The Interstate Natural Gas Association of America (INGAA) submitted comments on September 29, 2014 in response to the Federal Energy Regulatory Commission’s (FERC or Commission) Notice of Proposed Rulemaking (NOPR) proposing to amend the filing requirements for natural gas pipeline system map(s).
The Commission proposed to eliminate the annual requirement for a pipeline to file its system map(s) electronically as part of its tariff. In its place, the Commission proposed to require a pipeline to maintain its system map(s) on its publicly available website. In addition, the Commission proposed to require a pipeline to revise its system map(s) more frequently, within the calendar quarter of any major system change, rather than by the current April 30 annual deadline (18 C.F.R. §154.106(c)(2014)).
INGAA supported the Commission’s proposal that a pipeline maintain its system map(s) on its publicly available website. INGAA was concerned that the Commission’s proposal to require a pipeline to revise its system map(s) within the calendar quarter could increase a pipeline’s compliance risk associated with missing this new deadline. Accordingly, in lieu of the Commission’s proposed “within the calendar quarter” map update requirement, INGAA proposed that the Commission revise 18 C.F.R. § 154.106(c) to provide that a pipeline revise its system map(s) to reflect any major change “no later than the end of the calendar quarter that immediately follows the calendar quarter in which the major change occurred.” INGAA stated that this alternative balanced the Commission’s goal of revising tariff system map(s) more frequently with a pipeline’s need to have sufficient time to revise its system map(s) after any major change.