As you may know, the Federal Energy Regulatory Commission is in the process of implementing an electronic tariff filing system (eTariff). As of April 1, 2010, any tariff filing—regardless of what type of tariff or the scope of the filing—must be made electronically in a file format compatible with FERC's eTariff system.
How does this affect you?
After April 1, 2010, you will be unable to submit any tariff or tariff revision to FERC without complying with the new eTariff system's requirements. Also, by April 1 or shortly thereafter, you will be required to submit a complete electronic version of your tariff(s) to FERC to serve as baseline tariff(s) on the eTariff system. This baseline filing will be required before you can make any other tariff filing. FERC is developing, through a series of technical conferences, a schedule by which tariff filers will be required to file their baseline tariff. It is unclear at this point whether the schedule will be alphabetical or sorted by some other criteria.
What is Leonard, Street and Deinard doing to prepare for eTariff?
We are already well into the process of developing and implementing a software interface compatible with FERC's eTariff system. We are also developing Web sites for each of our tariff-filing clients, through which they will be able to access and update their tariff(s). Together, the Web sites and eTariff software interface will allow us to manage, coordinate and file your tariffs. We are currently on track to have our eTariff capabilities and client Web sites up and running by the end of January 2010.
What should you be doing to prepare for eTariff?
We have already completed much of the work in setting up an eTariff compatible system. The next step is much simpler—let us know if you want Leonard, Street and Deinard to provide you with eTariff capabilities. If so, we will follow up with you to determine how we can customize our eTariff capabilities to your needs and to obtain the information we need in order to support you.