When I began to oversee our tariff functions several years ago, I was struck by the fact that although incumbent telephone companies filed tariffs over an electronic filing system, the nondominant companies still filed their tariffs by paper and on CD-Rom. We had boxes and boxes of paper tariffs that needed to be processed. Many times it was difficult to find a nondominant tariff when a customer or carrier requested one.
The paper filings also presented problems for our tariff logs, which is how the public finds out when a new tariff is filed. Most tariffs are filed on 15 days’ notice, which means that other carriers/customers have a limited time to challenge a tariff before it becomes effective. Unfortunately, it took several days for a paper filing to appear on the tariff log, making carriers scramble if they wanted to challenge a nondominant tariff. For these reasons, we decided in the Pricing Policy Division that it would be beneficial to add these tariffs to our Electronic Tariff Filing System or ETFS.
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