Pipeline Tariff Filing Preparation

CID – Company Registration
 
Company Registration:

eTariff requires that every regulated entity have a Company Identifier as part of an eTariff filing. A Company Identifier is obtained from the Commission. Information on acceptable company name formats and suggestions on how to populate the Company Registration on-line form are available from the Instructions for Company Registration (updated September 11, 2015).

You will need one person eRegistered to do business with the Commission to register a company. As a safety measure, please provide more than one account manager when you do your initial registration or any future revisions / updates to the Company Profile. Once you have assembled the necessary information, proceed as follows:
  • If you are not eRegistered, go to https://ferconline.ferc.gov/ and click on New User. If you are eRegistered, skip to step (c).
  • Fill out and submit the form. You will receive and ID and password.
  • Go to https://ferconline.ferc.gov/LogIn.aspx. Use your ID and password to log in to FERC Online.
  • Go to the Company Registration page at https://ferconline.ferc.gov/Company.aspx, and click on “Register a company for the first time”.
  • Under Regulatory Program, select “NGPA 311 and NGA Hinshaw Gas Pipelines”, fill out the remainder of the form and submit.
  • You will receive a Company Identifier (CID) in a couple of business days.
  • Note that once you have registered your company, you will use the Company Identifier for all subsequent eTariff filings. You should not re-register your company again. If you do not know if your company has already been registered, you can search the Commission posted list of registered companies. The email address for Registration Issues is co-reg@ferc.gov.
  • Once you have a CID, Agents may be registered and then make an eTariff Filings.
TOFC – Type of Filing Codes
TOFC:
Filing Title:
Citation:		 TOFC Description
Filings with changes to Rates and / or to the Statement of Operating Conditions (SOC)
TOFC: 1300
Citation: 284.123(b),(e)+(g)/.224
Filing Title: OPT-State Election, Fuel filing or SOC chg w/o rate chg		 This is for a filing using the optional notice procedures under § 284.123(g). This is for all non-fee based; State Rate Election filings, Fuel filings (note the optional notice procedure only resets the five years filing requirement with respect to the Fuel rate), and / or revisions to the Statement of Operating Conditions. Combines TOFC 1280 into 1300.
TOFC: 1310
Citation: 284.123(b)(2)+(e)+(g)/.224
Filing Title: OPT-FEE-New or chg in Cost Based Rate		 This is for a filing using the optional notice procedures under § 284.123(g). This is for all fee based Cost of Service Based Rate filings with a 60 day statutory / regulatory timeline. Additionally, the filing may include changes to Statement of Operating Conditions. The filing requires a fee pursuant to § 381.403.
TOFC: 980
Citation: 284.123(b),(e)/.224
Filing Title: State Election, Fuel filing or SOC chg w/o rate chg		 This is for all non-fee based; State Rate Election filings, Fuel filings, and / or revisions to a Statement of Operating Conditions. Combines TOFC 770 into 980.
TOFC: 760
Citation: 284.123(b)(2)+(e)/.224
Filing Title: FEE-New or chg in Cost Based Rate		 This is for all fee based Cost of Service Based Rate filings with a 150 day statutory / regulatory timeline. Additionally, the filing may include changes to Statement of Operating Conditions. The filing requires a fee pursuant to § 381.403.
Filing an Amendments
TOFC: 1270
Citation: 284.123(b),(e)+(g)/.224
Filing Title: OPT-Amendment using optional notice procedure filing		 This is for filing an amendment using the optional notice procedures under § 284.123(g). The initial filing must have been made as a statutory / regulatory filing using TOFC of 760, 1300, or 1310 and any amendments made using TOFC 1270 or 1350.
TOFC: 1000
Citation: 284.123(b),(e)/.224
Filing Title: Amendment to non-statutory filings		 This is for filing an amendment to non-statutory / regulatory Rate filings, Fuel filings, and / or changes to the Statement of Operating Conditions.
TOFC: 1350
Citation: 284.123(b)(2),(e)/.224
Filing Title: Amendment to statutory filings		 This is for filing an amendment to a statutory filing, e.g., the initial filing must be made using TOFC of 760, 1300, or 1310.
Miscellaneous Filings
TOFC: 780
Citation: 284.123(b),(e)/.224
Filing Title: Data Response or Supplement to the record		 This is for filing a response to a data request or a supplement to the record of an existing tariff filing.
TOFC: 790
Citation: 284.123(b),(e)/.224
Filing Title: Compliance filing		 This is for making a compliance filing in response to a Commission order, for making a filing without a Tariff Record, or for a Hinshaw pipeline filing a cost and throughput study. If filing a new rate case in compliance with a five year rate review commitment, use a TOFC of 1300, 1310, 980, or 760.
