TULSA, Okla. (Nov. 26, 2014) - The Gas Processors Association (GPA) today filed comments with the Federal Energy Regulatory Commission (FERC), supporting the commission’s efforts to increase coordination between the natural gas and electric industries but opposing the proposed change to the start of the natural gas operating day (gas day).
FERC issued a notice of proposed rulemaking in late March, proposing to amend FERC Regulation 284.12. The proposed changes include moving the start of the gas day from 9 a.m. (Central time zone) to 4 a.m., which GPA says will negatively impact operational and commercial areas of companies in the midstream energy sector.
In its comments, GPA urged the commission to evaluate evidence of the risks to both safety and reliable service.
“Numerous studies have shown that the risk of workplace accidents is greatest when workers are compelled to work unusual hours,” the GPA comments said. “With a 4 a.m. gas day start, there would be an increased need for workers to operate on unusual schedules and in the dark, increasing the risk that fatigue could result in errors while traveling to a remote location or performing manual tasks.”
GPA also said the issue of reliability cannot be separated from the safety issue. Before the start of the gas day, GPA members often conduct a validation by schedulers with field employees and gas control regarding expected flow rates, but the scheduling and marketing employees may not be available before 4 a.m. to validate and adjust volumes based on current conditions. That lack of availability can create a number of issues, including potential outages.
“GPA also has concerns regarding the impacts of the proposed change in gas day on emergency operations. For example, in a significant winter weather event when the need for reliable delivery of natural gas is at its highest, access to facilities may be more difficult at 4 a.m. compared with later in the day,” the comments stated.
GPA explained that many of its member companies’ gathering facilities are in remote locations requiring manual intervention in emergency situations, which means their workers would have to drive to those locations between midnight and 3 a.m., deemed “the most dangerous hours” by the Department of Transportation.
FERC’s proposal would also impact midstream companies’ commercial operations, requiring changes to literally thousands of contracts.
“Many contracts relating to gathering, processing and intrastate transmission specify a 9 a.m. start of the gas day in the contract. Since these contracts are not subject to FERC’s jurisdiction, they cannot be modified by a change in the commission’s regulations. They would each have to be renegotiated,” GPA explained.
GPA encouraged the commission to gather more data before implementing a change to the start of the gas day.
“Our members’ biggest concern, and the same concern of our industry as a whole, is maintaining public and employee safety,” said GPA President and CEO Mark Sutton. “Right behind safety is providing reliable service. We’re asking the commission to take a much closer look at the risks associated with both and approach any changes to something that has been successful for many years with caution.”
The Gas Processors Association (GPA) has served the U.S. energy industry since 1921 as an incorporated non-profit trade association. GPA is composed of 130 corporate members that are engaged in the gathering and processing of natural gas into merchantable pipeline gas, commonly referred to in the industry as "midstream activities." Such processing includes the removal of impurities from the raw gas stream produced at the wellhead, as well as the extraction for sale of natural gas liquid products (NGLs) such as ethane, propane, butane and natural gasoline. GPA members account for more than 90 percent of the NGLs produced in the United States from natural gas processing.