INGAA requests the Commission retract the NOPR’s proposed amendment of 18 C.F.R. § 284.13(d), and thereby refrain from requiring interstate pipelines to post daily actual flows. Should the Commission instead go forward with an actual flow reporting requirement, INGAA requests the Commission revise its proposed regulations to not require the installation of new facilities; to categorically exclude mainline segment reporting; to limit reporting to the aggregate level of scheduled quantities; to limit reporting to points of custody transfer, but not pipelineeâ€tooâ€pipeline interconnections; to place the reporting obligation falling on the party operating the custody transfer meter; to limit reporting to a one-time, commercially reasonable basis, without obligation to revise; to limit onnâ€line posting to ninety (90) days; to categorically exempt information subject to a confidentiality agreement; and, to set a compliance deadline several months after the requirement is adopted.
Related
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
