Register Today for Courses in Cost of Service and Rate Design for Natural Gas Interstate Pipeline Companies (January 26th-27th)
Brown, Williams, Moorhead & Quinn, Inc.

The Energy Policy Act of 1992 ordered the Commission to devise simpler filing methods for oil pipeline rate changes and ushered in annual "indexed rate" filings to adjust rates. The streamlined procedures created difficult hurdles to challenging pipeline rates and protected final, non-appealable rates from routine challenges by shippers. Shippers must demonstrate reasonable grounds that a "substantial divergence" has grown between the indexed tariff rate and the actual underlying cost of service, in order to challenge the validity of the indexed rate. The evolved definition of these terms has created a complex, dimly understood gauntlet for pipeline customers. Brown Williams’ staff can help clients navigate these complex but critical terms-of-art that establish the threshold for acceptance of a filing at the Commission.