Regulatory Submissions

APGA Joins Comments Letter on Capacity Release Recall Rights as a Result of the Transition from Two to Three Intraday Nomination Cycles 

09-01-2015 04:27 PM

Yesterday, APGA joined the American Gas Association and Interstate Natural Gas Association of America in a comment letter to FERC addressing capacity release recall rights in light of the transition from two to three intraday nomination cycles, established by the Commission’s gas-electric coordination order. In an earlier filing, APGA and the other associations communicated to FERC that “it is not unduly speculative to presume that long-term capacity releases consummated before the April 1, 2016 implementation date for Order No. 809 will contain recall provisions based on the obsolete scheduling timeline and may not function as intended after the new scheduling standards are implemented.” As a result, the comments proposed that the Commission establish default provisions for capacity release transactions with the right to recall capacity that span the April 1, 2016 implementation date. The comments filed yesterday are in response to a July 31, 2015 Order in which requested comments on the Associations’ default proposal. Many of you provided input into whether APGA should join these comments and I want to thank you for your input!

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Associations' Joint Comments 083115 FINAL.PDF   53 KB   1 version
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