[Federal Register Volume 59, Number 87 (Friday, May 6, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-10920]
[[Page Unknown]]
[Federal Register: May 6, 1994]
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
18 CFR Part 284
[Docket No. RM93-4-001]
Standards for Electronic Bulletin Boards Required Under Part 284
of the Commission's Regulations
Issued: May 2, 1994.
AGENCY: Federal Energy Regulatory Commission.
ACTION: Final rule; order on rehearing.
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SUMMARY: The Federal Energy Regulatory Commission (Commission) is
issuing an order on rehearing of its final rule that adopted
regulations to standardize the content of, and procedures for
accessing, information relevant to the availability of service on
interstate pipelines. The Commission is granting rehearing on one
issue: the requirement to provide file downloads in an ASCII flat file
format.
DATES: The implementation date for the regulations published on January
5, 1994 (59 FR 516) is June 1, 1994, except when specified otherwise.
ADDRESSES: Federal Energy Regulatory Commission, 825 North Capitol
Street NE., Washington, DC 20426.
FOR FURTHER INFORMATION CONTACT:
Michael Goldenberg, Office of the General Counsel, Federal Energy
Regulatory Commission, 825 North Capitol Street NE., Washington, DC
20426, (202) 208-2294.
Marvin Rosenberg, Office of Economic Policy, Federal Energy Regulatory
Commission, 825 North Capitol Street NE., Washington, DC 20426, (202)
208-1283.
Brooks Carter, Office of Pipeline and Producer Regulation, Federal
Energy Regulatory Commission, 825 North Capitol Street NE., Washington,
DC. 20426, (202) 208-0666.
SUPPLEMENTARY INFORMATION: In addition to publishing the full text of
this document in the Federal Register, the Commission also provides all
interested persons an opportunity to inspect or copy the contents of
this document during normal business hours in Room 3104, 941 North
Capitol Street NE., Washington DC 20426.
The Commission Issuance Posting System (CIPS), an electronic
bulletin board service, provides access to the texts of formal
documents issued by the Commission. CIPS is available at no charge to
the user and may be accessed using a personal computer with a modem by
dialing (202) 208-1397. To access CIPS, set your communications
software to use 300, 1200, or 2400 bps, full duplex, no parity, 8 data
bits, and 1 stop bit. CIPS can also be accessed at 9600 bps by dialing
(202) 208-1781. The full text of this notice will be available on CIPS
for 30 days from the date of issuance. The complete text on diskette in
WordPerfect format may also be purchased from the Commission's copy
contractor, La Dorn Systems Corporation, also located in Room 3104, 941
North Capitol Street NE., Washington DC 20426.
Table of Contents
I. Introduction
II. Background And Summary Of Order No. 563
III. Issues Relating To Data Set Implementation And Maintenance
A. Implementation Date
B. Periodic Reports
C. Mechanism For Making Revisions To The Data Sets
D. Operation Of The Data Sets
1. Mandatory, Optional, And Conditional Nature Of The Fields
2. Pipeline Modification Of The Data Sets
IV. Issues Relating to Specific Information Included In The Data
Sets
A. Operationally Available (Unscheduled) Capacity
1. Objection to Posting the Amount of Operationally Available
Capacity
2. Derivation of the Estimates of Operationally Available
Capacity
B. Unsubscribed Firm Capacity
C. Information On Firm And Interruptible Flowing Volume
V. Electronic Data Interchange
A. ASCII Flat File Downloads
B. Uploading And Subset Downloading
VI. Common Codes
A. Common Company Codes
B. Common Transaction Point Codes
1. Pipeline Responsibility to Provide the Data Base and Ensure
Reasonable Fees
2. Point Locator Information
3. Establishment of New Receipt and Delivery Points
VII. Additional Standards
A. Index Of Purchasers
B. Business Practice Standards
VIII. Recovery Of EBB Costs
Before Commissioners: Elizabeth Anne Moler, Chair; Vicky A. Bailey,
James J. Hoecker, William L. Massey, and Donald F. Santa, Jr.
Standards for electronic bulletin boards required under part 284 of
the Commission's Regulations, Docket No. RM93-4-001.
Order No. 563-A
Order on Rehearing
Issued May 2, 1994.
I. Introduction
In Order No. 563,\1\ the Commission adopted a final rule requiring
the standardization of information relating to transportation of
natural gas across the interstate pipeline grid. The standards adopted
by the Commission reflected the consensus agreements reached by the
natural gas industry through a series of informal conferences
established by the Commission. Under these standards, pipelines will
have to provide access to the required information both on their
Electronic Bulletin Boards (EBBS) and through files which users can
download from the pipelines' computers to their own computers.
Pipelines are required to implement the requirements of this rule by
June 1, 1994, except for the requirements regarding a common code for
gas transaction points which are to be implemented by November 1, 1994.
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\1\Standards For Electronic Bulletin Boards Required Under Part
284 Of The Commission's Regulations, Order No. 563, 59 FR 516 (Jan.
5, 1994), III FERC Stats. & Regs. Preambles 30,988
(. 23, 1993).
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Nineteen parties have sought rehearing or clarification regarding
some of the requirements of the rule and the standards and
communication protocols.2 The Commission grants rehearing on one
issue, downloads in a standardized ASCII flat file format. The
Commission had required pipelines to provide for file downloads in two
formats: The first complied with established communication standards
and protocols for Electronic Data Interchange (EDI) and the second
would have required that downloads be made available in a standardized
ASCII flat file specified by the Commission. The Commission agrees with
those seeking rehearing that the future of communications in the
industry will be enhanced by the development of one industry standard
based on established communication standards and protocols, rather than
by promulgation of a second non-standardized methodology that has
significant disadvantages compared with EDI. The Commission also
clarifies the requirements of the rule and the protocols as discussed
below.
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\2\The parties seeking rehearing and clarification are listed in
Appendix A.
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II. Background and Summary of Order No. 563
In Order No. 636,3 the Commission required pipelines to
establish EBBs to provide shippers with equal and timely access to
relevant information about the availability of service on their
systems, including service available through capacity release
transactions and firm and interruptible capacity available directly
from the pipeline.4 The Commission recognized that the efficiency
of capacity allocation would be enhanced by standardizing both the
content of capacity release information and the methods by which
shippers could access that information.5
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\3\Pipeline Service Obligations and Revisions to Regulations
Governing Self-Implementing Transportation; and Regulation of
Natural Gas Pipelines After Partial Wellhead Decontrol, 57 FR 13267
(Apr. 16, 1992), III FERC Stats. & Regs. Preambles 30,939 (Apr. 8,
1992), order on reh'g, Order No. 636-A, 57 FR 36128 (Aug. 12, 1992),
III FERC Stats. & Regs. Preambles 30,950 (Aug. 3, 1992), order on
reh'g, Order No. 636-B, 57 FR 57911 (Dec. 8, 1992), 61 FERC 61,272
(1992).
\4\18 CFR 284.8(b)(3)(4), 284.9(3)(4).
\5\Order No. 636-A, III FERC Stats. & Regs. Preambles at 30,549.
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To facilitate the development of industry standards, the Commission
established informal conferences between the staff and all interested
members of the gas industry. The participants at these conferences
divided their efforts into five Working Groups.6 The Working
Groups submitted a series of reports to the Commission summarizing
their deliberations and the agreements reached. The Commission noticed
these reports and provided an opportunity for public comment.
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\6\Working Groups 1 and 2 were responsible for developing data
sets setting forth the information concerning available capacity.
Working Group 3 was responsible for developing standards relating to
business transactions between pipelines and their customers
unrelated to the sale or release of capacity. Working Group 4 was
responsible for developing a set of communication protocols
governing the dissemination of the information. Working Group 5 was
responsible for developing codes to identify companies and common
transaction points.
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The final rule adopted the consensus agreements reached by the
industry in the Working Groups, with only slight modifications.
Sections 284.8(b)(5) and 284.9(b)(4) require pipelines to provide
standardized information relating to firm and interruptible service on
their EBBs and to provide users with the ability to download the
standardized information in compliance with standardized procedures and
protocols. The rule provides that the details of the required
information, procedures, and protocols will be made available in a
document entitled ``Standardized Data Sets and Communication
Protocols,'' which will be available at the Commission's Public
Reference and Files Maintenance Branch.
The standardized data sets specify the information concerning
capacity availability that pipelines must provide both on their on-line
EBBs and through downloadable files.7 This information includes
offers to sell firm capacity (either by the pipeline or releasing
shippers), bids for capacity, awards of capacity, withdrawals of
capacity offers and bids, operationally available (i.e., interruptible)
and unsubscribed firm capacity, and system-wide notices. In addition,
the Commission established a mechanism for creating a common code data
base for identifying pipeline transaction points, such as receipt and
delivery points.
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\7\On-line EBB refers to a continuous computer connection
between a pipeline EBB and a user's computer in which the
information from the pipeline's computer is displayed visually on
the user's computer and the user can enter data directly to the
pipeline's computer. File downloading refers to the transfer, in
computerized format, of a file from the pipeline's computer to the
user's computer. The user then can use other computer programs to
manipulate the data off-line when it is not connected to the
pipeline's computer.
