FERC Proposal to Change Gas Day and Gas Nomination Cycles

Wednesday, June 18, 2014

On March 20, 2014, FERC issued a proposed rulemaking This link will open in a new window that would change the start of the Gas Day from the current 9:00 a.m., Central time (7:00 a.m., Pacific time) to 4:00 a.m., CT (2:00 a.m., PT). FERC also proposed to alter the nomination cycle times and add two additional intraday cycles.

FERC invited the North American Energy Standards Board (NAESB) to consider alternatives. Comments on any such alternatives as well as on FERC's Notice of Proposed Rulemaking (NOPR) are due by November 28, 2014. Although PG&E's California Gas Transmission is not regulated by FERC, we plan to comply with the ultimate resolution of start-of-the-Gas-Day and nomination cycle decisions.

That being said, CGT has serious safety and operational concerns with starting the Gas Day in the middle of the night (i.e., 2:00 a.m., PT). As part of its work with Control Room Management Standards, the federal Pipeline and Hazardous Material Safety Administration (PHMSA) has identified that 2:00 a.m. to 5:00 a.m. is the period of least human alertness. If activities in that time frame can be avoided, it is advisable.

Many of CGT's facilities require manual operations and having crews set up a new gas day at that time (e.g., switching a storage facility from injection to withdrawal) is unwise and increases the pipeline safety risk. Moreover, CGT's system can be packing during this time period in anticipation of the morning gas load and may not be able to accept increased nominations beginning at 2:00 a.m. In essence, this is the period of the least operational flexibility.

NAESB recently ended six weeks of intensive review and concluded that no change to the Gas Day was preferred. CGT helped coordinate a strong western coalition opposing a change to 4:00 a.m, CT (2:00 a.m., PT). While preferring the status quo, coalition members were nevertheless willing to compromise on the start of the Gas Day to 7:00 a.m. CT (5:00 a.m. PT) but not all participants reacted favorably.

NAESB is continuing with a separate effort to explore nomination cycle changes and is scheduled to conclude its work by September 29, 2014. Based on discussions to-date, it appears there is strong support for adding a third intraday cycle, as well as delaying the Timely Cycle deadline by an hour and a half.

CGT is continuing to work to build consensus on these issues, both nationally and within California. We would welcome the opportunity to engage in dialogue with you. Please contact Don Petersen (925.244.3542).

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