FERC Commences 4 New Electric Audits and Issues 41 Final Gas Audit Reports

In a very busy December, the Division of Audits in the Federal Energy Regulatory Commission’s Office of Enforcement issued four electric audit commencement letters on December 21.  It also issued final audit reports for twenty audits on December 10 and twenty-one audits on December 14 relating to compliance with the Commission’s gas regulations under 18 C.F.R. Part 284 (2009) and North American Energy Standards Board (NAESB) Wholesale Gas Quadrant (WGQ) Standards Version 1.8.

New Electric Audits:

Three of the four audits commenced on December 21, 2010 will evaluate compliance with the conditions established when the Commission granted the audit targets transmission rate incentives.  This is the first time the Commission has evaluated compliance with these requirements. If it identifies any common findings, it will likely commence additional audits.  The fourth audit is unusual in that it targets a company and its demand response and efficiency resources within ISO New England, Inc. and New York Independent System Operator, Inc.  A brief summary of these audits follows:

• PA11-11-000:  The Division of Audits will evaluate whether Xcel Energy Services, Inc. complies with: (1) the Commission’s regulations under 18 C.F.R. § 35 (2010), which govern incentive-based rate treatments for transmission investments; (2) Order Nos. 679 and 679-A; (3) the conditions established in the Commission’s December 21, 2007 order in Docket No. ER07-1415; and (4) FERC-730 reporting and filing requirements.
• PA11-13-000:  The Division of Audits will determine whether Northeast Utilities Service Company (NUSCO) complies with: (1) the Commission’s regulations under 18 C.F.R. § 35 (2010), which govern incentive-based rate treatments for transmission investments; (2) Order Nos. 679 and 679-A; (3) the conditions established in the Commission’s July 17, 2008 order in Docket No. ER08-966; (4) FERC-730 reporting and filing requirements; (5) the requirements of its market-based rate authorization; and (6) Electric Quarterly Report (EQR) filing requirements.
• PA11-14-000:  The Division of Audits will evaluate whether whether ITC Great Plains, LLC complies with: (1) the Commission’s regulations under 18 C.F.R. § 35 (2010), which govern incentive-based rate treatments for transmission investments; (2) Order Nos. 679 and 679-A; (3) the conditions established in the Commission’s March 16, 2009 order in Docket No. ER09-548; and (4) FERC-730 reporting and filing requirements.
• PA11-20-000:  The Division of Audits will evaluate EnerNOC’s compliance, as a market participant, with ISO-NE’s Markets and Services Tariff, NYISO’s Open Access Transmission Tariff, and NYISO’s Market Administration and Control Area Services Tariff.   Specifically, it will focus on tariff provisions relevant to EnerNOC’s participation in the capacity markets and other demand response programs within ISO-NE and NYISO.  The audit will include selective tests of customers for which EnerNOC registered into demand response and efficiency programs.

Final Gas Audit Reports:

The Division of Audits completed forty-one audits in which it evaluated whether informational postings on the audit target’s web site complied with Commission regulations under 18 C.F.R. Part 284 (2009) and North American Energy Standards Board (NAESB) Wholesale Gas Quadrant (WGQ) Standards Version 1.8.  In these audits, Audit Staff determined that, with one exception, the audit targets did not post all required information on their informational postings web sites.  In response to the findings, the Division of Audits made three recommendations.  First, it recommended that each company establish procedures to ensure that its informational postings web site adheres to Commission regulations and NAESB standards for informational postings.  Second, it recommended that each company review and correct the identified errors.  And finally, it recommended that each company review all public and nonpublic web site postings for compliance with Commission regulations and NAESB standards.