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The communication protocols establish principles and procedures
relating to the operation of pipeline EBBs and the provision of
downloadable files to users. The most important of these protocols is
the requirement that the pipelines provide downloadable files that
conform to the standards for Electronic Data Interchange (EDI)
promulgated by the American National Standards Institute (ANSI)
Accredited Standards Committee (ASC) X12.8 In addition to EDI, the
Commission had required the pipelines to provide for file downloads in
a standardized ASCII flat file format,9 but the Commission is
deleting this requirement on rehearing.
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\8\ASC X12 standards provide an electronic data submission
capability that allows computers to exchange information over
communication lines using standardized formats. Since the ASC X12
transaction sets provide generic data groups applicable to a range
of potential applications, the transaction sets must be customized
to individual applications by correlating or ``mapping'' the
specific information to an ASC X12 transaction set through an
implementation guide.
\9\ASCII refers to the American Standard Code for Information
Interchange, a code for character representation. ASC X12 downloads
also use ASCII characters. The term ASCII flat file download refers
to a standardized file download capability that does not meet the
requirements of the ASC X12 standards.
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In the rule, the Commission recognized that as pipelines began the
process of implementing the data sets, they could discover problems
requiring modifications. The Commission stated that pipelines should
communicate any problems to the Working Groups, which should make the
necessary modifications to the data set and submit them to the
Commission in sufficient time to permit implementation of the
requirements by June 1, 1994.
On March 4, 1994, Working Groups 1 & 2 filed revised capacity
release data sets and an implementation guide for downloading these
data sets using EDI. Public notice was given of the filing with an
opportunity for comments. By order dated April 1, 1994, the Commission
accepted the revised data sets and implementation guide.10
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\1\059 FR 16537 (Apr. 7, 1994), 67 FERC 61,006 (1994).
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The initial Working Group reports included a number of issues on
which the Working Groups had not yet reached agreement. In the Notice
of Proposed Rulemaking (NOPR), the Commission concluded that the
Working Groups should take more time to consider these issues and try
to reach consensus. The Commission provided that the Working Groups
submit reports on these matters to the Commission by February 1, 1994.
In Order No. 563, the Commission found that resolution of these issues
should await the February 1, 1994 reports. Nevertheless, many of the
requests for rehearing and clarification address the same issues.
The Commission has received a number of reports from the Working
Groups, which were publicly noticed with an opportunity for
comments.11 When appropriate, the Commission will address these
issues in this order to provide the Working Groups with guidance as to
how to proceed.
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\1\1Working Groups 1 & 2 could not reach consensus on several
issues, and submitted reports from participants on the following
issues: proposals for electronic index of purchasers which would
provide information about the capacity rights of firm shippers,
position papers on whether to require disclosure of aggregate firm
and interruptible nominations at pipeline points, and position
papers on the methods for recovering electronic communication costs.
Working Group 5 submitted reports on a consensus agreement for
implementing a common code for company names. Working Group 4
submitted a final report on communication protocols and operational
logistics. Working Group 3 submitted a report containing a proposal
for implementing standards for nominations and confirmations and a
schedule for developing standards for other business transactions.
Several participants also submitted position papers on the issue of
ASCII flat file downloads.
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The Commission will address the issues raised by the rehearing
requests in the following areas: data set implementation and
maintenance; specific information included, or proposed to be included,
in the data sets (operationally available capacity, unsubscribed firm
capacity, and firm and interruptible flowing volume); electronic
communication issues (ASCII flat file downloads, file uploads, and
subset downloads); common codes for companies and gas transaction
points; additional standards for an Index of Purchasers and non-
capacity business transactions; and proposals relating to the method
for recovering the costs for implementing standards.
III. Issues Relating to Data Set Implementation And Maintenance
A. Implementation Date
AER/MRT contend that the June 1, 1994 implementation date places
too great a burden on the pipelines, because they are still in the
midst of refining their restructured services and the compliance burden
falls during the critical shoulder months between January and March.
They suggest a December 1, 1994 date. In particular, they contend that
they require the implementation guide for the ASC X12 data sets by
February 1, 1994, and suggest that, if that date is not met, the June
1, 1994 date should be relaxed.
The Commission will not change the implementation date. In Order
No. 563, the Commission agreed to extend the implementation date from
the April 1, 1994 date proposed in the NOPR until June 1, 1994. But,
with this extension, the Commission expected a fully operational set of
standards to be in place by June 1. Working Groups 1 and 2 stated in
their comments that the June 1 date can be met if the ASC X12
implementation guide is available by March 1, 1994, and the Working
Groups substantially met this deadline, filing the data sets and
implementation guide with the Commission on March 4, 1994, with public
notice given on March 7, 1994. AER/MRT is the only party alleging that
the June 1 date cannot be met, and they have not provided sufficient
justification for extending the date further.
B. Periodic Reports
In Order No. 563, the Commission found no need for requiring
pipelines to file tariffs specifying how they would comply with the
rule or to file periodic reports of their implementation progress. UDC/
AGD renew their request that pipelines be required to file periodic
reports. Without such reports, they maintain no formal procedure would
exist to provide information on implementation progress or problems.
They further claim such reports would provide useful information about
the development of the secondary market and the interplay between
interruptible and released capacity.
The Commission denies the request for rehearing. As stated in Order
No. 563, the Commission will monitor implementation of the rule by
accessing the pipelines' EBBs, continuing to hold industry conferences,
and by examining complaints. These mechanisms provide a far more
flexible method of oversight than attempting to specify particular
items of information for inclusion in periodic reports. As stated
earlier, the Commission is committed to monitoring the EBBs and the
implementation of the standards, and to making revisions when needed.
C. Mechanism for Making Revisions to the Data Sets
In Order No. 563, the Commission recognized that the
standardization process was an ongoing one, which would require
revisions and modifications to the data sets and protocols as the
industry obtains experience with operations under the standards. The
Commission stated it would continue the informal conferences and the
Working Groups as the best means for monitoring the standards, but did
not adopt a specific mechanism for implementing proposed changes. The
Commission found that its determination of the proper method for making
revisions may depend on the type of change contemplated. The Commission
stated, however, that in considering proposed changes, it would comply
with the Administrative Procedure Act (APA) and ensure parties have
notice and an opportunity to comment on proposed changes.
Tenneco Gas asserts that providing a mechanism for addressing
changes to the standards is critical and requests the Commission to
adopt a specific mechanism for making changes, which is both flexible
and responsive. KGPC contends many participants are unable to commit
the resources to remain actively involved in the Working Group process
and urges the Commission to ensure adequate communication to the
industry of proposed changes with an opportunity for comment. AER/MRT
similarly request clarification that the Commission will comply with
the APA and provide notice and an opportunity for comment.
The Commission recognizes that the standards and protocols will
have to be revised and that a flexible mechanism is needed for
effectuating such changes. To provide the needed flexibility, the
Commission adopted only a general regulation referencing the separate
standards and protocols and did not include those standards and
protocols in the Code of Federal Regulations. However, as explained in
Order No. 563, the Commission cannot commit to one method for making
revisions because different circumstances may demand different
procedural mechanisms; for example, maintenance of the existing data
sets may be treated differently than implementation of new
requirements. As stated in Order No. 563, in making changes, the
Commission will adhere to the APA and provide notice and an opportunity
for public comment before implementing changes.
The Commission will clarify that the process for maintenance of the
data sets promulgated in the rule will be generally the same as the
process used previously to adopt the revised data sets and
implementation guide. The Working Groups will file their suggested
changes, which will be noticed with an opportunity provided for
comment. To facilitate discussion or improve understanding of proposed
changes, Commission staff may convene a technical conference to review
the changes with the industry. The Commission will then issue an order
adopting the data sets. This process will enable the Commission to make
changes in a timely fashion while still preserving the industry's
ability to comment on the changes. The Commission also encourages the
Working Groups to consider other methods of informing non-participants
of impending changes prior to filing with the Commission so that the
Working Groups themselves will be able to avail themselves of a broad
spectrum of input.
While the Commission recognizes the need to revise the data sets,
it also recognizes that making revisions and changes on a piecemeal
basis may be cumbersome and create added programming costs for both the
pipelines and those obtaining information either from the EBBs or
through downloadable files. The Commission encourages the Working
Groups to consider an appropriate schedule for accumulating and
submitting revisions.
Tenneco Gas states it did not understand that the Working Groups
would continue indefinitely. AER/MRT contend that the Working Groups
provide only a temporary solution and urge the Commission to recognize
the contemplated Gas Industry Standards Board (GISB) as the appropriate
group to handle standards development. Although GISB is still in its
formative stage, AER/MRT recommend the Commission endorse GISB and
charge it with the mission of further standards development. Columbia
Distribution suggests that one Working Group would be more efficient
than the current five, because the participants in the five Working
Groups are essentially the same and one Working Group would streamline
the process.
The Commission finds that some mechanism for consideration and
modification of the standards, whether GISB or the Working Groups, must
continue into the future. At this point, reliance on the GISB concept
is premature, and the Commission will continue the Working Group
process which has worked very well in developing standards. As stated
in Order No. 563, the Commission will consider the GISB concept when a
final proposal has been developed and the Commission can consider its
impact on all facets of the gas industry. Meanwhile, the Working Groups
should not delay or defer development of standards in anticipation of
the implementation of GISB. The Commission will leave the structure of
the Working Groups to be resolved by the industry at the informal
conferences.12
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\1\2At an informal conference held on April 12, 1994, the
participants did decide to consolidate into one Working Group. See
Notice of Consolidation of Electronic Bulletin Board Working Groups,
issued April 19, 1994. The Commission expects the combined Working
Group to adhere to the schedules set forth in the rehearing requests
and other filings submitted by the individual Working Groups.
