RCP Inc.

Search Open Menu

In This Issue

  1. Who is RCP?
  2. Final NPDES Exemption for Oil and Gas Exploration, Production, Processing, or Treatment Operations or Transmission Facilities
  3. New Offshore Discharge Reporting Form
  4. Texas Pipeline Integrity Management – Proposed Revisions
  5. Will your SPCC Plan pass an EPA inspection based on the new SPCC Inspectors’ Guidance document?
  6. Updates to Standards “Incorporated by Reference”
  7. Public Awareness Plans
  8. Gas Integrity Management – 7 year Re-assessment FAQs
  9. Reporting of Damage to Natural Gas Pipeline Facilities to FERC
  10. FERC Policy Statement on Natural Gas Interchangeability
  11. Minerals Management Service Seeks Comments
  12. Need to Update Your Current Operator Qualification Program?
  13. MMS Proposed Changes to ROW Pipeline Requirements

FERC Policy Statement on Natural Gas Interchangeability

Docket No. PL04-3-000

The Federal Energy Regulatory Commission has seen interest in natural gas quality and interchangeability issues escalate for several years, and these issues have come before the Commission in complaints, proposed tariff provisions and certificate proceedings. Historically, gas quality is one of many terms and conditions of service stated in individual pipelines’ FERC-jurisdictional tariffs. The Commission has no generic policy in this area, and individual pipelines have different standards, practices, and enforcement mechanisms.

On June 15, 2006, FERC announced its policy on natural gas quality and interchangeability issues. The Commission’s intention in issuing this statement of generic policy is to provide direction for addressing gas quality and interchangeability concerns, as well as to provide guidance to individual companies that have concerns about these issues. The Commission’s policy embodies five principles:

  1. Only natural gas quality and interchangeability specifications contained in a Commission-approved gas tariff can be enforced
  2. pipeline tariff provisions on gas quality and interchangeability need to be flexible to allow pipelines to balance safety and reliability concerns with the importance of maximizing supply, as well as recognizing the evolving nature of the science underlying gas quality and interchangeability specifications
  3. pipelines and their customers should develop gas quality and interchangeability specifications based on technical requirements
  4. in negotiating technically based solutions, pipelines and their customers are strongly encouraged to use the Natural Gas Council Plus (NGC+) interim guidelines filed with the Commission on February 28, 2005 as a common reference point for resolving gas quality and interchangeability issues
  5. to the extent pipelines and their customers cannot resolve disputes over gas quality and interchangeability, those disputes can be brought before the Commission to be resolved on a case-by-case basis, on a record of fact and technical review