NGSA Lays Out Big Producers/Marketers’ Stake in Gas-Electric Service Harmonization Effort

摘要

The Natural Gas Supply Association (NGSA) last week submitted written comments in response to the Technical Conference (AD12-12) convened by the FERC on April 25 to discuss whether the natural gas and electric industry schedules and practices could be harmonized in order to achieve the most efficient operations for both industries. NGSA holds that policy changes that may occur as a result of this proceeding will have a direct impact on NGSA and its members. NGSA submits that it would be imprudent to eliminate the IT no-bump rule, which plays such a significant and valuable role in the natural gas market, in order to provide limited opportunities for firm capacity holders to expand their firm rights. If any such actions are contemplated, such critical policy decisions should be made only by the Commission, and only after an appropriate notice and comment rulemaking process. Also, additional nomination cycles in the gas day, if not properly implemented, could have unintended consequences. Therefore, any additional standardized nomination cycles should meet key conditions. NGSA also believes that, with appropriate FERC guidance, the gas and power industry segments can find a mutually acceptable time to start the gas flow day.