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North American Energy Standards Board801 Travis, Suite 1675, Houston, Texas 77002

Phone: (713) 356-0060, Fax: (713) 356-0067, E-mail: [email protected] Page: www.naesb.org

North American Energy Standards BoardBoard Strategic Plan Task Force Report

2018 NAESB Standards Development Survey

Submitted to the NAESB Board of Directors on September 6, 2018

TABLE OF CONTENTS

Page

I. Summary 2

II. 2018 NAESB Standards Development Survey Results 10

Appendices A. Board Strategic Plan Task Force Meetings 41

B. Board Strategic Plan Task Force Members 42

NAESB Board Strategic Plan Task Force Report - September 6, 2018Page 1 of 36

http://www.naesb.org/



I. SUMMARY

As was done in the 2014 and 2016, the NAESB Board Strategic Plan Task Force distributed the industry-wide 2018 NAESB Standards Development Survey on June 15, 2018. This action was taken pursuant to the task force’s mission to provide assistance to the Board of Directors by (a) developing and maintaining a multi-year strategic plan, (b) appraising NAESB work products to ensure that NAESB is addressing member needs, (c) assessing NAESB structure to ensure that market segments that take part in development of NAESB work products are adequately and fairly represented, and (d) reviewing market trends to ensure that NAESB remains relevant. The task force distributed the industry-wide survey to over 5,600 members and non-members to solicit feedback on areas for potential standards development and other activities that NAESB could consider in the future. The purpose of the survey is to receive information from the industry that may be helpful for the Board of Directors as they develop the 2019 annual plans and to support the strategic session of the September 6, 2018 board meeting. The survey was developed by the task force, with the support of the Advisory Council, through two meetings on March 14, 2018 and May 31, 2018 and was primarily based on the comments and recommendations resulting from the February 10, 2018 Advisory Council meeting. Unlike previous NAESB surveys, this survey excluded questions concerning the projects already underway within NAESB and focused solely on potential standards development areas in an effort to maximize the utility of the results and to support future action of the Board of Directors.

The survey identified 8 areas of potential standards development and 4 areas for potential standards related activities that NAESB could consider in the next 18 to 24 months. Regarding potential standards development areas, the survey asked respondents to indicate whether they “strongly agree,” “agree,” “disagree” or “strongly disagree” with NAESB’s potential involvement in the areas identified. Respondents were also given an option of providing a “no opinion” or a “not applicable” response. In addition to selecting one of the responses provided, participants were given the opportunity to provide comments as an alternative to a provided response or in addition to a provided response. To encourage more detailed and/or specific responses through the comment sections of the survey, the descriptions of the standards development areas were intentionally left broad and subject to the interpretation of the respondents. Additionally, the survey identified 4 areas of standards related activities that the organization could consider in the future and provided respondents an opportunity to submit written comments, recommendations or other information in response. This portion of the survey was intended to support the development of the 2019-2021 NAESB Strategic Plan.

POTENTIAL STANDARDS DEVELOPMENT AREAS POTENTIAL STANDARDS RELATED ACTIVITIES

A. Standards that support distributed generation, microgrids, photovoltaic vehicles, Industrial Internet of Things (IIoT), and solar and wind generation

A. Activities focused on education of the NAESB standards and products

B. Standards that support block chain technology in the energy markets

B. Activities focused on the development of new NAESB tools that support the implementation of the standards

C. Standards that support the energy market reformation in Mexico

C. Activities focused on the development of new certification programs that support the implementation of the standards

D. Standards that support the increased activity in the liquefied natural gas markets

D. Activities focused on coordination with external organizations

E. Standards related to gas quality in light of the shale gas revolution

E. Other areas of standards related activities

F. Standards that support transitioning multiple types of fuel through a single pipeline





G. Standards that support gas-electric market coordination

H. Standards that support the cybersecurity of the energy markets

I. Other areas of standards development

In total, 87 responses were received from 77 companies/organizations. The responses were mostly comprised of NAESB member companies/organizations - roughly 74%. The number of responses received and the percentage of responses received from member companies both decreased from the 2016 survey, as 101 survey responses were collected, 85% of which came from member companies. The 23 Non-member respondents were asked to provide a reason why they have declined membership within in NAESB and were given 4 optional responses or an “other” option with a comment box. Of the non-members responding to question, over half identified themselves as an affiliate company of a member. One respondent cited financial reasons for not becoming NAESB members, two respondents answered that NAESB activities were not relevant to their companies/organizations, and one organization answered that their interests were represented by another entity. Five “other” responses were provided and are included in the survey results below in section two.

The respondents represented a wide array of market segments from the wholesale gas, wholesale electric and retail energy markets. Each respondent was requested to identify with one or more of the NAESB quadrants and segments. Respondents were also given an option to respond that they do not identify with any of the NAESB quadrants and/or segments as specified and were asked to describe their market function. Although nine respondents provided descriptions of their company’s/organization’s market function, only two respondents did not identify with a NAESB quadrant and segment in the preceding question, which is consistent with the 2016 survey results.

Of the respondents that selected one or more of the NAESB quadrants and segments, 46% identified affiliation with the Wholesale Gas Quadrant, 35% identified affiliation with the Wholesale Electric Quadrant and 19% identified with the Retail Markets Quadrant. On a market segment basis, responses from wholesale gas entities were roughly balanced between pipeline companies, distributors, service companies and end users. Only three respondents identified their company as a producer in the wholesale gas market. In the wholesale electric market, the number of responses from individuals identifying with transmission, generation, distributor and/or marketer/broker companies each nearly doubled the number of responses received from end users and technology/service companies. Six responses were received from companies identified as independent grid operators and planners. In the retail market, a majority of the responses were submitted by electric service providers/suppliers and utilities. A pie chart depicting the make-up of the respondents is provided below in Figure 1.





As noted above, respondents were given six optional responses to each of the 8 standards development areas identified in the survey. The following graph show the percentages of the responses received on each of the standards development areas, with the “strongly agree” and “agree” responses combined and the “strongly disagree” and “disagree” combined for ease of review. The potential standards development area garnering the highest number of “strongly agree” and “agree” responses on a cumulative basis (69%) is cybersecurity of the energy markets. The area garnering the least support or the fewest “strongly agree” and “agree” responses was transitioning multiple types of fuel through a single pipeline.


