INGAA strongly supports the proposed modifications to the gas scheduling timeline developed by the North American Energy Standards Board (NAESB), as set forth in the filing submitted by NAESB on September 29, 2014, in this proceeding. This revised scheduling timeline will provide electric generators greater opportunity to participate in the Timely Cycle as well as manage and respond to load variations during the operating day by adding an additional intraday cycle.
INGAA does not support the Commission’s proposal to move the start of the Gas Day to 4:00 a.m. Central Clock Time (CCT). Instead, INGAA supports retaining the current 9:00 a.m. CCT Gas Day. The reasoning behind the Commission’s proposal to move the start of the Gas Day is legally deficient under the Administrative Procedure Act (APA). Moreover, INGAA does not believe that the Commission can sustain its burden of proof under section 5 of the NGA to show that the existing 9:00 a.m. CCT Gas Day start is unjust and unreasonable. If the Commission decides that changes to the start of the Gas Day warrant further consideration, INGAA requests that the Commission defer a decision on implementing this change until one year after the scheduling timeline changes go into effect to determine whether changes to the scheduling timeline alone would address sufficiently the Commission’s concerns without the need to change the start of the Gas Day. The Commission could establish procedures prior to the end of the one-year deferral to assess whether the scheduling changes are sufficient.
INGAA supports retaining a national Gas Day. A bifurcated Gas Day would create operational challenges for pipelines that flow gas from one region to another, or make deliveries in more than one region. Such a change would impose upon them responsibility for balancing their systems to bridge the time differences between the zones. This would compel pipelines in, effect, to render an uncompensated park and loan service. Many pipelines do not have this capability.
Finally, to the extent that the Commission adopts the NAESB scheduling timeline, or any modification to the NAESB timeline, it must allow a sufficient implementation period so pipelines and all other segments of the gas value chain – producers, processors, gatherers, interstate and intrastate pipelines, local distribution companies (LDCs), and end users – can make the necessary physical and transactional changes to their operations to accommodate such modifications. Pipelines will need sufficient time to develop, test and implement the changes to automated business systems to reflect the revised scheduling changes and hire and train additional personnel. INGAA suggests that the Commission provide the natural gas industry a minimum of nine months to implement the scheduling timeline changes of any final rule. To ensure that these changes go smoothly, INGAA respectfully requests that the Commission avoid implementing any changes during the winter heating season (November through March), when traditional gas utility customers transport the greatest amounts of their gas, or the summer peak season (May through August), when generators rely most heavily on pipelines.
As noted above, INGAA opposes moving to a 4:00 a.m. CCT Gas Day. If, however, the Commission decides to move forward with a 4:00 a.m. CCT start to the Gas Day, INGAA submits that the Commission should allow pipelines a minimum of one year to design, test and implement the additional business system and facility modifications and make staffing changes necessary to reflect both the NAESB scheduling timeline and the new Gas Day.
Please see the attached comments for the full text.
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