E-Filing of GSD1 and GSD2 Natural Gas Tariffs

What is EDI and Gas Services Tariff eFile System?

Electronic Data Interchange, (“EDI”), is a filing method where a data file, in a standard format, is submitted electronically to the Railroad Commission of Texas (“Commission” or “RRC”) by the gas utility. Because EDI documents must be processed by computers, a standard format must be used so that the computer can read and understand the documents. A standard format defines and describes the required format of each piece of information in the data file. The format, by which a gas utility shall file tariffs, is prescribed by the Commission in accordance with 16 Texas Administrative Code (“TAC”) § 7.315, relating to Filing of Tariffs.

Gas Services (“GS”) Tariff eFile System, which was implemented in March 2020 and found via the RRC Online System, allows the processing of data files uploaded by gas utilities to the existing Oracle Tariff System. Please note, the new GS Tariff eFile System is a change to the upload filing process not the tariff file formation.

What are the benefits of the new GS Tariff eFile System?

  1. The new system streamlines the electronic filing process with the Commission’s RRC Online System.
  2. The new system increases security of confidential information submitted by gas utilities.
  3. The new system allows gas utilities to manage their eFile accounts.
  4. The new system improves the gas tariff upload process by:
    1. providing the ability view, search, and sort upload history;
    2. providing the ability to view and delete pending uploads before they are processed; and
    3. providing timely and clear upload error messages.

Does the Commission supply software to file tariffs via the GS Tariff eFile System?

No, the Commission does not supply any software solutions to file gas tariffs via the GS Tariff eFile System. Additionally, the Commission does not supply templates to assist gas utilities in filing of tariffs. A gas utility that files information electronically with the Commission may elect to develop or purchase software to facilitate the EDI and eFile process.

The Commission maintains a list of vendors which provide software to assist with the creation of Commission tariff files. The vendor list is updated when either a vendor or company using EDI software purchased from a vendor identifies themselves to the Commission and provides contact information. Please note, the list on the Commission’s website implies no endorsement by the Commission of any product or service and the Commission makes no guarantee as to the quality or suitability of any product or service offered. The eFile Software Vendor List is available on the Commission’s website

 

What are the roles and responsibilities for the GS Tariff eFile system?

External roles and responsiblities:

  • External Security Administrator. This role already exists for other RRC Online systems. The person with this role maintains accounts associated with their company in RRC Online.
  • Gas Utility (“GU”) Administrator. This is a new role for the GS Tariff eFile System. Designates Authorizing Agent for eFiler user ID and uploads files into the GS Tariff eFile System.
  • Gas Utility (“GU”) eFiler. This is a new role for GS Tariff eFile System. Uploads files into the GS Tariff eFile System.
  • Gas Utility (“GU”) Read Only. This is a new role for GS Tariff eFile System. Has read only access to all uploaded files associated with their company in the GS Tariff eFile System.

Commission roles and responsibilities:

  • Gas Services (“GS”) Security Administrator. This is a new role for the GS Tariff eFile System. A person with this role maintains Gas Services’ internal accounts in RRC Online. They also designate a tariff analyst for a company, maintain company information and form settings, and can also designate eFiler user IDs to a company when assistance is requested by a GU Administrator.
  • Gas Services (“GS”) Tariff Analyst. This is a new role for the GS Tariff eFile System. Reviews/administers uploaded files in the GS Tariff eFile System. May delete pending files.
  • Information Technology Services (“ITS”) System Admin. This role already exists for other RRC Online systems. A person with this role maintains accounts for internal Security Administrator users in RRC Online System.

What do I need to do to start uploading files via the GS Tariff eFile System?

  1. Read the requirements for participating in online filing found at https://www.rrc.texas.gov/about-us/resource-center/forms/online-filing-at-rrc/rrc-online-security-requirements/.
  2. Complete the Security Administrator Designation[CG1]  (“SAD”) form. More than one Security Administrator can be designated, but a separate SAD form must be completed for each additional Security Administrator. If the operator has already provided the SAD form for the Security Administrator(s), then step two is not required. Participants may change a Security Administrator designation at any time. For more information on the Security Administrator functions and responsibilities, please see the RRC Online System frequently asked questions[CG2] , and the PDF instructions for user account creation/maintenance.
    1. Submit the SAD form to the Commission’s Information Technology Services (“ITS”) at Railroad Commission of Texas, 1701 North Congress Avenue, Austin, Texas 78711 or by email to RRCOnline-Security@rrc.texas.gov. Please note, a SAD form should not be filed for each gas utility eFiler account. Receipt of the Security Administrator Designation will be acknowledged by e-mail.
    2. Wait for ITS to provide the designated Security Administrator a user ID and temporary password by email.
  3. The Security Administrator will log into the RRC Online System and assign user IDs and filings rights. The Security Administrator(s) will have control over who within the company receives authorization to file electronically. The Security Administrator is responsible for maintaining security of all assigned user IDs and passwords. 
  4. Review the Tariff Filing Guide to compose and file information electronically.
    1. Contact your assigned Tariff Analyst for questions or to set up a tariff training session (for new GU eFilers).
  5. Create the data file according to the file format standards outlined in the tariff filing guide.

