Comments of on Technical Sections Only

Updated Proposed Draft Implementation Guide

As of NAESB Meeting 10/23/07

Comments of on Technical Sections Only

Implementation Guide for Electronic Tariff Filing

EXCLUDING DATA TABLES

NAESB WGQ Standards [0.4.z] and WEQ Standard [X]

[DATE]

(Draft Updated 11/21/07)

The areas highlighted in yellow still need clarification from FERC.

The following draft Implementation Guide has been reformatted to reflect the structure of the final documentation. The background of the sections has been color coded to reflect the group(s) responsible for its contents:

BUSINESS

TECHNICAL – eTTF

BUSINESS and TECHNICAL

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Updated Proposed Draft Implementation Guide

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Table of Contents

Topic / Details / Page
Table of Contents
Executive Summary
Business Process / Definitions and Standards
Technical Implementation of Business Process / General Purpose
Process Flow - Brief Description and Diagram of a Tariff Filing through a Potential Web Portal
eTariff Data Set Overview
Explanation of the Data Element Information
Data Tables
Filing Data
Filing Attachment Data
Tariff Record Content Data
Code Values / Reference Tables
List of FERC URLs for Code Values
Code Values Tables for Data Elements not included in FERC list of URLs
XML Schema
Technical Specifications of Web Portal
Electronic Delivery Specifications
Error Code and Handling
Security Specifications
Use Cases
Testing Guidelines
Maintenance
Frequently Asked Questions

Executive Summary

This implementation guide is for use by an entity required to electronically submit Tariff Filings to the Federal Energy Regulatory Commission (Commission) pursuant to Title 18 Code of Federal Regulations Parts 35, 154, 284, 341284, 300, 341 or other Parts as required by the Commission. Following is a guide describing the various processes/mechanisms, data tables, code values / reference tables, and technical specifications used in the submission of Tariffs (including OATTS), Rate Schedules, certain service agreements, Statement of Conditions, rates, and any other material the Commission requires a Company to file electronically in accordance with NAESB WGQ Standards [0.4.z] and WEQ Standard [X].

Business Process

Definitions and Standards (pulled from the GEOC WP2 for the 7/27/07 eTariff Subcommittee meeting

D1Tariff Submitter is the term used to describe any entity that is required to submit Tariff Filings pursuant to Title 18 Code of Federal Regulations Parts 35, 154, 284, 341284, 300, 341 or other Parts as required by the Commission.

D2Tariff Filing is the term used to describe a compilation of all document(s), associated data and supporting documents that is required to be filed by a Tariff Submitter pursuant to Title 18 Code of Federal Regulations Parts 35, 154, 284, 341284, 300, 341 or other Parts as required by the Commission.

D3Tariff Record is the term used to describe a sheet, section or complete tariff document filed with the Federal Energy Regulatory Commission.

D4Whole Document Format is the term used to describe an entire tariff document submitted as a single Tariff Record within the Commission-defined constraints.

D5Sheet-based Format or Section-based Format is the term used to describe a Tariff Record that is submitted in logically divided portions within the Commission-defined constraints.

D6Tariff is the term used to describe a complete set of Tariff Records. (Proposed by Keith Pierce)

S1A Tariff Submitter should upload a Tariff Filing or components of a Tariff Filing and corresponding revisions, using a Sheet-based Format, Section-based Format or Whole Document Format for the Tariff Record(s), pursuant to the requirements as set forth in NAESB WGQ Standard [0.4.z] / NAESB WEQ Standard [X].

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Updated Proposed Draft Implementation Guide

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Brief Description of Process Flow and Diagram of a Tariff Filing through the FERC eFiling Web Portal

NOTE: The diagram belowwill be replaced with the subsequent diagram and brief explanation of such that was discussed at the 10/22/07 eTTF meeting. A narrative explanation of the diagram and process is being drafted.

