Following the 24 August Workshop Gas Industry Co and First Gas have agreed that First Gas will continue the work begun by MDL, aimed at addressing some of the issues identified in the Gas Quality work-stream.
In particular, First Gas intends to:
- Complete an internal review that will:
- Review MDL’s proposals, current MPOC/VTC and Interconnection Agreements’ provisions and associated documents governing Gas Quality;
- Examine international experience on suggested opportunities for improvement; and
- Compile a summary position paper that will;
- Describe how any identified opportunities for improvement have been examined further and how they align or may need to be amended compared with other jurisdictions;
- Identify ways in which the identified opportunities for improvement might be implemented.
- Subject to the outcomes from the internal review, look to develop and implement potential opportunities for improvement in the area of Gas Quality. It is envisaged that industry consultation and technical workshops would be held as part of this stage.
As noted at the GIC workshop, First Gas intends to consider how the Gas Quality work-stream will interface with the broader process to develop a new gas transmission code. Its current view is that a number of the possible improvements identified by MDL are “process” based, and could be progressed independently of the code development process. For example:
- Formalising and standardising the process for injecting parties to demonstrate compliance with the Gas Specification;
- Working with injecting parties to formalise and record the frequency of testing for gas components that are tested less frequently than the prescribed default intervals; and
- Developing agreed approaches to notify and manage Non-Specification Gas events.
The extent to which gas quality provisions are covered by the code is something that First Gas will consider as part of the code development process. However, First Gas’s preliminary view is that irrespective of the legal instrument used to govern parties’ rights and responsibilities vis-à-vis gas quality, it is likely that some tweaks will need to be made to the governing provisions to:
- Provide clear authority for physical curtailment of gas injection into the transmission system in the event of Non-Specification Gas incidents;
- Record any potential changes to the frequency of monitoring certain gas components or characteristics;
- Clarify legal responsibility for losses resulting from gas quality events (noting that this issue was not covered in the previous MDL proposals); and
- Add any required confidentiality provisions for information received from Producers as a result of any request to demonstrate compliance.
Gas Industry Co will continue to work with First Gas and will publish an update on the status of the Gas Quality work-stream before the end of 2016.