A new utility industry construct – the Distribution System Operator (DSO) – could help maximize the benefits of distributed energy resources.
FERC's GulfTerra Orders: Chnages in the Pipeline
- unusual circumstances to prove anomalously high risk.
- Support depreciation rates. Intrastate pipelines may be ordered to use their intrastate depreciation rates when FERC finds NGPA depreciation proposals inadequately supported.
- Remove charitable contributions. Intrastate policy notwithstanding, charitable donations are not valid operating costs for NGPA interstate service.
Rate Design Issues
- State gathering separately. FERC's lodestar is to avoid disadvantaging customers wanting to buy gas off-system that only need to pay the transmission service rate.
- Reflect cost variations for distance of haul. Previous mileage-sensitive intrastate ratemaking can create a presumption for NGPA interstate service rates.
- Meet the heavier burden to justify affiliate discounts. Identify service alternatives for affiliates. Compare rates at affiliate and non-affiliate receipt and delivery points. Show that basis differentials determine contract rates.
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