Washington, D.C. – The American Gas Association (AGA) today submitted the following comments to the Federal Energy Regulatory Commission (FERC) on contract reporting requirements of intrastate natural gas companies:
AGA supports FERC’s efforts to improve market transparency and to make sure FERC has the information it needs to adequately monitor the wholesale, interstate markets. FERC, however, should not impose burdensome reporting requirements on Hinshaw pipelines that outweigh the value of the information that would be provided.
While AGA believes FERC has dramatically underestimated the cost of compliance with the proposed rules, particularly the standardized electronic filing requirements, AGA believes that in general FERC has taken the right approach and that quarterly reporting of jurisdictional transactions strikes an appropriate balance.
AGA urges FERC to consider several modifications to reduce the burden on intrastate and Hinshaw pipelines, as follows:
- FERC should only apply the reporting requirements to the jurisdictional activities of Hinshaw pipelines and should not apply them more broadly to an LDC’s retail or intrastate services that are not FERC-regulated.
- FERC should not require Hinshaw pipelines to report each individual “transaction” separately, but should allow them to report aggregated transaction information under each “contract.”
- With regard to standardized shipper identification and common industry codes, FERC should use of the D-U-N-S® Number as a common company identifier. FERC should allow intrastate and Hinshaw pipelines to use an interstate pipeline’s Data Reference Number for any receipt and delivery points where such numbers have already been assigned. For all other points, FERC should allow proprietary codes to be used.
- FERC should support a variety of electronic filing methods including both the proposed XML Schema and ASP.NET methods as well a simple spreadsheet method in order to make it as easy as possible to comply with the electronic filing requirements.
- FERC should develop a Frequently Asked Questions Web page to assist filers in complying with the new requirements, and FERC should not penalize filers for inadvertent errors in reporting.
- Finally, FERC should consider when the new requirements would become effective and afford intrastate and Hinshaw pipelines sufficient time to take the necessary steps to comply.