Without storage data from the non-jurisdictional intrastate, LDC, and independent storage operators, which control almost one half the national inventory, there would be a substantial defect in the data base. In addition, daily storage data, unlike longer-term data, is vulnerable to significant and unrepresentative day-to-day fluctuations. Therefore, from the perspective of the natural gas market, the daily reporting of such data could lead to even greater market volatility, to the detriment of gas users. Moreover, while the Commission correctly states that electronic metering permits rapid posting of daily storage data, not all storage operators have such capability, and the cost of installing such equipment would likely outweigh any benefits.
From the perspective of pipeline transportation and storage customers, there does not appear to be any problem with the existing storage reporting requirements under the Commission’s regulations at 18 CFR § 284.13(d) that would warrant a change at this time.