TOFC: 1370
Citation: 284.123(b),(e)+(g)/.224
Filing Title: OPT-Compliance filing		 This is for a filing using the optional notice procedures under § 284.123(g). New TOFC for filing a compliance filing in response to a Commission order, for making a filing without a Tariff Record, or for a Hinshaw pipeline filing a cost and throughput study. A non-statutory / regulatory filing may not be converted to have a statutory / regulatory timeline by using this TOFC. To use this TOFC, the initial filing and all subsequent filings must have been made as a statutory / regulatory filing, e.g., the initial filing must have been made using TOFC of 760, 1300, or 1310 and any amendments made using TOFC of 1270 or 1350.
TOFC: 1200
Citation: 284.123(b),(h)/.224
Filing Title: Refund Report		 This is for filing all refund reports for section 311 and Hinshaw pipelines.
TOFC: 1260
Citation: 284.123(b)(1)+(g)(9)(ii)/.224
Filing Title: OPT-Certification of Unchg State Rate Election		 This is for a filing using the optional notice procedures under § 284.123(g). This is for filing a state rate certification that the pipeline's currently effective rates are based upon its current state approved rates. Filings using this TOFC must contain a tariff record. See 145 FERC ¶ 61,168 (2013) for additional filing guidance.
TOFC: 1360
Citation: 284.123(b)(1)/.224
Filing Title: Certification of Unchg State Rate Election		 This is for filing a state rate certification that the pipeline's currently effective rates are based upon its current state approved rates. See 145 FERC ¶ 61,168 (2013) for additional filing guidance.
TOFC: 1340
Citation: 284.224/.123
Filing Title: FEE-Blanket Certificate Application including a live SOC		 This is for a filing by a Hinshaw pipeline for a § 284.224 blanket certificate. The filing must include a live baseline Statement of Operating Conditions (SOC) including a rate election pursuant to §§ 284.123(b) and (e). The rate election may either be a state rate (§284.123(b)(1)) or a cost based rate (§284.123(b)(2)). The filing requires a fee pursuant to § 381.207.
TOFC: 770
Citation: Deleted
Filing Title: Deleted		 Deleted effective November 7, 2016. Use TOFC 980.
TOFC: 1280
Citation: Deleted
Filing Title: Deleted		 Deleted effective November 7, 2016. Use TOFC 1300.
Baseline filings only - either an Initial Filing of Statement of Operating Conditions (SOC) or a new (revised) Tariff Title
TOFC: 1330
Citation: 284.123(b),(e)+(g)/224
Filing Title: OPT-Baseline SOC-w/ State Rate Election or no rate chg		 This is for a filing using the optional notice procedures under § 284.123(g). This is for filing a baseline Statement of Operating Conditions (SOC). This may include filings for either, a new baseline SOC with a state rate election, or a baseline with a new Tariff Title and Tariff ID.
TOFC: 1320
Citation: 284.123(b)(2),(e)+(g)/.224
Filing Title: OPT-FEE-Baseline SOC-w/ Cost Based Rate		 This is for a filing using the optional notice procedures under § 284.123(g). This is for filing a new baseline Statement of Operating Conditions with a cost based rate. The filing requires a fee pursuant to § 381.403.
TOFC: 990
Citation: 284.123(b),(e)/.224
Filing Title: Baseline SOC-w/ State Rate election or no rate chg		 This is for filing a baseline Statement of Operating Conditions (SOC). This may include filings for either, a new baseline SOC with a state rate election, or a baseline with a new Tariff Title and Tariff ID.
TOFC: 820
Citation: 284.123(b)(2),(e)/.224
Filing Title: FEE-Baseline SOC-w/ Cost Based Rate		 This is for filing a new baseline Statement of Operating Conditions with a cost based rate. The filing requires a fee pursuant to § 381.403.
Withdrawal of filing / Termination of Statement of Conditions (SOC) and/or Blanket Certificatee
TOFC: 810
Citation: 284.123(h)
Filing Title: Withdrawal of entire filing		 This is to withdraw an entire filing prior to the filing being acted on by the Commission.
TOFC: 1290
Citation: 284.123(e)+(g)/.224
Filing Title: OPT-Termination of SOC and/or Blanket Certificate		 This is for a filing using the optional notice procedures under § 284.123(g). This is for a filing by a section 311 pipeline to terminate its entire Statement of Operating Conditions (SOC). This is also for a filing by a Hinshaw pipeline to terminate its § 284.224 blanket certificate and / or its entire SOC.
TOFC: 800
Citation: 284.123(e)/.224
Filing Title: Termination of SOC and/or Blanket Certificate		 This is for a filing by a section 311 pipeline to terminate its entire Statement of Operating Conditions (SOC). This is also for a filing by a Hinshaw pipeline to terminate its § 284.224 blanket certificate and / or its entire SOC.
Filing using § 284.123(g) - Optional Notice Procedures
 


