Version 2 - Reviewed: November 10, 2010
How do I cancel an entire Tariff Database?
In order to cancel an entire Tariff Database you must submit a cancellation-type filing. The following passages were clipped from FERC's eTariff Implementation Guide dated October 8, 2010:
Cancellation Filing Details
Cancellation filings require the standard Filing metadata, a transmittal letter (included as a FERC attachment), and a single Tariff Record Version. You read that right...you wish to cancel the entire Tariff Database and yet you need to make a filing that includes a Tariff Record Version. The reason for submitting a Tariff Record Version is that it's the only way to propose an effective date for the cancellation.
You could include a TRV without any content, but TariffShark issues validation failure messages when TRVs don't have content and FERC's validations would fail, too. You could include a TRV with content that says "Our tariff database is hereby cancelled" (or something similar), but it would never be visible in FERC's eTariff Viewer (after all, the whole thing is being cancelled) and doing so would require you to attach it to your Filing as a clean tariff attachment for eLibrary (an extra, pointless step). Therefore, the recommended approach is sort of a hybrid: make sure the TRV has content, but leave the body of the document blank. This will pass validations because a document is being provided, but because it is blank, there is no clean content to attach for eLibrary.
Shortcoming in TariffShark v1
Version 1 of TariffShark does not provide a mechanism to include TRVs in a cancellation Filing. Therefore, preparing a cancellation-type Filing requires some manual intervention. Follow these steps to prepare a cancellation Filing:
- Create a cancellation-type Filing and supply the standard Filing metadata. There are no special requirements regarding TariffShark's Filing data fields.
- Create a transmittal letter and attach it to the Filing as a FERC Attachment in TariffShark.
- Download the XML for the cancellation-type Filing.
- Create a normal-type Filing. You will delete this Filing shortly, so it doesn't matter what you name it and you don't need to enter any additional data about the Filing.
- Bring up the list of Tariff Records in TariffShark.
- Create a TRV for the very first Tariff Record listed and place it into the Filing created in step 4 above. For the Proposed Effective, enter the date on which you wish to cancel the Tariff Database.
- Download the XML for the second Filing.
- The XML from the two Filings needs to be merged into a single Filing. We will be happy to assist with this step. Send both zipped XML files to [email protected] with a brief explanation of your request and we will return a single zipped XML file suitable for filing with FERC.
Because TariffShark v1 does not understand how cancellation-type Filings must be submitted, it includes a few Filing Validations that should be ignored:
F031 - When submitting a Filing to cancel an entire Tariff Database, the Proposed Effective Date of all cancelled Tariff Records must be the same.
F033 - A cancel type Filing must include at least one Filed Tariff Record Version of type "Cancel". You can create Cancel Filed Tariff Record Versions by using the SmartBar to Cancel a Tariff or a Tariff Record.
Z001 - When submitting a Filing to cancel an entire Tariff Database, all Tariffs and Tariff Records must be cancelled. Tariff Record "<TR.DisplayName>" has been left uncancelled.