FERC Considers Changes To Posting Requirements

October 2009 Vol. 64 No. 10

Even though the natural gas posting requirements FERC established in Order 720 last November haven’t even gone into effect for major non interstate pipelines, the agency is already considering revising them.

The order stimulated 24 requests – surely a FERC record or close to it – for rehearing, from every corner of the industry, and for seemingly every reason imaginable. The commission is still working through the complex technicalities surrounding those requests, many of which were reiterated in comments coming into FERC at the end of August.

The new requirements for posting in Order 720 stem from new authority FERC was given in the Energy Policy Act of 2005 aimed at facilitating transparency in markets for the sale or transportation of natural gas in interstate commerce. Order 720 requires major non interstate pipelines and interstate pipelines to post certain data on their Internet websites. Specifically, the final rule requires major non interstate pipelines, defined as those natural gas pipelines that deliver more than 50 million MMBtu per year, to post scheduled flow information for each receipt and delivery point with a design capacity greater than 15,000 MMBtu per day.

Interstate pipelines must post information regarding no notice service. This requirement is in effect, although the Interstate Natural Gas Association of America is one of the 24 parties agitating for modifications. INGAA argues that in the clear majority of cases there is no way for the pipeline to determine a receipt point for its no notice service. It wants FERC to clarify that it is appropriate to report the volume of no notice transportation at the level at which the pipeline provides no notice service. If an aggregate volume is what the pipeline reports to its no notice customers, and an aggregate volume is what the pipeline uses to administer its no notice service contracts, reporting this aggregate volume should be found to satisfy the pipeline’s new posting requirement under Order No. 720.