Comments of the Interstate Natural Gas Association of America under RM14-2.

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Coordination of the Scheduling Processes of ) Interstate Natural Gas Pipelines and ) Docket No. RM14-2-000 Public Utilities ) COMMENTS OF THE INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA The Interstate Natural Gas Association of America (INGAA) submits these comments in response to the Federal Energy Regulatory Commissions (FERC or Commission) March 20, 2014 Notice of Proposed Rulemaking (NOPR) on coordination of scheduling processes of interstate natural gas pipelines and public utilities in the above-referenced docket.1 INGAA is a trade organization that advocates regulatory and legislative positions of importance to the natural gas pipeline industry in North America. INGAA is comprised of 25 members, representing the vast majority of the interstate natural gas transmission pipeline companies in the United States and comparable companies in Canada. Its United States members are regulated by the Commission pursuant to the Natural Gas Act (NGA), 15 U.S.C. 717-717w. INGAAs members, which operate approximately 200,000 miles of pipelines, provide an indispensable link between natural gas producers and natural gas consumers in the residential, commercial, industrial and electric power sectors. INGAAs members are committed to providing safe and reliable transportation services to their diverse customers, without undue discrimination, and to maintaining a high level of customer service. 1 Coordination of the Scheduling Practices of Interstate Natural Gas Pipelines and Public Utilities, Notice of Proposed Rulemaking, 79 Fed. Reg. 18223 (2014), FERC Stats. & Regs., Proposed Regs. 32,700 (2012). I. EXECUTIVE SUMMARY INGAA strongly supports the proposed modifications to the gas scheduling timeline developed by the North American Energy Standards Board (NAESB), as set forth in the filing submitted by NAESB on September 29, 2014, in this proceeding. This revised scheduling timeline will provide electric generators greater opportunity to participate in the Timely Cycle as well as manage and respond to load variations during the operating day by adding an additional intraday cycle. INGAA does not support the Commissions proposal to move the start of the Gas Day to 4:00 a.m. Central Clock Time (CCT). Instead, INGAA supports retaining the current 9:00 a.m. CCT Gas Day. The reasoning behind the Commissions proposal to move the start of the Gas Day is legally deficient under the Administrative Procedure Act (APA). Moreover, INGAA does not believe that the Commission can sustain its burden of proof under section 5 of the NGA to show that the existing 9:00 a.m. CCT Gas Day start is unjust and unreasonable. If the Commission decides that changes to the start ...