings from

the general public (approved or rejected). It is a system which

stores working documents, electronic tasks, and links to other

system functions.

• Records Information Management System (RIMS) – This

system’s objective is to store images and documents submitted

by the general public and issued by the FERC.
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-5 PEC Solutions

• Commission Issuance Posting System (CIPS) – This system is

used to provide timely access to issuances of the FERC (e.g.,

orders, notices, and rulemakings.) The issuances can be read and

downloaded in either ASCII or WordPerfect 8. CIPS also

provides a daily filing list that contains the FERC reports,

citations, and the daily calendars of hearings and meetings.

• Form Application Systems: the servers that are used for

processing forms, including :

• Form 1, Electric Utility Annual Report

• Form 6, Annual Report of Oil Pipeline Companies

• Form 423, Cost and Quality of Fuels for Electric

Plants-Monthly

• Windows Client Stations: Windows 95 based computers

(version 95a and 95b) are used for specific applications created

in Visual Fox Pro, Turbo Pascal, DOS Clipper, etc.

• IBM RISC 6000: IBM RS/6000 PowerServer 990 O.S. AIX

4.1.4. is used as the RIMS application and database server.

• Doorway Server: Compaq Proliant NT based computer. The

public may submit filings to the FERC electronically through the

Doorway server.

• NT Servers: The following types of NT servers are in use:

Compaq Proliant 1500 Server (CIPS Webserver) with a Pentium

II processor, 100 MB of RAM, 32 GB hard drive; and Dell

PowerEdge 2200 Server (RIMS Web Server) with a Dual 333

MHz Pentium II processors, 128 MB RAM, 9 GB SCSI-3 hard

drive.

• NetWare Servers: Novell 4.x.

• Index Server: Compaq Server. O.S. Windows NT; application:

MS Index Server (CIPSWeb).

• Virus-scanning Server: The application is McAfee VirusScan

that runs on a Compaq Proliant Server, O.S. NT Server 4.0.

• E-mail System: FAMIS includes an e-mail system that supports

dynamic e-mail groups by team; works with GroupWise v5.5

• Automatic Number System: This is a web-base query system

running on an NT platform.
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-6 PEC Solutions

3.1.3 Applications

The following paragraphs highlight the primary applications that are

involved in electronic filing.

3.1.3.1 FAMIS

The FERC Automated Management Information System (FAMIS) has

replaced the mainframe applications: CIS, ACAS and KICTS1. FAMIS

uses the Open Text Live Link EDMS/Workflow software. FAMIS is the

primary platform used to implement the requirements identified by the

FERC First! BPR effort. FAMIS is intended to provide the "one-stopshopping mall" for all FERC-wide data needs. FAMIS incorporates the

functionality of the following systems/applications:

• CIS: Commission Issuance System (a mainframe system used to

manage, track, and disseminate Commission Issuances in accordance

with the mailing and service lists it maintains, following the

documents associated with the issuances as they are logged in and

out through the registry, printing, and distribution processes.)

• ACAS: Automated Commission Agenda System (a mainframe

system used to schedule and maintain the agenda for each public

Commission meeting)

• KICKS; Key Indicator Case Tracking System (a mainframe system

used to track the Commission’s caseload, including the significant

milestones for each case or “docket).

Planned system incorporation includes:

• Rate & Tariff Information System (RATIS) & Auto Number

Sheet (ANS) systems for support electric transmission tariffs.

• Office of Energy Projects Information Tracking (OEP-IT)

system to consolidate the Hydropower annual charges system,

the Hydropower License Compliance Tracking System (HLCTS)

and similar information on natural gas pipeline projects.

FAMIS also has a "download link" to PeopleSoft to provide updated staff

listings.

 

1

As identified by the October 1, 1999 document "What to Expect from FERC

Automated Systems" all of the functionality of CIS, ACAS and KICTS is presently

implemented in FAMIS.
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-7 PEC Solutions

3.1.3.2 RIMS

The Records and Information Management System, illustrated in Exhibit

3-2, is a computerized index of all official documents submitted to and

issued by the Commission after November 16, 1981. Access to RIMS is

available to the public (and FERC users) via the Internet, and internally

to FERC users via the LAN/WAN. Documents from November 1995 to

the present can be viewed and printed from FERC's Home Page using the

RIMS link or the Energy Information Online icon. Documents from

November 1981 through October 1995 are stored on microfilm and can

be printed upon request. Scanned documents are initially saved as TIFF

images for optical storage but are converted to GIF images for web

browser display. Magnetic disk storage uses an EMC Symmetrix 160GB

while Optical storage resides on a Cygnet/ATG.

Scan Clients

Optical Storage

LAN Retrieval Clients

Windows NT Web Server

Internet and Intranet Access

AIX/Informix Server

Exhibit 3-2. RIMS System Overview

3.1.3.3 CIPS

Commission Issuance Posting System provides access to the texts of

formal documents issued by the FERC since November 14, 1994.

Documents are posted in WordPerfect and ASCII formats. CIPS is an Xbased database table running Microsoft’s Internet Information Server.

3.1.3.4 FASTR

FERC Automated System for Tariff Retrieval (FASTR) is used in the

Office of Markets, Tariffs, and rates for receipt, verification, database

management, and search and retrieval of natural gas pipeline company

tariff sheets submitted in electronic format. The tariffs contained in

FASTR are publicly available via the Commission’s web site.
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-8 PEC Solutions

3.1.3.5 Docket Sheet and Service List System (DS/SL)

The Commission (Office of the Secretary) assigns a docket number to

each proceeding initiated by an applicant, other party, or the

Commission. The Docket Sheet lists all submissions and issuances in a

particular case or “docket”.

The Office of the Secretary also maintains a list of contacts for all parties

that have filed Motions to Intervene in a particular case or “docket”.

Each party to a Motion to Intervene may add up to two contacts to the

“service list”. When parties to a case make a filing with the

Commission, they are required to serve a copy on all other persons on the

service list. Similarly, the Commission must serve a copy of its

issuances in a case to all parties on the service list for that docket. The

Office of the Secretary also maintains service lists for rulemaking

proceedings.

The Docket Sheet/Service List System is part of FAMIS and had query

capability for daily filing and issuance lists, and the service list for a

particular docket.

3.1.3.6 GASIS

GASIS is a repository for information filed with the Commission by

natural gas pipelines.

• FERC Form No. 2: Annual Report of Major Natural Gas

Companies

• FERC Form No. 2A: Annual Report of Non-Major Natural Gas

Companies.

• FERC Form No. 11: Natural Gas Pipeline Company Quarterly

Statement of Monthly Data.

• Index of Customers

As a result of Order No. 637, issued February 9, 2000, the Discount Rate

Reports will be discontinued September 1, 2000. Order No. 637 will

expand the information that natural gas pipelines must file as part of the

Index of Customers.

3.1.3.7 FERC Gas Data: Form 2 Admin

Used to support pre-processing of Form 2 & 2a electronic filings prior to

loading into FERC Gas Data System. Generated PDF version of filings.
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-9 PEC Solutions

3.1.3.8 FERC Gas Data: Form 2 Validate

To allow Utilities to review and validate their forms prior to submission

via the Web.

3.1.3.9 FERC Gas Data: Certificates Processor

Small file-type application utility used to copy Certificates (i.e. files) to

network drives.

3.1.3.10 CIPS Manager

CIPS Manager downloads information from CIPS in ASCII format and

provides staff with indexing and text search capability across documents.

3.1.3.11 Tracking Systems

The following tracking systems are used within FERC2:

• Litigation Tracking System (LTS): Office of Administrative

Litigation (OAL) tracking system for settlement cases and the

attorneys, analysts and judges assigned to them.

• General & Administrative Law Tracking System (GALTrack):

Office of the General Counsel (OGC), General and

Administrative Law case tracking system and notes.

• TRACKER: OMTR tracking system for Rate Applications,

Issues related to rates, Technical Conferences, and Budget Code

information.

• CERTTRACK: OMTR tracking system for Certificate cases,

Issues, Protests, Rehearing and Construction costs related to

certificate applications.

• Front Office Tracking System: OMTR system to track

milestones for congressional inquiries and front office

memos/correspondence.

• EISTrack: Office of Energy Projects (OEP) system to track

environmental case processing descriptions and milestones for

pipeline certificate casework.

 

2

 Of the 85 tracking systems referenced in

y2ksyslst.testassess.xls, these are the most important for E-filing.
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-10 PEC Solutions

• Environmental Conditions Tracking System (ECTS): OEP

system to track status of environmental conditions and

compliance for natural gas pipelines.

3.1.4 Communications

3.1.4.1 LANS

The local area network within FERC consists of both Token Ring and

Ethernet. Signal Corporation is transitioning the LAN from Token Ring

to a full Ethernet system. The FERC Ethernet Migration will take place

using Cisco Catalyst 5000 Series of Ethernet Switches. More specifically

the 5505 and 5509 models, along with the existing Synoptic Token Ring

3000 series Hubs. The Cisco Catalyst 5509 Ethernet Switch will be

installed at the FERC headquarters while the Cisco Catalyst 5505 will be

installed the Regional Offices.

A general illustration is provided below. When completed the system will

consist of 100 Mbps Ethernet to the desktop with a 1 Gbps backbone.

3.1.4.2 WANS

The Wide Area Network, illustrated in Exhibit 3-3, consists of an AT&T

Frame Relay system (FTS2001) that connects to the regional offices as

well as a separate frame relay to the Internet Service Provider, UUNet.
FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-11 PEC Solutions
FERC Electronic Filing Strategic Plan

SIGNAL Corporation 3-12 PEC Solutions

4.11

WDCO5

EA

LJ

HL (HQ)

4.11

WDCO6

OSEC

EP

ED-1

ED-20

ED-21

ED-22

ED-24

GC-13

Stay-in-School

 RIMS Ops.

Empl. Assist.

Couns.

Health Unit

Fitness Center

Childcare Center

4.11

WDCO7

CA

PR

Compaq

Proliant

5000

Compaq

Proliant

5000

Compaq

Proliant

5000

4.11

WDCO2

CO

CH

4.11

 FERCWIDE

Global Apps

 Server

Compaq

Proliant

5000

4.11

WDCO4

CI-1

ED-10

ED-11

ED-12

ED-13

ED-14

Signal/(Subs)

LaDorn

Compaq

Proliant

5000

Compaq

Proliant

4500 5/66

4.11

HQ1

E-Mail

4.11

WDCO8

PR

Compaq

Proliant

5000

4.11

WDCO9

GC

(except GC-13)

Compaq

Proliant

5000

Compaq

Proliant

5000

4.11

ARO1

HL-12.2

Atlanta

4.11

SFRO1

HL-12.6

San Francisco

4.11

CRO1

HL-12.3

Chicago

Compaq

Proliant

 2500

Compaq

Proliant

2500

Compaq

Proliant

2500

HQ SERVERS

REGIONAL OFFICE SERVERS

4.11

NYRO1

HL-12.4

New York

4.11

PRO1

HL-12.5

Portland

Compaq

Proliant

2500

Compaq

Proliant

2500

4.11

FERC_CD

Commission CD

Server

4.11

FERC_TRAIN

Commission Trtaining

Server

Compaq

Proliant

5000

Compaq

Proliant

5000

4.11

FERC_APPS

NDS Tree master replication

server

Time Reference server

Laser Fiche

Compaq

Proliant

5000

The illustration reflects some organizational codes from the FERC's

previous organizational layout. This is currently undergoing changes to

update the codes accordingly.
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3.2 Future Infrastructure

The future infrastructure that will support FERC’s electronic filing

activities can be one of several basic configurations. These alternatives

are discussed in the paragraphs that follow, along with their pros and

cons.

3.2.1 Fundamental Architecture Implementation Considerations/Alternatives

3.2.1.1 Maintain Status Quo

Maintaining the status quo is not a practical alternative for a multitude of

obvious reasons. FERC is presently improving the regulatory processes

by reducing the cost and volume of paper filed by applicants and

intervenors. It is anticipated that the volume of work that will be

processed will continue to grow due to expanded competition in the

energy market.

Additional considerations that prohibit maintaining the status quo include

a general requirement for access to data in a timely manner. This has

become an expectation brought about by the changing technology

available to both FERC and the energy industry. This has resulted in

business being conducted in an accelerated manner such that maintaining

the status quo would not be a viable alternative.

Our primary customers are demanding electronic filing capability and

enhanced electronic retrieval. To effectively regulate in a world driven

by electronic communication, transmission, storage and retrieval, an

electronic filing and publishing infrastructure must be implemented.