FIGURE 1 - QUADRANT AFFILIATION PROFILE OF RESPONDENTS




FIGURE 2 – POTENTIAL STANDARDS DEVELOPMENT AREAS PERCENTAGES OF RESPONDENTS

Similar to the 2014 and 2016 NAESB Standards Development Surveys, a significant number of respondents provided “no opinion” and “not applicable” responses to the questions presented in the survey. Roughly, 39% of all responses to the survey questions regarding standards development areas were “no opinion” and 7% of the responses were “not applicable.” The potential standards development area garnering the highest number of “no opinion” responses (56%) and “not applicable” responses (8%) was transitioning multiple types of fuel through a single pipeline. The least “no opinion” responses (18%) and “not applicable” responses (4%) were provided for cybersecurity of the energy markets. The two graphs below show the percentage of “no opinion” and “not applicable” responses provided for each standards development area, and may be helpful to gauge the interest levels of the respondents in specific areas.





FIGURE 3 – POTENTIAL STANDARDS DEVELOPMENT AREAS PERCENTAGES OF “NO OPINION” AND “N/A” RESPONSES

When broken down on a market basis of respondents providing an opinion on a potential standards development area - meaning they answered that they either “strongly agree/agree” or “strongly disagree/disagree,” all identified potential standards development areas received 50% or greater “strongly agree/agree” responses. Energy market reformation in Mexico received the greatest percentage of support from respondents that identified with the wholesale electric (95%) and/or gas market (100%). Distributed generation, microgrids, photovoltaic vehicles, IIoT and solar and wind generation received the greatest percentage of “strongly agree/agree” responses from those retail market respondents providing an opinion (88%).





FIGURE 4 – POTENTIAL STANDARDS DEVELOPMENT AREAS PERCENTAGES OF “STRONGLY AGREE/AGREE” AND “STRONGLY DISAGREE/DISAGREE” - CUMULATIVE

FIGURE 5 – POTENTIAL STANDARDS DEVELOPMENT AREAS PERCENTAGES OF “STRONGLY AGREE/AGREE” AND “STRONGLY DISAGREE/DISAGREE” – WHOLESALE GAS MARKET





FIGURE 6 – POTENTIAL STANDARDS DEVELOPMENT AREAS PERCENTAGES OF “STRONGLY AGREE/AGREE” AND “STRONGLY DISAGREE/DISAGREE” – WHOLESALE ELECTRIC MARKET

FIGURE 7 – POTENTIAL STANDARDS DEVELOPMENT AREAS PERCENTAGES OF “STRONGLY AGREE/AGREE” AND “STRONGLY DISAGREE/DISAGREE” – RETAIL MARKET





In response to the survey questions related to the four identified potential standards related activities, a total of sixty-eight comments were provided by respondents, and seven comments were provided in response to the open-ended “other standards related activities” question. Additionally, NAESB received seventeen comments in the final section of the survey requesting generalized comments. In addition to being included in this report, these responses will be used by the Board Strategic Plan Task Force to develop a draft 2019-2021 NAESB Strategic Survey to be proposed to the Board of Directors during the December 13, 2018 meeting.

*Potential Standards Related Activities & Generalized Comments: Number of Comments

A. Standards that support distributed generation, microgrids, photovoltaic vehicles, industrial internet of things (IIOT), and solar and wind generation 9

B. Standards that support block chain technology in the energy markets 11

C. Standards that support the energy market reformation in Mexico 7

D. Standards that support the increased activity in the liquefied natural gas markets 10

E. Standards related to gas quality in light of the shale gas revolution 12

F. Standards that support transitioning multiple types of fuel through a single pipeline 8

G. Standards that support gas-electric market coordination 18

H. Standards that support the cybersecurity of the energy markets 13

I. Other areas of standards development 10

General Comments 17

*This table captures the number of written comments submitted outside of the predefined responses

FIGURE 8 – POTENTIAL STANDARDS RELATED ACTIVITIES & GENERALIZED COMMENTS





2018 NAESB STANDARDS DEVELOPMENT SURVEY RESULTS

Results of Survey Distributed on Friday, June 15, 2018

Section I – Submitter Information

1. Please provide your contact information.

Company or Organization: Representative:

77 Companies/Organizations 87 Representatives

2. Do you participate in (check as many as are applicable):

62 Wholesale Natural Gas Market as a 3 Producer18 Pipeline13 Distributor12 Services or Technology Company17 End User 7 Other Participant

3. 48 Wholesale Electric Market as a 13 Transmission Company15 Generator13 Distributor/Load Serving Entity 5 End User 6 Independent Grid Operators and Planners10 Marketers/Brokers 6 Technology and Services Companies 3 Other Participant

4. 26 Retail Energy Market as a 9 Retail Electric Service Providers/Suppliers 3 End Users/Public Agencies 3 Retail Gas Market Interests10 Retail Electric Utilities 8 Other Participant

5. 9 If you do not fit into any of the market functions described in questions 2 through 4, or if one of your market functions has not been provided in questions 2 through 4, please describe your market function.: (Note: 7 of the 9 Representatives responded to questions 2-4 above)

1. The American Gas Association (“AGA”), founded in 1918, represents more than 200 local energy companies that deliver clean natural gas throughout the United States. There are more than 73 million residential, commercial and industrial natural gas customers in the U.S., of which 95 percent — more than 69 million customers — receive their gas from AGA members.

2. As a natural gas pipeline company ANR transports natural gas to Power Plants, LDCs and End Users.






3. None. I participate as a TP/BA.

4. Gas LDC

5. Daymark Energy Advisors is a consulting firm that represents or advises certain clients who participate in the wholesale and retail market electric and gas markets.

6. Emera Energy is a natural gas and energy marketing and trading and asset management firm.

7. Aggregator of loads seeking 100% renewable

8. Local Gas Distribution Company

9. NAESB advisory

6. Are you a member of NAESB?

64 Yes

23 No

7. As a non-member, why have you not become a member of NAESB?

1 Financial reasons

10 My organization is an affiliate of a member company

2 NAESB’s activities are not currently relevant to my organization

1 My organization’s interests are represented by another entity

5 Other

Other:

1. Don’t know

2. I can only answer topics concerning the Natural Gas Quadrant

3. Daymark Energy Advisors may have joined for a prior period in order to obtain current copies of the NAESB Wholesale and Retail Contracts.

4. Advisory

5. We presently only trade financial.






Section II – Potential Standards Development Areas

8. Please indicate whether NAESB should consider standards development in the following areas within the next 18 to 24 months. Comments may be provided for each development effort.