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D. Operation of the Data Sets
1. Mandatory, Optional, and Conditional Nature of the Fields
In the consensus data sets adopted by Order No. 563, data fields
were denominated as mandatory, optional, and conditional.13 The
Commission found that the rule required all pipelines to support the
mandatory data fields. Pipelines would choose whether to support the
optional fields, unless they were required to support these fields by
their tariff. The Commission also stated that pipelines were required
to display all information, whether mandatory or optional, on their on-
line EBBs.
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\1\3Conditional fields are filled only when a condition in
another field is met.
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AER/MRT seek clarification that the Commission was standardizing
only the information to be provided on the on-line EBBs, not the format
in which the information is to be displayed. Others seek clarification
about the display of all the mandatory data fields on the on-line
EBBs.14 They contend certain mandatory fields in the downloadable
data sets are required only for file transfers, but not for
interactive, on-line transactions. They assert users of on-line EBBs
will know some of the information in the mandatory fields without
having it displayed, so that required posting of the information is
unnecessary and will only clutter the EBB screens.15 They maintain
that the only requirement should be that the on-line EBB contain
information comparable to the data sets.
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\1\4KGPC, PEC Pipeline Group, Tenneco Gas, Working Groups 1 & 2.
\1\5Working Groups 1 & 2 point to the fields for rate schedule,
stand-alone offer indicator (whether the offer is tied to another
offer), and offer type (indicating the type of capacity being
offered) as examples of information that would be implicitly known
to users of on-line EBBs and so need not be included on the EBB
display.
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KGPC, PEC Pipeline Group, and AER/MRT also request clarification
that pipelines are not required to display optional information on
their on-line EBBs unless they choose to do so or their tariffs require
the display of that information. NGC requests clarification that
pipelines must support the conditional fields.
The Commission will clarify its requirements. The Commission
required all pipelines to support the mandatory fields because Order
No. 563 included certain substantive requirements that pipelines may
not previously have been required by their restructuring orders to
disclose on their EBBs. For example, not all pipelines may be providing
the information found in the operationally available capacity and
critical notice data sets on their EBBs. The intent of the requirement
was only to ensure that the downloadable data sets and the on-line EBBs
conveyed comparable information. Accordingly, the Commission agrees
that fields not required for on-line EBB use need not be displayed, so
long as the on-line EBB and the downloadable data set convey comparable
information.
Display of optional fields on the on-line EBB must take place when
such fields are included in the downloadable data sets (unless, as
stated above, they are not necessary for on-line use). Conditional
fields must be supported by the pipelines when the conditional field is
dependent on information in a mandatory field.16 If the
conditional field is predicated on the response to an optional field,
the conditional field will have to be supported only if the pipeline
supports the optional field.
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\1\6For example, the prearranged deal field is a mandatory field
requiring a yes/no response. Pipelines, therefore, must support all
the fields conditioned on the response to the prearranged deal
field.
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2. Pipeline Modification of the Data Sets
In Order No. 563, the Commission stated that pipelines could not
add fields to, or delete fields from, the data sets, finding that
standardization required that all pipelines use the same structure for
downloading. ASC X12 software is keyed to specific fields on the
implementation guide, and the Commission was concerned that if
pipelines could add or delete fields, shippers' software could not
interpret the information. The Commission pointed out that the data
sets were designed flexibly to accommodate special release offers or
unique circumstances by including fields for special terms and
miscellaneous notes.
KGPC contends EDI permits the addition of fields without inhibiting
communication with parties not using the additional fields. It asserts
the Commission should not unnecessarily inhibit the ability of the
pipelines to customize their EDI transactions with trading partners.
Although KGPC is correct that fields can be added to the ASC X12
data sets without affecting the ability of others to use the original
version, the Commission is concerned that if pipelines routinely add
fields, the result would be a plethora of non-standard data bases, and
users of multiple pipeline data bases could have difficulty accessing
information that others could obtain.17 The Commission, therefore,
will not permit pipelines to add additional fields.
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\1\7A simple example would be a standardized data set with 30
items. If pipeline 1 added data item 31 and pipeline 2 added data
item 31 to provide different information, a user of both pipelines
would be unable to use the 31st data item because its meaning would
not be standardized.
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Working Groups 1 & 2 are concerned about situations in which the
circumstances facing a particular pipeline do not fit the standardized
format. They cite, as an example, a mandatory data field denominated a
yes/no (Y/N) field and a pipeline needing a third category (U) for
unknown. They suggest the following working principle for dealing with
these problems: the pipeline will make a good faith effort to comply
with the data sets, but if it cannot, it must explain any discrepancies
and seek a correction through the Working Group process.
The Commission is concerned about pipelines changing the meaning of
data set items. While the addition of an unknown element for a field,
as Working Group 1 & 2 suggest, would seem unlikely to cause major
communication difficulties, the Commission cannot determine whether
other changes in meaning might adversely affect those seeking to obtain
information from multiple pipelines.18 Thus, pipelines should make
every effort to use the data sets as promulgated, for instance, using a
``no'' indicator or the miscellaneous note field even if these are not
optimum solutions. When pipelines encounter difficulties in using the
standardized data sets, they should inform the Working Groups so that
revisions can be considered. Once changes are received from the Working
Groups, the Commission is committed to reviewing them as quickly as
possible, but the Working Group changes may not be implemented
unilaterally without Commission approval.
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\1\8For example, those using multiple pipelines may have
difficulty learning of such changes, and their computer software may
not be able to effectively process data sets from multiple pipelines
if the meanings of elements are different.
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IV. Issues Relating to Specific Information Included in the Data Sets
A. Operationally Available (Unscheduled) Capacity
The Commission adopted the Working Groups' consensus agreement to
require the pipelines to provide information on the amount of
unscheduled capacity available at specific locations, such as receipt
and delivery points, mainline, or mainline segments. The Commission
found that this information satisfied the pipelines' obligation to post
the capacity available for interruptible service.19
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\1\918 CFR 284.9(b)(3).
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1. Objection To Posting the Amount of Operationally Available Capacity
TGPL requests rehearing of the requirement to post the actual
quantity of unscheduled capacity. It contends the posting of detailed
information on unscheduled capacity will serve only to reduce the value
of interruptible and firm service, because potential shippers can use
the unscheduled capacity information to demand the lowest price for the
capacity. It asserts the regulatory obligation to post interruptible
capacity could be satisfied by the pipelines simply indicating that
interruptible capacity is available.
The Commission denies TGPL's rehearing request. The Working Groups
reached a consensus agreement to provide unscheduled capacity, and TGPL
is the only party raising an objection. Moreover, a marker indicating
that interruptible capacity is available is not sufficient to comport
with the regulatory requirement to post available capacity. Under the
Commission's open access regulations, pipelines cannot withhold
available capacity, and shippers, therefore, have the right to know the
amount of capacity available. Moreover, shippers need to know the
amount of interruptible capacity available in order to make a
reasonable determination of whether interruptible service is sufficient
for their needs or whether they need to seek released firm service.
2. Derivation of the Estimates of Operationally Available Capacity
In Order No. 563, the Commission stated that the data for
operationally available capacity could be estimates, and left to the
Working Groups the issue of whether an additional field would be needed
to describe how the estimates were derived. Working Groups 1 & 2
reached agreement that a new field was not needed. They suggest a good
faith effort by each pipeline to provide a commercially reasonable
estimate using internally consistent methods is sufficient. The
Commission, therefore, will not require the additional field at this
time.
B. Unsubscribed Firm Capacity
KGPC requests clarification that the Commission's reference in
Order No. 563 to pipelines' posting their available firm capacity in
the offer data set does not require any change in its current practices
for posting its available firm capacity. KGPC states that, because it
is a grid system with thousands of receipt and delivery points, it
cannot post in the offer data set the myriad configurations of firm
capacity paths that might be available.20 Instead, it states that
it posts on its EBB the capacity available at each point and the
subscribed capacity at each point. Potential shippers then request
possible combinations of capacity paths, and if KGPC determines firm
capacity is available along these paths, the resulting firm service
will be posted in the capacity offer section of the EBB.
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\2\0The offer data sets would require the pipeline to define the
points between which the capacity is being offered.
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The revised data sets submitted by Working Groups 1 & 2, and
adopted by the Commission have accommodated KGPC's concern. The
operationally available capacity data set includes fields permitting
pipelines to post unsubscribed capacity available at receipt and
delivery points, as KGPC states it does now. Once a potential shipper
submits a request for a capacity path that is available, the pipeline
would then post the offer for that path in the offer data set.