3.2.1.2 Monolithic Alternative

The most common example of a centralized configuration is a mainframe

or central server-based system. In this environment all hardware,

software, and supporting applications execute on a single host or cluster

of servers residing in one location. This configuration incurs fewer

system administration and maintenance costs compared with a

distributed configuration. This configuration favors functions that can be,

or logically should be, centrally located, such as financial systems,

human resources systems, and common customer documents and profile

databases. Critical issues surrounding this configuration include its data

availability, user support, network bandwidth consumption (especially as

FERC moves to incorporate more complex data types), and supporting

infrastructure requirements. A centralized configuration includes a

system to run mission applications and real-time applications, run the

RDBMS, process batch jobs, and manage the primary storage subsystem.
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The centralized system can also act as a data repository for the enterprise

data. Servers may be included to support applications by acting as the

interface between the client and back-end data server (e.g., a three-tiered

architecture). In FERC’s environment, these application servers would use

the Windows NT operating system.

The ability to centralize data in a single environment allows database

administrators to more easily standardize interfaces and data formats from

filers; simplifies the collection and storage of FERC data; and channels

FERC analysts’ queries to one location. Further, by maintaining a centralized

configuration for its data, FERC would reduce its systems maintenance

requirements (over a distributed alternative) and reduce the number of standalone applications that are interspersed throughout the current environment.

Adopting a centralized configuration reduces the amount of data

redundancies (inherent in distributed alternatives) within the system and

allows for a single data source for all applications.

The risks of a centralized configuration include maintaining a single system

configuration capable of delivering acceptable system response times; batch

processing impacts on the system (e.g., whether there are enough CPU

cycles available to process the batch workload in the allotted time); its

potential as a single point of failure (adequate system and communication

redundancy would be necessary); scheduled system downtimes and their

impact on FERC processing; and configuration expandability limitations. A

centralized configuration does offer advantages over a distributed

configuration in the areas of security and maintenance. Security within a

centralized configuration is easier to implement and control compared with a

distributed configuration. Maintenance and data synchronization within a

single system environment is much more straightforward than distributing

and synchronizing data among many systems.

3.2.1.3 Distributed Alternative

Distributed data configurations are recognized for their modularity,

scalability, and relative ease at disseminating data to the desktop level.

The architecture supporting these configurations can span large

geographic areas or a single floor within an office building. This type of

configuration allows IT systems designers to place data and their

supporting platforms and software products in strategic locations to best

support mission critical functionality. However, it is the most complex of

the configuration options to manage and administer.

The distributed configuration uses application servers and local file servers

within office locations capable of supporting such an environment. The

configuration includes multiple servers to segment the RDBMS workload

and run the RDBMS and mission applications.

For the distributed configuration to be deployed, the data currently stored

in the enterprise or legacy data stores would have to be converted to the

target RDBMS environment and loaded onto the distributed servers. The
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RDBMS applications run on the distributed servers, which are designed

to handle the appropriate transaction volume and application workloads.

A thorough analysis would be needed to determine the load and

processing needs for the server to ensure that the servers are sized

properly.

To provide for RDBMS transactions, minimal down time, and the ability

to scale the system, an operating system needs to be robust and proven

within the industry to have successfully addressed these issues. A Unix

operating system is the predominant operating system for a distributed

RDBMS production environment, although Windows NT versions of

RDBMS products are available and are gaining market share with their

most recent releases. Data in this configuration must be accessible by all

FERC staff and possibly by FERC’s clients.

Distributed architectures are typically employed to minimize network traffic,

increase performance and responsiveness, provide redundancy for disaster

recovery, and enhance the ability to modularly grow an enterprise. Data may

be grouped or organized in any manner, regardless of quantity, location, or

format. This segmentation of data, such as might be done on a regional

basis, can increase performance for query and report generation within that

domain. However, it can also complicate report generation if enterprise-wide

reports containing data from multiple databases are needed. The

configuration’s flexibility creates added costs from a systems administration

point of view. Distributed configurations tend to be more complex to

maintain depending on the amount of data, the way in which it is distributed,

and its replication, backup, and recovery requirements.

A distributed configuration would allow FERC to distribute its data to

suit program requirements and business functionality. Further, because of

their modular nature, distributed architectures adapt and grow well with

future technologies. An increasing number of commercial products—

including analysis tools, platforms, and operating systems—are being

designed to operate in this environment.

Most of FERC’s existing applications are centralized (monolithic) by design

and will not migrate easily to a distributed configuration. These would be

better suited to a centralized data configuration rather than a distributed

configuration. This is because much of the data is used by FERC staff

located at the Washington, D.C. office, and most of the data is static once

received from the responsible parties. However, the Commission’s five

Regional Offices are also the initial points of receipt for most hydropower

dam-safety related filings and reports, and this “distributed” requirement

must be included in the architecture.

3.2.1.4 Alternative Evaluation

The evaluation criteria for comparing the four FERC architectures are:
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• Use of standards: the extent to which the overall architecture and

individual system hardware, software, and communications

components comply with the applicable standards, including

accessibility standards

• Open systems environment: the degree to which the FERC

configuration permits transparent interoperability and integration

among multi-vendor equipment and applications

• Modularity: the degree to which individual components (e.g.,

workstations, communication services, or applications) may be

incorporated and independently configured within the

architecture

• Expandability and Upgradability: the ability of the configuration

to support the current and projected data volumes, workloads,

workstations, and hosts by expanding, upgrading, or enhancing

the baseline component configurations

• Security: the degree to which the system and application

components provide appropriate security features

• Processing Capacity: the ability of the configured processing

resources to process the FERC workload

• Resource Sharing: the degree to which the architecture permits

sharing of local resources (e.g., host resources, file systems, and

data)

• Database Interface Standards: the degree to which the

configuration can support and RDBMS using SQL and the IRDS

standards

• Ease of Implementation: the ease with which configurations and

applications can be deployed relative to manpower, personnel

skill levels, and migration and implementation effort duration

• Hierarchical Storage Management: the degree to which the

architecture facilitates the use of an automated hierarchical

storage management system

• System Management: the degree to which system administration

and management faculties are provided to maintain and operate

the system

• Maintainability: the degree to which the configuration supports

minimization of maintenance requirements, problem isolation,

and easily replaced components.
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All of the above factors are important in evaluating a potential enterprise

architecture. But the most important factors are the first four: the use of

standards, provision of an open environment, modularity, and

expandability and upgradability. These are important because:

• Standardization simplifies integration.

• An open environment permits vendor-independent solutions and

improves competition.

• A single, modular, architecture that is applicable to all FERC

users is preferred over multiple, differing solutions supporting

special communities of interest and the attendant supportability

and integration issues.

• An expandable solution permits incremental deployment of

hardware and applications.

In the comparative evaluation of the candidate architectures, each

evaluation criterion is rated. The possible ratings include unsatisfactory,

satisfactory, or excellent. This will be done as part of the FERC E-Filing

Technical Architecture. An unsatisfactory rating indicates that the

architecture does not adequately meet the minimum requirements for that

criterion in the FERC environment. A satisfactory rating indicates the

architecture meets the minimum requirements. An excellent rating

indicates the architectural design significantly exceeds the minimum

requirements. An excellent rating is assigned based on a subjective

technical evaluation of factors that exceed the minimum requirements of

a particular criterion, such as additional features or functionality offered

by the approach, increased flexibility in the design and expansion of the

architecture, or higher performance or reliability.

3.2.2 Client/Server Implementation Considerations/Alternatives

In a client/server software architecture, two processes interact—one as

superior and the other as subordinate. The client process initiates

requests, and the server responds. Client and server can reside on the

same machine, but they typically run on separate machines linked by a

network. Data integrity and network bottlenecks top the list of

performance concerns for developers deciding whether to locate

application processing in the client or in the server and how “thick” or

“thin” to make the client portion of the application equation.

Client applications typically present information. Client goals include

making information easier to access, assisting end users in organizing

specific tasks, hiding complexity, and reducing learning time. Examples

of client applications in the FERC environment are applications
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implemented using Visual FoxPro, Visual Basic, or browser-based

application front-ends that execute on the desktop systems.

Server applications typically manipulate information. Server goals are

data oriented. These goals include transaction control, performance

optimization, physical-storage management, and ensuring data integrity.

The physical separation of client and server leads to several fundamental

constraints on application design. A good design involves finding the

correct balance between:

• Minimizing traffic on the network: minimize the number and

physical size of requests and responses between client and

server.

• Implementing important business rules in services running on

the server: the server can never be circumvented, so this

approach ensures data integrity.

• Offloading as much logic as possible to the client: the primary

two reasons are that it accelerates feedback when the user makes

incorrect entries on the client; and second, it reduces the load on

the server, which becomes a bottleneck if many clients compete

for services.

Problems can arise for many reasons. Placing too much data within a

client exposes limitations in desktop backup and recovery procedures.

Placing too little data on a client can cause networks to grind to a halt as

users ship records or image files between clients and servers. Building

many small transactions between the client and server can also generate

excess network traffic.

In addition to deciding data location, developers must decide on the

location for executing application functions. Putting large amounts of

procedural code on a client may give individual users the best response,

but may complicate software distribution, configuration management,

and trouble-shooting. Storing procedural code as triggers in a relational

database is becoming a more popular approach. However, this also poses

program maintenance challenges.

Characteristics of client processes include management of the graphical

user interface, presentation logic and control, procedural business logic

(guiding a user in the correct sequences to execute a business process),

local data file input and output, temporary file management, control of

functional access, input data validation, data manipulation and

calculations, on-line user help, event logging, error recovery, and server

session management.

Characteristics of the server process include data logic for record create,

read, update, and delete; enforcement of global business rules; file
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management; data access control; data integrity; event and transaction

logging; error recovery; and multi-client session management.

The functionality of the client layers encompasses:

• Presentation managers, such as Microsoft Windows, that handle

keystrokes and mouse clicks. In some cases, input is handled

entirely within the presentation manager layer; for example,

moving the scroll bar. In other cases, the presentation manager

passes a message to the presentation logic for further processing.

A 3270 character stream can be considered a very primitive

presentation manager. A web browser (e.g., Microsoft’s Internet

Explorer or Netscape’s Navigator) is an example of a very “thin”

presentation manager client (i.e., the bulk of the data and

business logic processing is performed by the server).

• Presentation logic, which includes navigating among forms,

preliminary data validation, managing window objects, and

handling presentation error messages. It also includes data

formatting and converting from data gathering transactions

(queries) into tables, graphs, charts, and other display formats.

• Business, or control, logic—which is a catch-all for processing

that is not directly tied to the database or the presentation. This

processing includes complex data analysis and manipulation,

implementation of business procedures, and directing

transactions from the presentation logic to data servers.

The corresponding server layers include:

• Data logic, which implements actions such as read and write

transactions involving SQL statements, commits and rollbacks,

and database error message handling. Write transactions change

system resources and leave the system in a logically and

physically consistent state. Read transactions are not as well

defined. They can be defined narrowly—as the creation of SQL

views, or more broadly—as the generation of summary

information from the database.

• Data managers, such as network file servers, legacy and

relational database managers, and object-oriented systems

present a range of APIs to the data-logic layer, from primitive

(file server) to sophisticated (object-oriented and extended

relational systems). As data managers become more

sophisticated, less code is needed in the data logic layer.

Requests and responses passing among these layers are called events.

Each layer accepts events from above and—in the course of executing

actions—generates internal and external events. External events are
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directed to the layer immediately above or below; in a true client/server

architecture, events directed from a lower level to a higher level are, by

definition, responses to outstanding requests. Figure 4-5 illustrates the

type of events passed among client/server layers. For example, the

presentation manager directs error messages and status information to the

user in response to keyboard and mouse actions. The data manager

directs query results to the data logic in response to SQL statements.

Examples of events directed from a higher level to a lower level include:

• From user to presentation manager, events are keystrokes and

mouse movements and clicks.

• From presentation manager to presentation logic, events are

procedure calls in the application programming interface that

carry new data and control inputs.

• From presentation logic to business or control logic, events are

functional (business) requests.

• From business logic to data logic, events are transactions.

• From data logic to data manager, events are SQL statements.

Viewed this way, the layer acts as a filter. Within the client, filters

successively concentrate many detailed events into fewer, more

significant events. Between client and server, each event is equivalent to

a business transaction. Within the server, the filters successively expand

events into SQL statements and low-level database access commands.

