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GPA comment on gas plant data collection changes

Hydrocarbon Engineering,

On July 18, the GAP filed additional comments with the EIA in response to proposed changes to data reporting associated with gas processing plants. The EIA published its intent to combine two older gas plant data collection forms into one new form, EIA Form 915, in the Federal Register in August 2012. The new form greatly expands the amount of data to the public on a plant by plant basis within six months of receiving the information.

The GPA got its initial response to the EIA on May 1 of this year, via the appointment of a high level ad hoc task force. The response focused on the confidentiality of contracts between gas plants and producers, the competitive nature of the gas processing industry, and the additional burden on gas plant personnel to collect the additional date. The GPA maintained that the proposal from the EIA to collect and release plant specific data to the general public poses confidentiality issues that would negatively impact companies operating in the midstream energy sector.

The EIA responded to the GPA’s initial comments in mid June and requested additional supporting information from the association explaining how publicly disclosing the requested information would cause substantial competitive harm to companies supplying the information.

The most recent comments from the GPA have detailed information on five data elements considered the cornerstone to commercial negotiations in the gas processing sector. The comments said the elements ‘dictate what a plant can promise to a customer, and in turn, how it might stack up against a competitor seeking the same business. The ability to negotiate these commercial terms in a proprietary forum is essential to quantifying risk and return in any agreement and a free market negotiation.’

Further GPA comments

The latest comments said, ‘to be clear, GPA does not oppose the release of appropriately aggregated data by the Petroleum Administration for Defence District (PADD). However, EIA’s plans to rapidly release data after collection that the industry has always treated as confidential is a change from its current practice and will have significant adverse competitive effects. The plant specific data that EIA is collecting on Form EIA-915 and then plants to release is the type of information that agencies should refrain from releasing. GPA believes this is the type of information that should be exempt from disclosure under the Freedom of Information Act.’

Mark Sutton, GPA President and CEO said, ‘preserving the ongoing confidentiality of such information is critical to maintain a level playing field in the high competitive midstream sector of the oil and gas business. We remain committed to the cooperative relationship we have enjoyed with the EIA and appreciate their willingness to hear our concerns.’

Edited by Claira Lloyd

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