Overview
Title
Notice Regarding Inclusion of OLE Objects in Tariff Records and Use of ALJ Settlement Codes; Electronic Tariff Filings
Agencies
ELI5 AI
The Federal Energy people say not to put fancy stuff like pictures, fancy documents, or computer programs inside some digital forms they get because it makes it hard to read. If people want to ask questions or need help, they can talk to someone at the Federal Energy office.
Summary AI
The Federal Energy Regulatory Commission (FERC) has issued a notice regarding the inclusion of OLE (Object Linking and Embedding) objects in electronic tariff records. FERC warns that filings with embedded objects like program files, PDFs, and PowerPoint files may be rejected or require re-filing, as these objects aren't allowed. Additionally, FERC clarifies the use of ALJ (Administrative Law Judge) Settlement Codes, emphasizing that these codes should be used exclusively for settlements filed during hearing and settlement procedures. For any questions, contact information is provided for FERC staff members.
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AnalysisAI
The Federal Energy Regulatory Commission (FERC) has issued a notice regarding specific requirements and limitations for electronic tariff filings. This notice is particularly focused on the use of OLE (Object Linking and Embedding) objects in electronic tariff records and the proper use of ALJ (Administrative Law Judge) Settlement Codes during filing procedures.
General Summary
The notice from FERC outlines two major points regarding the submission of electronic tariff filings, known as eTariff filings. Firstly, it emphasizes that any tariff records submitted electronically should not include OLE objects, which may encompass various embedded files like PDFs or PowerPoint presentations. Secondly, it provides guidance on the appropriate use of settlement filing codes, which should only be used under specific circumstances involving settlement judge procedures.
Significant Issues or Concerns
One notable issue with the notice is its mention of potential rejection of filings if they contain OLE objects, but it does not address the consequences for organizations that may need to revise and resubmit their filings. The process of recreating these filings could lead to a significant duplication of effort and potential delays.
Another concern is the guidance on including pictures in tariff records. The notice makes a distinction between inserting and pasting images without providing clear instructions, which could confuse filers. Similarly, the document's use of technical terms like "OLE objects," "eTariff," and "ALJ Settlement codes" might be challenging for individuals without specialized knowledge, making compliance difficult.
Impact on the Public
The general public might not be directly affected by these technical requirements. Still, the broader impact could be seen in how efficiently energy regulations are managed and updated. If filings are delayed due to compliance issues, it could slow down regulatory processes, ultimately affecting how promptly energy services or infrastructure updates are implemented.
Impact on Specific Stakeholders
For specific stakeholders, such as energy companies and regulatory compliance officers, the implications of this notice are significant. These stakeholders must ensure that their electronic submissions comply with the updated FERC guidelines to avoid rejections and subsequent delays. The lack of detailed explanation on the proper use of ALJ Settlement codes also raises the possibility of misfiling, which could result in administrative burdens and potential legal ramifications for these organizations.
Furthermore, software developers providing third-party solutions for handling tariff records may need to update their tools to ensure they can detect and prevent the inclusion of OLE objects in eTariff filings. This could involve additional development work and costs to align with regulatory standards.
In conclusion, while the notice aims to streamline and improve the regulatory filing process, stakeholders must carefully navigate these requirements to ensure full compliance and avoid unnecessary setbacks. The document highlights the ongoing challenge of balancing regulatory efficiency with clarity and user-friendliness in communication.
Issues
• The document discusses the rejection of eTariff filings with OLE embedded objects but does not specify the potential impact on organizations that may need to recreate these filings, which could lead to wasteful duplication of effort.
• There is unclear guidance on what constitutes an acceptable method for including pictures in tariff records, with a distinction made between inserting and pasting that might confuse filers.
• The document's use of technical terminology, such as 'OLE objects,' 'eTariff,' and 'ALJ Settlement codes,' might not be easily understandable for individuals without specialized knowledge in the area, potentially making compliance difficult.
• The contact information provided is useful, but without additional context on the kind of support available, individuals might not know what type of queries are appropriate to direct to those contacts.
• There is a lack of detailed explanation on how to use ALJ Settlement codes properly, aside from mentioning specific scenarios, which may lead to misfiling.