FERC's eTariff final rule (Order 714) states...

In order to provide companies with sufficient time to develop and test software, we will provide 18 months for implementation, until April 1, 2010, with a staggered implementation schedule for companies over the next six months.

Regarding the "staggered implementation schedule," on December 1, 2009, FERC issued this notice regarding a schedule for eTariff implementation. What is certain is that FERC cannot allow every gas, electric, and oil company file their baseline tariffs at the same time. The volume of filing activity would be too much for FERC systems and staff to handle. Therefore, at a minimum, your use of TFMS may continue until April 2010. Your company's implementation date for eTariff could be as many as six months later, however. So, your use of TFMS could extend through September 2010.