FERC Order 809 occupies a large share of the time I allot to “what’s next” thinking. There are so many opportunities inside what the FERC has assigned the industry in Order 809.
Let’s put our thinking caps on and get creative!
In Order 809 the FERC asked us to “. . . explore the potential for faster, computerized scheduling when shippers and confirming parties all submit electronic nominations and confirmations, including a streamlined confirmation process if necessary.” The discussion here is the reference to submittal of electronic confirmations. There are some pipelines in the gas industry today that have made great progress in implementation of electronic confirmations through EDI. But there are others who have not done any electronic confirmations and, generally, electronic confirmations are executed between interstate pipelines.
So what can we do?
1 – Is there an opportunity for XML to become the standard for confirmations so that it is less expensive to implement and more web-enabled?
2 – Do we need confirmation-clearing companies such as those used in trading?
3 – Do these streamlined confirmations need to cover the entire natural gas supply chain or do they only need to apply to deliveries to electric generation and their suppliers? Do electric generation suppliers only need to confirm upstream to the nearest point of on-demand supply, such as storage, park-and-loan, etc.?
4 – Is there a new on-demand service offering that would provide a service to supplant streamlined confirmations?
5 – Are there new confirmation services that can be offered to expedite the process while still providing reliable delivery?
6 – Should electric generators be allowed to submit hourly nominations and, consequently, incur hourly imbalances to minimize the number of intraday confirmations?
On September 17th the FERC issued an Order on Rehearing (Docket No. RM14-2-001) where they stated “…the Commission requests that the natural gas and electric industries, through NAESB, begin considering the development of standards related to faster, computerized scheduling and file such standards or a report on the development of such standards with the Commission by October 17, 2016.” This gives us a deadline to work toward. Deadlines are good. It also give us a lot of time to get the job done. So let’s start thinking about this assignment.