This approach minimizes traffic on the wire and simplifies the critical

interface between client and server.

3.2.3 Storage Implementation Considerations/Alternatives

3.2.3.1 Data Retention Requirements

Data retention and data accessibility can be addressed together. Data

retention indicates the length of time a particular data set must be

retained. For legal reasons, FERC must retain much information for

years after the initial filing. Some letters generated to a customer may

need to be retained for only as long as it takes to generate and print a

copy of them; a record of the type of letter and date sent might be

sufficient. The National Archives and Records Administration (NARA)

requires that the Commission establish record retention schedules for all

official agency records. (See Appendix C). The requirement applies to

both paper and electronic records. The Commission must be able to

destroy records at the end of the applicable period specified in the

Records Retention Schedule. In some cases, records must be retained for
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more than 50 years (e.g. hydro licensing related documents). Another

concern is the availability of applications in the native application

formats up to 50 years from now. As a consequence, a long-term

program for electronic record keeping must be considered. The longer

the data must be retained, the larger the data store grows.

In conjunction with data retention requirements, data accessibility

addresses the speed with which a data set must be accessed.

Requirements can span between sub-second response times to overnight

batch staging of data, depending on the particular business requirements.

These requirements drive the choice of storage location and media for

the data. In terms of retrieval speed, retrieval from local magnetic storage

is quickest. Other storage areas, in order of fastest to slowest retrieval

speed, include LAN-attached storage (i.e., file server) or a host’s

magnetic disk storage, optical storage, or magnetic tape. Magnetic

storage is typically referred to as on-line storage. Optical storage (e.g.,

jukeboxes) or automated magnetic tape library systems are referred to as

near-line storage because media can be automatically loaded upon

request without human intervention. Magnetic tape or optical platters

sitting on a shelf are off-line storage. They must be physically inserted

into a drive by a system operator.

Therefore, a combination of retention, accessibility, and protection

requirements will dictate the location at which data is stored in the

overall architecture. Hierarchical storage management systems aid in

migrating stored data to less expensive, but slower, storage media as it

ages and is accessed less frequently. Hierarchical storage management

can also be implemented using system administration procedures to

move data from one storage medium to another.

3.2.3.2 Media Alternatives

The Commission must retain official records in a format that accurately

renders a document for the duration of the retention period. For paper

records, scanned image formats always reproduce the document As-filed.

For electronic submissions, the ability to render a document As-filed

may be hindered by the proprietary software application used to create

the electronic submission.

3.2.3.3 Storage Management

Accurate user requirements and data characteristics are important factors

in designing data stores for FERC applications and in making decisions

about storage location and access. The hierarchy of available data storage

locations includes the FERC centralized systems, LAN file servers, and

networked workstations. Data storage technologies at each location

consist of three levels: main memory, magnetic disks and disk arrays,

and tapes and optical disks. Each successive level offers lower cost and

slower access rates but much higher storage capacity.
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General industry surveys indicate that up to 80 percent of data stored on

file servers is rarely, if ever, used again. Easier access to shared storage

adds to the growing file storage capacity requirements. In addition, the

introduction of text search and retrieval and image-enabled applications

can quickly consume vast amounts of storage. Consequently, automated

storage management systems may be necessary to distribute data to faster

or slower storage devices when dealing with large amounts of on-line

data.

Hierarchical storage management (as a business process) simplifies the

process of storing, managing, and accessing data. The explosion in data

volumes and the proliferation of microcomputers and networks has

forced vendors of storage technologies to redefine data management.

HSM allows system managers to streamline the storage environment

through hardware that positions data based on frequency of access. Many

vendors offer products that prioritize data according to user needs and the

cost of storage media. The most vital data is kept on-line, while different

levels of archiving define what is stored off-line.

Near-line is an industry term for an intermediate category of storage that

uses optical storage technologies such as CD-ROM or optical jukeboxes

and improves the efficiency of cartridge-tape management by using

robotic handling. Near-line storage has improved the efficiency of data

processing operations and substantially lowered the overall cost of

storage for optical disk and cartridge tape users. By coupling the robotic

handling of platters or tape cartridges with the speed of the drives, data

processing installations can maintain a class of service that falls between

on-line and off-line. Optical storage devices using jukebox technology

can store massive amounts of information on readily accessible highdensity platters. Competition is fierce in the storage area network market

as technological advances continue to increase storage densities and

drive the cost per gigabyte lower and lower. Near-line storage offers the

cost-effectiveness of removable media without the lower performance of

manual operation.

Tape is the most widely used medium for off-line long-term mass

storage, but optical disk is receiving increasing attention although costs

still are generally higher for disk than for tape. Optical disk is good for

storing bulk data that must be kept available but is not time critical, and

is far less expensive than magnetic disk. Its weakness is that access time

is slower; newer drives, however, continue to provide faster access

speeds. Its strengths are that it is incredibly dense in terms of the amount

of data that can be stored, and it has a longer shelf life than its magnetic

counterparts.

The goal of system managers is to maintain a balance between storage

responsiveness and cost-effectiveness. It is not enough to allocate space

for inactive files; the files must be positioned on the appropriate media

while remaining accessible. Inactive files may be continually transferred

to slower, cheaper media. HSM balances active files remaining on high-
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performance storage media with less active files automatically moved to

more cost-efficient storage. Upon request for an archived file,

hierarchical storage managers automatically restore the requested file

onto active media. This ability to transparently migrate files up and down

the hierarchy based on usage is becoming increasingly attractive to

system designers and administrators. But because HSM systems are

designed to move files, not portions of files, their use with applications

involving very large databases must be carefully examined.

Integrated storage servers combine tape, optical disks and magnetic disks

with hierarchical file-server software. Vendors of integrated storage

servers say their products automate data backup and archiving, store

infrequently needed data on the least-expensive medium, and make

frequently needed data available quickly anywhere on an enterprise

network.

3.2.4 Security Implementation Considerations/Alternatives

3.2.4.1 Security Requirements

The Commission must comply with the Privacy Act of 1974. The

purpose for an information request should be provided anytime the

public provides or enters data. The public should be given the right to

choose whether or not to provide information. When information is used

for other purposes or those other than originally intended, a privacy

notice should be provided. In addition, privacy information maintained

by FERC will be properly secured.

In addition, regulated companies need to protect proprietary information.

The FERC must ensure that all electronic submissions containing

sensitive information are transmitted and stored in a secure manner.

Furthermore, the FERC must provide the industry with defined

procedures for filing, receiving, and posting documents of mixed

proprietary and non-proprietary content.

3.2.4.2 Levels of Security

Information security is a broad topic, from both a policy and a

technology perspective. One of the key objectives of the overall

architecture is to facilitate information sharing within FERC and with its

customers. When interoperability between FERC and its customers is

being considered, a host of challenges arise to achieving the required

levels of confidentiality, integrity, availability, and non-repudiation. The

computer systems that reside within the FERC facilities will provide

proper levels of security from an internal perspective. However, it cannot

be presumed that the industry’s computer architecture will provide for

proper levels of security. As an example, the Windows 9x family of

desktop operating systems should be viewed primarily as a

workstation/personal computer application environment and graphical
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user interface that does not provide authentication or access control

features suitable for the protection proprietary or privacy-sensitive

information. Since most of the industry utilizes the Windows platform it

is necessary to require that appropriate levels of authentication be

required for any electronic filing requirements. FERC will need to ensure

that firewalls are in place to prevent unauthorized access to FERC

information. FERC will also need to work with regulated entities to

determine what type of information is considered proprietary and

therefore should have limited access by the public and other regulated

entities.

These challenges and their solutions involve technical, policy,

administrative, and procedural issues. The technical issues can be readily

addressed using appropriately configured and integrated commercial

products. Policy and procedures must be instituted via appropriate

directives, guidelines, training, and sustained enforcement.

The services that represent the basic building blocks of secure

interoperability are:

1. User Authentication – A security measure designed to establish

the validity of the originator, or a means of verifying an

individual’s authorization to receive specific information.

2. Confidentiality – Assurance that information is not disclosed to

unauthorized persons, processes, or devices.

3. Data Origin Authentication – A security measure designed to

establish the validity of a transmission or message.

4. Data Integrity – Condition existing when data is unchanged from

its source and has not been accidentally or maliciously modified,

altered, or destroyed.

5. Non-repudiation – Assurance the sender of data is provided with

proof of delivery and the recipient is provided with proof of the

sender’s identity, so neither can later deny having processed the

data.

6. Availability – Assurance that adding the interfaces required to

allow the sharing of information will not create situations in

which authorized users are denied service.

A fundamental prerequisite to information sharing is trust between

parties and agreement on access and protection mechanisms. The

security interoperability model must provide a logical progression for

implementing secure information exchange and a framework for

positioning infrastructure and technology requirements. Sharing data

among applications within the FERC internal domain is a simple

example illustrating a situation in which data stored in systems of similar
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security levels are being shared. Sharing data between systems of

differing security levels, such as might occur when allowing customers

access to on-line FERC data or systems, requires additional technological

mechanisms.

The technical security services needed by FERC must rely on standardsbased technology to support viable interfaces to external customers. The

technologies that implement these services include (1) identification and

authentication (I&A) management; (2) cryptography; (3) digital

signature and key management (i.e., Public Key Infrastructure, or PKI);

(4) firewalls, routers, gateways, and guards; and (5) virtual private

networks (VPNs).

3.2.5 Information Exchange Implementation Considerations/Alternatives

The Government Paperwork Elimination Act (GPEA), which takes effect

in FY 2004, provides a strong impetus for agencies to develop the

capability of managing records electronically for their full legal retention

period. Under the GPEA (Pub. L. 105-277), by October 2003, agencies

must give persons and entities that are required to maintain, submit, or

disclose information to the Federal Government the option of doing so

electronically when practicable as a substitute for paper, and to use

electronic authentication (electronic signature) methods to verify the

identity of the sender and the integrity of electronic content.3

GPEA further provides that electronic records submitted or maintained in

accordance with procedures developed under this title, or electronic

signatures or other forms of electronic authentication used in accordance

with such procedures, shall not be denied legal effect, validity, or

enforceability because such records are in electronic form. (GPEA,

section 1707).

 

3

From NARA document: http://www.nara.gov/records/policy/b2000-02.html
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3.2.5.1 Format Alternatives

File Type (Extension) Creating the File Formatting the File Viewing the File Editing the File File Sizes

Word 6.0 or other

word-processing

software (.doc)

Requires proprietary software

(Word 6.0);

Requires proprietary software

(Word 6.0); Wide array of

formatting options that are

maintained when files are

transferred

Must be downloaded before viewed or

modified, unless the Word Viewer is installed

Easy to edit once downloaded; Format is

mostly maintained; Font changes across

various platforms can cause problems in

formatting; Requires proprietary

software (Word 6.0);

File sizes tend toward

the heavy size

Word Perfect 8.0

(.wpd)

Requires proprietary software

(WordPerfect)

Requires proprietary software

(WordPerfect 8.0); Wide array of

formatting options that are

maintained when files are

transferred

Must be downloaded before viewed or

modified.

Easy to edit once downloaded; Format is

mostly maintained; Font changes across

various platforms can cause problems in

formatting; Requires proprietary

software (WordPerfect 8.0);

File sizes tend toward

the heavy size

HTML (.html, .htm) Requires a basic understanding of

HTML, a text editor, or software

Requires a basic understanding

of HTML, a text editor, or

software; basic formatting options

are available in HTML 3.2

Requires any browser and can be viewed

immediately on screen or online - access is

immediate

Requires a basic understanding of

HTML, a text editor, or software

File sizes tend to be

on the lighter side -

quickly downloaded

Portable Document

Format (.pdf)

Postscript files are created in any

software, e.g. Microsoft Word,

Adobe Photoshop, Microsoft Excel

and converted into the PDF format

by means of Distiller or PDFWriter;

also hard copy can be scanned

and converted to PDF using

Acrobat Capture

Preserves formatting

Bytestreaming also allows direct viewing

online with the use of Acrobat Reader or

Exchange; Otherwise, files must be

downloaded and opened in Acrobat Reader

or in Acrobat Exchange

Minor editing is permitted with the aid of

Acrobat Exchange, e.g. addition of

notes, addition of links, page cropping

Significantly smaller

file size when created

from an electronic

source

ASCII Text File (.txt) Any text editor

Limited formatting options - no

font options, text alignment

options, etc.