C. Information on Firm and Interruptible Flowing Volume
NGSA and NGC contend the Commission needs to require additional
information to satisfy the pipelines' obligations to post available
firm and interruptible service.21 NGSA asserts the firm capacity
available through capacity release is only a piece of the total picture
of firm capacity needed by potential shippers. NGSA contends the
Commission also should require pipelines to post the total amount of
unscheduled (potentially available) firm capacity. NGC contends
potential shippers cannot make reasonable pricing decisions unless they
know flowing primary firm volumes, flowing secondary firm volumes,
flowing interruptible volumes, and unscheduled volumes. KGPC, on the
other hand, maintains that the Commission should not require the
posting of any information in addition to the unscheduled capacity
already required.
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\2\118 CFR 284.8(b)(3).
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Working Groups 1 & 2 were unable to reach consensus on whether to
require additional information about firm and interruptible volumes or
nominations at each point. Their February 24, 1994 report contained
papers from three groups on this issue. One group22 supported the
arguments of NGSA and NGC that detailed information about flowing firm
and interruptible volumes is needed for shippers to make informed
decisions about the capacity to purchase.
---------------------------------------------------------------------------
\2\2Ad hoc Group of Power Generators, American Iron & Steel
Institute, Amoco Production Company, Baltimore Gas & Electric,
Chevron U.S.A. Production Company, Conoco, Inc., Destec Energy,
Edison Electric Institute, Fuel Manager's Association, Gaslantic
Corporation, GPM Gas Corporation, Marathon Oil Company, Natural Gas
Clearinghouse, New England Power Company, O & R Energy Inc., Oryx
Gas Marketing Company, Oryx Energy Company, Phillips Gas Marketing
Company, Phillips Petroleum, Company, Process Gas Consumers, Texaco
Gas Marketing, Inc., Vastar Gas Marketing, Inc., Virginia Power
Company.
---------------------------------------------------------------------------
A second group23 opposes providing any additional data. They
contend the information is not readily available, the costs of
providing it would be high, and the information is not related to
capacity release. They also assert the information would tilt the
capacity release market to favor capacity seekers at the expense of
capacity holders. Whenever the information showed that significant
interruptible volumes are scheduled to flow, they maintain the value of
released firm capacity would be devalued. They further contend the now
devalued released capacity will displace interruptible pipeline
capacity, thereby reducing the interruptible revenue credits provided
to firm shippers.
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\2\3ANR Pipeline Company, Brooklyn Union Gas Company, Colorado
Interstate Gas Company, Great Lakes Gas Transmission Limited
Partnership, Koch Gateway, Natural Gas Pipeline Company, Transco Gas
Pipeline, Williston Basin.
---------------------------------------------------------------------------
A third group24 submitted a compromise seeking to balance the
need for information about flowing volumes with the costs of providing
that information. Under their proposal, the pipelines would provide a
``flag'' indicating that interruptible volumes are flowing at a point
which would otherwise have no operationally available capacity. They
assert that this flag would alert both buyers and sellers that firm
capacity at the point is available and could be valuable: if
interruptible volumes are flowing at a point that is operationally
full, a purchaser of firm capacity could bump the interruptible
shippers.25 They assert the cost of providing this flag is less
than the cost of providing the estimated quantities.
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\2\4Algonquin Gas Transmission, Consolidated Natural Gas, East
Tennessee Natural Gas, Enron Corp., Kern River Gas Transmission,
Midcon, Midwestern Gas Transmission, National Registry, Natural Gas
Pipe Line, Panhandle Eastern Pipe Line, Producer-Marketer-
Transportation Group, Southern California Edison, Southern
California Gas, Tennessee Gas Pipeline, Texas Eastern Transmission,
Trunkline Gas Company, Washington Gas, Williston Basin Interstate
Pipeline.
\2\5If the shipper sought to use interruptible transportation,
it might not be able to receive service if the point was
constrained. Its ability to receive service would depend on the
pipeline's tariff mechanism for allocating interruptible capacity
when requests exceed demand.
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Public notice of these filings was given on March 3, 1994, and the
PEC Pipeline Group submitted a comment supporting the interruptible
flag proposal. It contends the flag provides a reliable indicator of
the availability of firm capacity (by showing that interruptible gas is
flowing), but at a fraction of the cost of the proposal to post flowing
volumes.
The Commission finds that the flag proposal identifying when
interruptible capacity is flowing at constraint points provides a
reasonable compromise between informing users that firm capacity may be
available at certain locations and the costs of providing that
information. With the addition of information on interruptible capacity
provided by the ``flag,'' shippers will have a sufficiently broad range
of information about capacity availability. They will know the amount
of capacity available at points (operationally available capacity),
whether firm capacity is available at constraint points (interruptible
flag), the firm capacity available through posted release transactions,
and the unsubscribed firm capacity available from the pipeline. This
information should be sufficient for shippers to make reasonable
decisions about the transportation option to select. The Working Groups
must include the interruptible flag in the next iteration of the data
sets.
V. Electronic Data Interchange
A. ASCII Flat File Downloads
In addition to adopting the consensus agreement to require EBB
operators to provide for electronic file downloading using EDI, the
Commission also required pipelines to make the data sets available in a
standardized ASCII flat file format in an effort to ease the transition
to EDI for those not familiar with this technology. The Gas*Flow group,
which was to develop the EDI implementation guide, also was to provide
the ASCII flat file formats.
A number of parties seek rehearing or modification of the
requirement to provide downloads in a standardized ASCII flat file
format.26 They contend the requirement for ASCII flat file
downloads goes beyond the consensus agreement of Working Group 4, which
left the provision of ASCII flat file downloads up to the pipeline.
They assert that imposing a redundant download capability is costly and
provides little benefit. Natural and INGAA contend the requirement is
unjustified since only two comments on the NOPR requested ASCII flat
file downloads and the Commission failed to make an effort to estimate
the number of customers wanting to use ASCII flat files. Tenneco Gas
maintains ASCII flat file downloads pose a risk to the receiver of
information, because they do not contain the safeguards inherent in the
ASC X12 process. AER/MRT assert the Commission should limit the
requirement to provide ASCII flat file downloads to seven months, which
will provide a sufficient transition period while reducing the burden
on the pipeline to maintain two formats indefinitely. A number of
parties also argue that Gas*Flow will not be supporting ASCII flat file
standards because such an effort goes beyond its charter.27
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\2\6AER/MRT, INGAA, Natural, PEC Pipeline Group, Tenneco Gas,
TGPL, Working Groups 1 & 2.
\2\7Natural, TGPL, Tenneco Gas, Working Groups 1 & 2.
---------------------------------------------------------------------------
Working Groups 1 & 2, PEC Pipeline Group, TGPL, and Tenneco Gas
suggest that, if the ASCII flat file requirement is not eliminated, the
Commission modify the requirement that the pipelines provide ASCII flat
file downloads according to a standardized format. Instead, they
recommend the pipelines be free to develop their own ASCII flat file
format.28 TGPL believes standardization is not needed because
customers wanting to use ASCII flat files in place of ASC X12 are most
likely to be small customers transacting business primarily, if not
exclusively, on a single pipeline.
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\2\8Working Groups 1 & 2 assert each pipeline should be
responsible for defining its ASCII flat file in either a fixed field
or delimited form. It encourages the pipelines to use the same field
names as in the Commission approved data sets and to apply the
pipelines' format (fixed field or delimited) consistently across all
customers.
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The Commission also has received filings from Working Group 3 and
other parties arguing that while ASCII flat file downloads are easy to
document and import into spreadsheet programs, communication using
ASCII flat files has significant disadvantages when compared with ASC
X12 communication.29 The cited disadvantages of ASCII flat file
downloads are: the ASCII flat file format itself is inefficient and
inflexible, because it relies on sequential data display; ASCII flat
files are less reliable because validation programs are available for
ASC X12, but not for ASCII flat files; the lack of validation also
makes using ASCII flat files more labor intensive and expensive; and
ASCII flat files do not provide a foundation for further
standardization in the industry as does ASC X12.
---------------------------------------------------------------------------
\2\9March 9, 1994, filing from Working Groups 1 & 2, and March
25, 1994 filing from Working Group 3.
---------------------------------------------------------------------------
Although Enron Gas Services Corporation created an ASCII flat file
format should the Commission wish to use it, neither Enron nor Gas*Flow
supports the use of ASCII downloads. Enron further states that
requiring pipelines to provide ASCII flat file downloads is not
necessary even for users wanting to use a flat file format. It
maintains that these users can obtain commercially available software
at low cost which will translate the ASC X12 information into an ASCII
flat file format.
The Commission will grant rehearing and eliminate the requirement
that pipelines provide an ASCII flat file download.30 Working
Group 4 reached consensus on using only EDI as the industry standard
for file downloading.31 Both Working Groups 1 & 2 and Working
Group 3 oppose the ASCII flat file requirement as not being in the long
term interest of the industry. Moreover in response to the NOPR's
request for comment on this issue, only two commenters favored a
requirement that pipelines provide a flat ASCII download.
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\3\0The provision of file downloads through EDI will be
sufficient to satisfy the Commission's requirement for file
downloads in Order No. 636. 18 CFR 284.8(b)(4)(i). Pipelines,
however, are still free to provide an ASCII download to their
customers.
\3\1The Working Group left the issue of whether to provide ASCII
flat file downloads up to each pipeline depending on its assessment
of its customers' needs.
