Storage Reporting INGAA Comments 9-10-04

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.

If the Commission adopts new storage posting requirements to collect aggregate storage inventory data, it should follow as closely as possible the Energy Information Administration’s (“EIA’s”) current reporting requirements for a sample of storage operators chosen by EIA to provide aggregate weekly inventory data on Form EIA-912. Those storage operators subject to the Commission’s jurisdiction could post the same data on their websites at the same time that such data is provided to EIA. In any event, the Commission should, consistent with its Policy Statement on Natural Gas and Electric Price Indices, 104 FERC ¶ 61,121 at P. 37 (2003), establish a “safe harbor” provision under which the Commission will not penalize or prosecute parties for inadvertent errors that occur in the process of following Commission-established reporting procedures. In addition, in order to avoid duplicative or inconsistent reporting, the Commission should take into account that storage fields and reservoirs are subject to a variety of joint ownership and operation forms, and impose the reporting requirements accordingly.