Potential Standards Development Areas:

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Wholesale Natural Gas Market 3 7 20 0 2 3 38

Wholesale Electric Market 7 6 2 2 0 0 17

Retail Energy Market 1 2 0 0 0 0 3

Wholesale Natural Gas Markets/Wholesale Electric 3 5 4 0 0 0 12

Wholesale Electric/Retail Energy Markets 2 3 0 0 0 1 6

Wholesale Electric/Wholesale Gas/Retail Energy Markets

3 3 2 2 0 0 10

None of the Above 0 1 2 0 0 0 3

A. Standards that support distributed generation, microgrids, photovoltaic vehicles, industrial internet of things (IIOT), and solar and wind generation:

19 27 30 4 2 4 86

9 Comments:

1. If NAESB has requests by members. NAESB does not need to pursue these areas to look for opportunities for standardization. If selected, NAESB must also be open to alternative fuels not directly associated with the production of electricity, such as ethanol, biofuels, etc. NAESB is an ENERGY standards board. All energy sources would be open to standards - Pandora's Box could be opened.

2. Potential of conflict between state and federal jurisdictions and standards efforts are under way at the state and federal levels.

3. Potential of conflict between state and federal jurisdictions and Standards efforts are under-way at the state and federal levels. In addition, these items are first evolving and rapidly changing, we believe trying to establish standards at this infancy stage could be detrimental and restrictive. What should be done is a robust sharing of Best Practices.

4. Generally Direct Energy believes that NAESB may have a role to play in the future setting standards in this category, but at this time does not believe NAESB should take any action. NAESB should wait for more formal requests for coordination/standardization that would come from the RTOs, states and/or FERC.







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5. Liberty disagrees that NAESB is the appropriate group to set standards in these areas.

6. Don't believe we need standards in DG, microgrids, PV vehicles or IIot. Industrial scale solar and wind do need some standards about how they can support reliability.

7. We need standard that enables prices to devices and especially electric vehicles and water heaters. We need to commercialize ANSI/CTA-2045 as the key enabler for cost effective control of residential loads. API for residential inverters (battery and solar)

8. The integration of these technologies into electricity markets should not be given any advantage over traditional services provided to users/customers. NAESB business practices may be helpful for certain new technologies like Distributed Generation, where consistency in aggregation of loads and distributed resources to allow bulk power control as a bulk power resource may provide market benefits as well as reliability benefits.

9. For DG, solar, wind. forget the rest. too early. my hope would be that standards would provide transparency around DG and renewables, because now there is little to none.




Wholesale Electric/Wholesale Natural Gas Markets 2 5 5 0 0 0 12



1 0 5 1 2 1 10


B. Standards that support block chain technology in the energy markets:

11 18 35 6 9 6 85

11 Comments:

1. This is a new buzz word that has gotten a lot of attention. Per the research and the speaker at a previous meeting, many companies that serve NAESB customers are already accomplishing that and we do not need standards in that area.

2. Too early for standards development in the next 18-24 months.

3. Too early for Standards Development, perhaps reconsider in 18-24 months

4. Con Edison believes this is premature, although may be useful once it is ripe for action.NAESB Board Strategic Plan Task Force Report - September 6, 2018

Page 13 of 36






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5. While blockchain applications are in early stages of development, it is important to anticipate how the current NAESB contracts can be included as smart contracts in a blockchain with or without modification, as transaction processing time is a key feature to support such applications.

6. Block chain technology needs further refinement and actual implementation in other commodities before it would be fully understood and adapted for natural gas or electric wholesale energy markets.

7. This is not the future, it is the present, and it needs to be addressed.

8. Wait until stakeholders have implementations to standardize.

9. Liberty disagrees that NAESB is the appropriate group to set a particular software technology standard.

10. There are regulatory requirements for payment of goods and services which asset owners must abide by as well as credit ratings by credit agencies which may be impacted by payments which have not yet be recognized. Until such time Block Chain technologies can be backed by regulatory agencies and credit institutions, there may be a hesitation or resistance for asset owners to accept Block Chain technologies.

11. Maybe it will help us all finally understand it. :-(







0 3 7 0 0 0 10


C. Standards that support the energy market reformation in Mexico:

10 27 41 1 1 5 85

7 Comments:

1. I love the idea of working with Mexico but have found it difficult to get any traction. NAESB and member companies would have to be the investors to make this happen. We would need to determine if the financial investment it worth it. CRE, Sener and Mexican companies do not seem willing to make the investment to achieve this.







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2. AGA is not in a position to provide input in this area because it is unclear what the phrase “market reformation in Mexico” means or, more broadly, what any such market reformations would involve. NAESB must clearly define and explain what is meant by “energy market reformation in Mexico” in advance of NAESB moving forward with any related standards development.

3. Do not need a Standard at this point in time for this area.

4. This might be a hard one to do. You do need people who are familiar with the market and structure.

5. Liberty has no opinion on this at this time. Liberty is unclear as to what you mean by "Standards that support the energy market reformation in Mexico". The topic is so broad and at this time, Liberty does not do business in Mexico and there is already in place, mechanisms to deal with cross border exchange of energy between the US and Mexico.

6. As more power is traded between U.S. and Mexico, there may be a need to standardize terms and measures for business communications to ensure translations between English and Spanish are not misinterpreted.

7. But needs to be done in a sensible way - fully in the NAM context (reciprocity). It will expose aspects of the MX system that need policy support for competition.







2 2 4 2 0 0 10


D. Standards that support the increased activity in the liquefied natural gas markets:

15 21 37 5 0 7 85

10 Comments:

1. Where LNG is being delivered off of a pipeline or LDC there is value in having standards to support those transactions. Today, several companies are already sending transactions to LNG using the existing nomination. NAESB participants should REQUEST development of additional standards if needed.







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2. Significant growth in domestic natural gas production is altering the energy landscape in the U.S. A combination of advances in drilling and well completion technologies widely deployed during the past few years has rejuvenated natural gas production, particularly from shale formations. As a result, natural gas is well positioned to serve as a reliable, secure and clean energy source for U.S. homes, businesses and industries for decades to come. Domestic gas production and the potential for future sustainable growth is so substantial that it has attracted attention from natural gas marketers and producers envisioning the U. S. as an exporter of LNG to markets in Europe, the Caribbean, South America and Asia. Momentum appears to be building for development of LNG export infrastructure along the U.S. Gulf Coast as well as at points along the eastern U.S. and the west coast of Canada. Approvals granted by the U.S. Department of Energy (“DOE”) and the Federal Energy Regulatory Commission (“FERC”) for export licenses and project planning have set the stage for the transition of the U.S. to be a net exporter of LNG. FERC should take the lead in establishing a clear energy policy framework that reflects variations in reliability issues at the regional level in terms of infrastructure, scope and timing. Furthermore, DOE and FERC must provide policy guidance in advance of NAESB moving to implement specific LNG market standards.

