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.