February 6, 2023

Volume XIII, Number 37

Error message

  • Warning: Undefined variable $settings in include_once() (line 135 of /var/www/html/docroot/sites/default/settings.php).
  • Warning: Trying to access array offset on value of type null in include_once() (line 135 of /var/www/html/docroot/sites/default/settings.php).

February 03, 2023

Subscribe to Latest Legal News and Analysis

FERC Updates Voluntary Gas Price Reporting Policy

On April 21, 2022, the Federal Energy Regulatory Committee (FERC) revised its guidelines pertaining to the voluntary reporting of natural gas transaction prices by market participants to price index developers (e.g., NGI, S&P, OPIS, Argus, ICIS, and others). Specifically, FERC issued a Revised Policy Statement (RPS) modifying the standards for such reporting to price index developers. In doing so, FERC largely adopted policies first proposed in late 2020. The RPS is effective on December 31, 2022. 

There has been a dramatic decline in voluntary reporting to price index developers by market participants of natural gas transaction prices since 2010. FERC hopes the changes in the RPS will help encourage more market participants to report their transactions to price index developers.  

The RPS revises price index policy standards for market participants. It will allow market participants to report either their next-day or their next-month transactions. Previously, for those market participants choosing to report, reporting both was required. Additionally, FERC will now permit market participants that provide such data to self-audit twice per year rather than annually. 

The RPS also modifies FERC price reporting standards to require price index developers to disclose when they use a market assessment other than trades at the index specified location to calculate the price index. Additionally, price index developers will need to seek approval or re-approval from FERC every seven years that they meet the standards set forth in the Initial Policy Statement (IPS). Finally, beginning six months after the effective date of the RPS, interstate natural gas pipelines and public utilities using price indices in jurisdictional tariffs will no longer be entitled to a rebuttable presumption that such indices provide for just and reasonable rates, unless the referenced price index developer has obtained the IPS-related FERC approval. 

© Steptoe & Johnson PLLC. All Rights Reserved.National Law Review, Volume XII, Number 129

About this Author

Kurt Kreiger, Energy Attorney, Steptoe Johnson Law Firm

Kurt Krieger focuses his practice in the areas of utility regulation and energy law. He has experience representing interstate natural gas pipeline companies, midstream companies, and gas and electric utilities before the Federal Energy Regulatory Commission (FERC), and state and commonwealth public service (or utility) commissions.  His experience includes counseling gas and electric companies on economic, safety and facility siting regulation, and counseling and drafting commercial agreements pertaining to energy-related transactions.


(304) 353-8124
Kevin W. Hivick Jr. Associate Attorney West Virginia Charleston Enery Natural Resources Law Steptoe & Johnson PLLC

Kevin Hivick focuses his practice in the areas of transactional and regulatory law with an emphasis on energy and natural resources. Prior to becoming an attorney, Kevin spent several years working in federal regulation with the United States Department of Agriculture. There, he witnessed firsthand the unique legal challenges facing businesses both large and small. Kevin also has a strong dedication to community service, having served as a firefighter in a rural fire district for years. He brings this same sense of duty and service to his clients every day.