Can be viewed directly online through most

browsers- immediate access Any text editor can make editions File sizes tend to beon the light side
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3.2.5.2 Transferring Files

The ability to exchange electronic data easily is critical to the success of

an open architecture and FERC’s electronic filing initiative. Data

exchange may occur by several methods, including:

• Application-to-application data exchanges

• Intra- and inter-site electronic mail among FERC system users

• Sharing of files using a network file server

• File transfer utilities

• Use of windowed applications or terminal emulators capable of

capturing session data

• Exchange of data on common portable media such as diskette,

CD-ROM, or magnetic tape

• Exchange of data among heterogeneous databases.

Application-to-application data exchanges can be transparent to the user

or a can be a direct result of user-directed action. For example, in

client/server environments that use TCP/IP as the underlying

communication protocol, application processes typically establish

sessions with one another using TCP/IP sockets to exchange data. EDI is

another example of applications that use a standard method for peer-topeer data transfer.

Electronic mail offers a relatively straightforward way for users and

applications to send and receive information. Many commercial products

rely on proprietary message formats and protocols but offer format

conversions or gateways for standardized mail exchange. These

standards include the International Telecommunications Union (ITU),

Telecommunication Standardization Sector, formerly known as the

International Telegraph and Telephone Consultative Committee’s

(CCITT), X.400 Message Handling Systems (X.400, X.401, X.405,

X.410, X.411, and X.420), the X.500 Directory Services, and the SMTP

and MIME standards.

Network file servers can provide shared file access to LAN-attached

personal computer users. System administrators can assign directory

access permissions to control directory and file access. To the user, the

file server simply appears as another disk. Redirectors are used to

forward requests for remote files to the file server.

Data exchange in the form of file transfers would use the File Transfer

Protocol with TCP/IP. This standard permits systems using the

corresponding protocols to transfer files reliably.

Many personal computer applications in the MS-Windows environment

allow copying data from one window to another, while terminal

emulation packages support the ability to capture interactive session data
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to a local file. The data, stored as simple ASCII text, may then be

imported into word processing, spreadsheet, or database applications for

further manipulation.

Using removable media to exchange information may not be “high tech,”

but it is another method for sharing data. Removable media includes

diskettes, removable hard disks, magnetic tape, optical disks, and CDROM disks. For some organizations with low-frequency distribution

needs, it has proven more cost-effective to make distribution media and

mail it to customers or remote sites than to maintain an extensive,

infrequently used WAN for electronic distribution of files and data.

To make exchanged data useful to the recipient, the receiving application

must be able to recognize and input the data. This requires the use of

standardized file formats augmented by widely accepted de facto

industry-standard file formats. A file format that has been defined by

independent standardization committee is the Open Document

Architecture/Open Document Interchange Format (ODA/ODIF). Federal

standards for document interchange are also available. These include the

standard generalized markup language (SGML under Federal

Information Processing Standard Publication 152 (FIPS PUB 152)),

vector graphics data (CGM under FIPS PUB 128), raster graphics data

(Type I under FIPS PUB 152), and the Initial Graphics Exchange

Specification (IGES). Other applicable standards include TIFF, HTML,

JPEG, and CCITT Group 3 (facsimile). PDF, although proprietary, is

another popular format in which to exchange files.

An additional method of data exchange includes extracting data from

databases to obtain necessary data or exchange data between

heterogeneous databases. Database management systems maintain a

dynamic store of data accessible by all types of applications. The

Structured Query Language (SQL) standard (FIPS PUB 127-2) specifies

a database interface language used to access database information. SQL,

used in conjunction with ODBC, can be used to extract information from

one database into another database, or into a file that is then imported

into another database. Of course, database replication and

synchronization are also possible through features of the DBMS within a

particular COTS product line. In addition, the Information Resource

Dictionary System standard (IRDS specified by FIPS PUB 156)

identifies interfaces to database dictionaries.

3.2.6 Document Management

This section outlines document management vendors that provide

products relevant to the E-filing initiative. These have been identified by

reviewing the present and proposed products available from market

leaders in the document management arena.
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3.2.6.1 Adobe

Adobe has long been recognized as the market leader in the printing

industry and of recent years has broadened its' market focus to include

portable documents that can be distributed via the Internet.

The Portable Document Format (PDF) is a recognized industry format

and has recently been accepted by the U.S. courts as the approved format

for electronic file submission. The PDF standard is specified in "The

Portable Document Format Reference Manual" by Adobe Systems, Inc.,

Addison-Wesley Publishing Co., 1993, ISBN 0-201-62628-4. More

recent extensions to the technical specification are published

electronically via the Internet at http://www.adobe.com. An inter-agency

group within the federal government has recommended that the National

Institute of Standards and Technology (NIST) develop a Federal

Information Processing Standard (FIPS) based on the published PDF

specification.

The latest version of Adobe Acrobat also supports interactive, fill-in

forms, with PDF-based format for data that can be imported, exported,

transmitted, and received from the Web.

3.2.6.2 Documentum

Documentum AutoRender is an automation server that generates Acrobat

Portable Document Format (PDF) and HTML renditions of content

stored in the Documentum repository. This makes it easy to create PDF

and HTML renditions of content that can be viewed using Web browsers

or other PDF viewing tools. AutoRender lets you take full advantage of

PDF's portability, annotation capability, searching, and easy access to

distribute content for review, approval, and final release. Because the

transformation is fully automated, documents no longer need to be

converted to Web formats manually.

3.2.6.3 OpenText

OpenText provides complete solutions supporting electronic filing,

document management and records retention. The product Livelink PDF

Forms Professional includes a standard PDF Forms module plus eForm

Warehouse, a product developed by Cardiff Software specifically for

Livelink. The eForm Warehouse product extends and enhances the

capabilities of the Livelink PDF Forms module by offering point-andclick form design, server-side data verification, and a form processing

system. These forms can then be integrated with the workflow

management process also supported by Livelink. Form data can be

extracted for transfer to external databases, XML, or other applications.

Completed forms can be indexed and searched. Features include:

• point-and-click form template design with automated

JavaScripting
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• server-side data verification

• form processing system

• integration with Livelink Workflow

• extraction and reuse of submitted data via external ODBC

databases or XML

• archiving of submitted forms in Livelink

• ability to capture paper forms

• store them as PDF or TIFF documents in Livelink.

3.2.6.4 Cardiff Software Inc.

Cardiff's product, TELEform, can handle any kind of form, whether

paper or a “digital” format such as a fax, a PDF file, an HTML file, or an

e-mail attachment. The product also supports output to PDF, TIFF as

well as XML. The XML format which can be exported to other systems

including e-commerce, e-business, and server applications. These forms

do not require special software development. Forms can be saved

directly to FoxPro or other database formats. Cardiff has a partnership

with both Adobe and OpenText. The Cardiff product, PDF+Forms,

works directly with OpenText's Livelink.

3.2.6.5 Provenance

Primarily focused on Records Management and Document Retention.

The primary product, ForeMost Enterprise, provides an advanced 3-Tier,

32-Bit architecture for records management.

ForeMost Enterprise has a seamlessly integrated Web Edition offering a

complete records package with web- based thin client functionality.

• Web Access: Remote users can access the ForeMost Enterprise

database using Netscape Navigator or Microsoft Internet

Explorer. This web access eliminates the need to perform DBMS

client installations.

• Document Viewing: ForeMost Enterprise's Web Edition includes

powerful, ActiveX viewing to view over 150 document types.

The Active X viewer allows users to view documents in their

original format, eliminating the need to install multiple

applications on their desktops.

• Audit Trails: ForeMost Enterprise's Web Edition incorporates a

comprehensive auditing system. Audit trails can be generated on

Files, Documents, Users and System operations. ForeMost

Enterprise's Web Edition audit trails provide legal proof of

official records activity.
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3.2.6.6 Tower Software

TOWER Software's product, TRIM CapturaTM is an Electronic

Recordkeeping system designed to provide a complete and seamless

management solution for physical and electronic documents.

TRIM enables the capture and management of all important documents

at the point of creation. Through TRIM’s tight integration with Microsoft

and other office suite desktop applications, all forms of electronic

documents (including email) can be easily captured, indexed and

subsequently accessed.

3.2.6.7 Hummingbird

CyberDOCS®, a Web-enabled document management product, provides

full document management functionality from a web browser over a

corporate intranet, extranet, or the Internet. Features include:

• Web browser interface

• Check-in/Check-out from a Web browser

• New document creation

• Java-based DOCS Open forms interpreter

• Searching across multiple DOCS Open libraries

• Use of standard Internet technology (HTML, Java, Java applets,

JavaScript, ASP)

• Complete customization

• Projects and Quick Searches for web browser user

• Seven levels of security

3.2.6.8 FileNET

FileNET provides a variety of products under the heading of “Panagon”.

The following products are available:

• Web Services: Core product and development environment that

integrates with each of the Panagon products to help you build

Web-centric eBusiness applications.

• Capture Desktop: Acquires digital and paper-based content into

Content Services and your Web servers.

• Capture Professional: Acquires digital and paper-based content

into Image Services for enterprise-wide use.

• Content Services: The digital content server that manages

dynamic electronic documents throughout their lifecycle, from

collaborative creation to secure delivery to revision and re-use.
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• Web Publisher: Breakthrough product providing indexing and

automatic formatting for documents your authors simply drag

and drop to your Panagon Web site repository.

• Image Services: The high-volume digital image server for

storing, retrieving, and managing transactional content and

objects of all types.

• Report Manager: Specialized software to store, access, mine and

analyze computer-generated reports, statements and forms.

• Visual WorkFlo: High transaction eProcess software enabling

customers, partners, and internal users to automate and drive

critical business activities and personalized content creation.
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Section 4 – E-Filing Information Technology Architecture

The Information Technology Architecture (ITA) is centered around a

Technical Reference Model (TRM) that is built upon the concept of three

layered infrastructures: the information infrastructure, the

communication infrastructure, and the processing infrastructure. The

security infrastructure is a connection mechanism that spans the layers.

This is illustrated in Exhibit 4–1.

Processing

NIU NIU NIU

NIU NIU

NIU NIU

SEGMENT B

Communication

Information 1011000111011000011 ... Security

Exhibit 4-1: Technical Reference Model

These infrastructures support a suite of fundamental ITA services (i.e., Efiling functional requirements), and each service is supported by ITA

standards, design guidelines, and preferred approaches or products. The

infrastructures are explained further in the following paragraphs.

Associated standards are presented in Section 4.5.

4.1 Information Infrastructure

The users of E-filing applications are concerned with collecting, saving,

sharing, and retrieving information easily and expeditiously.

Consequently, the information used and generated is an important aspect

of the architecture.
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Users' daily responsibilities depend on the information, which exists in a

variety of forms, not on the nuances of the technology and its

configuration. This intricate information base, taken as a whole,

represents the Commission’s “information infrastructure.” The

information infrastructure characterizes the type of information used

within the Department: it shows who needs the information and how it is

generated, accessed, and maintained. It defines data, models data

relationships, facilitates storage and retrieval of data, and describes the

constraints on the use of data. This knowledge is then used to develop a

technology strategy for efficiently managing the needed data.

The information infrastructure is supported by a diverse suite of

application servers, and it provides value through its use of common data

format and exchange standards. Well-defined data and data relationships

are essential to a secure and interoperable information infrastructure.

4.2 Communications Infrastructure

The communication infrastructure provides the IT connectivity that

allows the FERC to share information effectively between systems that

are involved in E-filing. The communication infrastructure uses standard

protocols and COTS equipment to facilitate data exchange within the

FERC and between the Commission and Industry. It consists of the data

communication equipment, software, and networks that link computers

and peripherals within and between offices. The communication

infrastructure provides:

• Pipelines for information movement

• Management of pipelines

• Protocols for information movement

• Mechanisms for information movement through pipelines

• Mechanisms for detecting network faults and failures

• Mechanisms for linking with other networks.

The communication infrastructure is designed in the context of three

functional objectives:

• Connectivity: It must be able to interface to current and

anticipated processing equipment within the Commission.

• Interoperability: It must provide mechanisms that permit

hardware from competing vendors to communicate,

implementing an open system design that allows independence

and flexibility.

• Scalability: It must be configurable to support the required range

of user community sizes, traffic requirements, and unique

topologies.
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4.3 Processing Infrastructure

The processing infrastructure supports the information and

communication infrastructures by providing the computer systems and

software necessary to support the FERC’s E-filing business needs. The

computer systems range from desktop systems to dedicated servers. The

processing infrastructure provides mechanisms for:

• Computing, comparing, selecting, evaluating

• Moving information

• Managing user interfaces

• Displaying multimedia information

• Managing processing hardware and software

• Managing system processes

• Controlling system usage.

