UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
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1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Commissioner Philip D. Moeller s Inquiry into ) The Trading of Natural Gas, and the Proposal ) Docket No. AD To Establish an Electronic Information and ) Trading Platform ) COMMENTS OF SPECTRA ENERGY PARTNERS, LP Pursuant to the Post-Meeting Notice issued by the Federal Energy Regulatory Commission ( Commission ) on September 19, 2014 in the captioned-docket, Spectra Energy Partners, LP, on behalf of its interstate natural gas pipelines ( Spectra Energy ) hereby submits comments regarding the proposals discussed during the September 18, 2014 meeting held by Commissioner Philip D. Moeller. Spectra Energy also supports the comments filed by the Interstate Natural Gas Association of America ( INGAA ) in this proceeding. I. CORRESPONDENCE AND COMMUNICATIONS *Richard J. Kruse Vice President, Regulatory Phone: (713) rjkruse@spectraenergy.com *Jennifer R. Rinker Senior Counsel Phone: (713) jrinker@spectraenergy.com Janice K. Devers General Manager Tariffs and Commercial Development Phone: (713) jkdevers@spectraenergy.com service list. *Spectra Energy requests that these persons be included on the Commission s official
2 II. COMMENTS Spectra Energy believes the key to serving the emerging needs of the electric industry is to develop specialized tools tailored to the needs of the electric market while preserving traditional services that were developed for local distribution companies and industrial users. Spectra Energy has been successful in marketing firm capacity to traditional integrated electric utilities; however, selling firm services to markets in the Mid-Atlantic and Northeast, where gasfired electric generation demand is rapidly increasing, has been particularly challenging. Spectra Energy s experience in developing customized services for various markets, such as no-notice service with firm and interruptible non-rateable flows and additional nomination cycles, demonstrates that pipelines and generators can work together within the existing industry structure and without Commission-mandated changes to homogenize services across the interstate pipeline industry. To that end, Spectra Energy supports the comments filed by INGAA. Among other points, INGAA notes that some pipelines, such as the Spectra Energy pipelines, already provide the additional nomination opportunities beyond the standard NAESB timeline requested by the electric generators, but that the entire process cannot be fully automated. INGAA s point that the nomination and scheduling process on pipelines cannot be automated is an important one. Spectra Energy has invested significantly in resources to support additional nomination opportunities, but the process of scheduling is so complex that it continues to require personal input and oversight. In addition to being expensive, transitioning to fully automated scheduling among all pipelines, as suggested at the September 18 meeting, would require eliminating many of the inputs to the scheduling process, including potentially eliminating specialized services that pipelines have developed. Spectra Energy believes the better answer is to develop more tools for 2
3 electric generators, rather than eliminating customized tools already in place through automation and homogenization of services. Spectra Energy has proposed innovative services that specifically support electric generation in the Northeast. When approved by FERC, these new services will meet the needs of the electric market. For example, Rate Schedule ERS (Electric Reliability Service) is a new type of no-notice service that will be included as part of the Access Northeast Project (a joint venture between Algonquin Gas Transmission, LLC and Northeast Utilities). 1 Under this rate schedule, which would operate in tandem with regional storage facilities, a customer s full maximum daily transportation quantity can be delivered non-ratably, as primary firm deliveries, at any time. Algonquin processes nominations on an hourly basis, as discussed below, which will allow generators receiving service Rate Schedule ERS to access capacity at critical junctures, manage gas flow in response to increases in demand, and optimize the capacity when unneeded. The Multi-shipper Option Agreement ( MSOA ), also offered as part of the Access Northeast Project, would work in conjunction with a firm transportation service agreement to allow multiple shippers to share a single contract, with one designated contract administrator who manages the collective capacity. MSOAs can be used to ensure maximum efficiency in terms of pipeline capacity utilization and the sculpting of service to generation demand, since MSOA customers have access to pipeline capacity on a firm basis, with the flexibility to allow increased or decreased flows based on need and the availability of capacity under the MSOA through hourly nominations. During periods when the generators demand for gas is lower, the contract administrator can optimize the unneeded capacity, such as through a capacity release. By permitting both shared capacity and specialized no-notice service, Spectra Energy believes it 1 The specialized no-notice service in Rate Schedule ERS will be in addition to the no-notice services already offered by the Spectra Energy pipelines. More information about Rate Schedule ERS is available at 3
4 can accommodate generators stated desire for additional flexibility through nominations and non-ratable flows without the need for radical changes to operations across the interstate pipeline industry. In addition to these services targeted at the electric generation market, the Spectra Energy pipelines offer scheduling and nominations processes that currently meet the specific requirements identified by electric generators at the September 18 meeting. Each of the Spectra Energy pipelines offers additional nomination opportunities, rather than just the four nomination periods under the NAESB guidelines. Over the period leading up to the gas day and during the gas day itself, then, customers of Spectra Energy pipelines have as many as 42 opportunities to submit nominations for validation and scheduling. Certain Spectra Energy pipelines also permit customers to enter retroactive adjustments to nominations up to three days after the relevant gas day. The Spectra Energy pipelines have also constructed facilities for customers who need firm non-ratable flows, such as that sought by electric generators. As part of the New Jersey- New York Project, Texas Eastern constructed facilities that allow a customer to flow up to 1/20 th of its daily nomination in any hour and as little as 1/27 th of its daily nomination in an hour on a firm basis, subject to certain usage limitations to ensure a balanced daily flow. Customers on Texas Eastern s Freehold Lateral enjoy similar non-ratable flow rights. On all of its pipelines, Spectra Energy permits non-ratable flows on an interruptible basis on facilities not specifically designed to provide such service on a firm basis. The service flexibility and capacity utilization tools available from the Spectra Energy pipelines in the Northeast demonstrate Spectra Energy s commitment to be responsive to the needs of electric generators. Nevertheless, customized services offered by pipelines are 4
5 supported by infrastructure which in turn requires long-term contractual support from customers. Certain comments from parties that are seeking specialized firm services suggest that they are only willing to pay for service on an interruptible basis. However, pipelines cannot be expected to provide infrastructure enhancements and additional services, such as virtually unlimited hourly swing rights, without executing contracts for long-term service at rates that can support the infrastructure underlying such services. The non-ratable flow entitlements on the New Jersey-New York Project and the Freehold Lateral, for example, were developed based on the willingness of customers to pay for the additional facilities that provide for such service on a firm basis. Similarly, Rate Schedule ERS will rely on access to regional storage facilities to support the no-notice service, which in turn must be backed by customer contracts. Spectra Energy remains committed to developing services and facilities that can deliver the needed flexibility for generators, but the generators likewise must be willing to contract for these services, such as through the Access Northeast Project. III. CONCLUSION Spectra Energy supports the comments filed in this docket by INGAA. Spectra Energy and its pipelines have demonstrated that the pipeline industry has the ability to meet the needs of the electric generation market through innovative services backed by the appropriate facilities and scheduling/nomination flexibility on their systems, and without Commission-mandated changes to the interstate pipeline industry. Respectfully submitted, October 1, 2014 /s/ Jennifer R. Rinker Jennifer R. Rinker Senior Counsel 5
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