Transco's Y2K Plan Under Fire
Transcontinental Gas Pipe Line's Y2K contingency plan to have
transportation nominations for the first seven days of the new year
submitted in advance by Dec. 28 has caused concern among some of
Transco filed the request for a limited waiver of tariff
provisions and FERC regulations on Sept. 2, asking the Commission
to allow it to require all of its shippers to provide gas
nominations for the first week in January no later than 5 p.m. CDT
on Dec. 28. Transco said it intends to use the nominations in the
event of a communications failure.
While applauding Transco's foresight, Dynegy requested the
Commission require the pipeline to waive imbalance penalties during
the period and perform "after-the-fact reallocation" to match
scheduled capacity with actual shipper use in order to ensure that
penalties will not apply for the contingency period.
The proposal "fails to designate how imbalance penalties
associated with standing gas nominations will be handled...
Ordinarily, shippers would have the opportunity to manage their
imbalances through intra-day nominations to ensure service is
sustained and would likely utilize the intra-day nominations
opportunity to the fullest extent during this very volatile week of
the year," said Dynegy. "In the event Transco must move to its
contingency plan, however, a shipper's hands will be tied with
respect to its ability to manage imbalances."
Florida Gas Transmission said if the Commission approves
Transco's plan, FGT wants no part in it because its automated
nomination, confirmation and scheduling system simply can't handle
advance nominations. FGT is joint owner with Transco of the Mobile
Bay Onshore Pipeline, which Transco operates, and FGT transports
309,000 Mcf/d on MBP. FGT also nominates gas transportation
requirements to Transco on behalf of its customers. In addition,
FGT has three other interconnects with Transco and receives and
additional 140,000 MMBtu/d at those points.
"The FGT system overrides earlier nominations when customers
submit more current nominations each day. Thus the one-time,
seven-day nomination proposed by Transco cannot be retained in the
FGT system," the pipeline said. To implement a change in the FGT
system would be too expensive, the company added. Besides, FGT
doesn't think it's necessary for its relationship with Transco. In
the event of a communications failure FGT said it could "hand
deliver nominations" because it's located in the same city.
Furthermore, to require its shippers to predict seven days of
gas needs is ludicrous, according to FGT, particularly during a
peak winter period. It would be more reflective of customers' needs
to simply rely on their most recently scheduled nominations, FGT
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