Functional servers provide specialized services and may take the form of

a remote access server, electronic mail server (e.g. LISTSERV),

electronic mail gateway, fax server, dial-in/dial-out server, remote LAN

access server, database server, text search and retrieval server, or image

server. The server software includes COTS packages and applications

developed specifically to address Commission needs.

4.4 Security Infrastructure

IT security covers a broad spectrum of operational and policy issues. The

E-filing ITA security services comprise the requirements, policies, and

practices to secure information sharing. The security infrastructure:

• Safeguards resources

• Supervises resource sharing

• Facilitates digital signatures

• Ensures resource availability to authorized users

• Ensures denial of service to unauthorized users

• Detects and reports intrusion attempts by unauthorized users.

A fundamental prerequisite to information sharing is trust between

parties and an agreement on access and protection mechanisms. Given an

understanding between the FERC and industry at the policy and practice

levels, an IT architecture can be implemented in which trust and secure

interoperability are established.

The four levels of secure interoperability defined by the architecture

organize the security infrastructure and technology into a single, missionrelated framework:
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• Basic - Ability to support simple security protocol exchanges

between similar security mechanisms. Secure, ad hoc

information exchange procedures are developed to support

specific FERC-industry information exchanges.

• Intermediate - Ability of systems to exchange and process

complex file formats using heterogeneous products. The

products consist of items such as simple enterprise data

encryption systems, single certificate authority trees, and

certificate management protocols. The intermediate level can be

implemented by establishing a trusted system between the FERC

and one or more regulated entities.

• Advanced - Security systems that are partially interconnected

and allow users from FERC and Industry to directly access the

other’s information systems.

• Universal - The ultimate goal of security infrastructures for

achieving interoperability. At this level, security information is

shared globally through a distributed information architecture in

which applications and systems operate across organizational

boundaries and across all security domains. Note, however, that

because the standards and products in the IT security are still

maturing, achieving the universal level of security cannot be

realistically expected in the near future.

Today, the FERC operates at the basic level—establishing ad hoc

security and information sharing policies and procedures for projects like

the E-Filing Pilot. To meet current E-filing goals and objectives, the

FERC will require an Intermediate level of security. Secure transmission

of data and robust digital signatures will require established, trusted

systems between the FERC and Industry. As E-filing evolves and the

FERC strives for increased interoperability with Industry, the advanced

level of security will be necessary.

4.5 Standards Overview

Developers have often turned away from comprehensive systems

strategies and purchased products or services to satisfy immediate needs,

rationalizing that technology and its relevance to mission performance is

changing so rapidly that long-term commitments are no longer possible.

In the short term, there may be benefits in not establishing an

architecture; but, over time, cost efficiencies will diminish and it will

become increasingly difficult to leverage existing resources and manage

the multitude of system configurations. A well-designed architecture

takes into account the need to deliver business value today and the need

to put a solid foundation into place that can support tomorrowís multiple

systems and information needs.
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The Technical Reference Model is built using the concept of four

infrastructures: the information infrastructure, communication

infrastructure, processing infrastructure, and security infrastructure. The

standards presented later in this section are organized around these

infrastructures.

The transition to an standard architecture forces the Commission to make

many difficult choices among products and technologies, implementation

plans, and development practices and policies. A standard architecture

reduces the complexity of the computing environment by promoting

consistency among applications and data and reducing the number of

redundant products used in it. It also helps to focus the expertise of

developers and management onto a smaller set of technologies, thereby

reducing implementation risk because many integration and

interoperability issues will have been addressed before the standard or

product is adopted by the E-Filing ITA.

Central to the definition of an architecture is the identification and use of

standards. Standardization fosters an environment in which the FERC,

the public, and the regulated entities benefit. Selection and adoption of

appropriate standards will greatly simplify integration and maintenance

requirements and improve the Commission’s access to emerging

technologies. Because the FERC’s environment currently relies on

equipment from multiple the architecture must be based upon a suite of

widely supported industry and Federal Information Processing

Publications standards to promote interoperability.

The Technical Reference Model promotes the use of products and

solutions based on industry-derived de facto standards, and preferably on

standards developed and ratified by nationally or internationally

recognized standards bodies, such as the American National Standards

Institute (ANSI), the Institute of Electrical and Electronics Engineers

(IEEE), the International Standards Organization (ISO), and the

International Telecommunications Union (ITU). Specifications

developed by the Internet Activity Board (IAB) and the Internet

Engineering Task Force (IETF) can also provide the basis for standardsbased implementations of protocol technologies. These products must be

highly interoperable, open, and well-supported across platforms and

vendors, and they must facilitate interoperability within and between the

FERC and its partners. These products must also be highly flexible and

scalable to support existing applications and readily accommodate new

ones. Except in rare cases, proprietary products have limited strategic

benefit to the Commission, and these products defy the spirit of the ITA.

These products should be transitioned, as opportunities are presented, to

more open and interoperable products.

Much of the functionality and operational benefit presented to users by

automated systems depends on the user's ability to transparently interact

and exchange information with other systems and users. Because this is

so important, standards and configurations that promote an open systems
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environment must be carefully selected. Products and designs

conforming to such standards can then be used to construct the integrated

applications and networks required by E-filing.

The following sections identify the recommended ITA Technical

Reference Model standards. They are organized by functional need

within each infrastructure layer: information, communication,

processing, and security. As technologies change, the standards identified

with the ITA will also change. The intent is to identify proven

mainstream standards upon which scalable systems and applications can

be built. In using these standards, a project team must first evaluate its

functional, operational, and support requirements and then determine

which ITA standards apply. (Section 4.6 discusses how the Technical

Reference Model is kept up to date as standards, missions, and functional

needs evolve and how the TRM is used in the project review process.)

The standards tables presented in Sections 4.5.2 through 4.5.5 include

products. In some cases, the products comply with the indicated standard

and are currently in use within the Commission. In other cases, an

independent standard does not exist, and the ITA adopts a product

standard for the indicated service. Although the ITA does not mandate a

particular product selection, common products within an enterprise

simplify design and integration efforts; provide a basis for cost-effective

licensing, training, and technical support; and facilitate system

administration and maintenance.

4.5.1 Overview

This section provides an integrated summary of the E-filing ITA

standards, focusing on standards that are architecturally significant—

standards that define a specific technological approach to an E-filing

functional requirement. The analysis in this section describes how the

standards, as a group, form an overall, high-level strategy for the E-filing

ITA. In particular, it considers:

• How the recommended standards align with current industry and

technology trends

• How standards in different service areas interrelate to form an

integrated framework

• How the standards recommendations fit against E-filing

objectives.

The ITA does not define a specific implementation; it provides a

framework for building software and hardware systems to support Efiling. The ITA is flexible enough to allow implementers to follow many

design paths and still comply with the architectural model. Because the
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selection criteria applied in formulating the ITA standards align with

FERC goals and objectives, a strategy emerges when considering the

standards as a whole.

4.5.2 Information Infrastructure Standards

Information exchange standards address format, interchange protocols,

directory, and video teleconferencing services.

Information Format

An objective of the TRM is to reduce the number of standards wherever

possible. This strategy generally results in easier integration and

interoperability with a reduced operations cost. One of the fundamental

purposes of data interchange is to support the transfer of information

both internal and external to FERC. This necessitates supporting a

number of different formats. By supporting many of the mainstream data

format standards, this interchange will be possible with a wide variety of

external systems and organizations, without overburdening these systems

and organizations with the requirement to translate to a prescribed

format.

The focus in recommending multimedia standards (e.g., MPEG, TIFF,

GIF, and JPEG) was compliance with commonly used Internet standards.

This is an example of intentional overlap in some of the ITA standards.

For example, GIF and JPEG are both used to describe a graphical object

and both are in common use, so it makes sense for FERC to accept data

in both formats1.

Information interchange also includes document format standards.

Standardized document formats are essential to FERC because

documents are presently referenced by page number. The dilemma is that

there are no true vendor-independent standards for document formats. A

large percentage of documents throughout the Industry are prepared in

Corel WordPerfect or Microsoft Word formats, both of which are

proprietary formats. The Information Technology Architecture includes a

reasonably open standard in this area: Portable Document Format (PDF).

The PDF file specification was developed by Adobe Inc. and released as

a standard. It has become a widely used de facto industry standard that

provides good exchange qualities while providing platformindependence; the viewing software is available free of charge and does

not require the recipient to have the native word processing package to

 

1

 For additional discussion on GIF, see: 2.4.3.21 Digital Pictures
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view the document.2 However, PDF typically requires investment in

stand-alone software packages to convert native file formats to PDF;

because the PDF specification has been released as a standard it is

possible for independent software vendors to create their own PDF

output capability; one company that has created its own independent

PDF generating capabilities is Corel which has provided this feature

within WordPerfect version 9.0.

The ITA also includes several Internet-derived standards for documents,

including the following:

• Hypertext Markup Language (HTML),

• Standard Generalized Markup Language (SGML), and

• Extensible Markup Language (XML).

HTML is the primary Web document presentation standard; HTML

helped establish the Internet by providing a universal way to present

information. However, HTML only addresses the presentation of data.

SGML is a language for coding hierarchical structures and so can be used

to mark up hierarchically structured data of the type typically found in

books. The standard defines a set of semantics for describing document

structures, and an abstract syntax of formally coding document type

definitions. Unfortunately, SGML is considered too complex for day-today document production and exchange. The third alternative, XML,

provides greater functionality for the immediate future.

XML, a sub-set of SGML, describes a class of data objects called XML

documents and partially describes the behavior of computer programs

which process them. XML is a non-mutually exclusive alternative to

HTML. HTML describes document structure and visual presentation,

while XML describes data in a human readable format with no indication

of how the data is to be displayed.

XML is a meta-language used to define other domain- or industryspecific languages. To construct your own XML language (also called a

"vocabulary"), you supply a specific Document Type Definition (DTD),

which is essentially a context-free grammar like the Extended BNF

 

2

 The PDF standard is specified in "The Portable Document Format Reference

Manual" by Adobe Systems, Inc., Addison-Wesley Publishing Co., 1993, ISBN

0-201-62628-4. More recent extensions to the technical specification are

published electronically via the Internet at www.adobe.com. An inter-agency

group within the federal government has recommended that the National

Institute of Standards and Technology (NIST) developed a Federal Information

Processing Standard (FIPS) based on the published PDF specification.
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(Backus Naur Form) used to describe computer languages. In other

words, a DTD provides the rules that define the elements and structure of

your new language. Any browser (or application) with an XML parser

can interpret the web page by using the rules defined by the DTD.

XML is designed to be transmissible over the Internet in such a way that

document browsers do not need to access the document type definition to

validate the document before display. Since XML is truly extensible,

rather than a fixed set of elements like HTML, use of XML will

eventually eliminate the need for browser developers and middleware

tools to add special HTML tags (extensions). Microsoft, and all other

major software vendors, are making extensive efforts to support XML

documents, for display as well as for document creation.

Information Exchange Protocols

To exchange information in a standard way, the ITA relies on the Internet

to provide standard protocols for functions such as file (FTP) and

multimedia document transfer (HTTP). An important area of network

service, however, has resisted full standardization and interoperability:

electronic mail. Electronic mail protocols, particularly for the post office

and client, are still dominated by vendor-specific implementations. The

dominant industry products are Microsoft Exchange, Lotus Notes Mail

and cc:Mail, Novell GroupWise, and an array of Internet-sourced

products such as Eudora and Netscape’s mail client.

The ITA addresses electronic mail not as just an office automation

function, but as a broader message handling transport. Increasing

numbers of information system applications use electronic mail as a

general-purpose message interchange protocol. Electronic mail plays an

important role in E-filing. The ITA does not specify how filings are

submitted to the FERC but assumes that electronic mail is a viable

alternative. The area where electronic mail standards are strongest is in

the messaging backbone the network connection between electronic post

offices. In this area, SMTP and MIME, for attachments, provide a wellsupported set of standards to establish ITA interoperability.

The other related Internet post office and client standards, POP and

IMAP, are working their way into currently proprietary products from

Microsoft, Lotus, and Novell. Adoption of SMTP and MIME will

provide enough product support and interoperability to maintain

messaging systems that meet E-filing ITA requirements.

An additional architectural feature that supports e-mail is that of a

LISTSERV. A List Server provides the functionality necessary for

automated mailing of documents. This function could be used by FERC

to enable individuals or industries to subscribe to Commission issuances.