A brief summary of the findings in each audit follows:

• PA10-46-000:  In its audit of Dominion Cove Point LNG, LP, Audit Staff identified 24 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards.  These errors involved two categories: missing or incorrect data field labels and the use of an incorrect code value. During the audit, Cove Point corrected all 24 posting errors.
• PA10-36-000:  In its audit of CenterPoint Energy – Mississippi River Transmission Corporation, Audit Staff identified 15 posting errors relating to NAESB’s capacity release standards. These errors involved missing and incorrect data labels. During the audit, MRT corrected all 15 posting errors.
• PA10-37-000:  In its audit of CenterPoint Energy Gas Transmission Company, Audit Staff identified 15 posting errors relating to NAESB’s capacity release standards. These errors involved missing and incorrect data labels. During the audit, CEGT corrected all 15 posting errors.
• PA10-44-000:  In its audit of Viking Gas Transmission Company, Audit Staff identified 27 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved six categories: an incorrect navigational area, incorrect navigational links, missing or incorrect data field content, incorrect data field labels, incorrect code values, and the use of incorrect NAESB software. During the audit, Viking corrected all 27 posting errors.
• PA10-45-000:  In its audit of Dominion Transmission, Inc., Audit Staff identified 35 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved missing or incorrect data field labels and the use of an incorrect code value. During the audit, DTI corrected all 35 posting errors.
• PA10-47-000:  In its audit of Dominion South Pipeline Company, LP, Audit Staff identified 24 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved three categories:  missing or incorrect data field labels, missing data field content, and the use of an incorrect code value. During the audit, DSP corrected all 24 posting errors. The Company made a filing, with the Commission, requesting a waiver and is waiting for a decision before addressing the corrective actions for the remaining error.
• PA10-49-000:  In its audit of TransColorado Gas Transmission Company LLC, Audit Staff identified 18 posting errors related to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved three categories: incorrect navigational areas, missing or incorrect data field labels, and the use of an incorrect code value. During the audit, TransColorado corrected all of the posting errors.
• PA10-50-000:  In its audit of Trailblazer Pipeline Company LLC, Audit Staff identified 17 posting errors relating to NAESB’s electronic delivery mechanism, flowing gas, and capacity release standards. These errors involved three categories: incorrect navigational areas, missing or incorrect data field labels, and the use of an incorrect code value. During the audit, Trailblazer corrected all of the posting errors.
• PA10-51-000:  In its audit of Kinder Morgan Interstate Gas Transmission LLC, Audit Staff identified 22 posting errors relating to NAESB’s electronic delivery mechanism, flowing gas, and capacity release standards. These errors involved four categories: incorrect navigational areas, missing data field content, missing or incorrect data field labels, and the use of incorrect code values. During the audit, KMIGT corrected all of the posting errors.
• PA10-54-000:  In its audit of Discovery Gas Transmission, LLC, Audit Staff identified three posting errors relating to NAESB’s electronic delivery mechanism standards. These errors involved two categories: incorrect data field labels and missing data field content. During the audit, Discovery corrected all of the posting errors.
• PA10-55-000:  In its audit of Southwest Gas Storage Company, Audit Staff identified 13 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved three categories: missing or incorrect data field labels, an incorrect navigational area, and incorrect code values. During the audit, Southwest corrected all of the posting errors.
• PA10-56-000:  In its audit of Trunkline Gas Company, LLC, Audit Staff identified 22 posting errors relating to NAESB’s flowing gas, electronic delivery mechanism, and capacity release standards. These errors involved three categories: missing or incorrect data field labels, an incorrect navigational area, and incorrect code values. During the audit, Trunkline corrected all of the posting errors.
• PA10-57-000:  In its audit of Sea Robin Pipeline Company, LLC, Audit Staff identified 22 posting errors relating to NAESB’s flowing gas, electronic delivery mechanism, and capacity release standards. These errors involved three categories: missing or incorrect data field labels, an incorrect navigational area, and incorrect code values. During the audit, Sea Robin corrected all of the posting errors.
• PA10-58-000:  In its audit of Panhandle Eastern Pipeline Company, LP, Audit Staff identified 20 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved three categories: missing or incorrect data field labels, an incorrect navigational area, and incorrect code values. During the audit, Panhandle corrected all of the posting errors.
• PA10-15-000:  In its audit of Williston Basin Interstate Pipeline Company, Audit Staff identified six posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved three categories: incorrect data field labels, incorrect navigational links, and incorrect code values. During the audit, Williston Basin corrected all six of the posting errors.
