FERC Filings
EPSA's Comments on Natural Gas Council’s White Papers
Preface
The Electric Power Supply Association (EPSA) submits these comments in response to the Commission’s request for further comments on the Natural Gas Council’s (NGC) white papers on liquid hydrocarbon drop out and natural gas interchangeability and the associated petition for rulemaking submitted by the Natural Gas Supply Association (NGSA). EPSA participated in and generally supports the regulatory approach and processes proposed in the Natural Gas Council plus (NGC+) group’s white papers. The issues of natural gas interchangeability and hydrocarbon liquids drop out facing the natural gas industry need to be addressed at the national level without delay as all market participants, including generators, need clarity and certainty on these issues.
EPSA supports the establishment of a Notice of Proposed Rulemaking (NOPR) on natural gas interchangeability in order to give users of natural gas more market certainty and clarity about future quality specifications and parameters. Additionally, EPSA supports NGSA’s petition to put in pipeline tariffs the cricondentherm hydrocarbon dew point (CHDP) levels and associated procedures. Such matters need to be in an enforceable tariff rather than outlined in non-enforceable policy statement. However, while EPSA agrees that interchangeability specifications must be defined and stated in pipeline tariffs, the NGSA petition overstates the consensus and definitiveness surrounding its proposed CHDP and interchangeability specifications. EPSA recommends that the Commission in the NOPR include a range for the Wobbe index similar to the recommendation offered in the interchangeability white paper (i.e.; include a minimum as well as a maximum Wobbe specification) and use the maximums for inerts and butanes recommended by both NGSA and NGC+. At the same time, there remain data gaps and research requirements surrounding these issues and possible resultant impacts of such specifications. EPSA therefore urges the Commission to utilize the collection of information in a rulemaking process to seek further technical input from parties, e.g. through public conferences and discussion with key industry representatives, rather than relying on the NGSA proposal as the basis for any action.
EPSA also recommends that the Commission investigate through the NOPR process whether the Commission’s Section 5 complaint procedures include adequate criteria to allow a complainant to demonstrate that the public interest standard is maintained or compromised due to particular pipeline specifications. Should there be additional criteria required, the complaint process suggested by NGSA provides a solid foundation but would require greater clarity and certainty on the area of cost burdens due to changes made to meet the specifications are paid for. The Commission should proceed, using EPSA’s suggestions as set forth below, with a rulemaking proceeding to set national standards that create regulatory and business certainty, increased efficiency and lower costs for all participants in the natural gas value chain.