3. Don't see a need for standard at this time in the area.

4. Too broad

5. FERC should take the lead in establishing a clear energy policy framework that reflects variations in reliability issues at the regional level in terms of infrastructure, scope and timing. Furthermore, DOE and FERC must provide policy guidance in advance of NAESB moving to implement specific LNG market standards.

6. Only upon request of market participants who can assure sufficient interest to make the effort worthwhile.

7. Only when stakeholders submit requests within scope of the NAESB certificate (e.g. streamline business transactions).

8. Liberty has no opinion on this at this time. Liberty believes that these markets need further policy guidance from DOE, FERC, and any appropriate State level Regulatory Agencies in advance of NAESB moving to implement specific LNG market standards.

9. The U.S. Department of Energy (DOE) and the Federal Energy Regulatory Commission (FERC) should provide policy guidance in advance of NAESB moving to implement specific LNG market standards.

10. Other groups deal with gas quality, which is the main consideration.









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E. Standards related to gas quality in light of the shale gas revolution:

11 22 31 9 6 6 85

12 Comments:

1. Only if requests are submitted. Additional speakers highlighting the issues and opportunities around this topic may bring more requests to light.

2. Regarding gas quality, local distribution companies (“LDCs”) must be able to count on the fact that the gas being delivered to their systems is merchantable based on the existing infrastructure. The quality specifications should be set on a pipeline-by-pipeline basis, depending on the regional needs of the pipeline’s customers. Furthermore, quality and interchangeability issues are generally addressed in individual pipeline and LNG proceedings before FERC. Through the stakeholder and FERC processes, gas quality specifications should be designed to ensure that gas tendered to, and delivered by, interstate pipelines is safe and reliable, and meets the requirements of end-use applications. Gas quality specifications should not unreasonably limit the development of new or expanded gas supplies, or limit the diversity of sources of gas supply. Changes to pipeline tariffs should be explored that would establish acceptable gas quality specifications for supplies delivered to the pipeline that will meet reasonable end-use requirements and ensure system safety and integrity. The existing flexibility used by interstate pipelines to meet operational safety and integrity and end-use gas quality needs, must remain as part of the industry-wide infrastructure to supply merchantable natural gas to customers.

3. Have not seen natural gas quality issue at generator level at this time.

4. Reporting requirements for gas quality have already been addressed appropriately.

5. As an LDC, standards for gas quality are important, particularly if the pipeline standards are materially different from the gas quality standards set by our regulators.

6. Better approach is to understand how pipeline quality specifications that can vary by geographic location would lend themselves to a generic contract. NAESB can already accommodate such specifications by referencing the specifications already embedded in the pipeline tariff.







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7. Should be addressed at the FERC.


9. FERC policy and pipeline tariffs have and should address interchangeability.

10. Liberty has no opinion on this at this time. Liberty is a local distribution company and as such, must be able to receive merchantable gas from the various pipeline companies that supplies it. Liberty operates in various regions of the US and the gas quality specifications should be handled through the current process under the Only if requests are submitted. This takes us into the NGL's space and that is something I would consider in scope. FERC. Pipeline tariffs need to be flexible and meet the proper needs of the end users and ensure system safety and integrity.

11. The quality specifications should be set on a pipeline-by-pipeline basis, depending on the regional needs of the pipeline’s customers. Gas quality specifications should be designed to ensure that gas tendered to, and delivered by, interstate pipelines is safe and reliable, and meets the requirements of end-use applications. Gas quality specifications should not unreasonably limit the development of new or expanded gas supplies, or limit the diversity of sources of gas supply.

12. Per above







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F. Standards that support transitioning multiple types of fuel through a single pipeline:

4 17 47 7 2 7 84

8 Comments:

1. Only if requests are submitted. This takes us into the NGL's space and that is something I







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would consider in scope.

2. Regarding standards related to transitioning to multiple types of fuel through a single pipeline, it is unclear from the wording of the 2018 NAESB Standards Development Projects Survey what types of fuel are contemplated to be transported. As noted elsewhere in this survey response, LDCs must be able to count on the fact that the gas being delivered to their systems is merchantable based on the existing infrastructure. Furthermore, consistent with FERC policy, gas quality specifications should be set on a pipeline-by-pipeline basis, depending on the regional needs of the pipeline’s customers.

3. This potential standard is unclear.


5. Only when stakeholders submit requests within scope of the NAESB certificate (e.g. streamline business transactions).

6. Liberty has no opinion on this at this time. Liberty is unclear as to what types of fuel are being contemplated to be transported. As stated previously, Liberty must be able to receive merchantable gas into its systems that meets the proper needs of the end users and ensure system safety and integrity.

7. Per above

8. What are the technical standards for running multiple fuel types through one pipeline?







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G. Standards that support gas-electric market coordination:

23 25 20 5 9 2 84

18 Comments:

1. I do not believe that NAESB can accomplish anything in this area without direct support and cooperation of state legislators. This is not an interstate issue on the pipeline side. It







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must be agreed to at the state level.

2. FERC should provide further policy guidance before NAESB implements gas-electric coordination standards. AGA believes that the overall goal of gas-electric coordination efforts should be to preserve and enhance reliability for all customers. Over the past several years, AGA and its members have engaged in the stakeholder process before FERC and NAESB to address issues of gas-electric coordination. This effort has resulted in certain reforms and policy changes. Prior to any NAESB initiative on gas-electric coordination, FERC must establish a clear energy policy framework that reflects variations in reliability issues at the regional level in terms of infrastructure, scope and timing. It is critical that FERC provide policy guidance in advance of NAESB moving to implement specific gas-electric market coordination standards. In the meantime, AGA members are meeting directly with electric utilities, and the Independent System Operators (“ISOs”) and Regional Transmission Organizations (“RTOs”) to address coordination matters.

3. Support revisiting this keeping in mind increase reliance on natural gas generation, gas/electric day mismatch, and bumpable cycles.

