On September 18, 2014, Commissioner Moeller convened a meeting to consider a national electronic information and trading platform for natural gas (Docket No. AD14-19).
In response to the commissioner’s invitation to submit additional comments, the Interstate Natural Gas Association of America (INGAA) filed comments on October 1, 2014, in which it offered several observations regarding the topics discussed at that meeting:
1. Hourly nominations should not be confused with non-ratable flow rights.
2. There are reasons to doubt that pipeline nomination, confirmation, and scheduling can be automated fully so as to guarantee that the process can be completed in near real-time.
3. Pipelines can offer customized services that are designed to meet the needs of firm shippers.
4. Pipeline services cannot create liquidity in the intraday market if no gas commodity has been allocated to the additional opportunities for nominations.
5. The scope of the problem is unclear.
6. It does not appear that a centralized trading platform could be created via only incremental changes to the current natural gas pipeline model.
7. Even if implementation of the centralized trading platform is feasible, it would not provide a means to relieve pipeline infrastructure constraints that affect the ability to serve electric generators during periods of high demand for natural gas.