I often hear people comment that compliance issues don’t apply to them because they are not a FERC-regulated company. If you are involved in transportation at any point in the natural gas business then compliance issues matter to you.
You can see the reason when you refer to the old adage that ‘it all rolls downhill’ but there is more to it than that.
Look at some of the basic FERC regulations.
The Gas Day. NAESB, hence FERC, says that the Gas Day is from 9:00 am – 9:00 AM Central Time for interstate pipelines. If you are transporting on an interstate pipeline, you must work within this timeline. What about if you are delivering onto this pipeline as an upstream interstate pipeline or a midstream operator? Then you must work within this timeline. What about if you are an LDC or Utility receiving from the interstate? Same story – you must use the timeline. Now, if you have to use the timeline to put gas onto or take gas off of the interstate, guess what? It’s best if you run your own operations on that timeline! So as a midstream operator or an LDC, the easiest answer is for you to match the gas day of the interstate that you connect with.
This same logic applies to the nomination cycles. Your business may not need to use all of the nomination cycles, but if you interconnect to an interstate or nominate on an interstate then you have to comply with those cycles in some manner to confirm your gas. You may be able to run your business such that you only have one official cycle, such as the Timely cycle, but you still have to be aware of and confirm on the other cycles.
As a midstream operator, you may not need all of the upstream party and contract information because you know where the gas is coming from in your gathering system, but you will need the downstream party and contract information to be collected with nominations so that it can be provided in the confirmation process.
As an LDC, you may not need the downstream party and contract information because you know where the gas is going in your distribution system, but you will need the upstream side of the information for support of confirmations on your upstream interconnects.
And then there is customer service. Customers who nominate gas on your system are often the same customers transacting with interstate pipelines. The more that you use the same terms, deadlines, and processes, the easier the communication will be with your customers.
I believe that there is an opportunity in the NAESB process for nomination model types to be defined that are specific to the needs of the midstream and LDC businesses. The current model types are close to what these business lines need, but they require too much information compared to the true business model of the upstream. If a model type existed that supported gathering from many wells without including upstream information but required the interconnect documentation on the downstream side, it would be a golden tool. If a model type existed that supported the distribution side of the business without all of the unused downstream information but required the corresponding upstream interconnect documentation, it could ease the burden of some of the transactions.
But it takes someone to lead the charge.
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