In Order No. 735 the Commission reconfirmed its policy to periodically review the rates and terms of service of section 311 and Hinshaw pipelines. Order No. 735 revised the reporting requirements in FERC Form 549D, for section 311 and Hinshaw pipelines, switching to a quarterly from an annual report along with greater detail and more granular transactional data. The Commission balanced the increased transparency reporting requirements of jurisdictional transactions with a lengthening of the periodic rate review policy from three to five years.

In Order No. 781 the Commission adopted an Optional Notice Procedure, while maintaining the same rate review standards under §§ 284.123(b)(1), (b)(2) and/or (e), that allows a pipeline to commit to meeting the five year rate review policy in exchange for a quicker and less administratively burdensome, but just a thorough review of its filing. Prior to the implementation of the Optional Notice Procedures, staff and the pipeline would engage in a settlement process that often required negotiating, drafting and then filing a settlement, followed by and order that often required a compliance filing, further followed by an additional order on the compliance filing. Under the new Optional Notice Procedures if the filing is not protested, the filing is deemed approved at the end of the 60 day optional notice period. As part of the new process staff encourages the pipeline to work with all stakeholders and file rates and SOC revisions that is the equivalent to the results of a prepackaged settlement.

The periodic rate review requires a pipeline with cost based rates pursuant to § 284.123(b)(2) to make a rate filing under §§ 284.123(b)(1) or (2) on or before the five years from the date it filed its most recent rate application. A pipeline with rates based upon a state rate election pursuant to § 284.123(b)(i) must, within the same five year period, file either a State Rate Certification that its rates continue to comply the requirements of § 284.123(b)(1) or make a rate filing under §§ 284.123(b)(1) or (2). A Hinshaw pipeline may always meet its periodic rate review obligation by submitting an informational cost and throughput study in the form specified in §154.313 of the Commission’s regulations. Additionally, any pipeline with a state rate election pursuant to § 284.123(b)(1), and that filed pursuant to the optional notice procedures, § 284.123(g), must file for new rates within 30 days of a new state rate becoming effective.

The Optional Notice Procedure is selected by a pipeline by making its eTariff filing using a TOFC (Type of Filing Code) for a filing pursuant to § 284.123(g). The Optional Notice Procedure TOFCs are designated with a “OPT” in the Filing Title Description. The Optional Notice Procedure timeline:

 
  • FERC staff will review the filing within seven days to ensure the filing does not patently fail to comply with to §§ 284.123(e) and (f). If the filing fails to comply FERC staff will reject the filing without prejudice. If the filing was made to comply with a periodic rate review obligation, the pipeline must refile within 14 days. (§ 284.123(g)(2)).
  • The Secretary of the Commission will notice the filing within 10 days. The notice will provide for intervention and comments due within 21 days and final comments and protests due by intervenors and staff within 60 days or the “prior notice period.” (§§ 284.123(g)(3) and (4)).
  • If the filing is not protested, or all protests are resolved and withdrawn by the end of 60 day prior notice period, the filing is deemed approved. (§ 284.123(g)(8)(i)).
  • If all protests are not resolved and withdrawn by the end of the 60 days, staff will engage all parties to attempt to resolve all contested issues during a 30 day reconciliation period. (§ 284.123(g)(8)(5).
    • If at the end of the 30 day reconciliation period all protests are withdrawn, the filing is deemed approved. (§ 284.123(g)(8)(ii)).
    • If at the end of the 30 day reconciliation period all protests are not withdrawn, the filing is not deemed approved. Within 30 days of the end of the reconciliation period the Commission will establish procedures to resolve the proceeding. (§ 284.123(g)(5)).
  • At any point during the proceedings the pipeline may file an amendment or modification to a tariff record filed in the initial filing. The amendment will have the effect of tolling the prior notice period, and the Secretary of the Commission will issue a notice establishing a new deadline for comments and protests to the entire proceeding. (§ 284.123(g)(7)).
Tariff Filing
Contents to Include in an eTariff Filing
Tariff Filing Contents:

