kmi ( ngpl ) order 637 changes protested note : see gas quality section at the bottom that they propose adding on
their other pipelines , like they have
on ngpl .
shippers protest kmi ' s order 637 tariff changes
kinder morgan interstate gas transmission ( kmi ) has attempted an end run
around ferc ' s order 637 ,
filing wide - ranging operational and rate changes early under expedited tariff
procedures to avoid the
more rigorous review in store for compliance filings , according to customer
protests .
items in kmi ' s tariff filing fall into no less than 13 general categories ,
indicated shippers said . they include
imbalance provisions , storage balances , small customer service , gas quality ,
point allocations , curtailment
priorities , right of first refusal , scheduling priorities , incidental
purchase and sale , capacity release ,
unauthorized gas , capacity rights overrun charge , and miscellaneous .
indicated shippers called for summary rejection or maximum suspension of
kmi ' s june 5 tariff filing ( rpo 0 - 316 ) ,
saying " most of the changes proposed in this case represent an effort by kmi
to implement elements of
order 637 selectively and in a manner designed to minimize the opportunity
for meaningful review and
comment by kmi ' s customers . " only 12 days are allowed for intervention and
comment on usually routine
tariff filings , while the federal energy regulatory commission has allotted
30 days for comments on
order 637 compliance filings . kmi was among the group of pipelines slated to
make compliance filings june 15 .
kmi said its filing did not constitute its compliance filing , but was aimed
at changing its tariff to reflect " the
current natural gas business climate and evolving business practices . . " it
did acknowledge , " a number of the
changes proposed herein are consistent with and advance the commission ' s
goals in order no . 637 . "
indicated shippers also protested changes that would make decisions regarding
negative storage imbalances
and end of season inventory swaps a matter of kmi ' s discretion without any
standards on how those decisions
would be made . the shippers also protested changes to the default methodology
for point allocations for billing
purposes , and the injection of kmi discretion into the formula for accepting
or rejecting predetermined allocation
agreements with upstream or downstream parties . in addition curtailment
provisions filed by kmi appear to be
contrary to order 637 - a ' s mandate that shippers moving gas within the primary
path should have primary rights .
the filing also would give the pipeline the opportunity to bottle up
significant quantities of coal bed methane gas
in wyoming ' s powder river basin by imposing more rigorous standards on
nitrogen content , according to
western gas resources . a key change would impose a nitrogen gas quality
specification of 3 % by volume .
while kmi states the change is necessary to accommodate transfers with
interconnecting pipelines , six of the
seven connecting pipelines identified have no nitrogen specifications . only
kmi ' s affiliate , natural gas
pipeline co . of america , has similar rules , western gas said .
" kmi ' s proposed nitrogen specification would enable kmi to refuse to accept
coal bed methane production for
transportation , thereby foreclosing the availability of one of the principal
means of downstream pipeline egress
out of powder river production areas , " western gas added . producers would
have to shut in production while
they construct costly nitrogen facilities . this could " create at least a
temporary gap in the downstream
movement of coal bed supplies to mid - continent and eastern markets , thus
frustrating consumer access to
these significant supplies . "
- -
kmi ( ngpl ) order 637 changes protested
note : see gas quality section at the bottom that they propose adding on
their other pipelines , like they have
on ngpl .
shippers protest kmi ' s order 637 tariff changes
kinder morgan interstate gas transmission ( kmi ) has attempted an end run
around ferc ' s order 637 ,
filing wide - ranging operational and rate changes early under expedited tariff
procedures to avoid the
more rigorous review in store for compliance filings , according to customer
protests .
items in kmi ' s tariff filing fall into no less than 13 general categories ,
indicated shippers said . they include
imbalance provisions , storage balances , small customer service , gas quality ,
point allocations , curtailment
priorities , right of first refusal , scheduling priorities , incidental
purchase and sale , capacity release ,
unauthorized gas , capacity rights overrun charge , and miscellaneous .
indicated shippers called for summary rejection or maximum suspension of
kmi ' s june 5 tariff filing ( rpo 0 - 316 ) ,
saying " most of the changes proposed in this case represent an effort by kmi
to implement elements of
order 637 selectively and in a manner designed to minimize the opportunity
for meaningful review and
comment by kmi ' s customers . " only 12 days are allowed for intervention and
comment on usually routine
tariff filings , while the federal energy regulatory commission has allotted
30 days for comments on
order 637 compliance filings . kmi was among the group of pipelines slated to
make compliance filings june 15 .
kmi said its filing did not constitute its compliance filing , but was aimed
at changing its tariff to reflect " the
current natural gas business climate and evolving business practices . . " it
did acknowledge , " a number of the
changes proposed herein are consistent with and advance the commission ' s
goals in order no . 637 . "
indicated shippers also protested changes that would make decisions regarding
negative storage imbalances
and end of season inventory swaps a matter of kmi ' s discretion without any
standards on how those decisions
would be made . the shippers also protested changes to the default methodology
for point allocations for billing
purposes , and the injection of kmi discretion into the formula for accepting
or rejecting predetermined allocation
agreements with upstream or downstream parties . in addition curtailment
provisions filed by kmi appear to be
contrary to order 637 - a ' s mandate that shippers moving gas within the primary
path should have primary rights .
the filing also would give the pipeline the opportunity to bottle up
significant quantities of coal bed methane gas
in wyoming ' s powder river basin by imposing more rigorous standards on
nitrogen content , according to
western gas resources . a key change would impose a nitrogen gas quality
specification of 3 % by volume .
while kmi states the change is necessary to accommodate transfers with
interconnecting pipelines , six of the
seven connecting pipelines identified have no nitrogen specifications . only
kmi ' s affiliate , natural gas
pipeline co . of america , has similar rules , western gas said .
" kmi ' s proposed nitrogen specification would enable kmi to refuse to accept
coal bed methane production for
transportation , thereby foreclosing the availability of one of the principal
means of downstream pipeline egress
out of powder river production areas , " western gas added . producers would
have to shut in production while
they construct costly nitrogen facilities . this could " create at least a
temporary gap in the downstream
movement of coal bed supplies to mid - continent and eastern markets , thus
frustrating consumer access to
these significant supplies . "
- -