4. I do not ever see the two markets coordinated/aligned. They are very different types of energy with different avenues of delivery.

5. Support re-visiting this topic, keeping in mind increase reliance on natural gas generation, gas/electric day mismatch, and bumpable cycles.

6. FERC should provide further policy guidance before NAESB implements gas-electric coordination standards. We believe that the overall goal of gas-electric coordination efforts should be to preserve and enhance reliability for all customers. Gas and electric stakeholders must collaborate to meet this overall objective. Prior to any NAESB initiative on gas-electric coordination, FERC must establish a clear energy policy framework that reflects variations in reliability issues at the regional level in terms of infrastructure, scope and timing. It is critical that FERC provide policy guidance in advance of NAESB moving to implement specific gas-electric market coordination standards.

7. FERC has already attempted coordination. Further coordination should emphasize increasing gas generation firm transportation commitments.

8. See NAESB's ability to reference pipeline FERC tariffs which address such concerns already.

9. Generally Direct Energy believes that NAESB may have a role to play in the future setting standards in this category, but at this time does not believe NAESB should take any action. NAESB should wait for more formal requests for coordination/standardization that would come from the RTOs, states and/or FERC.

10. Only upon request of FERC to implement updated policy standards that resolve the many issues and concerns of prior NAESB efforts.

11. NAESB standards alone will not significantly improve any Gas-Electric coordination







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issues. New non-ratable services can only be developed if the gas generation market is willing to support the pipe capacity needed for a pipeline to provide these services. FERC policy decisions around cost-recovery for those generators of securing reliable pipeline capacity can address this main issue.

12. Liberty has no opinion on this at this time. Liberty believes that the FERC should provide further policy guidance on this before NAESB considers implementing something in this area.

13. FERC should provide further policy guidance before NAESB implements gas-electric coordination standards.

14. We have been here before. Flow of natural gas continues to be a regional problem for the Northeast, and public opinion appears to be a challenge. Developing standards will not remove the obstacles.

15. When each market runs Market trading

16. Coordination is a good thing.

17. The reliance on gas fired electric generation continues to grow. Although there have been localized and point specific solutions that have ensured supplies are available during times of heavy demand for gas and electricity, the tension between supplying gas for LDCs vs. electric generators can still result in electric shortages. Compounded by increasing amounts of variable resources which rely on quick start generators to respond to sudden loss of energy supply, there could be unknown market/weather circumstances that stress gas supplies at critical times for gas fired generators. NERC’s focus on reliability through fuel availability will likely highlight the challenges faced by Bulk Power System Operators and Inter/Intra state pipeline facility operators. As these issues are brought to light, it is imperative that NAESB is engaged as the forum for standards development around data and communication standards between these industries in support of grid resiliency related to gas fuel supply.

18. Perhaps second or third time will be a charm






Wholesale Electric/Wholesale Gas/Retail Energy 1 3 2 2 2 0 10







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ngly

Agr

ee

Agr

ee

No

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e

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D

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N/A

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Markets


H. Standards that support the cybersecurity of the energy markets:

34 25 15 3 5 3 85

13 Comments: (Comment #2 was repeated two times in the survey responses)

1. AGA advocates for reasonable and effective cybersecurity policies and programs to help bolster federal government and industry partnerships, as well as promote coordination among government agencies. AGA’s cybersecurity initiatives and actions ensure that Federal policies and programs address the cybersecurity concerns of natural gas utilities. AGA believes that any effort by NAESB to develop cybersecurity of the energy markets should reinforce and be consistent with policies and programs already implemented by the federal government and industry participants. AGA and its members actively engage in cybersecurity risk management practices, ensuring the continued safe and reliable delivery of natural gas to our customers. These measures aim to:

minimize the risk of cyber risks and vulnerabilities; improve our collective capability to monitor, detect, and respond to incidents; mitigate the impact of successful cybersecurity incidents; and implement security measures that reduce the risk of disruption from

cybersecurity incidents.

AGA notes that the Transportation Security Administration (“TSA”) acts as the lead Federal entity for transportation security, including hazardous materials and pipeline security and it already has Pipeline Security Guidelines (“Guidelines”) that include security measures for pipeline cyber assets. The Aviation & Transportation Security Act of 2001 gave the Department of Homeland Security authority over all modes of transportation, including modes under the purview of the Department of Transportation. Specific to pipeline security, oversight was given to TSA, and TSA has been partnering with natural gas pipelines for over a dozen years on security matters. The Guidelines have been widely adopted by industry and AGA member gas utilities implement these Guidelines as applicable to their individual environments. Additionally, TSA and the Department of Transportation have a Memorandum of Understanding to coordinate pipeline safety and pipeline security, which further enhances TSA’s role in coordinating and promoting security throughout the sector. TSA should provide policy guidance in advance of NAESB moving to implement specific energy market cybersecurity standards.

2. Current NERC standards cover existing market operators.

3. Should clarify first if by this question NAESB is referring to another category of Force Majeure.

4. There are Federal and State Agencies with the appropriate experts addressing this issue.







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6. This is an area that has the highest risk for grid reliability, but has not been sufficiently monitored or enforced.

7. If deficiencies are found by Sandia National Laboratories.

8. Liberty has no opinion on this at this time. Liberty believes any effort by NAESB in this area must be consistent with the policies and programs implemented by the Federal Government and industry participants. Federal Government Agencies such as DOE, DHS, TSA, and NIST, are currently involved in this area, along with industry participants, as well as State specific activities. Policy guidance must be provided in advance by these various parties prior to NAESB moving to implement specific standards in this area.

9. The Transportation Security Administration (TSA) should provide policy guidance in advance of NAESB moving to implement specific energy market cyber-security standards.

10. Where Cybersecurity is not covered by

11. Comments: We support the use of cybersecurity techniques to protect electric market systems. However, because the authority and jurisdiction of NAESB is limited to members and those who are FERC tariff jurisdictional, holding these entities responsible for their vendors/suppliers to build-in cybersecurity protections will be difficult. NAESB may instead want to explore ways to certify market participants that they have adequate levels of cybersecurity in the systems they use (similar to ISO 9001 certification) to encourage to industry to adopt safeguards. Further, gas industry transactional cyber standards are woefully outdated and NAESB is a forum that can facilitate their improvements.