Every tariff filing is required to have the following material:
  1. Transmittal Letter: The Transmittal Letter identifies:
    • The company and its contacts,
    • Identifies what section of the Commission’s regulations it is filing pursuant to,
    • Identifies the action it is requesting of the Commission,
    • Identifies the documents and tariff records it is submitting in support of its request,
    • Any other statements it deems necessary to complete its tariff filing. 18 C.F.R. § 385.203, and
    • Any certifications or attestations may be included as part of the Transmittal Letter.
  2. Attachments: Supporting documentation and worksheets (when applicable) in native file format. See Tariff Statement of Operating Conditions (SOC) Requirements.
  3. Tariff Records: Tariff text in eTariff required format.
Preparing and Filing the eTariff “xml” Package
Making an eTariff Filing

If you are using:
  • Third party vendor software,
  • Your own software, or
  • A service,
Follow their instructions. It is always advisable, even when using eTariff software or services, to test your filing against the Commission’s Sandbox described in Step 2 below. The Commission cannot recommend and does not review or endorse any eTariff software package or vendor. The North American Energy Standards Board also does not recommend or endorse any eTariff software. However, they do maintain a list of eTariff vendors on their home page.

If you are not using eTariff software, simple eTariff filings can be created using the following instructions.
  1. Create your .xml file
    1. Download a sample.xml file.
    2. You can use a text editor, such as Notepad, to edit an .xml file. Standard word processors and other similar software may not work well.
    3. Use the eTariff type of filing codes for a Part 284 rate filing document and XML Schema Tables to populate your .xml file with the correct metadata.
    4. You need to obtain a binary 64 converter for the binary fields. Binary 64 converters can be found online. These converters will convert word processing, spread sheets and many other electronic documents, including formatting codes, into binary text fields, so your tariff and documents can be displayed properly. Be aware that this will look like meaningless text. When encoding your attachments and tariff records, set the encoder to UTF-8 character set.
    5. You can use the copy command to copy text from your source tariff file (.rtf or .pdf) and paste into the ‹record_plain_text› field.
    6. Your proposed effective date should not be before the date of filing.
    7. If your tariff filing requires a filing fee, please follow the special instructions on how to make this payment and how the use the resulting documentation in your .xml filing.
    8. Save your .xml file.
    9. Zip your .xml file (and only your .xml file – not the documents).
  2. Submit your xml
    1. Submit your xml file to our Sandbox Electronic Test Site.
    2. Please review the Test File Instruction Guide.
    3. Correct any pertinent errors you receive and resubmit to the Sandbox.
    4. Continue correcting any errors and resubmitting until no pertinent errors are reported.
  3. Submit your Filing
    1. Log on to FERC Online.
    2. Click eFiling
    3. Under “How is your filing to be directed?” choose Gas
    4. Under “What kind of filing are you making?” choose eTariff
    5. Under “Filing Type (Fee)” choose “eTariff” (even if your tariff filing requires a fee – see the special instructions) and click Next
    6. Select your CID number from the dropdown box. The CID that you use here should be the same one used in your .xml filing.
    7. Upload the zip file that contains your .xml file
    8. You will receive 2 emails verifying that we received your filing:
      1. If you receive any errors, correct your .xml file and resubmit your filing.
      2. ii. If you receive Warnings, your filing has been received, but you need to double-check that you submitted the correct information as such warnings are indications that what you submitted is different than what was expected.
Name Change
Name Change

If the pipeline changes its name, merges with another entity, or has its tariff adopted by another entity, i.e., a change in operations (18 C.F.R. § 284.123(e)), it must notify the Commission. The notice is required to be submitted through the Company Registration system and then, as necessary, followed by a Tariff Revision in eTariff. This is a two-step process:
  1. Company Registration. Log in using the Company Identifier and password, and modify the pipeline's name and effective date. Company Registration only accepts proposed effective dates the later of the date of the logging in or the proposed effective date.
     
  2. Tariff Revision. If the company's name appears in the text of the tariff, then the company should file a tariff revision through eTariff to modify the name. If the pipeline's name is not in the tariff text, then the modified Company Registration will be reflected as part of the Public Tariff Viewer's meta data and no tariff filing is required.
     
Notices of Cancellation or Succession to a Tariff
Notices of Cancellation or Succession to a Tariff

The pipeline must notify the Commission if the pipeline desires to cancel a service or its complete tariff (18 C.F.R. § 284.123(e)). This notice is required to be submitted through the eTariff portal. If the tariff is the only tariff the seller has on file, or all of the records under one tariff are being cancelled, then the seller must also as part of that filing request that the Commission cancel that Tariff ID using a complete tariff Cancellation type of filing. However, if cancelling just part of the tariff, the pipeline should file a revision to the tariff that either removes the service from the tariff text or cancels the tariff records that contain the service.

This page was last updated on April 27, 2023