This automated workflow process would reduce the quantity of

documents that must be mailed to parties in a proceeding.
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Directory Services

Directory services are strongly related to many other areas. Security

depends upon a well-defined and well-maintained directory of principals

(users) and resources (information, processing, communications).

Unfortunately, there are several competing standards in the directory

services market, and the interoperability problem is not completely

solved. The ITA adopts the Lightweight Directory Access Protocol

(LDAP) as the standard of choice. It is simple, covers a wide range of

applications, and is well supported by commercial products. However,

many information security tools, particularly those used to build Public

Key Infrastructures (PKI), rely on the X.500 directory protocol. Finally,

DCE directory services are included in the ITA list. Similar to the

strategy used in distributed systems standards area, the ITA includes all

three of the dominant industry standards (LDAP, X.500, DCE), with a

preference for LDAP if the requirements of E-filing do not drive the

selection to an alternative.

4.5.3 Communications Infrastructure Standards

Communication services and associated standards are a fundamental part

of establishing interoperability. In general, most mainstream

communications service standards are mature and supported well by

industry. The popularity of the Internet has bolstered interoperability

between different products and platforms based on TCP/IP and related

standards. E-filing will benefit from this situation.

The communication infrastructure must be able to support the same level

of service and performance in the Commission’s five regional offices as

in the main office in Washington, DC. The standards should reflect

document filing in both the regional offices and the main office, and the

need to transmit text and graphics between the main office and the

Regional Offices and between regional offices. For filings submitted to

the regional offices, the official receipt date is the date received in the

regional office.

Local and Wide Area Networking

TCP/IP is the standard ITA transport service in wide area and local area

environments. FERC should fully transition to TCP/IP on the LAN and

WAN as new capital investment opportunities arise. The Internet has

solidified the position of TCP/IP as a leading standard for end-to-end

connectivity in both LANs and WANs. The current version of IP, version

4, is widely supported. The upcoming version, version 6, promises a

future growth path but the current thinking is that IP version 6 will not

become a dominant standard until well into the twenty-first century.

At the lower levels of the LAN protocol stack, the ITA adopts the

Ethernet family of standards. Ethernet is extremely flexible in terms of
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wiring requirements and throughput capacities. All new LANs should be

configured to support both 10 Mbps and 100 Mbps Ethernet. The highend 1 Gbps Ethernet is still a very new standard and will be monitored by

FERC for future adoption.

The protocols rejected for LANs include Token Ring and ATM (although

ATM is recommended for WANs). Token ring has not received the

industry support Ethernet has; as a result, Token Ring implementation

costs are generally much higher. ATM, as a desktop or LAN standard, is

still immature. Although ATM has been touted as a promising single endto-end protocol, stretching over LANs and WANs to connect two

desktops or a desktop to a server, there are still technical and practical

obstacles in fulfilling that promise.

The two primary WAN transports are Frame Relay, for low to medium

speeds (fractional to full T1: 1.55 Mbps), and ATM for high speeds (155

Mbps to 2.4 Gbps).

Network Management

Total Cost of Ownership (TCO) is receiving a lot of attention in the

industry. IT managers realize that operations and maintenance costs of

client/server and other distributed architectures follow a different model

than traditional centralized information systems. TCO can grow beyond

expectation if not explicitly addressed during system conceptualization

and design. Enterprise management is a tool for controlling TCO in a

distributed environment. Enterprise network management will play an

increasing role in the design and operation of the E-filing

communications infrastructure as it matures.

Two important enterprise network management standards are included in

the ITA: SNMP and MIB II. These protocols are Internet-sourced and

specify the monitoring and control protocols for network devices and the

structure that describes the particular device being monitored. Enterprise

management includes many more functions than those covered by SNMP

and MIB. FERC E-filing system implementers should choose an

enterprise tool such as IBM Tivoli, HP Openview, or CA Unicenteróthat

includes MIB and SNMP as underlying standard protocols.

The Mail and Directory Management MIBs define a framework for the

management of networked applications. This definition is from a service

perspective and is independent of the implementation of the application

in terms of processes or installed files. Three MIBs have been defined.

The first is the Network Services Monitoring (NSM) MIB which defines

the generic attributes for management of network applications. The

remaining two MIBs are extensions of the first for the management of

Message Transfer Agents (MTA) and Directory Systems Agents (DSA).
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4.5.4 Processing Infrastructure Standards

Processing infrastructure standards include those for the operating

system, presentation, distributed computing, language, and database

services.

Operating System Services

Operating system services is an area dominated by proprietary products,

not independent standards. The exception to this rule is POSIX. POSIX

provides a comprehensive specification of nearly every operating system

function. Most vendors have an implementation of the POSIX standard,

but many extend it to add unique proprietary features.

The ITA standards for operating systems recognize that proprietary

operating systems, such as those from IBM and Microsoft, will continue

to dominate the industry and are an acceptable alternative. However, the

MS-Windows family of desktop operating systems should be viewed

primarily as a workstation/personal computer application environment

and graphical user interface that does not provide authentication or

access control features suitable for the protection proprietary or privacysensitive information.

JavaOS is an open standard, owned and maintained by Sun

Microsystems, that specifies a full operational environment for executing

portable Java applications. JavaOS is included in the ITA as an emerging

standard to be monitored as it matures for possible later adoption. As

described earlier, the network computing model and lightweight client

design strategies are might play an important role in the future of E-filing

at FERC. Java and its support environment are key technologies in

implementing these strategies. However, Java still currently lacks

sufficient security and performance characteristics to warrant full

adoption. Deployment should be limited to situations where the FERC

has full control over the Java server and client application and

environment.

Presentation Services

Open but proprietary products dominate the user interface. It is projected

that Microsoft Windows (95, 98 and NT) will be installed on more than

90 percent of new personal computers purchased. In the browser market,

Microsoft Internet Explorer and Netscape Navigator collectively control

more than 95 percent of the market. FERC will support these dominant

user interfaces.

Distributed Computing

Until recently, there were three battling factions in distributed system

standards: (1) the Distributed Computing Environment (DCE) defined

and maintained by the Open Group, (2) the Common Object Resource
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Broker Architecture (CORBA) from the Object Management Group, and

(3) the Distributed Component Object Model (DCOM) from Microsoft.

Many factors, particularly the dominance of the Internet, have caused

DCE and CORBA to align and in many ways interoperate. DCE does not

include any object standards expressed in CORBA; and CORBA can

benefit from some of the mature distributed system management

functions in DCE. These two standards have become complementary

rather than competing, but there continues to be competition between

DCOM and CORBA/DCE.

DCOM has its roots in desktop software objects. Its predecessor,

Common Object Model/Object Linking and Embedding (COM/OLE), is

the fundamental tool used to build Microsoft Windows applications.

CORBA has its stronghold in the network. The Internet Inter-ORB

Protocol (IIOP) is a powerful and widely accepted mechanism that

allows software objects to interoperate over the Internet. Although

DCOM and CORBA have attacked the industry from two different

starting points, they are rapidly gaining in each others strengths. CORBA

has strong backing from a broad set of vendors including Netscape,

Oracle, IBM, and Sun. DCOM has strong backing from Microsoft.

The distributed system/distributed object standards battle is far from

being resolved. This technology is very important in the design and

implementation of new distributed systems. Based on FERC’s Microsoft

server and application legacy systems, we recommend that FERC adopt

DCOM for use in the distributed architecture arena. Because the entire

industry is in this situation (faced with two strong competing standards),

tools are available to translate between the two standards.

Because distributed systems are relatively new on the technology

landscape, there are some emerging standards that show promise but that

are too immature to include in current implementation plans. For

example, Java Beans is an object implementation extension to Java. This

standard will become an important tool in implementing the network

computing model. Another example, Web NFS, promises to provide a

way to implement a single, coherent file system over a very large

distributed environment such as the World Wide Web, but it is still more

of a research topic than an implementation tool.

Programming Languages

The ITA focuses on strategy and long-term architecture targets.

Accordingly, Visual Basic, Visual FoxPro, C, and its object-oriented

variant, C++, are included as the preferred strategic programming

languages. Also present as an emerging standard is Java. Java offers

great promise in building open, transportable applications because of its

platform-independent nature. In addition, it is the principal technology in

developing thin client, network-centric applications.
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Database Services

Database services is an area of technology that is traditionally driven

more by vendor-specific products and features than independent

standards. The three leaders in relational database technology (Oracle,

Sybase, and Informix) and the leading mainframe DBMS vendors (IBM,

CA, and SoftwareAG) have unique and mostly proprietary data storage

and management standards associated with their respective products.

Two standards included in the ITA provide standardized data access:

ODBC and SQL. ODBC provides product-independent database access.

SQL defines a standard query language. Both standards are well defined,

but most ODBC and SQL products include ample vendor augmentation

and extensions that tend to undermine full application portability.

4.5.5 Security Infrastructure Standards

A fundamental E-filing objective is to make information more readily

accessible to those who need it. This increases the importance of

information security and the need to ensure confidentiality, integrity, and

availability. There are very well-defined practices and procedures for

handling National Security Information (NSI). The Commission,

however, deals with a lot of industry-related proprietary information. The

ITA therefore focuses on how components can use security standards and

products to gain the assurances needed to confidently share and protect

proprietary information.

Information security technology is an active area. Although there are

many mature standards, just as many are emerging. The central

Government standard for information security is FIPS 140-1. This FIPS

refers to many other standards and defines the protocols that are to be

applied for a wide variety of security applications within the Federal

Government. FIPS 140-1 includes many well-accepted stable standards

such as DES for data encryption and DSA for digital signature. However,

the FIPS has not been able to keep up with the rapid pace of change in

information security technology. Many standards that the FERC may

require are not addressed by FIPS 140-1. Many Federal Government

agencies are finding that they have to go outside the FIPS to implement

their information security policies. The ITA starts off with FIPS 140-1 as

its guiding standard. Other mainstream information security standards

are added to provide a full range of security services.

The additional security standards originate from two sources: (1) the

Internet and (2) a long-time leader in information security, RSA. The

Internet has spawned a number of useful security standards including

Secure HTTP (S-HTTP), and Secure Sockets Layer (SSL). However, the

motivation for these standards has been primarily to support electronic

commerce on the Web. By themselves, these protocols are not broad

enough to implement even the most basic information system security

policy. They must be augmented by other standards in FIPS 140-1 and in
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some cases developed by RSA. RSA publishes a list of specifications,

each labeled APKCS-number, that describes methods and protocols for

using public key encryption technology to secure information systems.

Added to the list of standards are Secure MIME (S/MIME) and Internet

Protocol Security (IPSEC). S/MIME secures electronic mail attachments.

IPSEC is used to create Virtual Private Networks (VPNs). VPNs allow

the use of public, non-secure telecommunications facilities to build

private subnetworks that protect information from unauthorized access.

4.6 E-Filing Standards Profile

Appendix D contains a detailed list of the proposed standards to be used

within the FERC E-Filing Technical Architecture: Technical Reference

Model and Standards Profile. {summary provided in Appendix D)

The primary categories included are as follows:

CATEGORY PURPOSE

SYSTEM SERVICES Details the Operating System

Services, Directory and Naming

Services, System and Network

Management Services, and

Application Software Development

Support Services

COMMUNICATION

SERVICES

Details LAN, WAN, cable plant,

connectivity, facsimile, Multimedia

and Collaborative Communication

Services, and Distributed Computing

Services

INFORMATION

SERVICES

Details Infrastructure Application

Services, Data Management

Services, Data Interchange Services,

and Transaction Processing Services

HUMAN/COMPUTER

INTERACTION

SERVICES

Details User Command Interface

Services, Character-based User

Interface Services, Windowing

Services, Graphics Services,

INFORMATION

SECURITY SERVICES

Details Identification Services,

Authorization Services, Access

Control Services, Authentication
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Services, Data Integrity Services,

Non-Repudiation Services,

Confidentiality Services,

4.7 Managing the E-Filing TRM and Standards Profile

4.7.1 The TRM Change Process

The Technical Reference Model plays a pivotal role in furnishing

information to projects by translating concepts into platforms and

services and providing the basis by which project teams can determine

whether their requirements can be satisfied using the ITA's standards and

products. To fulfill this role, the Technical Reference Model must be

evolutionary in nature. Standards and requirements for new products will

continue to emerge and evolve as state-of-the-art technology is advanced.

Consequently, changes to the ITA Technical Reference Model may be

identified at any time by anyone within FERC. Suggested changes need

not be associated with a particular project.

