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As reported previously (article in June 2014 , and article in July 2014 ), PG&E's California Gas Transmission has been very involved in the FERC Notice of Proposed Rulemaking (RM14-2-000) related to the start of the Gas Day and changes to the nomination cycles.

On November 28, 2014, the Coalition for Enhanced Electric and Gas Reliability filed comments with FERC in opposition to FERC's proposal to move the start of the national Gas Day to 4:00 a.m. Central Time (2:00 a.m. Pacific Time) from the current 9:00 a.m. CT (7:00 a.m. PT). CGT took a leadership role in organizing the Coalition comments.

Approximately 80 companies from all over the United States and Canada, both gas and electric companies representing over 25% of all U.S. gas and electric customers, joined PG&E in raising safety, reliability and affordability concerns.

Safety concerns focused on asking operators to perform field activities in the middle of the night when access may be difficult, and, as scientifically proven, the time of day of least human awareness and alertness. Reliability concerns focused on uncertainty that not all operators may make the middle of the night changes (commensurate with the start of the upcoming Gas Day) and the impact this may have on local distribution companies like PG&E that have to meet and manage customer consumption.

PG&E also filed its own comments that detailed specific impacts on PG&E facilities.

The Coalition comments did support expansion and revision of the gas nomination opportunities (including adding an additional intraday nomination cycle) as proposed by the North American Energy Standards Board (NAESB).

In total, approximately 75 parties filed comments with FERC. There is no deadline for FERC to take action. Implementation of a new time for the start of the Gas Day, if a change is made, will likely be no earlier than winter of 2015 - 2016.

If you have questions about these filings, please contact Don Petersen (925.244.3542).