• PA10-18-000:  In its audit of Vector Pipeline L.P., Audit Staff identified 75 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved three categories: missing or incorrect data field labels, an incorrect navigational area, and incorrect code values. During the audit, Vector corrected all of the posting errors.
• PA10-20-000:  In its audit of Pine Needle LNG Company, LLC, Audit Staff identified 14 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved three categories: incorrect navigational area, missing or incorrect data field labels, and the use of an incorrect code value. During the audit, Pine Needle corrected all 14 of the posting errors.
• PA10-27-000:  In its audit of High Island Offshore System, Audit Staff identified 72 posting errors relating to NAESB’s flowing gas, electronic delivery mechanism, and capacity release standards. These errors involved five categories: missing or incorrect data field labels, missing data field content, incorrect navigational areas, incorrect code values, and incorrect navigational links. During the audit, HIOS corrected all 72 posting errors.
• PA10-22-000:  In its audit of Northern Border Pipeline Company, Audit Staff identified 18 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved five categories: incorrect navigational areas, incorrect navigational links, incorrect data field labels, the use of incorrect code values, and incorrect NAESB software. During the audit, Northern Border corrected all 18 of the posting errors.
• PA10-30-000:  The audit of Energy West Development, Inc. did not result in any findings or recommendations that require EWD to take corrective actions at this time. Audit Staff based its conclusion on
• the review of EWD’s informational postings web site, discussions with company personnel, and the Company’s written responses.
• PA10-35-000:  In its audit of Alliance Pipeline L.P., Audit Staff identified 52 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors cover three categories: missing or incorrect navigational areas, missing or incorrect data field labels, and the use of incorrect code values. During the audit, Alliance corrected all 52 posting errors.
• PA10-52-000:  In its audit of Clear Creek Storage Company, L.L.C., Audit Staff identified 39 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved four categories: incorrect data field labels, missing data field content, incorrect code values, and improper navigational links. During the audit, Clear Creek corrected all 39 posting errors.
• PA10-33-000:  In its audit of Carolina Gas Transmission Corporation, Audit Staff identified 16 posting errors relating to NAESB’s flowing gas and capacity release standards, and Commission design capacity regulations. These errors involved three categories: missing or incorrect data field labels, missing or incorrect data field content, and the use of an incorrect code value. During the audit, CGT corrected 15 of the 16 posting errors.
• PA10-39-000:  In its audit of Columbia Gas Transmission, LLC, Audit Staff identified 50 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards, and Commission regulations requiring documents be directly downloadable without the need to first view them. These errors involved six categories: downloading functionality, missing or incorrect data field labels, missing data field content, incorrect navigational area, incorrect code values, and a missing navigational link. During the audit, Columbia corrected all 50 posting errors.
• PA10-34-000:  In its audit of Bobcat Gas Storage, Audit Staff identified 22 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved five categories: missing or incorrect data field labels, incorrect code values, missing data field content, an incorrect navigational area, and a missing navigational link. During the audit, Bobcat corrected all of the posting errors.
• PA10-42-000:  In its audit of Central Kentucky Transmission Company, Audit Staff identified 44 posting errors relating to NAESB’s electric delivery mechanism and capacity release standards. These errors involved five categories: missing or incorrect data field labels, missing data field content, missing or incorrect links within the navigational area, the use of incorrect code values, and absence from the NAESB Central Repository. During the audit, Central Kentucky corrected 43 of the 44 posting errors.
• PA10-43-000:  In its audit of Guardian Pipeline, L.L.C., Audit Staff identified 22 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved six categories: an incorrect navigational area, incorrect navigational links, missing data field content, incorrect data field labels, incorrect code values, and the use of incorrect NAESB software. During the audit, Guardian corrected all 22 posting errors.
• PA10-40-000:  In its audit of Columbia Gulf Transmission Company, Audit Staff identified 50 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards, and Commission regulations requiring documents be directly downloadable without the need to first view them.  These errors involved six categories:  downloading functionality, missing or incorrect data field labels, missing data field content, incorrect navigational area, incorrect code values, and a missing navigational link.  During the audit, Columbia Gulf corrected all 50 posting errors.
• PA10-41-000:  In its audit of Hardy Storage Company, LLC, Audit Staff identified 33 posting errors relating to NAESB’s electric delivery mechanism and capacity release standards. These errors involved four categories: missing or incorrect data field labels, missing or incorrect data field content, missing or incorrect links within the navigational areas, and the use of incorrect code values. During the audit, Hardy corrected 32 of the 33 posting errors.
