Mirroring an earlier complaint brought against Trunkline Pipeline, a group of natural gas producers and marketers called on FERC last week to order El Paso’s Tennessee Pipeline and Columbia Gulf Transmission to “discontinue immediately” their alleged practice of using multi-year “critical notices” to enforce tougher quality specifications on the gas that they will accept into their systems.

In two separate complaints filed at the agency, producers and marketers accused both pipelines of bypassing FERC regulations and the Natural Gas Act (NGA), which require pipelines to get Commission approval before making make changes to the gas quality specifications in their tariffs. The complainants included BP America Production Co., BP Energy Co., ChevronTexaco Exploration & Production, ExxonMobil Gas & Power Marketing, Shell Offshore Inc. and ConocoPhillips Co.

They contend that Tennessee unilaterally has imposed a strict hydrocarbon dew point (HDP) limit on gas entering its system through the use of multi-year “critical notices,” when the “authority to impose an HDP limit is not provided for in [the pipe’s] FERC gas tariff.” Similarly, producers and marketers complain that Columbia Gulf has required a Btu limit (not more than 1,050 Btu) for gas entering its system through the use of multi-year “critical notices,” although this authority is not specified in its FERC gas tariff [RP04-98].

The first documented “critical notice” of a lower HDP limit on Tennessee appeared on Oct. 17, 2001, and has been in “continuous effect” since then, according to the group. On that date, Tennessee reduced its HDP limit for gas upstream of Station 87 to 20 degrees Fahrenheit from 30 degrees Fahrenheit, the producers and marketers said [RP04-99]. They argued that the critical notice on Columbia Gulf limiting the Btu content of gas has in effect become a “perpetual critical notice,” too.

They urged the Commission to respond to both complaints on a fast-track basis to “avoid a shut-in or other impediments that would keep gas supply from the market.”

In a similar complaint brought in late November, BP America Production, BP Energy and ChevronTexaco Natural Gas called on FERC to order Trunkline, a Southern Union pipeline, to “cease and desist” from its alleged practice of posting multi-year “critical notices” to lower the heating value of the gas that it will accept into its system (see NGI, Dec. 1)

At issue in that case was a critical notice that was first posted by Trunkline on Jan. 26, 2001, and still remains in effect today, the producers said. The critical notice reduced the heating value of the gas Trunkline would accept to 1,050 Btu, while the pipeline’s tariff on file at the agency put the upper Btu limit at 1,200 Btu, they noted [RP04-64]

The gas quality issue is likely to become more contentious as more high-Btu regasified LNG enters the U.S. gas system (see NGI, Oct. 20). Several of the complainants are planning LNG import projects.

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