12. NERC is the appropriate agency for development of these standards for the electric industry.






Wholesale Electric/Wholesale Gas/Retail Energy 0 0 5 0 0 3 8







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I. Other areas of standards development: 5 4 25 1 0 10 45

10 Comments:

1. We need to look at more modern technologies to get us away from EDI - it's a 1970's technology!!2. Standards development activities should come from the FERC regulatory process and/or industry

requests that are found in the scope of NAESB.3. Require all natural gas pipelines to adhere to and fully participate in EDI standards to increase

efficiency and automation.4. Liberty has no comment on this at this time.5. Re-visit Tariff Shark to make use of new and better technology.6. EDI downloads for 'Firm` and 'Interruptible Transactional Reporting7. NERC is seeking to retire over 100 reliability requirements. NAESB should ensure there are no

impacts on the business practices.8. Standards at natural gas "pooling points", including what constitutes a legitimate Force Majeure

event in the case of the sale and purchase of FIRM gas.9. FERC eForms - XBRL Tags and Taxonomies, if not provided by FERC10. No other comments






Section III – Potential Standards Related Activities

9. Please indicate whether NAESB should consider development projects in the next 18 to 24 months in the following areas. Comments may be provided for each development effort.

Potential Standards Related Activities:

Tot

alR

espo

nses

Wholesale Natural Gas Market 6

Wholesale Electric Market 6

Retail Energy Market 1

Wholesale Electric/Wholesale Natural Gas Markets 4

Wholesale Electric/Retail Energy Markets 0

Wholesale Electric/Wholesale Gas/Retail Energy Markets 4

None of the Above 0

A. Activities focused on education of the NAESB standards and products : 21

21 Comments: (Comment #18 was repeated three times in the survey responses)

1. Yes, but any courses need to include more than just a walk through, one by one, of the standards. I believe topical courses - such as a focus on one book, coupled with education on how the business process works, would have value. Current approach to courses assumes a good working knowledge of the subject matter. Additionally, courses focused on needs of specific segments such as endusers, LDCs would be effective. But all of these would require extensive development work.

2. Roadshow

3. Supportive of increased focus on education of NAESB process/background/roles.

4. This would be a good area to support. If you are new to a position and participating in the NAESB calls for standard's development, there isn't an easy way to become familiar with the current status. You just end up on the calls trying to absorb what is being discussed and where they are at in the process. It took me three years to finally understand the why/where of these groups. There isn't any way to become familiar without stopping the meeting discussions and asking for an overview.

5. Supportive of increased focus on education of NAESB process/background/roles.

6. Unfortunately many of the states working groups to no utilize the NAESB EDI standards. Also Gas Retail markets across the US all seem to use properties standards. Getting companies to common standards and processing would be







Tot

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helpful.

7. No comments

8. Education on NASEB standards would be a worthwhile activity. New employees and experienced employees could benefit from learning the standard development lifecycle along with how NAESB works with FERC

9. Recommend

10. Continue the workshops/training sessions on NAESB business practice standards and NAESB Contracts. Suggest possible workshops on Green Button initiative.

11. The contract training class is very helpful, especially for new members/participants.

12. Webinar series would be beneficial. If those are already available, it is not easily known.

13. Liberty has no specific comments on this at this time but would welcome any effort by NAESB to increase/improve its educational activities related to its standards and products.

14. Provide opportunities as needed/requested.

15. Educational Presentations on revised Preemption and Competition Standards, NITS Standards, Synopsis of Changes in Upcoming WEQ Standards and their impacts, Versions, and Processing of Requests, and EIR Timelines would be helpful.

16. Yes.

17. New folks are entering (and exiting) the work force all the time. Annual or biannual NAESB Standards training seminars would be good.

18. Support and encourage continuing opportunities for education of NAESB standards & products

19. None













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None of the Above 0

B. Activities focused on the development of new NAESB tools that support the implementation of the standards:

16

16 Comments: (Comment #14 was repeated two times in the survey responses)

1. Yes, I have a couple of ideas on this one.

2. Pilot programmes on new technologies

3. Unclear what could be done but supportive of implementation collaboration with software vendors.

4. Unclear what could be done - supportive of implementation collaboration with software.

5. No comments

6. This activity is overdue. Being a new NAESB member I can see how better tools could be used to implementation standards. Formatting of standards website, documents could greatly be improved to be easier to read and follow.

7. Recommend

8. Not new tools but improvements of usability and technology upgrade of existing tools would be great. The current tools are old and clunky to get access and use.

9. Liberty has no specific comment at this time but would welcome any effort by NAESB to develop new tools that support the implementation of its standards.

10. Yes.

11. More tools that identify clearly the changes made to standards in a readily available format to members are needed. Currently members have to database historical versions of standards themselves to trace the progression, deletion and redlining of changes through subsequent standards generations.

12. Only if industry calls upon their development. Too many times in the past efforts to address inefficiencies were barely implemented - it is hard to get folks to stop doing the old things.

13. Entities subject to NERC standards are expanding their internal compliance processes to cover NAESB business practices. Because NAESB does not have a formal compliance program, it has not had to address implementation and interpretation of standards in ways NERC has had to. This has been left to individual NAESB members. NAESB could help entities who desire to track business practice implementation/compliance with tools/templates/guidance







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associated with the NAESB business practices.

14. Support concept of NAESB tools, no specific comments for new tools at this time.

15. None







None of the Above 0

C. Activities focused on the development of new certification programs that support the implementation of the standards:

18

18 Comments: (Comment #2 and #12 were repeated two times in the survey results)

1. Nah

2. Yes, supportive of NAESB certifying compliance with new/changing standards.

3. A NAESB sponsored certification process for the deregulated Retail Electric markets would be a cost savings for both utilities and retailers.

4. No comments

5. Recommend

6. Could coordinate with existing certification programs instead, such as CEM, CEP.

7. Possible webinar on NAESB Certification programs, their benefits, and required resources.

8. Liberty is unclear as to what you are asking here. NAESB currently has a software certification process for software and software solutions and it is voluntary and confidential.

9. Certifications would be necessary for any cyberspace technology.

10. Yes, with FERC's guidance.







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11. See our response to 9.B.

12. Blockchain certification program after standards are developed

13. Support development of certification for Blockchain once standards are developed.

14. Development of a certificate program for Blockchain after standards are developed.

15. I think the ability to get certifications from NAESB would be a great thing to offer.

16. Like what? could be interesting, but the question is what form, what certs, which groups, etc.







None of the Above 0

D. Activities focused on coordination with external organizations: 19

19 Comments: (Comment #14 was repeated two times in the survey results)

1. Yes, supportive of current coordination and improving where necessary.

2. No comments

3. This type of effort would be useful when organizations are trying to do an "industry scan" or just be able to get questions answered like I wonder how other organizations deals with this type of issue?