• PA10-17-000:  In its audit of Texas Gas Transmission, LLC, Audit Staff identified 16 posting errors related to NAESB’s flowing gas, electronic delivery mechanism, and capacity release standards. These errors involved two categories: an incorrect navigational area and missing or incorrect data field labels. During the audit, Texas Gas corrected all of the posting errors.
• PA10-19-000:  In its audit of Steuben Gas Storage Company, Audit Staff identified 19 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved four categories: incorrect navigational links, incorrect data field labels, missing data field content, and the use of an incorrect code value. During the audit, Steuben corrected all of the posting errors.
• PA10-23-000:  In its audit of National Grid LNG, LP, Audit Staff identified 12 posting errors relating to NAESB’s electronic delivery mechanism standards, Commission firm and interruptible service regulations, and Commission design capacity regulations. These errors involved four categories: missing or incorrect navigational links, missing or incorrect navigational areas, a missing data field label, and missing data field content. During the audit, National Grid LNG corrected all 12 posting errors.
• PA10-25-000:  In its audit of KO Transmission Company, Audit Staff identified 21 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards, and Commission design and scheduled capacity regulations. These errors involved two categories: missing or incorrect navigational areas and missing data field content. During the audit, KOT corrected all 21 posting errors.
• PA10-48-000:  In its audit of Cheyenne Plains Gas Pipeline Company, L.L.C., Audit Staff identified 60 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards and Commission design capacity regulations. These errors involved five categories: missing or incorrect data field labels, missing data field content, incorrect navigational areas, the use of incorrect code values, and an incorrect central repository listing. During the audit, CPG corrected 59 of the 60 posting errors. CPG expects to correct the remaining error relating to the posting of design capacity, by November 1, 2010.
• PA10-24-000:  In its audit of Maritimes & Northeast Pipeline, L.L.C., Audit Staff identified 21 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involved three categories: missing or incorrect data field labels, missing or incorrect navigational areas, and the use of incorrect code values. During the audit, MNP corrected all 21 posting errors.
• PA10-31-000:  In its audit of Crossroads Pipeline Company, Audit Staff identified 43 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards, and Commission regulations requiring documents be directly downloadable without the need to first view them. These posting errors include six categories: downloading functionality, missing or incorrect data field labels, missing data field content, incorrect navigational areas, incorrect code values, and missing navigational links. During the audit, Crossroads corrected all 43 posting errors.
• PA10-53-000:  In its audit of Cheniere Creole Trail Pipeline, L.P., Audit Staff identified 47 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors
• involved three categories: missing or incorrect data field labels, incorrect data field content, and the use of incorrect code values. During the audit, Creole Trail corrected all of the posting errors.
• PA10-21-000:  In its audit of Panther Interstate Pipeline Energy, LLC, Audit Staff identified 22 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards, Commission design and scheduled capacity regulations, and Commission firm and interruptible services regulations. These errors involved four categories: missing data field labels, missing navigational areas, missing or incorrect navigational links, and missing data field content. During the audit, Panther corrected all 22 posting errors.
• PA10-28-000:  In its audit of Gulf States Transmission Corporation, Audit Staff identified 33 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards, and the Commission regulation that access to certain postings be maintained for a period of not less than 90 days from the date of posting. These errors involved four categories: missing data field content, missing or incorrect data field labels, incorrect code values, and missing or incorrect navigational links. During the audit, Gulf States corrected all 33 posting errors.
• PA10-26-000:  In its audit of Iroquois Gas Transmission System, L.P., Audit Staff identified 31 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards. These errors involve five categories: missing or incorrect data field labels, missing or incorrect data field content, an incorrect navigational area, missing or incorrect navigational links, and incorrect code values. During the audit, Iroquois corrected all 31 posting errors.
• PA10-29-000:  In its audit of Great Lakes Gas Transmission Limited Partnership, Audit Staff identified 41 posting errors relating to NAESB’s electronic delivery mechanism and capacity release standards, and Commission design capacity and interruptible service regulations. These errors involved five categories: missing or incorrect data field labels, missing data field content, incorrect code values, missing navigational areas and incorrect navigational links. During the audit, Great Lakes corrected 37 of the 41 posting errors.