Partial List of Items to be included in the process description:

Log in Process - via FERC’s eFiling web portal and then to the eTariff section for submission

Deadline – based on eFiling RM07-16

How validations are communicated back to the submitter

If the filing does not satisfy the validation checks, the Tariff Submitter will need to resubmit a corrected version of the filing in its entirety

When will the filing be deemed as “accepted”?

Language from previous documentation – may be used as a start for this section.

Once a Tariff Filing is submitted to the FERC, the FERC will perform its validations off-line and then provide e-mail notification to the Tariff Submitter’s Filer as to whether the filing is accepted or rejected and why. If the filing does not satisfy the validation checks, the Tariff Submitter will need to resubmit a corrected version of the filing in its entirety.

Alternatively, the description is effectively the same as the description that is provided in the Electronic Delivery Specifications section. Therefore, is another description needed here and / or should the diagram be moved to be in front on the Electronic Delivery Specifications section.

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Technical Implementation of Business Processes

GENERAL PURPOSE:

The purpose of the NAESB WGQ / WEQ eTariff dataset NAESB WGQ Standard [0.4.x] and WEQ [Y] (eTariff Dataset) is to submit Tariff Filings to the Federal Energy Regulatory Commission (FERC) in an electronic format such that the information can be stored in the FERC relational database. The eTariff Dataset is used by an entity (Tariff Submitter) required to electronically submit Tariff Filings to FERC pursuant to Title 18 Code of Federal Regulations Parts 35, 154, 284, 341284, 300, 341 or other Parts as required by FERC. For purposes of the use of this dataset, a tariff includes OATTS, Rate Schedules, certain service agreements, Statement of Conditions, rates, and any other material the FERC requires a Tariff Submitter to file electronically in accordance with NAESB WGQ Standards [0.4.z] and WEQ Standard [X].

Set forth below is an explanation of how the eTariff Dataset works, including a guide describing the various processes / mechanisms, data tables, code values / reference tables, and technical specifications used in the submission of a Tariff Filing.

The eTariff Dataset is used to electronically (1) submit a new Tariff; (2) make modifications to an existing tariff; and, (3) withdraw an existing tariff or a portion thereof. Within the FERC relational database, each Tariff Submitter will have its own tariff(s). A Tariff Submitter may have more than one tariff in effect at any time. A tariff must contain at least one Tariff Record.

A Tariff Record is a single occurrence (row) in a database (similar to a row in a spreadsheet) and will consist of multiple data element fields. There are different types of organizational options when creating a Tariff Record. A Tariff Record can be created utilizing a Tariff Records with sheet-based, section-based, or whole document formatsapproach.

Sheet-based Format or Section-based Format is the term used to describe a Tariff Record that is submitted in logically divided portions within the Commission-defined constraints. Whole Document Format is the term used to describe an entire tariff or document submitted as a single Tariff Record within the Commission-defined constraints.

eTariff DATASET OVERVIEW:

The eTariff Dataset consists of three data tables, as more fully explained below, that set forth the explanation of the data elements used when creating a single Tariff Filing. Once the Tariff Submitter has completed all of the requirements for the various data elements, the data in the tables will need to be compiled into a single xml file pursuant to the xml schema contained in the technical section of this implementation manual, and then put into a zip file for submission to FERC via the eFiling / eTariff web portal.

The three data tables are:

Filing Data Table

This table includes the data elements that identify to what company the Tariff Filing is applicable, what tariff is being created, modified or withdrawncancelled, and the key parties involved in the filing process.

Attachment DataTable

This table includes data elements that describe each of the supporting / attached documents (e.g. transmittal letter, form of noticesupporting work papers, etc.) submitted regardless if they are required for the given Type of Filing or they are optionally submitted, as set forth in the FERC rules and regulations. For each supporting document, the Tariff Submitter must indicate if a waiver is requested. If a waiver is requested, it is still necessary to provide identifying information for the supporting document. If a supporting document is not required, and is not included in the submission, it is not necessary to provide attachment data.

