A group of major interstate pipelines has called on FERC to discontinue its development of the costly eTariff system for electronically filing tariffs, saying it would result in a “major step back” for the industry.
The “eTariff, in its present form, does not improve efficiency or administrative convenience for interstate pipelines, does not facilitate customers’ access to tariff information, does not improve the overall management of the tariff or tariff change process, and does not improve research capability within the tariff,” the Interstate Pipeline Group told FERC [RM01-5]. In fact, the eTariff system, as currently devised, would represent a step backward in each of these areas, the group said.
In July 2004, FERC issued a notice of proposed rulemaking (NOPR) to initiate the development of an eTariff filing system so that regulated companies could submit tariff changes electronically instead of filing hard copies. The Federal Energy Regulatory Commission established a working group to test and evaluate the eTariff system, which included the Interstate Pipeline Group.
Members of the Interstate Pipeline Group include Black Marlin Pipeline, Discovery Gas Transmission LLC, Dominion Cove Point LNG LP, Dominion Transmission, Dominion South Pipeline Co. LP, CenterPoint Energy Gas Transmission, CenterPoint Energy — Mississippi River Transmission, TransCanada, Pine Needle LNG Co. LLC, Gulf South Pipeline Co., Kern River Gas Transmission, Northern Natural Gas and Panhandle Energy.
Based on its “hands-on experience” over the past year and a half, the pipeline group said it believes the Commission’s goals “will best be met with a simple, cost-effective solution as opposed to an expensive system with long-term maintenance issues.”
FERC “has underestimated the time and expense that will be involved in converting the tariffs to the new software system, as well as the time and expense involved in completing the development and continuing to maintain eTariff,” it noted.
The Interstate Pipeline Group recommends that FERC explore the use of its existing eFiling system instead. “Since that system is currently being used successfully for the electronic filing of other documents with the Commission, adapting it to accommodate tariff filings as well could be accomplished quickly with a minimal amount of effort and expense.” If further believes that the use of the eFiling system would meet the needs of the Commission’s NOPR.
“It is uncertain when eTariff will be ready for pipelines’ use. This delay in the implementation of the proposed software offers an opportunity for the Commission to reappraise the direction of the eTariff process and implementation of new procedures,” the pipeline group said.
“If a decision is made to continue with the implementation of eTariff, its use should be optional until such time as the system is redesigned so that pipelines and third-party vendors can develop software applications that support the system and pipelines are able to meet their system requirements as well,” the group noted.
The pipelines’ biggest problem with eTariff is that it would shift ownership of the tariff from the pipeline to the Commission. Historically, pipelines have been responsible for developing and maintaining their tariffs according to FERC guidelines. But “under eTariff, pipelines will have little or no control, as all electronic tariff activity is initiated, revised and data-based within the Commission’s eTariff software environment. The eTariff system becomes the warehouse of all tariff content. Information that goes in cannot be extracted in its same format.”
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