4. Recommend

5. See answer to C. above. Also find regional organizations that are willing to provide local training and certification.

6. Continue the effective efforts with NARUC (Advisory Council) and NERC. Further, continue meetings with FERC Commissioners and key staff.







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7. Forums on gas-electric market coordination.

8. Liberty is unclear as to what you are asking here. The topic is much too broad to comment on.

9. Coordination of Committee Meetings with Regional (i.e. WECC) meeting times.

10. Yes.

11. This should be an "always".

12. As new technologies are introduced to electric markets (wholesale and retail level), NAESB should keep its members educated through presentations from technology vendors and market participants implementing these new products. This can dramatically change the response to question 8.A. if there is indication of a rise in the implementation of a particular technology.

13. FERC eForms - XBRL Tags and Taxonomies, if not provided by FERC

14. Would like to see a regular, ongoing relationship with APPA to include more public power companies that may be too small for direct NAESB involvement

15. Would like to see a regular, ongoing relationship with APPA to include the many small public power companies who are unable to directly participate in NAESB

16. Would like to see a regular, ongoing relationship with APPA to include more Public Power companies that may be too small for direct NAESB participation.

17. As DER grow, NERC will be developing standards and procedures to deal with this shit. NAESB should be prepared to coordinate to determine whether business standards may be necessary.

18. None













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None of the Above 1

E. Other areas of standards related activities: 9

9 Comments: (Comment #2 and #6 were repeated two times in the survey responses)

1. The request form initiating a NAESB standard and the parameters used by the appropriate subcommittee to review a proposed standard should be evaluated and potentially revised. Specifically, the standard request form should be revised to require a more detailed benefit analysis for a proposed standard. While the current request form does ask for a description of any tangible or intangible benefits of the proposed standard, an illustration of such benefits must be an essential element of any request and those benefits should be thoroughly examined by the applicable subcommittee. Furthermore, such requests should demonstrate that there is industry demand or need by industry participants, such as customers of pipeline, for a proposed standard. NAESB has thousands of standards and several were implemented for unique situations and are not applicable to the general industry as a whole.

2. Increase coordination on timelines and testing of standards before compliance dates.

3. No comments

4. Recommend

5. The request form initiating a NAESB standard and the parameters used by the appropriate subcommittee to review a proposed standard should be evaluated and potentially revised. Specifically, the standard request form should be revised to require a more detailed benefit analysis for a proposed standard. While the current request form does ask for a description of any tangible or intangible benefits of the proposed standard, an illustration of such benefits must be an essential element of any request and those benefits should be thoroughly examined by the applicable subcommittee. Furthermore, such requests should demonstrate that there is industry demand or need by industry participants, such as customers of pipeline, for a proposed standard. NAESB has thousands of standards and several were implemented for unique situations and are not applicable to the general industry as a whole.

6. None

7. Liberty supports the AGA's responses to this survey.






Section IV – General Comments

10. General Comments:

17 Comments:

1. NAESB Website. Since AGA has been a NAESB member, it has received informal feedback from its members regarding difficulty in navigating the NAESB website and accessing specific standards. In essence, for those not involved in NAESB on a regular basis, navigating and searching the current NAESB website can be cumbersome and not user-friendly. Therefore, AGA recommends that NAESB consider conducting a separate survey of its members that focuses on possible improvements to its website. The survey could solicit member feedback on possible improvements to the navigation of the NAESB website, access to NAESB materials and standards, and ways to improve the searchability of the NAESB standards and related material. AGA believes a simplification of the website and implementing a user-friendly interface would generate more involvement from the industry and relevant stakeholders. Survey Questions. Regarding the 2018 NAESB Standards Development Projects Survey (“Survey”), AGA is concerned that the results of the Survey may be skewed toward favorable responses. This is because the Survey does not seek information regarding the practical implications for developing any new standards or the policy direction that NAESB is pursuing. For example, the Survey does not ask about, inter alia, the time commitment that industry participants would be willing to make to be involved in the development any new standards; any possible resource constraints that may affect the development of the standards, i.e., whether NAESB or industry participants have the budget to develop new standards; or the federal and state policies that are consistent with implementing standards in the areas addressed in the Survey. To address this issue, for example, the Survey could have asked whether a respondent would likely be actively engaged in a specific standard’s development; how much time and resources would be committed to such an effort; and what is the policy direction that NAESB should follow in implementing any new standards. Furthermore, due to the structure of the Survey, there is no ability for NAESB to measure the knowledge or expertise of the respondents on the topics listed in the “Potential Standards Development Areas” section of the Survey. For example, there may be only a limited number of persons being surveyed that have the appropriate working knowledge on block chain technology and how it specifically applies to the energy industry to credibly respond to the Survey. Similarly, it is also unclear to what extent the Mexican stakeholders are involved and committed to the implementation of “market reformation” standards. Policy Direction. It is also not clear to AGA what regulatory policy direction exists on the topics listed in the “Potential Standards Development Areas” section of the Survey and identified for potential standards development. For example, there appears to be no clear policy direction cited in the Survey regarding LNG standards, shale gas quality standards, and standards regarding multiple types of fuel through FERC jurisdictional pipelines. Such policy determinations must be made prior to NAESB taking any actions on related applicable standards.

2. Efforts to lessen lag time and streamline standards finalization process would be helpful.

3. The NAESB website is extremely difficult to navigate. I use the NAESB website and t takes me a while to figure out where to find information. Let say a System Operator wants to look up a Standard, they won't be able to locate the information, because it is buried in the multi-layered dropdowns and they will stop and just ask me for the information. I would say that the NAESB website is not User Friendly and is only setup for those who have developed it and the standards. Thank you for allowing me to provide this feedback.

4. Efforts to lessen lag time and streamline standards finalization process would be helpful.






5. Standards development activities should come from the FERC regulatory process and/or industry requests that are found in the scope of NAESB.