Attachment Data –

oHave to provide attachment data for every attachment submitted.

oHave to provide attachment data for those that are required even if the Tariff Submitter is requesting a waiver of that requirement.

oIt is not necessary to provide attachment data for optional attachments that are not submitted.

Tariff Record Content Data –

This table includes the data elements that are used to uniquely identify the individual Tariff Records being submitted, the proposed effective date, the order in which the Tariff Records should be assembled, and the binary data for each record.

Explanation of the data element information – high level

The data element fields are the individual pieces that make up the Tariff Filing. Each will have a defined format, may be required, conditional or optional and may have restricted values. A data element field may contain text or a document (e.g. a .pdf file) as more fully explained in this implementation manual. An explanation of the individual data elements is reflected in the data table portion of this implementation guide. In such tables, for each data element, the following information is provided:

• Business Name
• Element Name (this is the corresponding technical (metadata) name used in the XML schema)
• Definition of Data Element
• Field Format (length)
• Valid Values
• Usage / Responsibility and Conditions
• Other Pertinent Information, if applicable

A Tariff Filing is unique by the combination of the Company Identifier, Filing Identifier, and Tariff Identifier. A Tariff Record is unique by the combination of the Tariff Record Identifier, Option Code, Tariff Record Proposed Effective Date and Record Effective Priority Order.

The following is proposed in lieu of Column 7 in the Data Tables:

Details of Individual Data Elements –

The following are the individual data elements provided in the same order as they appear in the Data Tables:

Note – for additional information see the definitions and other requirements as set forth in the data tables.

Filing Data Table Data Elements:

Schema Version:This is the version of the XML schema used to create the specific tariff filing. The Schema Version and the actual schema will be published on the FERC website (include URL). Any changes to the schema will be made through a FERC notice or order.

Company Identifier:A FERC-designated company identifier code used to define an entity. The code will be assigned by FERC once the company registers with FERC. This data element is required in all three data tables as part of the unique identification key.

Tariff Identifier:A unique identifier for the tariff for the Company company as it pertains to the tariff being modified by the filing. A company may have more than one active tariff. A tariff may contain one or more volumes of a tariff (applicable to gas tariffs). This data element is part of the unique identification key. A Tariff Identifier is supplied by the company. Once a Tariff Identifier in a Tariff Filing has been accepted for filing by the Secretary of the Commission, it cannot be changed. A Tariff Identifier, even if cancelled, cannot be reused.

Tariff Title:The name of the database that is assigned by the Tariff Submittercompany. Examples: “THIRD REVISED VOLUME NO. 1.” The data element is required for the baseline Types of Filings only and initial, first-time filings. After the initial submission, the Tariff Identifier is used for identification purposes. The name of the tariff may not be changed but the Tariff Identifier can not change. It is suggested that the Tariff Submitter’s name Is not contained in the Tariff Title, as the Tariff Submitter’s name is captured by the Company Identifier.

Filing Identifier:A unique numeric Identification of the subject filing. The Filing Tariff Submitter assigns the value. If numbers are utilized, they don’t have to be assigned chronologically from one filing to the next. This data element is part of the unique identification key. If a tariff filing is rejected for filing by the Secretary of the Commission, the Filing Identifier may be reused.

Filing Title/Description:The title given to the filing by the Tariff Submitter. Additional instructions may be published on the FERC website or via FERC notice or order.

Type of Filing / Filing Reference Code:Describes the type of filing being made as defined by FERC regulation, e.g. Compliance, Surcharge, etc. Only one type of filing can be submitted in a single Tariff Filing. The type of filing will dictate the data requirements for the subject filing. A list of allowable codes for the various types of filings will be published on the FERC website (include URL?) or via a FERC notice or order. FERC will provide this information in a data friendly format (csv file appropriate for download in a data processing file format) and will be kept up to date as regulations are modified. .

Associated Filing:When used, it identifies the previous filing to which the subject filing pertains. The value provided is the Filing Identifier for the previous filing to which the current filingis relates. Providing Whether a value for this field is required is dependent on the Type of Filing. When Associated Filing data is required, only one Associated Filing number can be provided.

