Version 1 - Reviewed: March 14, 2019
Recently, EQR filers have experienced automated filing rejections from FERC with the following message:
---Error List - Severe defects that result in rejection of the filing.
Subject: ContractProduct(...) Message:
F.23.24 One of the four rate fields: Rate (Field 34), Rate Minimum (Field 35),
Rate Maximum (Field 36), Rate Description (Field 37) must be included.
This error is repeated "..." times.
The Contract Product fields to which this validation error refers are shown circled in the PowerShark EQR screenshot below. The field Rate Description and value "N/A" is indicated by the arrow.
Figure 1 - Contract Product in PowerShark EQR
Prior to filing EQRs for Q4 2018, PowerShark EQR users could have filed "N/A" or "None" as the Rate Description value. However, FERC has modified their validation and, as a result, both of these values will trigger a rejection citing validation error F.23.24.
FERC staff has issued the following suggested remedy:
"We recently modified [validation rule F.23.24] when we discovered that it was not working properly to ensure that not all 4 rate fields could be blank. However, what we have since discovered (and did not realize at the time) was that if "N/A" or "None" is the only information in the Rate Description field, the validation will cause an error also. Please review your contract file to determine if either of these conditions may have tripped the validation. If you provide a more verbose description that rates are not associated with the specific contract, the file should pass validation. One thing that you should also need to keep in mind is that any refiling you may do will also trip this validation."
The PowerShark EQR support team recommends that if all four Contract Product Rate fields are essentially blank (with Rate, Rate Minimum, and Rate Maximum as 0.0000) and thus, no Rate Description applies, as shown above in Figure 1, that a Rate Description value of "N/A – Does Not Apply" be used (refer to Figure 2 below). This should sidestep the validation error and rejection.
Figure 2 - Contract Product in PowerShark EQR
Going forward, the PowerShark EQR software team is working with FERC staff to add this change to the software's validation rules so that users can confidently submit their EQR filings knowing that PowerShark EQR has already done a thorough validation based on the most current FERC requirements.
PowerShark EQR is the leading software solution for making FERC-compliant EQR filings.
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