Why do I have to maintain two user IDs to use the GS Tariff eFile System?

Every GU eFiler who will be uploading files via the GS Tariff eFile System will have to maintain two user IDs. The two user IDs are required due to the different character requirements in both systems. The user ID in RRC Online System can be up to 10 characters in length, while the user ID in the GS Tariff eFile System is limited to 8 characters in length.

I am a GU eFiler for a gas utility, but I don’t see the GS Tariff eFile System link under my account, what should I do?

If you don’t see “GS Tariff eFile System” on your RRC Online System menu, please contact your company’s Security Administrator. They will be able to assign the appropriate filing rights to you.

What if the GU eFiler and the Security Administrator are the same person?

If the GU eFiler and the Security Administrator for a company are the same person, then the Security Administrator will need to define a second user ID for themselves and assign filing rights as a GU eFiler to the new account.

I am a GU Administrator and I have GU eFilers who upload files for multiple gas utilities who have different operator numbers, how do I manage the GU eFilers?

GU Administrators will have to associate the RRC Online user ID with an Authorizing Agent user ID for each GU eFiler in order for them to be able to upload files for a company. This association must also be done for the GU Administrator if they are going to upload files. This set-up is done on the “Add New User” screen. If a GU eFiler uploads files for more than one company, the GU Administrator for each company must associate the RRC Online user ID with an Authorizing Agent user ID of the GU eFiler and check the “Check if user is a company agent” checkbox so that the GU eFiler can be assigned to more than one operator number.

Where is my upload history before the new GS Tariff eFile System was implemented?

Data files uploaded prior to the implementation of the new GS Tariff eFile System were not migrated. Only new data submitted after implementation will be shown.

I have never filed tariffs; do I still need to file test files?

Yes, it is highly recommended that new users file test files prior to filing production data. Please contact your assigned tariff analyst to schedule a training session. Please note, test file RRC assigned IDs received from the Commission are not valid in the production environment. The GU eFiler will need to re-submit data files to generate new RRC assigned IDs.

What files can be filed through the GS Tariff eFile System?

The Commission’s Gas Services Department has several gas tariff data files that can filed electronically. Those files are:

  • GSD1 - Distribution Sales and Service
  • GSD2 - Sales and Utility Services, Transportation and Exchange Service or Rates
  • TAR1 - Company Contact Information
  • TAR2 - Company Customer Information
  • TAR3 - Company Delivery Point Information
  • TAR4 - Company Current Rate Component
  • TAR5 - Company Curtailment Plan
  • TAR6 - Company Line Extension Policy
  • TAR7 - Purchased Gas Adjustment
  • TAR8 - Company Quality of Service Rule
  • TAR9 - Company Rate Schedule
  • TAR10 - Company Service Charge
The files will continue to have a delimited format by using the pipe “|” separator as outlined in the Tariff Filing Guide.

Which TARs pertain to which GSDs?

The following associations exist between the GSDs and TARs:

GSD1 - Distribution Sales and Service

  • TAR1 - Company Contact Information
  • TAR2 - Company Customer Information
  • TAR5 - Company Curtailment Plan
  • TAR6 - Company Line Extension Policy
  • TAR7 - Purchased Gas Adjustment
  • TAR8 - Company Quality of Service Rule
  • TAR9 - Company Rate Schedule
  • TAR10 - Company Service Charge

GSD2 - Sales and Utility Services, Transportation and Exchange Service or Rates

  • TAR1 - Company Contact Information
  • TAR2 - Company Customer Information
  • TAR3 - Company Delivery Point Information
  • TAR4 - Company Current Rate Component

What is the Authorizing Agent (AA) Record?

The Authorizing Agent record tells the Commission who is responsible for the information that was uploaded via the GS Tariff eFile System. Your organization can assign multiple agents for each of the files or forms submitted electronically. However, you must include the Authorizing Agent record for each record and file. The Authorizing Agent record is mandatory and must be the first record submitted in the file.

