INGAA Supports FERC’s Call to Discontinue Semi-Annual Storage Report
Continuing efforts started over one year ago, INGAA filed comments supporting FERC’s proposed elimination of the semi-annual storage report. INGAA noted that with two exceptions — storage injections and withdrawals by customer and storage revenues by customer — the current report was completely redundant because pipelines reported the same information in their daily postings, their index of customers and their Form 2 reports. INGAA first raised these arguments when FERC issued a notice of inquiry calling the semi-annual report into question.
INGAA asserted that the two non-redundant elements of the report have no demonstrated utility for monitoring competition or fostering market transparency. INGAA’s rebutted the American Public Gas Association, which supported per-customer reporting by market-based storage providers, and the Independent Oil & Gas Association of West Virginia, Inc., which supported per-customer reporting by cost-based storage providers. Addressing reporting at his level of detail, INGAA agreed with FERC that the purported benefits, which were meager and generally unsubstantiated, did not justify the cost of collecting the information.
INGAA agreed with the American Gas Association, which argued that reporting each customer’s injections and withdrawals not only fails to foster competition and transparency, but actually may compromise a customer’s bargaining power by broadcasting whether the customer was long or short on storage.