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Retail Supplier Files Complaint Against Utility, Says Other Marketers Face Similar Harm; Case Of First Impression
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SCANA Energy Marketing, LLC ('SCANA' or 'Petitioner') filed a formal complaint against Atlanta Gas Light Company ('AGL' or 'Respondent') at the Georgia PSC in which SCANA seeks to be relieved of Operational Flow Order ('OFO') imbalance penalties as SCANA alleged that AGL did not provide an avenue for SCANA to mitigate the imbalance
SCANA alleged, "This case presents a question of first impression for the Commission: whether OFO penalties should be imposed where a utility controls the conditions of compliance but deprives a marketer of the ability to respond."
SCANA alleged, "AGL’s operational control foreclosed any meaningful opportunity for SCANA to mitigate its imbalance. Although AGL required and confirmed delivery of gas into its system, it failed to implement available operational measures necessary to enable SCANA to respond."
SCANA alleged, "AGL’s decisions and omissions that prevented SCANA from mitigating or avoiding penalties include, among other things: (1) failing to designate a pipeline for deliveries into the Atlanta Pool; (2) failing to adequately revise supply requirements to reflect changing system conditions; (3) failing to reduce or reject nominations; (4) failing to communicate operational constraints or available mitigation options; and (5) failing to provide notice to SCANA before the post-cycle nomination deadline."
SCANA alleged that AGL communicated with AGL's asset manager regarding options to address system imbalances, but did not provide comparable information to SCANA.
The penalty specifically relates to a bracketed OFO issued by Transco affecting deliveries into the Atlanta market for December 13, 2025
SCANA alleged that, following the OFO Event, Transco assessed OFO imbalance penalties to six Georgia natural gas marketers delivering gas into the AGL system, including SCANA
SCANA alleged, "The OFO penalties associated with the OFO Event were significant. They affected multiple marketers serving customers within the AGL distribution system, exposing those marketers to substantial financial liability that may ultimately affect retail natural gas customers."
SCANA alleged that it incurred $329,900 in OFO penalties arising from a 6,598 Dth imbalance during the applicable OFO Event
SCANA alleged, "During the relevant period, AGL issued a supply-mismatch order for the OFO Event and exercised control over nominations into the Atlanta pool."
SCANA alleged, "AGL did not designate a pipeline for deliveries into the Atlanta pool, leaving that decision to marketers. SCANA elected to supply the pool using Southern Natural Gas (51 percent) and Transco (49 percent) volumes. On the morning of the OFO Event, AGL reduced SCANA’s Daily Supply Requirement by 12 percent, and SCANA adjusted its volumes: Southern Natural Gas (44 percent) and Transco (56 percent). Throughout the OFO Event, AGL retained authority to revise the Daily Supply Requirement, reduce nominations, or decline to confirm volumes. AGL did not meaningfully exercise any of these options. Across all five nomination cycles, AGL repeatedly confirmed SCANA’s nominated volumes and did not communicate any limitation on its ability to accept those volumes, even though AGL was aware that forecasted demand conditions had changed due to the anticipated cold weather being delayed."
SCANA alleged, "AGL did not communicate operational constraints affecting its system to SCANA. SCANA was best suited to adjust nominations or cure imbalances during the applicable nomination cycles. Instead, AGL chose to communicate to its asset manager -- an entity not subject to OFO penalties and not having title to SCANA’s gas -- about these operational constraints."
SCANA alleged, "Because that information was not communicated, SCANA was deprived of the opportunity to respond within the applicable nomination and scheduling cycles. As a result, SCANA incurred OFO penalties that would have been avoided or materially mitigated with reasonable operational notice from AGL."
SCANA alleged, "Although the OFO penalties were assessed pursuant to the Transco tariff, the conditions that prevented marketers from complying with nomination requirements occurred within the AGL distribution system and were subject to AGL's operational control and communication practices. Accordingly, the allocation and recovery of those penalties within the Georgia retail natural gas market falls within the regulatory authority of this Commission."
SCANA alleged, "These circumstances warrant a Commission investigation into AGL’s operational coordination practices."
SCANA alleged, "Following the OFO Event, discussions among market participants and Commission staff included a proposal under which marketers would bear fifty percent (50%) of the OFO penalties immediately and the remaining fifty percent (50%) through adjustments within the Market Adjustment Recovery System ('MARS')."
SCANA stated, "SCANA opposed that proposal because it would require marketers and their customers to absorb all penalties resulting from operational conditions outside their control, immediately and in the future, from adjustments to MARS."
SCANA sought an order from the PSC requiring AGL to provide a 100 percent credit or reimbursement to SCANA for OFO penalties assessed as a result of the event
SCANA also asked the PSC to direct AGL to implement operational or procedural changes necessary to prevent recurrence of similar penalty events, including improvements to communication protocols, nomination management, and operational coordination with marketers
The complaint has been docketed in existing Docket 56177, relating to AGL's Capacity Supply Plan
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April 6, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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