---------------------------------------------------------------------------
On reconsideration, the Commission agrees with those requesting
rehearing that the future of electronic communications in this industry
will be better served by establishing one industry standard based on
already established communication protocols, such as ASC X12 EDI,
rather than by developing a second system which is not based on
recognized communication standards and which would provide a less
reliable method of communication. The provision of a transition period
to EDI does not warrant the expense of establishing a standardized
ASCII download capability. Users that are not currently EDI capable
will still be able to use the EBBs to conduct capacity release
transactions while they are learning EDI.32 In addition, ASCII
flat files may be designed in different configurations depending on the
customer's use for that data. The Commission's specification of a
particular format, therefore, would not necessarily have met customers'
needs.
---------------------------------------------------------------------------
\3\2Those pipelines that currently provide ASCII downloads in
the pipeline's proprietary format must provide a grace period for
their users if they do not intend to continue to support such
downloads in the future.
---------------------------------------------------------------------------
Moreover, the Commission's adoption of ASC X12 EDI standards for
communication has created the foundation for software vendors to
develop specific software or other services which will convert the
standardized ASC X12 EDI data into the file structures needed by users,
whether large or small. For example, in other industries, software
vendors have developed low-cost desktop EDI translators for personal
computers that convert from EDI to a flat ASCII file structure (a
``canned'' file structure) without the user having to understand EDI or
learn how to program or operate the translator.33 The Commission
is confident that all customers will be able to acquire software or
other services that meet their individual data communication needs at
reasonable prices. Relying on the market to develop such services is
preferable to the Commission mandating a second file download structure
that may not even provide a good fit with customers' needs.
---------------------------------------------------------------------------
\3\3Other EDI translators permit customers to map the EDI data
set to the customers' individual needs. While this feature provides
greater versatility than a specified or canned translation, it does
require understanding of EDI and the translator program.
---------------------------------------------------------------------------
B. Uploading and Subset Downloading
In Order No. 563, the Commission stated that the ability of users
to transmit (upload) capacity release files to the pipelines' computers
and to download subsets of files would enhance communication efficiency
for capacity release transactions. File upload capability would permit
users to submit offers to release and bids without using the pipelines'
EBBs, while subset downloads would permit users to obtain only the
capacity release files they need.
KGPC contends the development of file uploads and subset downloads
should be driven by market demand, so the pipeline has some assurance
its customers want the service before being compelled to provide it.
Tenneco Gas suggests the development of file uploads for capacity be
delayed until after the upload capability being developed by the
Working Groups for nominations and confirmations is underway. It
contends most industry participants at the Commission's conference gave
first priority to the development of upload capability for nominations
and that upload capability for capacity release, particularly for bids,
is more difficult to develop. It also states upload capability should
be market driven, because the parties supplying the upload information
are not pipelines. NGSA supports the development of file upload and
subset download capability and suggests this task is within the purview
of Working Group 1, not Working Group 4 (as stated by the Commission).
In their March 4, 1994, filing, Working Groups 1 & 2 provided data
sets that would enable users to download subsets of capacity release
information and these have been adopted by the Commission. Working
Groups 1 & 2 have agreed to report by June 1, 1994 on capacity release
uploading and ask the Commission not to prejudge the issue.
The Commission still is interested in the use of file uploads to
facilitate capacity release by eliminating the need for shippers and
bidders to go through the process of signing-on to EBBs to submit
offers and bids. But the Commission will not require the Working Groups
to go forward with this approach until Working Groups 1 & 2 have the
opportunity to make their June 1, 1994 filing on this issue.
VI. Common Codes
A. Common Company Codes
In the NOPR, the Commission stated that it expected Working Group 5
to finalize its proposal for identifying companies by use of a common
code by February 1, 1994. In its March 24, 1994 report, the Working
Group stated it has reached consensus on a procedure for assigning
company codes. The Working Group states that use of company names alone
is unreliable because different abbreviations and aliases would render
electronic posting ineffective. The Working Group, therefore, selected
the D-U-N-S Number assigned to companies by the Dun & Bradstreet
Corporation as the common code number. The Working Group states that
Dun & Bradstreet will assign a D-U-N-S number free of charge to any
company that can establish that it is a business entity located at a
specific address and engaged in a legitimate business. Dun & Bradstreet
also allows trading partners to exchange D-U-N-S numbers without charge
and will provide the company name and address corresponding to a D-U-N-
S number to any other party requesting the information for internal
use.
The Working Group proposes that pipelines provide a means by which
capacity release participants can provide common code numbers to be
used in EDI transactions involving the capacity release data sets. The
participants would be solely responsible for obtaining the common code
numbers from Dun & Bradstreet and providing them to the pipeline. Those
participants that do not have a D-U-N-S number would so inform the
pipeline and only their company name would be included in the data
sets. The Working Group asserts this process would be self-implementing
by the participants and would not require any new institutional
arrangements to implement.
The National Registry submitted comments stating that its
understanding of the Working Group 5 agreement was that any company
having one or more D-U-N-S numbers would supply at least one valid D-U-
N-S number to the pipeline. According to the National Registry, the
only exception to the requirement is when a company does not have a D-
U-N-S number. The National Registry further contends that D-U-N-S
numbers should be included in any of the data sets when releaser or
bidder company name information is supplied. Great Lakes Gas
Transmission Limited Partnership (Great Lakes) supports the Working
Group 5 proposal because parties can acquire D-U-N-S numbers at no
charge and the use of D-U-N-S numbers is self-implementing by capacity
release participants.
The Commission already has adopted the revised data sets submitted
by Working Groups 1 & 2 which contain fields for display of D-U-N-S
numbers. No further Commission action on this proposal seems required
at this time. Those using the EBB should provide the pipelines with
their D-U-N-S numbers (if they have them) and the pipelines will
display those numbers on their EBBs and the downloadable data sets.
B. Common Transaction Point Codes
In Order No. 563, the Commission accepted the consensus approach
proposed by Working Group 5 for identifying common pipeline transaction
points. Under this approach, a third-party code assignor, the Petroleum
Information Corporation (PI-GRID), will prepare a computerized cross-
reference table correlating pipelines' proprietary codes (as verified
and updated by the pipelines) to a common code. Those wanting to use
the common code will maintain the cross-reference table on their
computers and can convert proprietary pipeline codes to the common
code, and vice versa. All transactions with the pipeline will take
place using the pipelines' proprietary codes.
In the communication protocols, the Commission required the
pipelines to provide the validated computerized data base by November
1, 1994. Pipelines were required to verify the required information
about their transaction points to the code assignor. The Commission
also required each pipeline to provide the code assignor with
sufficient information to enable users to locate the position of each
common code point on that pipeline in relation to other points, such as
by using geographic coordinates, line numbers, or line markers. In line
with the Working Group proposal, the Commission required the pipelines
to ensure that users can obtain the common code data base from PI-GRID,
and any updates, without charge, except for reasonable distribution and
handling fees.
1. Pipeline Responsibility To Provide the Data Base and Ensure
Reasonable Fees
Columbia Distribution contends the use of the common code
translation table is an inefficient method of communicating common
codes. Instead, it maintains the Commission should require the
pipelines to adopt the common code.
Several parties object to the Commission's requirement that the
pipelines be responsible for ensuring that a validated computerized
base is available by November 1, 1994, and that the fees charged by PI-
GRID are reasonable.34 They contend the Commission's requirements
are at odds with the Working Group 5 process in which an industry
consortium would be negotiating and signing the contract with PI-GRID.
TGPL argues that placing the compliance burden on the pipelines gives
PI-GRID unreasonable leverage in negotiating its duties as code
assignor. TGPL asserts the Commission should do nothing more than
accept the Working Group 5 proposal and require the pipelines to
validate their proprietary point information to PI-GRID. KGPC suggests
that the Commission set up a process to monitor the provision of
services by PI-GRID, rather than placing that burden on the pipelines.
AER/MRT argues that instead of placing the burden on the pipelines to
ensure a November 1, 1994 implementation date, the Commission should
set a compliance date for PI-GRID and, if this deadline is not met,
should give the pipelines additional time to comply with the common
code requirements.
---------------------------------------------------------------------------
\3\4KGPC, INGAA, Natural, Tenneco Gas, TGPL.
---------------------------------------------------------------------------
TGPL, Tenneco Gas, Natural, and KGPC contend that pipelines should
not be responsible for ensuring the reasonableness of fees because they
will not be signatories to the contract with PI-GRID and, therefore,
can have only an indirect influence on the contracts. Natural further
contends the requirement to ensure reasonable fees is unduly vague and
establishes no basis for determining when such costs are reasonable.
INGAA maintains the industry consortium approach of Working Group 5
provides a competitive market mechanism for controlling fees that is
superior to imposing a requirement on only one segment of the industry.
INGAA points out that the contract with PI-GRID requires that PI-GRID
make the codes available at a cost covering only shipping and handling.
On the other hand, NGSA contends the Commission did not place
sufficient requirements on the pipelines to ensure that the November 1,
1994 implementation date is met. It suggests the Commission require the
pipelines to cooperate with the code assignor by designating, prior to
a specified date, a pipeline liaison who will work with the code
assignor to establish and validate the transaction points.
The Commission denies the request by Columbia Distribution to
require the pipelines to adopt the common code. Such a requirement goes
beyond the consensus reached by the Working Group. The translation
table provides users with the benefits of common codes within a
reasonable time frame, while, at the same time, pipelines need not
incur the burden and expense of making an immediate conversion of their
computer systems and operations to accommodate the common codes.