Exhibit 4-2 below illustrates the process for incorporating changes into

the Technical Reference Model. A change proposal is prepared by the

originator describing the nature of the change and the specific changes

proposed. These may identify addition, modification, or deletion of

particular standards, products, or version numbers. The originator

submits the request through the appropriate channels for coordination of

the change review.
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Exhibit 4-2: Change Request Process

4.7.2 Obtaining a TRM Waiver

The standards, platforms, and products included in the model will be

adhered to unless a waiver has been obtained because:

1) the requirements of the project cannot be met by the existing

standards and products, or

2) adherence to the existing standards and products would not be

cost effective over the life of the project, or

3) new standards, platforms, or products have become available

that can provide more cost-effective solutions in support of

requirements.

The ITA waiver process is much like the change process, the distinction

being that the change process provides a mechanism by which the

Technical Reference Model may be amended and kept up to date; the

waiver process addresses materials needed from projects that deviate

from the architecture.
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Section 5 – The Future of E-Filing at FERC

To this point, the Electronic Filing Strategic Plan has addressed

the FERC organization, its core filing requirements, it’s current

IT infrastructure, and the ITA to support E-Filing. As a capstone,

this section discusses the future of E-Filing at FERC. This

includes the goals and ensuing benefits of E-filing, technical and

business-related implementation considerations, and a strategy

for the transition from paper to paperless.

5.1 Goals

According to the Office of the CIO, the vision statement for

FERC’s E-filing Initiative reads:

“We will provide Commission staff and our customers

(regulated entities and the general public) with efficient,

cost-effective access to the information they need—when

they need it—and in a format that is useful to them.”

Similarly, FERC’s E-filing Initiative goal statement is:

“To provide more information to Commission staff,

regulated entities, and the public in a more flexible,

practical, and efficient way and to improve our

regulatory processes by reducing the cost and volume of

paper filed by applicants and intervenors with FERC

and each other.”

These goals have several drivers; the first and foremost is to

increase the efficiency of the regulatory process thus reducing

cost and increasing taxpayer benefit. Other drivers include the

reduction of burden to regulated entities and compliance with the

government’s paperwork reduction initiatives. These drivers

could be considered high-level benefits and, in fact, are

embedded in the specific benefits of E-Filing.

5.2 Benefits

Stable and timely regulatory treatment of regulated companies

and their customers is a strategic goal of the FERC’s E-filing

initiative. This can be achieved by creating process

improvements to both the flow of information and the processing

of that information within FERC. An electronic filing system can

be used to create an automated workflow that creates a consistent

approach to work as well as reducing the processing cycle.

Timely access to filed documents can be provided, virtually in
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real-time, by posting the documents to the FERC web site

following a quality control process.

Easier access to more complete information can also be

enhanced by e-filing. In a properly designed system, external

entities can relate an e-filing to subsequent issuances by the

Commission that are the result of that filing.

Data integrity can also be enhanced with an E-filing process. In

addition to having direct access to the “as-filed” document, there

is also the ability to incorporate the text-based information

directly into FERC databases using XML, thereby enhancing online search capabilities.

Cost-based benefits can also be considered, both to industry as

well as to FERC. It is generally accepted that industry uses

industry-standard computers and computer-based software

programs to generate the documents required by FERC.

Consequently, allowing the industry to use computer-generated

output will decrease their operating costs. e.g.: printing, copying,

mailing, and courier service associated with filing paper

documents. This benefits regulated entities by ensuring the

regulatory process does not impose an unnecessary burden or

impede their efforts to be profitable. The cost-reduction to FERC

can be in the form of minimizing, or eliminating, complex

workflow processes; e.g., the scanning of hard copy documents.

An adaptable filing process can provide additional benefits. The

Electronic Filing pilot project has already demonstrated the

benefits of an adaptable (i.e., modifiable) filing process. This

was done by implementing a client-server architecture; this

virtually eliminates the problems associated with configuration

management of different versions of stand-alone applications.

All of the benefits discussed here can be rolled up into a few

high-level strategic benefits—reduced costs and more efficient

operations. Automated business processes, accurate and readily

available information, and flexible IT solutions all help to

achieve these benefits.

5.3 Implementation Considerations

5.3.1 Business/Process Considerations

Continued implementation of electronic filing must take into

consideration the three primary entities that are associated with

FERC; they consist of:

1. The regulated industries
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2. FERC

3. Controlling agencies and document recipients, including

federal regulations, OMB and NARA.

Regulated Industries

FERC has demonstrated a willingness to work with industry to

create an improving E-filing business process, and industry is

likewise to be commended for participating in the pilot project.

This working relationship is critical to ensure that future process

improvements are based on mutual goals having a direct effect

on cost reduction for both parties. FERC will have to complete

additional cost/benefit analyses prior to implementing additional

E-filing efforts.

The following quote, taken from a Gas Industry article,

demonstrates the industry’s perspective on FERC’s

standardization of business processes:

“As a voluntary organization composed of

representatives of many segments of the industry, GISB

developed and adopted standardized business practices

aimed at simplifying the process of transacting business

across the interstate natural gas pipeline grid. The

Commission reviews and adopts those standards and

subsequently reviews individual filings by natural gas

pipeline companies to comply with those standards. By

standardizing business practices, transacting business

with multiple pipelines and suppliers should be easier for

customers.”

But e-filing must consider the wide range in size, capabilities,

and resources of the regulated and non-regulated entities that

interact with the Commission, including individual landowners.

FERC

FERC recently completed a Business Process Re-engineering

initiative called FERC FIRST!, and is implementing most of the

organizational and procedural recommendations of the reengineering team. One BPR issue that is being addressed is the

workflow process. This effort must ensure that any gains or

improvements made by electronic filing are not hindered by nonelectronic processing, i.e., all manual processes immediately

following the electronic filing process. FERC must ensure that

manual processes related to the receipt of filings are minimized

or replaced by automated methods.
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Controlling Agencies and Document Recipients

OMB is largely responsible for the technological revolution that

is taking place in Government. Clinger-Cohen (establishment of

the CIO) and conditional funding based on proper IT strategic

planning have forced IT to the top of agency agendas. OMB’s

role in implementing E-Filing is significant. It will ultimately

provide funding for the initiative based on the FERC’s E-Filing

Strategic Plan. The Commission must demonstrate a

comprehensive understanding of E-Filing and how it affects

FERC, their business processes, their IT investments, and their

industry partners.

OBM also provides guidance to agencies that are required to

comply with the Government Paperwork Elimination Act. GPEA

mandates that agencies be able to accept electronically filed

documents by 2003 and that any agency accepting more than

50,000 documents on an annual basis must give filers two

options for providing digital signatures.

On Friday, June 30, 2000, President Clinton signed the

Electronic Signatures in Global and National Commerce act (ESign) that passed through Congress two weeks earlier. The new

digital signature law will render digital signatures legally

equivalent to those signed on paper. The bill requires that online

users give their affirmative consent to use electronic versions of

paper forms and allows them to opt for offline equivalents. The

bill also requires that agencies disclose to users the hardware and

software required for performing the electronic signing and

giving the user the same legal protections online as they would

have offline. However, the bill does not specify what kind of

technology can be used to implement digital signatures.

FERC and its industry partners have agreed that signatures are a

necessary component of documents filed with the Commission.

By making digital signatures the legal equivalent to paper

signatures, E-Sign gives the FERC the backing it needs to

complete paperless filing process.

Because E-Sign does not mandate technology, the FERC must be

sure that the technology used for implementing digital signatures

and authentication is supported by Industry. For example, if PKI

(currently recommended by OMB) is used, FERC must establish

a trust relationship with each of its industry partners. This could

be done through a trusted third party (within or external to the

Federal government). PKI also requires detailed policies for

establishing and maintaining trust. For example, policies must be

established for linking a user to his/her private key. Passwords,

smartcards, and biometrics are viable alternatives for this

activity. Finally, it is important to emphasize the E-Sign does not

mandate that users fill out forms electronically. On the contrary,
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it mandates that an offline equivalent be available. E-Sign

supports FERC E-Filing initiative by giving digital signatures

legal status, but it does legally require electronic filing.

As discussed in the Electronic Document and Records

Management Requirements section (Section 2.5), FERC must

comply with the National Archives and Records Administration

guidelines for developing and monitoring record keeping

systems as well as properly designating electronic documents for

disposition. The E-Filing solution must include guidelines and

processes for use, storage, and disposition of any information it

collects electronically.

5.3.2 Technical Considerations

There are numerous technical issues that must be addressed both

from the perspective of implementing a “first cut” at E-filing as

well as continued modifications to the IT architecture. Primary

considerations include the concepts of flexibility, enhancement,

security, cost/benefit, and standards.

Web-Enabling Standards and Technologies

An IT architecture based on internet-enabling technology

provides the opportunity to pursue continuing enhancements to

the electronic business process. However, this enabling

technology does arrive with a growing number of expectations

on the part of the end-users. For example, client/server based

applications are giving way to web-enabled applications; the end

user is expecting a web browser interface for the majority of

internet-based interactions. With this expectation comes the

presumption that any internet-capable web browser will suffice.

It can be anticipated that one of the final outcomes of the

Microsoft/Justice Department dispute will be a “Microsoft

neutral” requirement on the part of Government agencies. This

could have a direct effect on the software development efforts

proposed by FERC.

FERC’s primary consideration therefore becomes one of

flexibility: pursue web-enabling technologies without placing

unnecessary constraints upon the end users. This is not as

limiting as at first it might appear. Although Microsoft has

created numerous “Microsoft-only” solutions they have also

adopted, or are in the process of adopting, several industry

standards and/or recommendations. The following are a few

examples:

• ECMAScript: this is the script language originally

developed by Netscape (JavaScript) but now

supported by Microsoft. ECMAScript has been
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accepted as a standard by the European Computer

Manufacturers Association (ECMA) (ECMAScript

262). See:

http://webreview.com/pub/98/09/11/feature/sidebar1.

html

• Document Object Model (DOM): The Document

Object Model is a platform- and language-neutral

interface that will allow programs and scripts to

dynamically access and update the content, structure

and style of documents. DOM allows the document

to be processed and have the results of that

processing incorporated back into the presented

page. Numerous companies are participating in the

DOM Working group including both Microsoft and

Netscape. See: http://www.oasisopen.org/cover/dom.html

• Simple Object Access Protocol (SOAP): The

Simple Object Access Protocol is an XML

(Extensible Markup Language)-based RPC (remote

procedure call) standard originally developed by

Microsoft Corp., Develop Mentor Inc. and UserLand

Software Inc. (later joined by IBM and Lotus

Development Corp.) that can greatly simplify crosslanguage and cross-business development.

One final thought concerning Microsoft needs to be mentioned:

despite all comments to the contrary, Microsoft is intent on

supporting Microsoft at the expense of supporting standards. A

recent technical article will illustrate the point1:

“eWeek Labs recommends that companies make deployment

of IE 5.5 ...a low priority...Microsoft has used DHTML

(Dynamic Hypertext Markup Language) to add

features...unfortunately, these enhancements serve to worsen

Internet Explorer’s support for Document Object Model

(DOM), which, unlike Microsoft’s proprietary DHTML is an

accepted standard. Given that (Microsoft’s newest) initiative

is centered on XML, Microsoft seems to be making a wrong

turn by falling behind on support for the XML-based DOM.”

In addition to the issue of flexibility, the previous examples also

raise an equally important technical consideration, that being the

requirement to support standards. The World Wide Web

Consortium (W3C) has made significant strides to define webbased standards that can be adopted by the industry. The W3C

 

1

eWeek (magazine) July 17, 2000; page 14.
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merely makes recommendations, it cannot enforce them. While

standards provide a certain degree of flexibility for the end user

they also place constraints upon developers. Of special

significance is the fact that SOAP, referred to above, is not an

industry standard but this is not inhibiting the industry

(Microsoft among others) from pursuing enhancements to the

internet-enabling technology. This “hot pursuit” does not come

without risks; one risk being the first to market with a product

that doesn’t meet the end users needs or expectations. FERC

will be required to establish clear guidelines, based on risk

analysis, that defines the issues surrounding Standards versus

nascent web-enabling technologies.

Digital Signatures and Security

Security has taken a front seat as web-based architectures

compete with traditional client-server architectures for the

dominant position in distributed computing. Web-based solutions

open up an entire new arena of security concerns because

information is no longer transferred over private LAN/WAN’s

but over the public domain. Add on FERC’s legal requirements

for signatures and authentication and you have a difficult

security requirement.

