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 .
We brought our proposal to add nondominant tariffs to ETFS to our Bureau Chief, Sharon Gillett, who was very enthusiastic about the idea. Chairman Genachowski was also very supportive of the plan. So last year, we released the NPRM in this docket to provide notice of the proposed plan and rule modifications. Public comment was supportive. On June 9, the Commission adopted a Report and Order  at its open meeting. We are now working with our technology staff to make the necessary changes to ETFS to ensure that the system is up and running once the rules become effective. And I can’t wait to see the end of those boxes!