However, as pipelines review and update their financial systems to
accommodate the new business conditions created by Order No. 636, the
Commission fully expects them to incorporate the use of common codes.
The Commission will clarify its position on pipeline
responsibility. The Commission is accepting the code assignor approach
put forward by the Working Group. While the Commission recognizes that
other parties have been involved in developing the concept and will be
signing the contract with PI-GRID, the pipelines are the only
jurisdictional entity involved in the transaction. The pipelines can
fulfill their obligation by either individually, or through their trade
association INGAA, entering into the contract with PI-GRID as developed
and presented by the Working Groups. The Commission understands that
this contract will specify that the charges for obtaining the common
code data base cannot exceed reasonable shipping and handling costs.
The Commission, at this point, will leave the monitoring of these costs
to the signatories to the contract.
The Commission has required the pipelines to confirm their
proprietary point information to PI-GRID, and the Commission expects no
problems in pipeline cooperation with PI-GRID. However, to facilitate
PI-GRID's development of the common code data base, each pipeline must
designate a liaison to work with PI-GRID and must cooperate with the
schedule set up by PI-GRID so that the data base will be available by
the November 1, 1994 date.
2. Point Locator Information
TGPL and INGAA seek rehearing of the Commission's requirement that
pipelines provide PI-GRID with information sufficient to locate
pipeline points in relation to other points. They argue the two
comments to the NOPR requesting such information do not provide a
sufficient basis for the Commission to reject the consensus agreement
of Working Group 5 under which pipelines would provide this information
only if they have it readily available. They maintain Working Group 5
treated this information as optional to avoid imposing additional
burdens on pipelines that do not maintain this information in
electronic form, while providing useful data when the information is
readily available and accessible.
The Commission denies the request to make point locator information
optional. Shippers considering capacity release offers need information
about point location to determine whether a particular offer fits their
needs. Point locator information provides shippers with the ability to
determine electronically whether the transportation path they desire is
encapsuled within the transportation path of the posted release. For
instance, without such information, the shipper cannot determine
whether the delivery point it wants to use is upstream or downstream of
the delivery point on the capacity release offer.
Nevertheless, the Commission recognizes that some pipelines may
have a large number of receipt points and may not maintain the
geographic location of these points in an easily accessible form. The
Commission also considers the geographic location of delivery points to
be more important to evaluating capacity release offers than receipt
point information, because the potential bidder generally needs only to
determine whether the path of the capacity release offer extends to its
desired delivery point. To ease the burden on those pipelines without
easily accessible information, the Commission will require that they
confirm to PI-GRID the geographic location of their delivery points and
most important receipt points in time to meet the November 1, 1994
deadline. Those pipelines would then be responsible for completing the
confirmation process for all their receipt points as soon as possible,
but no later than May 1, 1995. Pipelines desiring to take advantage of
this exception should file a request for an extension of time,
explaining their system for maintaining geographic information and
justifying their inability to make full compliance by November 1, 1994.
Such extensions will be granted only upon good cause shown.35
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\3\5The Director of the Office of Pipeline Regulation can
approve such requests pursuant to its delegated authority under
section 375.307(d)(4) of the Commission's regulations.
---------------------------------------------------------------------------
KGPC requests clarification that the Commission's reference to
geographic coordinates referred to latitude and longitude. The
Commission agrees. Natural states that its paper pooling and storage
points used for nominations have no identifiable location on the
pipeline and it presumes that for such points, it need only include an
identifier showing the points have no geographical location. Pipelines
should consult with PI-GRID to determine how to report points without
identifiable geographic locations.
The National Registry states that most pipelines appear to be
cooperating with the requirement to provide point locator information
in a form that will enable users to locate points in relation to each
other. It requests clarification that the Commission's complaint
process is the appropriate means of dealing with possible situations in
which pipelines do not provide the point locator information in usable
form. The Commission does not anticipate that any problems will
develop, but, if they do, an attempt should be made to resolve the
problem through the Working Group, and, if that fails, the Commission's
complaint procedure or enforcement hotline would be appropriate
vehicles for pursuing a problem.
3. Establishment of New Receipt and Delivery Points
In the final rule, the Commission adopted the agreement reached by
Working Group 5 that information concerning new receipt and delivery
points, or modifications to existing points, must be provided to the
code assignor 10 days before any business will be transacted using the
new or modified point. Natural requests clarification that shippers may
utilize a new receipt or delivery point prior to the expiration of the
10-day period. It contends situations arise in which a shipper has an
immediate need for a new receipt or delivery point and a 10-day delay
would pose an unnecessary hardship. It also argues pipelines sometimes
need to add a point immediately, for example, to identify a second
proprietary code for an existing point or create a paper point for
accounting purposes. It suggests that no more than a one day delay in
implementing points should be mandated.
The requirement for a delay in implementing points was intended to
ensure that parties using the common code data base would not be at a
disadvantage to those using the pipelines' proprietary points as listed
on the EBB. Except in emergency situations, pipelines should give PI-
GRID at least 10 days advance notice of new points or modifications to
point information so that those using the common code data base will
not be disadvantaged relative to those using the pipeline's EBB.
VII. Additional Standards
Parties had requested that the Commission require an electronic
Index of Purchasers, which would disclose information about capacity
rights, and require the development of standards for non-capacity
release business transactions. The Working Groups were continuing their
deliberations in these areas, and, in Order No. 563, the Commission
stated that it would await the Working Group reports before making
decisions on these issues. The Working Groups have submitted reports on
these issues. Several rehearing petitions address these issues as do
comments received on the Working Group reports, and the Commission will
address these issues below.
A. Index Of Purchasers
The National Registry and Gaslantic support the so-called Tennessee
compromise being developed by the Working Groups, but, in the event the
compromise falls through, the National Registry requests the Commission
to grant rehearing and require the pipelines to implement the limited
Index the National Registry proposes. KGPC suggests that, if an
electronic Index of Purchasers is required, the Commission should
eliminate or modify its current regulations that require pipelines to
file similar information with the Commission.
Working Groups 1 & 2 failed to reach consensus on an Index. One
group, consisting of 44 participants drawn from a cross-section of the
industry (Group 1),\36\ support a compromise proposal under which the
Commission would eliminate the paper reporting requirements relating to
firm and interruptible transportation, including the initial and
subsequent reports (but not the annual reports or the reports on
bypasses) and the requirement to include an Index of Purchasers in a
pipeline's tariff. These reports would be replaced by an electronic
Index provided in downloadable form consisting of the following nine
data elements for each firm transportation and storage shipper:
shipper's name, contract identifier, rate schedule, contract start
date, contract end date, contract quantity, receipt points (and
associated maximum daily quantities (MDQs)), delivery points (and
associated MDQs), and conjunctive restrictions, if any.\37\ The
information would be updated whenever a new contract for firm capacity
was written or a pipeline filed a section 4(e) rate case.
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\36\Algonquin Gas Transmission, American Iron and Steel
Institute, Amoco Production Company, Aquila Energy Marketing
Corporation, Aquila Energy Resources Corporation, Bass Enterprises
Production Co., BP Exploration Inc., BridgeGas U.S.A. Inc., Chevron,
Conoco, East Tennessee Natural Gas, EnerSoft, Fuel Managers
Association, Gaslantic Corporation, Georgia Industrial Users Group,
Heath Petra Resources, Inc., Independent Oil & Gas Association of
Pennsylvania, Independent Oil & Gas Association of West Virginia,
KCS Energy Marketing, Inc., Kern River Gas Transmission, Marathon
Oil, Midland Marketing Corporation, Midwestern Gas Transmission,
Mobil, National Fuel Gas, National Registry of Capacity Rights,
Natural Gas Clearinghouse, New York Mercantile Exchange, New York
State Electric and Gas, Panhandle Eastern Pipe Line, Peoples Gas
Systems, Premier Gas Company, Process Gas Consumers Group, Producer-
Marketer-Transportation Group, Richardson Products Co., Samson
Resources Company, Tenneco Gas Marketing Co., Tennessee Gas
Pipeline, Texas Eastern Transmission, Transcontinental Gas Pipe
Line, Trunkline Gas Company, Valero Gas Marketing, L.P., Virginia
Power, Washington Gas.
\37\Conjunctive restrictions were undefined in the proposal.
According to the comment by the National Registry, one of the
signatories to the agreement, conjunctive restrictions are
provisions that operate across multiple points or contracts and may
limit a shipper's rights at a particular receipt or delivery point.
It gives as an example a shipper with stated rights 2,000 MDQs at
three points, but a restriction that it cannot ship more than a
total of 2,500 MDQ's from all three points on a single day.
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A smaller number of participants (11) (Group 2)\38\ support a more
limited Index which essentially excludes the receipt and delivery point
information contained in the first group's proposal. The parties
supporting this proposal state that they do not believe any Index is
truly necessary, but that, in the spirit of compromise, their proposal
would provide a reasonably cost effective Index.\39\ They are concerned
that disclosing specific receipt and delivery points potentially could
place firm shippers at a disadvantage with respect to future gas
purchase options.
