by sylviamunson

Fun with FERC Order 809 continued – or – “Continuous and Contiguous Scheduling”

We have an interesting challenge ahead of us. One of the take-aways of FERC Order 809 is the requirement for the North American Energy Standards Board (NAESB) to look at and consider ways to make natural gas pipeline scheduling faster and closer to real time. Electric generators have made it clear that they need more flexibility with scheduling as they move more electric generation to a natural gas dependency.

This is not a new idea. It has been tossed about more than once before Order 809. One of the very first principles written by NAESB in GISB Version 1.0 in the mid-1990’s was Principle 1.1.2 which states “There should be a standard for the nominations and confirmations process. Agreement notwithstanding, it is recognized that this is an interim step to continuous and contiguous scheduling.”    (Copyright North American Energy Standards Board, NAESB Version 3.0 published 2014)

NAESB quickly, in Version 1.0, created the standardized Nominations and Confirmations processes including a few touches on the scheduling process in that mix.  A great step was made when NAESB added the Intraday Cycles and now, via NAESB 3.0 and Order 809, there is an additional Intraday Cycle giving shippers a total of 5 nomination opportunities in the day-ahead and day-of scheduling process.

And that’s not all.

Some pipelines have already implemented multiple scheduling cycles throughout the day that are in addition to the NAESB cycles.  A few pipelines have gone so far as to create hourly cycles. But without a consistent solution, the ‘contiguous’ side of scheduling becomes difficult.

Not all pipelines have gone beyond the standard cycles. So, what do we do?  Are we ready for that ‘Continuous and Contiguous’ process that we considered so long ago?

I believe we are. I believe that it will require some serious paradigm-shift-type thinking to make it happen.

The actual excerpt from Order 809 is below, from the Commission request, and as noted in paragraph 107:

However, the use of computerized scheduling would appear to provide an opportunity for faster and more frequent scheduling of intraday nominations for those shippers and their confirming parties willing to commit to scheduling electronically. We request that gas and electric industries, through NAESB, 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. Providing such an option would enable those entities that need greater scheduling flexibility to have their requests processed expeditiously.

What are the opportunities here?

  • If we converted the nomination and confirmation processes to XML based transactions and generated the confirmation request straight from the requested nomination then we could have more immediate communication and create that contiguous chain.
  • If we kept our traditional ‘Timely’ Scheduling cycle, possibly even the ‘Evening’ cycle and then, after that, opened the process to a first come, first serve processing with a quick turnaround, then we could eliminate the interim cycles and provide that continuous service.
  • We would still need a no-bump cutoff where IT shippers could count on their gas to flow. Possibly at the time of the current cutoff already agreed to in NAESB.

These ideas require major technology investments. These are just a few ideas. I have others, but I’d like to hear from other people first.

The NAESB Board has voted to make this aspect of Order 809 a primary topic in 2016.  As an industry, we need problem solvers to step up and create straw man solutions before those NAESB meetings begin.  Let’s get the discussion started.

by sylviamunson

Terminology: What is an EBB?

I work with a lot of young people in the energy industry.  They are often in the technology end of the business, but they are just as likely to be from the business side of natural gas.  When the term ‘EBB’ comes up, I get the quizzical look and the imminent question…”What is an EBB”?  And it is a question that I don’t like answering because it is somewhat embarrassing.

EBB stands for Electronic Bulletin Board.  Back in the days before the Internet, there was EnerNet.  EnerNet was a company that formed out of the FERC Order 436 requirement that interstate pipelines make certain information publicly available for shippers and potential customers on their pipeline.  We didn’t have the Internet, but we had fancy 2400 baud dial up modems.  Some pipelines formed their own public boards for posting this information and some subscribed to services, such as EnerNet to make that information available.

The EBB is a term that has lived a good life and a long life, but to use the term today causes confusion.  Today, in natural gas we have websites.  An interstate pipeline usually has two distinct website offerings to meet regulatory requirements: the Customer Activities Website (CAW) and the Informational Postings Website (IPW).

CAW and IPW have meaning.  When you mention a CAW you know that this is the secured access site that customers use to transact business with a pipeline. When you mention and IPW you know that you are referring to the public information, unsecured posted information on a pipeline.

So does the EBB cover both the CAW and the IPW or is it something else? Good question!  In some of the NAESB standards they refer to the EBB/EDM as those electronic standards related to the website without specification of whether this is the IPW or CAW.  Elsewhere in NAESB WGQ definitions there is a definition of EBB/EDM that points directly to the CAW with no mention of the IPW. If you go deep enough to look at the EDM manuals, you will see that the EDM subcommittee has distinguished that EBB is the CAW and they refer to the IPW as IP/EDM.

Are you confused yet? You are not alone.  It is time to change the terminology and put the EBB term to rest and let the distinct IPW and CAW terms become the common language.

The answer to the question is that, even though Electronic Bulletin Board precedes the internet, it refers to the Customer Activities Website in Natural Gas.  For me, I try to avoid the term all together and just refer to them as CAW and IPW.

by sylviamunson

Why compliance matters to non-regulated entities

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.