Validation e-mail:This is a valid email address that will receive notification on whether the filing meets the technical requirements such that it can be passed on to the Office of the Secretary of the Commission for further processing. If errors are detected in the XML filing package, the e-mail will contain information about the errors detected. The Validation e-mail address does not have to be eRegistered with FERC.

Payment Confirmation Code:For certain types of filings, the regulations require that a fee be paid along with the filing. The payment of such fee is made at The confirmation number obtained after the successful payment is used to populate this value. It is suggested that the tariff Tariff Submitter knows the procedures or pre-pay a set of fees prior to making the filing with FERC to avoid last minute delays that may prevent a timely filing.

Suspension Motion:Currentlythis data element is only applicable to by certain Part 154 filings made by interstate natural gas pipelines. It is not applicable to the electric or oil industries. This data element indicates whether or not the Tariff Records should automatically go into effect at the end of the applicable suspension period. If the value provided is “no”, FERC’s tariff maintenance will retain the status of “Suspended” until such time as the Tariff Submitter files an appropriate Motion. If the value provided is “yes”, FERC’s tariff maintenance will automatically change the status from “Suspended” to “Effective” with no further action required of the Tariff Submitter.

Filing Attachment Data Table Data Elements:

Attachment Reference Code:If the specific Type of Filing indicates the requirement to provide an attachment, this data code identifies the type of attachment according to the list of standardized codes provided by FERC. A list of allowable codes for the various types of filings will be published on the FERC website (include URL?) or via a FERC notice or order. FERC will provide this information in a data friendly format (csv file appropriate for download in a data processing file format) and will be kept up to date as regulations are modified. .

Attachment Description:This is the description of the individual attachment. For attachments that are pre-defined by FERC's regulations, the description should be the FERC pre-defined description. For attachments that are added by the Tariff Submitter, the description can be any value desired. The Attachment Description is required regardless if a waiver has been requested for the subject attachment. The Attachment Descriptions provided will be displayed in eTariff and eLibrary. Additional instructions regarding this data element may be published on the FERC website or via FERC notice or order.

Waiver Requested:In tthe FERC provided table on rules for attachments (provide URL?),it will indicate whether an attachment for a given Type of Filing can be waived. If the attachment can not be waived, the field is filled in with a “no”. If waiver for the attachment is allowed, the field is filled in with either a “yes” or “no” dependent on whether the Tariff Submitter wants to request a waiver. If “yes” is chosen, then there is no need to attach the corresponding document. If a waiver is requested, it is still necessary to provide the Attachment Reference Code and Attachment Description. The Waiver Requestis code is solely for the purpose of passing the FERC Office of the Secretary of the Commission’s electronic filing validity checks. The actual request for waiver of the Commission’s regulations and support must be provided in an attached text document.

Attachment Document File Name:This is the actual file name for the identified attachment provided by the Tariff Submitter. The file name is the name of the individual electronic document, including the extension. The name is chosen by the Tariff Submitter, unless otherwise provided in FERC instructions. The Secretary of the Commission’s File Name extension rules be enforced. The Attachment Document File Name will appear in eLibrary.

Attachment Document :/ Attachment Document File Name:If the Waiver Requested above is “no”, tThis is the actual document for the identified attachment provided by the Tariff Submitter. The file name is the description of the individual document, including the extension. The name is chosen by the Tariff Submitter. For all Tariff Filings a clean copy of the tariff for posting in eLibrary is required. All Tariff Filing attachments must meet the same rules and requirements applicable to any document filed with the Commission through its eFiling web site. Additional iInstructions may be published on the FERC website or via FERC notice or order with regard to the electronic format, electronic document formats and content of electronic documents will be published on the FERC website or via FERC notice or order. However, the eTariff validation process does not enforce these rules, which are subject to other Secretary of the Commission processes.