6. Thank you for the opportunity to provide feedback

7. Reporting for Gas Quality Standards: We do not suggest that NAESB work on standards for gas quality, but instead focus on a standardized reporting requirements for gas pipelines. There is disparity between pipelines on the amount and type of information that is disclosed to shippers. We think it may helpful be for NAESB to help standardize the type and scope of information reported by pipelines. Survey Questions. Regarding the Survey, Con Edison is concerned that the results of the Survey may not adequately inform NAESB on the feasibility of adopting standards in the identified areas. This is because the Survey does not seek information regarding the practical implications developing any new standards or the policy direction that NAESB is pursuing. For example, the Survey does not ask about, inter alia, the time commitment that industry participants would be willing to make to be involved in the development any new standards; any possible resource constraints that may affect the development of the standards, i.e., whether NAESB or industry participants have the budget to develop new standards; or the federal and state policies that are consistent with implementing standards in the areas addressed in the Survey. To address this issue, for example, the Survey could have asked whether a respondent would likely be actively engaged in a specific standard’s development; how much time and resources would be committed to such an effort; and what is the policy direction that NAESB should follow in implementing any new standards. Policy Direction. It is not at all clear what regulatory policy direction exists on the topics listed in the “Potential Standards Development Areas” section of the Survey and identified for potential standards development. For example, there appears to be no clear policy direction cited in the Survey regarding LNG standards, shale gas quality standards, and standards regarding multiple types of fuel through FERC jurisdictional pipelines. Such policy determinations must be made prior to NAESB taking any actions on related applicable standards.

8. It may be time to update the NAESB Base Contract for the Sale and Purchase of Natural Gas.

9. There is plenty of activity going on in regards to gas/electric and cyber without NAESB adding one more hurdle.

10. None

11. NAESB plays a vital role in maintaining order and standards in an ever growing/changing industry.

12. Liberty has no comment.

13. MISO is not expressing an opinion on whether NAESB should/should not develop additional requirements for existing Business Practice Standards or develop new business practice standards. NAESB has multiple mechanisms for generating new standards/requirements such as FERC orders, coordination with NERC, request for Annual Work Plan Items, and standards requests. With NAESB’s current workload we do not see a need to recommend that NAESB does/does not develop additional requirements for existing Business Practice Standards or pursue new areas to develop standards. MISO is familiar with the current processes to initiate standards development projects. If/when we think NAESB should develop additional standards and/or requirements, we will submit standard request(s) or Annual Work Plan Items.

14. Thank you for asking!

15. Open competitive markets need standards. not sure this is true for strongly regulated, government






controlled regimes. this puts naesb in an interesting spot with respect to trends in US and elsewhere - whether it is government support for renewable/alternative energy expansion or bailouts for energy sources like coal and nuclear power gen. both are bad, both are pushing us away from competition and toward intervention.

16. Bring the search function back to your website. It is always difficult to find documents when trying to implement or understand new standards or business processes, even with the search function, but now it's impossible.

17. NAESB does a good job writing energy market standards. I'm not certain that NAESB needs to be involved in reliability standards--NERC and PHMSA do those already.





APPENDIX A: BOARD STRATEGIC PLAN TASK FORCE MEETINGS

Date Committee Notes

Sep 1, 2016 Board of Directors https://www.naesb.org/pdf4/bd090116fm.docx

Oct 7, 2016 Strategic Plan Task Force https://www.naesb.org/pdf4/bd_strategic_100716mn.docx

Nov 29, 2016 Strategic Plan Task Force https://www.naesb.org/pdf4/bd_strategic_112916mn.docx

Dec 8, 2016 Board of Directors https://www.naesb.org/pdf4/bd120816fm.docx

Feb 16, 2017 Strategic Plan Task Force https://www.naesb.org/pdf4/bd_strategic_021617mn.docx

Apr 6, 2017 Board of Directors https://www.naesb.org/pdf4/bd040617fm.docx

Apr 19, 2017 Strategic Plan Task Force https://www.naesb.org/pdf4/bd_strategic_041917mn.docx

Sep 7, 2017 Board of Directors https://www.naesb.org/pdf4/bd090717fm.docx

Nov 17, 2017 Strategic Plan Task Force https://www.naesb.org/pdf4/bd_strategic_111717mn.docx

Dec 14, 2017 Board of Directors https://www.naesb.org/pdf4/bd121417dm.docx

Mar 14, 2018 Strategic Plan Task Force https://www.naesb.org/pdf4/bd_strategic_031418mn.docx

Apr 5, 2018 Board of Directors https://www.naesb.org/pdf4/bd040518dm.docx

May 31, 2018 Strategic Plan Task Force https://www.naesb.org/pdf4/bd_strategic_053118mn.docx

Aug 17, 2018 Strategic Plan Task Force To be posted shortly

NAESB Board Strategic Plan Task Force Report– September 6, 2018Appendix B – Board Strategic Plan Task Force Meetings

Page 35 of 36


https://www.naesb.org/pdf4/bd_strategic_053118mn.docx

https://www.naesb.org/pdf4/bd040518dm.docx


https://www.naesb.org/pdf4/bd121417dm.docx


https://www.naesb.org/pdf4/bd090717fm.docx










APPENDIX B: BOARD STRATEGIC PLAN TASK FORCE MEMBERS

Members of the NAESB Board Strategic Plan Task Force

Name Company Email Phone

J. Cade Burks Big Data Energy Services [email protected] 832-661-9127

James P. Cargas City of Houston [email protected] 832-393-6255

Valerie Crockett Tennessee Valley Authority [email protected] 423-751-6096

Lorraine Cross Cross & Company, P.L.L.C. [email protected] 202-609-9862

Dave Darnell Systrends USA [email protected] 480-756-6777

Michael Desselle Southwest Power Pool (Chairman of the Board Strategic Plan Task Force) [email protected] 501-614-3206

Mark G. Lauby North American Electric Reliability Corporation [email protected] 404-446-9723

Debbie McKeever Oncor Electric Delivery Company LLC [email protected] 214-486-5883

Timothy Simon TAS Strategies [email protected] 415-505-1723

Terence (Terry) Thorn JKM Energy & Environmental Consulting [email protected] 713-248-7138

Sue Tierney Analysis Group, Inc. [email protected] 617-425-8114

Roy True Alliance for Cooperative Energy Services Power Marketing LLC (ACES) [email protected] 317-344-7203

NAESB Board Strategic Plan Task Force Report– September 6, 2018Appendix C – Board Strategic Plan Task Force Members

Page 36 of 36


Documents

January 2, 2002 - naesb.org · Web viewThis is a new buzz word that has gotten ... Pipeline tariffs need to be flexible and meet the proper ... //. Dec 8, 2016