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\38\American Gas Association, Brooklyn Union Gas Company,
Colorado Interstate Gas Company, Consolidated Edison Company of New
York, Inc., Enron Interstate Pipelines, Koch Gateway Pipeline
Company, Natural Gas Pipeline Company of America, Peoples Gas Light
& Coke Company, Public Service Company of Colorado, Southern
California Gas Company, Williston Basin Interstate Pipeline Company.
\39\They assert that those seeking the Index claim that it will
help users locate available firm capacity. But the group argues that
an Index is not needed for this purpose because firm capacity
holders have every incentive to post their available firm capacity
and shippers seeking capacity can post ``want ads'' advertising
their need for capacity.
---------------------------------------------------------------------------
The Arkla Companies\40\ oppose any Index. They assert the
justification given for the Index (that it is needed so capacity buyers
can locate available capacity) is unsupported. They argue that this
function is satisfied by the firm shipper's incentive to release
capacity and potential buyers' ability to place ``want ads''
advertising their interest in acquiring capacity. If firm shippers, not
already posting firm capacity, fail to respond to a ``want ad,'' the
Arkla Companies maintain the capacity holder is unlikely to be
interested in releasing capacity. Further, they assert that small users
(who are alleged to be at an information disadvantage to large users)
would not likely be sophisticated enough to manipulate the data on the
thousands of contracts electronically available through the Index. If
the Commission does require an Index, they maintain the Commission
should eliminate its Part 284 reporting requirements and permit the
pipelines to charge a fee for the use of the Index.
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\40\ANR Pipeline Company, Arkla Energy Resources Company,
Mississippi River Transmission Corporation, and Minnegasco.
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Public notice of these filings was given on March 3, 1994, and the
National Registry and PEC Pipeline Group filed comments supporting
Group 1's proposal containing the nine data elements. The National
Registry contends the information on receipt and delivery point MDQs is
needed so the market can be aware of receipt and delivery point
capacity that can be acquired through capacity release. It points out
that many pipelines allocate greater firm receipt and delivery point
capacity than they do mainline capacity and shippers may want to
acquire the receipt or delivery point capacity independently of
mainline capacity.\41\ In response to those opposing disclosure of
receipt and delivery point information, the National Registry contends
that capacity information should not be considered proprietary. It also
argues that disclosure of receipt points is unlikely to reveal a
purchaser's gas purchase strategy, since it does not disclose pricing,
duration, or delivery conditions and, in most cases, even the supplier
could not be divined from the information.
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\41\For example, it asserts that a replacement shipper (having
obtained a package of mainline capacity) and using a particular
point as an alternate point may want to acquire firm rights at that
point from another shipper.
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The PEC Pipeline Group supports the Group 1 proposal because this
option actually will reduce costs by eliminating the duplicate
reporting requirements for firm transportation contracts. It points out
that the information required by the Index is essentially the same as
is now required to be filed in the initial and subsequent reports under
Part 284, so no additional costs for gathering the information are
created by the proposal.
The Commission finds that the Group 1, more inclusive, proposal has
significant merit, and the Commission is very interested in pursuing
this proposal further. The proposal provides useful information to the
market about capacity, while also setting the stage for reducing filing
burdens on pipelines and streamlining the Commission's reporting
requirements. The Group 2, more limited, proposal is not as attractive
because, without receipt and delivery point information, it would not
reduce filing burdens. Moreover, information on receipt and delivery
points would be of value to those seeking releasable capacity and
disclosure of such capacity information is not confidential, since it
presently is disclosed publicly through the initial and subsequent
reports.
The Commission, however, is unsure about some details of the
proposal. For example, as framed, it would eliminate the initial and
subsequent reports for firm and interruptible transportation, but would
provide only information about firm transportation in the electronic
Index. The proposed Index would be updated only when a new contract was
written or upon the filing of a section 4 rate case, whereas the
subsequent reports now must be filed whenever a material change in the
contract occurs. The proposal states that the Index would be available
in downloadable form, but does not specify the format for the download
(EDI or another format) nor whether shippers will have access to the
information in other forms. In addition, the proposal does not discuss
how the information will be archived in the event access to historical
data is needed. The Commission staff and the Working Group, therefore,
should work to develop a final proposal to be provided to the
Commission by September 30, 1994.
B. Business Practice Standards
In Order No. 563, the Commission concluded that standardization of
business transactions unrelated to capacity release should be the next
step in the standardization process. Working Group 3 had been
considering such standards and had identified 33 high priority items,
of which ten were considered most critical.\42\ The Commission found
that standardization of these ten, or most of them, provided a good
departure point for this effort. The Commission stated that the Working
Group should propose an appropriate implementation schedule for the ten
identified data elements. The Working Group also was to continue its
efforts to identify which of the remaining 23 high priority data
elements, as well as any others, require standardization and propose a
schedule for implementation of standards for these elements as well.
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\42\The ten elements were: timely flowing volume; timely volume
allocation reports; predetermined allocations and shipper ranking;
imbalance status; customer scheduled receipts and deliveries;
customer specific curtailment/interruption information; customer
specific operational flow orders; daily nominated volume
acknowledgement; customer penalty status; and input and modify gas
nominations.
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PEC Pipeline Group contends the Commission should not be issuing
mandatory standards for non-capacity release transactions. It asserts
mandatory standards for such transactions would be inconsistent with
the Commission's position in restructuring orders that Order No. 636
required only the posting of information related to available capacity
and not information on nominations, scheduling, and gas flow. PEC
Pipeline Group and Tenneco Gas assert that implementation of non-
capacity release standards should be determined by the market, not
regulation. Tenneco Gas also states that the industry is working on
standardization related to nominations and that these standards should
be reviewed first before additional standardization is attempted.
Natural seeks clarification that the Commission is not prejudging or
dictating the items to be standardized, but is relying on Working Group
3 to make this determination.
On the other side, NGC and NGSA contend the Working Groups are
deadlocked on whether pipelines should be required to implement the
high priority data elements. They contend the Commission should direct
the pipelines, in conjunction with Working Group 3, to develop an
implementation schedule for all 33 high priority data elements. NGC
suggests that the schedule for the ten high priority items should be
submitted by April 1, 1994 and for the remaining 23 by June 1, 1994.
On March 25, 1994, Working Group 3 filed a consensus agreement
regarding the development of standards for non-capacity release
business transactions. They anticipate completion of 12 upload and
download data sets relating to confirmations and nominations by June 1,
1994.43 At the time of the filing, 55 trading partners, including
a number of pipelines, have committed to begin implementation of these
data sets in June 1994, with pilot testing by December 31, 1994.
Several pipelines and their trading partners are expected to be in full
implementation by January 1995. The Working Group encourages other
industry participants that are EDI capable to support these data sets
by September 1995.
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\4\3These data sets deal with the nomination, the request to
confirm, the confirmation, and the scheduled volumes.
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Working Group 3 anticipates it will complete its consideration of
the other high priority data sets by January 1, 1995, with development
of data sets by January 1, 1996 and implementation within the 6 month
period from January to June, 1996. The Group states this schedule may
be affected by the Group's analysis of the transactions involved and
its evaluation of the use of EDI for capacity release and for
nominations and confirmations.
The consensus of Working Group 3 was that significant and
sufficient progress can be made in developing and implementing these
standards without the Commission mandating implementation. It,
therefore, recommends that the Commission accept the consensus
agreement without mandating compliance with the data sets by the
pipelines.44 The Working Group commits to making quarterly
progress reports, starting July 1, 1994, which will be made available
to the Commission and other interested parties.45
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\4\4If parties are dissatisfied with progress under the
voluntary agreement, they have reserved the right to request
Commission action at a later time.
\4\5Great Lakes filed a comment supporting the Working Group 3
proposal and stated that it will be adding its name to the list of
trading partners intent on meeting the time table set out by the
Working Group.
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Although the Commission began the standardization process with
capacity release, the Commission recognizes that the process now needs
to be expanded to include other business practices in order to
facilitate the movement of gas across multiple pipelines. In addition
to standards governing electronic communication, such standards could
include other business practices, such as standardization of gas days
and nomination times to help shippers schedule deliveries across
multiple pipelines. The Working Group's use of a pilot program,
implemented as quickly as possible, appears to be a worthwhile approach
for assessing the value of proposed standards and approaches, so that
lessons learned can be applied to other areas and the process can move
forward quickly.
At this point, the Commission will honor the consensus agreement of
Working Group 3 and allow the industry to proceed in developing such
standards, without Commission mandate. The Commission applauds the
progress of the industry to date and hopes that a consensus can be
achieved on implementing the nomination/confirmation standards on
schedule as well as implementing the additional proposed standards by
the targeted dates if not earlier. The Commission also recognizes that
other efforts are underway in the industry to standardize business
practices. The Working Group should keep abreast of these developments
and coordinate these efforts. The Commission staff will continue to
actively monitor the Working Group's progress in developing these
standards. Depending on the progress made by the industry in this
endeavor, the Commission will evaluate the need for mandating
compliance with such standards either in this docket or in another
appropriate forum.
VIII. Recovery Of EBB Costs
In Order No. 563, the Commission responded to comments addressing
the mechanism for recovering the costs of standardization. As a general
matter, the Commission stated that its policy of permitting recovery of
fixed costs through a reservation charge and variable costs through a
usage charge was appropriate for the basic EBB service, which would
include the downloadable data sets and communication protocols of this
rule. The Commission stated that these services should be included in
the basic EBB package because they were needed to provide a viable
capacity release market and would provide system-wide benefits to all
users. For enhancements to the basic EBB package, the Commission stated
it was open to cost recovery approaches that would recover fixed costs
from the limited number of users deriving benefit from the service.
