|Natural Gas Technical Conference|
The Commission will convene a natural gas technical conference on March 29, 2018, at its Harrisburg office pertaining to prior proposals on accelerated switching as well as utility business practices, including capacity release, penalties and imbalance trading. Multiple commenting parties to the proposals requested a technical conference to discuss the proposals.
The following key topic areas have been identified for discussion:
"Accelerating NGS Switching
1. Gas Nomination Process/wholesale market FERC rules. Procedures that place NGDCs in the middle of transactions between NGSs potentially violate FERC "shipper must have title" rules?
2. Impact on demand curves, capacity assignment, pricing, etc. Need for daily changes?
3. The use of estimated and customer-supplied meter reads.
4. Different standards/timeframes for different NGDCs? Different rate classes?
5. To what extent are technical concerns alleviated if limitations are imposed (i.e., one switch per billing cycle)?
1. PTC impacts/presentation.
2. Experience in other states (New York, Virginia).
3. Does this shift competition (i.e., removes capacity from competition)?
4. Suppliers benefiting from capacity they didn't pay for/double dipping if the NGDC sells capacity?
5. Auditing issue - PGC/GCR true-up problems.
6. Potential FERC problems - must pay for capacity.
1. "Slice of the pie" concept:
a. How to handle the limitations or are NGDCs' workarounds good enough?
b. Capacity should be able to serve the customer it's released for.
2. Virtualization is a "step backwards"?
3. Virtualization reduces the value of the asset?
Daily Imbalance Trading
1. What technological features are needed to make this work like an electronic bulletin board?
2. Is upstream trading sufficient or do we need some on the NGDC system?
3. Is lack of communication the bigger issue here?
4. Introduces a reliability risk rather than a benefit?
5. Impact to interruptible customers and other rate classes.
Penalties - During non-emergency conditions
1. Market Based versus flat fee.
a. At what fee level and does there have to be a minimum level?
b. Should there be safe harbors when it benefits the system?
c. Tier approach based upon?
2. Can it be pegged to a local hub for each NGDC? Multiple hubs for different areas, etc.? Some NGDCs have widely scattered service territories.
3. Interruptible constraints and problems.
4. Impact of tolerance bands within a penalty structure."
RSVPs for the event are due by March 14, 2018, to RA-OCMO@pa.gov. The full text of the Secretarial Letter is available on the NEM Website.