PKI has been around for many years but it’s full potential has yet

to be realized. Just recently, with the proliferation of web-based

IT solutions, has PKI begun to materialize as a practical,

although still maturing, security solution. PKI provides

encrypted data transfer, digital signatures (with non-repudiation),

and authentication using hard-tokens and biometrics.

There are several technical issues to consider when designing

and building a PKI. Aside from the policy issues discussed

earlier, all partners in a PKI have to support the technical

components of the infrastructure. If trust is required in both

directions, FERC and industry will have to set up a trusted third

party Certificate Authority (e.g., Verisign) to validate public

keys. If trust is only required in one direction, (i.e., industry

groups send encrypted and digitally signed electronic documents

to FERC but not vise versa) then FERC can own the Certificate

Authority. In this case, FERC would also have to set up directory

services to store public keys and related information. Other

components include smart card and biometrics readers, which

are client-side software and hardware components. A successful

PKI must be a collaborative effort between all parties involved.

XML and Data Content Considerations

Extensible Markup Language (XML), a sub-set of SGML,

describes a class of data objects called XML documents and

partially describes the behavior of computer programs that
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process them. XML is a concomitant alternative to HTML, it

does not supersede HTML. HTML describes document structure

and visual presentation, while XML describes data in a human

readable format with no indication of how the data is to be

displayed.

XML can be used to provide a vendor-neutral, cross- platform

method of transporting, and validating mission critical data. The

actual data presentation is handled as a separate process. This

will allow a web server to provide data to separate client (e.g.

web browser) that is responsible for their own presentation style.

Business rules can be created that deal directly with the

document’s content rather than its specific layout. XML can be

used to provide flexibility at the industry’s end while

maintaining formal control, via business rules, implemented in

servers.

The gas industry has already demonstrated an interest in

implementing XML as illustrated by the following product

announcement:

“The initial release of PetroXML provides a first-ever

standardized eXtensible Markup Language (XML) tag

set for vendor invoicing for oil and gas field operations.

A development kit to integrate XML tagged transactions

to users' accounting systems and databases will also be

available. The revolutionary XML tag sets create

standardized statements for Internet transactions that

were previously unavailable from any vendor. Operating

companies and vendors will be able to transport detailed

invoicing between each other, despite having

incompatible accounting systems.”2

Additional efforts are under way to integrate XML and forms

processing. The standard, called XForms, is part of a larger

effort to replace traditional HTML (Hypertext Markup

Language) with XHTML (Extensible Hypertext Markup

Language), an XML version. XForms is implemented using

Extensible Forms Description Language (XFDL). XFDL is the

first submission acknowledged by the W3C for legally binding

XML forms. The Securities Exchange Commission, the U.S.

Patent and Trademark Office, and other public sector

organizations have deployed e-commerce solutions using XFDL3

 

2

 http://www.oasis-open.org/cover/petroXML.html

3

 See: http://www.uwi.com/news/000705.htm
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Document Retention and Refresh

Encrypted documents created in old formats may not be easily

transferred to more modern formats and may not retain assurance

of their authenticity. This will eventually include documents

created today that may be opened 10 years hence by applications

expecting formats that will be in use at that time. The issue

centers on how we maintain not only the document files

themselves, but also the native applications used to create the

documents. OMB does not directly address that issue in its

guidance, but suggests that the National Records and Archives

Administration should take the lead in working with agencies on

questions on and methods for maintaining, preserving and

disposing of electronic records.

5.3.3 Industry/Government “Best Practices”

The following paragraphs describe what IT related tools and

architecture other industries and government agencies are

considering. These examples are not exhaustive

Federal Emergency Management Agency: For future

capabilities, FEMA will consider the following tools.

Office Automation Tools:

• Authoring of XML

• Authoring, use, and enterprise-wide integration of

electronic forms on the desktop.

“Improved Data Integrity over Life Cycle: The proposed

IT architecture will be designed to increase levels of assured

data integrity in order to stay in sync with the CIP program,

electronic records, documents and data in FEMA IT systems

and data bases. This involves setting up adequate policies

and procedures to support digital signatures, date-time

stamping, long-term archival access, and hash

mechanisms.” (emphasis added)

Department of Energy: “Computer security is a major concern

at the local workstation level and in a networked environment

and standards for developing should be considered. DOE has

considered the following options and standards for the proposed

security services:

• Encryption techniques

• Integrity, auditing, and electronic signatures
FERC Electronic Filing Strategic Plan

SIGNAL Corporation 5-10 PEC Solutions, Inc.

• Operating system security, network security, data

interchange security, data management security

• Open system security”

Department of Commerce: “A major goal of implementing EC

in the Federal acquisition process is to create a communication

and computing infrastructure composed of standard support

services, with facilities based on standards and the principles of

open systems. The infrastructure must provide a means of

interchanging standard transactions at a low cost with minimum

impact on existing automated systems. There is a clear need to

use open systems based on nonproprietary standards to support

extensibility, scalability, portability, and maintainability

requirements. Three primary policy variables must be monitored

and nurtured: operating system environment preferences,

communication protocol preferences, and data base preferences.

We recommend an open systems environment including the

portable operating system specification (POSIX), the

Government Open Systems Interconnection Profile (GOSIP), the

structured query language (SQL), and other governmentapproved protocol suites. “

U.S. Patent and Trademark Office: “The implementation of

electronic filing and electronic examination is critical to the

efficiency, effectiveness, and operational cost reductions

associated with processing patent applications. The Patent

Business plans to implement electronic filing and electronic

examination in stages. The replacement PALM system, PACR,

and PPP will provide the foundation for a comprehensive

electronic examination capability throughout the prosecution of a

patent application. Upon receipt of electronic input from PACR,

the Electronic Mailroom, and automated PCT operations

(POWER), the Tools for Electronic Application Management

(TEAM) system will create the electronic file wrapper. As

presently envisioned, the TEAM system will be capable of

processing an application file from the point where it enters the

Examining Group to the publication of the application file in

electronic format... The Patent Business is conducting a pilot of

electronic filing of patent applications in FY 2000 and will begin

accepting electronic applications in FY 2001. Significant use of

electronic filing by applicants will greatly improve the quality

and lower the cost of the data capture process. The Patent

Business plans to promote the use of electronic filing to facilitate

Pre-Grant Publication.”4

 

4

 http://www.uspto.gov/web/offices/cio/sitp/sitp_eo.html#sitp_eo_f4
FERC Electronic Filing Strategic Plan

SIGNAL Corporation 5-11 PEC Solutions, Inc.

PeopleSoft: PeopleSoft Inc. has just released a new version of

their applications which include “...59 new E-business

applications, a new Web architecture, and a browser-based user

interface.5

5.4 Transition Strategy

Fully implementing an electronic filing process for FERC will

require a smooth and effective transition. This will require a

detailed Transition Strategy that addresses the concerns of

industry and FERC and captures the required modifications to

business processes, document management, and the IT

infrastructure. The following paragraphs elaborate the essential

elements that must be included within the transition strategy.

Incremental change. It is essential that FERC adopt an

incremental change paradigm. The alternative to incremental

change is what is referred to within the industry as the “systems

leap” paradigm; the leap occurs when organizations standardize

on a system for several years, and then “leap” forward to new

systems every 3-5 years. The preferred approach, “incremental

change” occurs when organizations continuously adopt

incremental upgrades in software and hardware, “slipstreaming”

technology change into daily work patterns. An incremental

change strategy has several advantages:

1. Training costs are kept to a minimum because support

staff can be trained in short “mini-sessions” which

disrupt work in progress less than traditional all day

classes;

2. Staffing and communications problems are minimized

by utilizing current technology; and

3. Budgetary considerations are minimized because full

system replacements are obviated.

Rolling replacement. Closely tied to incremental change is the

“rolling replacement” concept. Budgetary constraints inhibit the

ability to perform a complete enterprise-wide system

replacement every few years. Instead, organizations are

increasingly adopting “rolling replacement” strategies in which,

for example, a third of the organization's notebook computers are

replaced each year. Carefully planned, a rolling replacement

strategy can normalize technology spending over a period of

years, so that technology spending mimics a business expense

 

5

informationweek.com (magazine) July 17, 2000; page 32.
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SIGNAL Corporation 5-12 PEC Solutions, Inc.

model rather than a capital replacement model. As already noted,

FERC is to be commended for adopting this model with respect

to desktop computers. The present transition from Token Ring to

Ethernet also satisfies this model.

Risk Analysis. In order to comply with Federal Regulations

regarding IT related security, it will be necessary to establish a

Risk Analysis program.

see: http://www.cio.gov/docs/gpea2.htm

File Formats. The pilot project for electronic filing has already

established a policy for accepting electronic documents. The

existing policy established a flexible process that seems to

satisfy both FERC and industry. Recent events with Microsoft

and the Justice Department, along with the financial difficulties

faced by Corel (i.e. WordPerfect), would dictate that prudence is

of the utmost concern with respect to file formats; that is to say,

any effort to implement industry standards could obviate any

legal concerns.

Operating Systems. There is less immediate concern about the

differences among operating systems. Both FERC and industry

are standardized on Microsoft operating systems. Again, with

respect to recent events, it would be advisable to develop a

transition plan that does not require industry to employ the

“official” OS. As an example, the Visual Fox Pro (VFP) form

applications all require the Microsoft OS. Additional forms are

being created that support the same methodology. It is not

necessary to perform a “system leap” (see reference above) to

accommodate this suggestion; as an example, it is possible to

deploy a web-based solution, used by industry, that would deploy

XML to populate the VFP database on the backend. All

applications, and IT infrastructure procurements should be

evaluated as to their transitional/upgrade capabilities.

Document Capture and Content. There are several issues

related to the document capture and content. One of the primary

concerns related to the filing process is the “as-filed” process. As

noted previously, this is complicated due to differences in

applications used by industry. Documents are presently captured

via three primary methods: 1) the actual hard copy is retained, 2)

the electronic version is saved in both original format and

converted format (e.g. PDF), and 3) the image is scanned and

saved as a non-editable image document.

All industries in general have recognized the benefit of

referencing documents by paragraph number rather than the page

number. The move toward electronic filing should accelerate a

move toward this approach.
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SIGNAL Corporation 5-13 PEC Solutions, Inc.

Document scanning needs to consider the benefits associated

with Optical Character Recognition. The re-distribution of

captured documents, via the web pages or other electronic

means, can benefit from the improved readability of OCR’ed

documents.

Once the content of the submitted documents are captured it

becomes more important to focus on data content rather than

data format. Web page layout and search engine capabilities are

not dependent upon the original document layout but only upon

the document content. This focus can greatly enhance the

business process by enabling the automation of data content.

Client/Server and Web-based Applications: The industry is

clearly moving away from a client/server based architecture to a

web-enabled architecture. This can consist of simple HTML

web pages, HTML Forms, PDF Forms, Java applets, etc. The

FERC development team will have to balance end user

expectations with clearly defined goals, benefits, risk analysis,

etc.

Pilot Projects. FERC must continue the transitional efforts

established by the first E-filing pilot project. The next phases of

development have already been established by the FERC

development team but the development focus also must take into

consideration the newly available technology (e.g. XML) as well

as the industry approved standards. The following table, Exhibit

5-1, is offered as a point of discussion for the original planned

phases with consideration given to the possible standards and

technology that could be implemented during each phase. The

speed of internet development requires that each phase be

reevaluated prior to pilot project initiation.
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 5-14 PEC Solutions, Inc.

PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5

Motions to Invervene Gas, Electric & Oil Rate 

Filings (including Tariffs)

Gas Pileline Certificate 

Applications (except 

maps)

Maps (for Gas P/L and 

Hydro Applications) Protected Data

Comments Gas, Electric & Oil 

Forms and Reports

Hydro 

License/Relicencing 

Applications (except 

maps)

GIS System Privileged Data

Protests Other Hydro Reports Autocad drawings Briefs

Answers Testimony

Other Motions Exhibits

Form 1

Hydro Dam Safety 

Inspection Reports

STANDARDS to 

consider for 

Implementation

VFP forms (in process) XML, including XMLbased forms

PDF based Forms, 

SOAP Vector Graphics

Digital Signatures

web-browser 

independence; 

W3C approved

Optical Character 

Recognition ECMAScript

Exhibit 5-1: Standards and Phased Implementation
 FERC Electronic Filing Strategic Plan

SIGNAL Corporation 5-15 PEC Solutions, Inc.

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