KGPC states that EBB implementation and development costs should be
recovered as fixed costs. Columbia Distribution and UDC/AGD, on the
other hand, object to the Commission's statement that the fixed costs
of the basic EBB package should be recovered through reservation
charges. They assert the Commission's statement is at odds with its
statement in the NOPR that it would be open to cost recovery methods
that would spread costs across all those benefitting from the
standards. Edison similarly contends that ``data aggregators''
(companies which are not shippers on pipelines, but which will be
downloading data from multiple EBBs to provide electronic services)
should pay their share of the costs for additional services provided at
their request. All three contend the Commission should adopt a policy
on cost recovery under which the costs would be equitably shared among
all users of EBBs with the precise method of cost allocation determined
in section 4 rate proceedings.
UDC/AGD also request clarification of the criteria the Commission
will use to determine which enhancements are not to be included in the
basic EBB package. They state, for example, that some of the non-
capacity release standards which the Working Groups are developing may
not be of general benefit. KGPC suggests that any standards imposed by
the Commission should be treated as part of the standard EBB service.
Columbia Distribution and UDC/AGD further assert the Commission's
statement on cost recovery could interfere with the development of
alternative cost recovery approaches by the Working Groups, and UDC/AGD
contend that if the Commission does not revisit this issue, it should,
at least, refer the issue to the Working Groups for further
consideration. In contrast, NGSA contends that the method of cost
recovery is a policy issue outside the scope of this proceeding and
that the Working Groups should not be asked to resolve this issue since
they are set up to deal with technical issues.
NGC requests clarification that all cost recovery related to EBBs
will take place in full section 4 rate cases so that savings as well as
costs can be taken into account. NGC further argues that variable costs
should not be recovered through usage charges because a usage charge
ignores the system-wide benefits of EBBs and other forms of electronic
nominations. If the Commission does permit a separate charge for EBB
use, NGC contends the Commission should not permit EDI users to be
singled out for separate charges. NGC maintains that some in the
industry have argued for a separate charge for EDI users because not
all users find EDI suitable. NGC responds that some users find on-line
EBBs equally unsuitable.
As part of the Working Groups 1 & 2 report, position papers were
filed reiterating the points made above. One group46 contends the
interminable debate over the cost issue is impeding the ability of the
Working Groups to complete their work.47 They urge the Commission
to resolve this issue by stating that the cost issue should be left to
section 4 proceedings, and not be considered by the Working Groups.
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\4\6American Iron & Steel Institute, Amoco Production Company,
Chevron U.S.A. Production Company, Conoco Inc., Enron Gas Services,
Gaslantic Corporation, GPM Gas Corporation, Marathon Oil Company,
Natural Gas Clearinghouse, Phillips Petroleum Company, Phillips Gas
Marketing Company, Process Gas Consumers, Texaco Gas Marketing Inc.,
Vastar Gas Marketing, Inc., Virginia Power Company.
\4\7They assert some parties have held up consensus on further
standardization until the group agrees to a cost allocation
statement.
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Another group48 supports an equitable sharing of costs by all
EBB users. They assert that if firm capacity holders are required to
pay all EBB costs through a reservation charge, the firm holders will
be subsidizing other users of the system. They further assert that
having to absorb all EBB costs will place firm users at a competitive
disadvantage compared with brokers and marketers that can obtain the
EBB services at no cost. This group asserts the Commission state that
its policy is to equitably share costs, with the mechanics of the cost
sharing approach to be developed in section 4 cases, in which the
parties could consider a number of options, such as annual user fees or
on-line usage charges.
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\4\8Baltimore Gas & Electric Company, Brooklyn Union Gas
Company, The Columbia Distribution Companies, Consolidated Edison of
New York, New York State Electric & Gas Company, Southern California
Gas Company, United Distribution Companies, Washington Gas Light
Company, American Public Gas Association, Associated Gas
Distributors, and New England Gas Distributor Group.
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The Commission will clarify its position on cost recovery. As
provided in Order No. 636, the recovery of all EBB costs must take
place in a full section 4 rate filing.49 Parties are free in these
proceedings to propose alternative methods of cost recovery.
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\4\9Order No. 636, III FERC Stats. & Regs. Preambles at 30,460;
Order No. 636-A, III FERC Stats. & Regs. Preambles at 30,664.
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The Commission recognizes that those supporting cost sharing raise
a legitimate concern that users should be responsible for paying the
costs that their use imposes on the system. On the other hand, in Order
No. 636-A, the Commission rejected a user fee approach to EBB cost
recovery in favor of a reservation charge approach out of concern about
potential consequences of user fees. The Commission intended EBBs to
provide for wide dispersion of information about capacity availability
as well as information concerning market and system operational
information. In fact, to further the secondary capacity market, the
Commission has sought to remove impediments to the development of
services by third parties that would aggregate information from
multiple pipeline EBBs, thereby improving access to information.50
The Commission, therefore, rejected user fees for EBBs because high
user fees can work to the disadvantage of firm shippers by discouraging
the use of EBBs for capacity release transactions and by providing
advantages to the pipelines' sale of interruptible transportation at
the expense of capacity release.51 Without more detail about how
cost sharing would work, the Commission cannot endorse a policy of
equitable cost sharing at this point. The Commission, however, is not
ruling out adoption of a fully supported and justified proposal of this
nature. At this point, these issues are best examined in the context of
an individual rate case.
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\50\Northwest Pipeline Corporation, 63 FERC 61,124 (1993),
aff'd, 65 FERC 61,007 (1993).
\5\1See Order No. 636-A, III FERC Stats. & Regs. Preambles at
30,563-64 (rejecting user charges for EBB to eliminate advantages
for pipelines' interruptible service); ANR Pipeline Company, 66 FERC
61,335 (1994) (rejecting $50 usage charge).
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Similarly, the Commission does not have sufficient basis to
establish a generic standard for cost recovery for enhancements to the
basic EBB package. All the standards the Commission has adopted are of
sufficient system-wide benefit to be included in the basic EBB package.
Also, as discussed above, the Commission will not be mandating
implementation of the non-capacity release standards proposed by
Working Group 3 at this time. The Working Group is proposing a pilot
program to evaluate its efforts, so an attempt to develop a generic
cost recovery approach for these standards is premature. At this point,
cost recovery for implementation of the standards is best addressed in
individual rate cases.
The Commission agrees with NGSA that cost recovery is a policy
issue that need not be resolved by the Working Groups, and the Working
Groups should not permit debates over cost recovery to side-track them
from their work on developing standards. If parties have developed
concrete proposals for alternate methods of cost recovery for
particular standards, they can submit the proposals in comments on the
Working Group reports or address the issue in individual section 4
cases in which EBB cost recovery is an issue.
List of Subjects in 18 CFR Part 284
Continental shelf, Natural gas, Reporting and recordkeeping
requirements.
In consideration of the foregoing, the Commission denies rehearing
in part, grants rehearing in part, and clarifies Order No. 563 as
described above.
By the Commission.
Lois D. Cashell,
Secretary.
Note: This Appendix will not appear in the Code of Federal
Regulations.
Appendix A--Docket No. RM93-4-001--Parties Filing Requests for Rehearing
and Clarification
------------------------------------------------------------------------
Filer Abbreviation
------------------------------------------------------------------------
ANR Pipeline Company and Colorado ANR/CIG.
Interstate Gas Company.
Arkla Energy Resources Company and AER/MRT.
Mississippi River Transmission
Corporation.
Columbia Gas Distribution Columbia Distribution.
Companies\52\.
Gaslantic Corporation............... Gaslantic.
Interstate Natural Gas Association INGAA.
of America.
Kern River Gas Transmission Company. Kern River.
Koch Gateway Pipeline Company....... KGPC.
National Registry of Capacity Rights National Registry.
Natural Gas Pipeline Company of Natural.
America.
Tenneco Gas......................... Tenneco Gas.
Texas Eastern Transmission PEC Pipeline Group.
Corporation, Panhandle Eastern Pipe
Line Company, Trunkline Gas
Company, and Algonquin Gas
Transmission Company.
Transcontinental Gas Pipe Line TGPL.
Corporation.
United Distribution Companies and UDC/AGD.
Associated Gas Distributors.
Southern California Edison Company.. Edison.
Natural Gas Supply Association...... NGSA.
Texaco Gas Marketing, Inc........... TGMI.
Enron Interstate Pipelines (Northern Enron.
Natural Gas Company, Transwestern
Pipeline Company, and Florida Gas
Transmission Company).
Natural Gas Clearinghouse........... NGC.
Working Groups 1 & 2................ Working groups 1 and 2.
------------------------------------------------------------------------
\52\Columbia Gas of Kentucky, Inc., Columbia Gas of Maryland, Inc.,
Columbia Gas of Ohio, Inc., Columbia Gas of Pennsylvania, Inc., and
Commonwealth Gas Services, Inc.
[FR Doc. 94-10920 Filed 5-5-94; 8:45 am]
BILLING CODE 6717-01-P
