by sylviamunson

What Can I Say?

It’s not often that I run out of things to write about.  Actually – that has never happened.  The situation that I’m in right now is that there are so many things that need to be written about that I find myself stuck – unable to make a choice and run with it.

I could spend days on the upcoming changes from Order 809.  It is potentially the most exciting set of changes that I have seen out of FERC in quite a few years.  If we don’t do our job well on this one, they could be minimal, boring changes. But I am hoping and praying that we do our job well and make some changes that positively impact our industry and our customers.

I could spend days writing about technology and the challenges that we face when met with such wonderful opportunities in technology.

I could spend days on the details of the business processes in natural gas.  I learn more every day and am regularly surprised at the new ways that companies find to do business in such an ever-changing marketplace.

I love hearing from you.  I have learned through three different people this last week that my questions to you put you in a difficult position. Often you cannot provide a response to my postings because it would be seen as a company position and you cannot afford to make that statement or, more likely, you are not permitted to make that statement. Don’t hesitate to pick up the phone and call me!  Don’t hesitate to send me an email.  I can use the information, if appropriate, by stating that “A friend told me,” or some other vague reference that points no fingers.  I promise that I won’t say “A friend that works in building X for company Y in the Z department told me…”

Sylvia

by sylviamunson

Choose to be Creative – 6 Ideas for Consolidating the Confirmations Process in Natural Gas

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!

Confirmations

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.

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

Fun with FERC Order 809 or “How to Put Two Shippers on One Contract” . . .

The Federal Energy Regulatory Commission (FERC) recently issued Order 809 for interstate pipelines. One of the components of the order was for pipelines to support the ability for a Firm transportation contract to have multiple shippers.  The good news is that the pipeline only has to support this ability IF shippers request the service.  The bad news is that the pipeline only has 60 days to implement the service once it is asked for.  This means that the pipeline has to be prepared to offer the service because I don’t know of many pipelines who can implement such a change in just 60 days.

So why on earth would you need two shippers in a contract?  I can imagine several scenarios where this could be advantageous.  For instance, if a shipper needs reliable firm service on an as-needed basis and can find another shipper, such as a marketer, to utilize the un-used firm.  The would give the first shipper the reliability that they need and give them an out for when that service is not needed without having to enter the Capacity Release race on a regular basis.  Another example may be where a shipper needs seasonal firm capacity but the pipeline doesn’t offer a program that meets their specific needs. In this case, the shipper could match up with another shipper that can handle the off-peak quantities and share the transportation obligation. There may even be credit advantages, though I may be stretching my imagination too far on that one.

So what does the FERC have to say about this?  In Order 809, there were very few specifics.  There were references to a number of pipelines already offering this capability and, via that reference, the FERC decided that the service requirement only applies to Firm transportation and implied that there would be an agent involved to manage the contractual relationship and pipeline interaction.

A pipeline could implement such that each shipper had nomination rights.  The pipeline could implement such that the agent is mandatory and the agent manages the different shippers.  In the example pipelines that I researched, it appeared that there was always an agent relationship and the agent was responsible for managing the transactions for the shippers. These pipelines implemented this service prior to Order 809.

Again, the FERC was silent on nominations, billing, quantity rights, and location rights in Order 809.  It did say that the financial responsibility was with both parties.  So, like Capacity Release, if the one party fails to perform, the second party is financially responsible.

If the pipeline implements this in the easiest way, with an agent, then the transaction datasets would be unaffected.  The only impact will be to be able to add two shippers and their separate terms onto one contract and to be able to post those separate terms in the Transactional Reporting requirements.

We have 75 days from the FERC issuance of Order 809 and then 60 days after a shipper issues a request for such a service.  The worst case scenario is that a pipeline would have to implement this on June 14th, 2015 – 75 days after Order 809 was issued. The best case is any 60 day period after June 14th.

Is this something where shippers can find value? Does it help producer services, electric generators or agents?  It will be interesting to see the filings for this requirement, in response to Order 809, and to see how many shippers utilize this offering.