What are the Totals (Z9) Record?

The Totals Record is the total amount of records/lines between the Authorizing Agent (AA) and the Totals (Z9). If the incorrect count/number is included, the system will reject the upload.

What are upfront files?

Upfront files must be filed first, except for the TAR7 or Purchase Gas Adjustment, via the GS Tariff eFile System before filing GSD1 and GSD2, or what is also considered to be the tariff. The following upfront files exist: TARs 1, 2, 3, 4, 5, 6, 8, 9, 10. Once the file is successfully uploaded and processed, the gas utility’s assigned tariff analyst will provide the filer a pdf report(s) via email containing the RRC assigned IDs that are needed to complete the tariff filing process.

What is a tariff code?

Tariff code describes the tariff’s overall type of service. For example, if a gas utility gathers and processes natural gas for a customer, then the appropriate tariff code is TM – Transmission Miscellaneous. Please note, the system will not process tariff files if the customer (TAR2) and delivery/receipt points (TAR3) tariff codes do not match the GSD’s tariff code. The available tariff codes are:

  • DM – Distribution Miscellaneous
  • DS – Distribution Sales
  • DT – Distribution Transportation
  • TM – Transmission Miscellaneous
  • TS – Transmission Sales
  • TT – Transmission Transportation.

Which upfront TAR do I need to submit when there is a new customer with a new contract and no assigned RRC IDs?

The TAR2 – Company Customer Information, must be filed first. After the system has processed the TAR2, the filer will receive an RRC Customer assigned ID. The filer can insert the ID into the appropriate tariff form (GSD1 or GSD2).

Can I use the same RRC Customer assigned RRC number for multiple tariffs?

Yes, the filer may use the same RRC Customer assigned ID (TAR2) for multiple tariffs. The tariff code used for the TAR2 must match the GSD’s tariff code. It is recommended that the gas utility file all customer information for each tariff code. After customer IDs have been generated by the system, you may use the Customer ID for any number of contracts between the gas utility and customer. The same is required for delivery or receipt points (TAR3) filed with the Commission.

What file form is used to report rate escalators or rate updates?

Escalator information is filed by amending the C3 (Delivery or Receipt Point) section of the GSD2 tariff

Is this file format reported only once per customer contract?

No, the system does not allow filers to update contact information once it’s been successfully filed. Please contact the gas utility’s assigned tariff analyst by email to request the change.

Who is my assigned tariff analyst?

Please contact Gas Services at 512-463-7167 or gastariff@rrc.texas.gov to obtain the gas utility’s assigned tariff analyst’s contact information.

What method should I use to report rate descriptions?

There are 3 methods to report rate descriptions:

  1. Rate Adjustment Provision - This method is used for short descriptions. This section has a 2,000 character limit.
  2. TAR4 – This method is used for long rate descriptions, can be used with multiple GSD2 tariffs, and must be filed prior to filing the GSD2 tariff. The TAR4 is considered an upfront file. Additionally, this method allows for reporting capabilities, meaning GS Tariff Analysts can generate PDF reports for the company for a specific or all TAR 4s filed to date.
  3. D4 – This method is similar to the TAR4 method but is not considered an upfront file. This method also allows reporting capabilities.

What should I include in the rate description?

The gas utility shall state the billing unit (such as Mcf, MMBtu, Cf, etc.); shall list all charges that may apply under the contract or agreement; shall describe all components used in the calculation of the current rate including but not limited to standby charges, reservation fees, imbalance provisions and charges, penalties, treating provisions, taxes, pooling fees, etc.; and shall state the effective date. A statement on the rate schedule that a particular rate includes certain provisions, without restating all the details or contingencies of the contract, is sufficient. If the rate the gas utility charges is based on a formula or requires a calculation to determine the unit rate to be charged, the gas utility shall identify in the tariff all components used in the calculation of the unit rate, including each component of the cost of gas.

I have not received my RRC assigned IDs; where can I find them?

Once a TAR or GSD form has been uploaded and processed successfully, it is recommended that you contact your assigned tariff analyst by email requesting the specific TAR or GSD pdf report. Please note, each tariff filing shall be subject to review by the tariff analyst within 30 days.

How many days do I have to file a tariff after a change is effective?

The gas utility shall file tariffs with Gas Services within 30 days of the effective date of the change as prescribed in Texas Administrative Code § 7.315 – Filing of Tariffs.

How many times can I file a tariff?

A tariff that has been filed successfully can only be filed once per day. If the tariff was filed with an error, the filer may reupload the tariff the same day.