Who may sign, and why it narrows the review
The rule lists the permitted signatories. They are the person on whose behalf the filing is made, and officers of corporations, trusts, or other organized groups. They also include officers or agents of governmental authorities, and a qualified representative authorized under the Commission's own rule of practice.1 Electronic signatures are permitted, and typed characters representing a person's name satisfy the requirement for a document filed electronically.1
The practical effect is that a filing assembled by a dozen people is attested by one. That person is rarely the person who wrote each section, and they are certifying the contents of all of them.
A document review that reduces what they have to verify personally is therefore worth more here than on almost any other kind of business document. The saving is measured in the signatory's time rather than in pages.
What an editor can settle before it reaches the signatory
Four things, and none of them requires knowing the tariff, the rate design, or the engineering.
The first is internal agreement. A filing built from a narrative, exhibits, schedules, and testimony will state the same figure in several places, and those places diverge as drafts move. Editors Canada's copy editing standards cover resolving variations in terminology, logic, and mechanics, and checking calculations and conversions.3
The second is defined terms. A filing that defines a term in the narrative and then uses a synonym in an exhibit has two terms and one definition, and the exhibit is the part a reviewer will test.
The third is cross-references. Every reference to an exhibit, a schedule, a section, or a prior docket should point at something that exists and says what it is said to say.
The fourth is completeness against the Commission's own instructions. Where a requirement names contents, an editor can confirm the contents are present without deciding whether they are adequate.
Why plain writing is not a soft consideration in a filing
A filing is read by regulatory staff, by intervenors looking for weaknesses, and eventually by a decision-maker with limited time. The federal definition of plain writing applies to agency communications rather than to filings, and it still describes the target. That definition is writing which is clear, concise, well-organized, and follows other best practices appropriate to the subject and audience.4
Two habits do most of the work. Putting the subject and the verb near the front of the sentence, so a reader does not hold thirty words in suspension. And naming the thing rather than referring to it, because a pronoun with two possible referents in a filing is an ambiguity somebody else gets to resolve.
Neither habit changes what the filing says. Both reduce the number of sentences that can be read two ways, which is the property a signature is attesting to.
Where the editor's authority stops
An editor does not decide whether a rate is just and reasonable, whether an exhibit supports a claim, whether a filing satisfies the Commission, or whether a statement is true. Those are the filer's determinations and its regulatory counsel's, and they arrive with the copy.
What an editor supplies is the list: where the document disagrees with itself, where a defined term drifts, where a cross-reference fails, and where a sentence can be read two ways. Each item is something the signatory can resolve before certifying rather than after.
Everything a client sends is treated in confidence, including draft filings, workpapers, and correspondence with counsel or a regulator. We work on energy and utility documents and on regulatory submissions against whatever specification the filer supplies.
The most useful brief on this work names the signatory. A document reviewed with one reader in mind gets a different, shorter report than one reviewed for nobody in particular.