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Frequently Asked Questions (FAQs)
Form No. 552
Updated: 11/22/2010
Staff has made numerous changes to the FAQ as a result of Order 704-C 
and added several additional questions under Posting 4. The FAQ in Postings 1, 2, and 3 have been retained, although the answers have been modified.
1. What is meant by "could contribute to a gas index"?
The phrase "could contribute to a gas index" applies to natural gas transactions that Respondents have chosen not to report to Price Index Publishers. If the transaction is one that any Price Index Publisher would have accepted, then Respondents should include the transaction in its totals when completing the form on page 4 with respect to lines 2, 4, 6, and 7. Order 704-C at paragraph 15 provides additional details.
"By 'could be reported to an index publisher,' we mean bilateral, arms-length, fixed price, physical natural gas transactions between non-affiliated companies at all trading locations."
"By 'could be reported to an index publisher,' we mean bilateral, arms-length, fixed price, physical natural gas transactions between non-affiliated companies at all trading locations."
2. Must a company holding a blanket certificate under either sections 284.284 or 284.402, but which has made no natural gas purchases or sales for calendar year 2008 or 2009, submit Form No. 552?
No. Order 704-C exempts entities who were obligated to report solely by virtue of possessing a blanket sales certificate issued under § 284.402 or § 284.284 and struck the form's references to the blanket sales certificate. Only Respondents who have either reportable sales or purchases equal to or greater than 2.2 million MMBtu are required to file the form.
3. Is there a way to note on Form No. 552 that data provided are incomplete or missing?
Form No. 552 was revised by Order 704-C and now includes a remarks field on page 2 - List of Schedules that would allow this type of notation. The Commission expects Respondents submitting the form to do so in good faith and on a timely basis. Furthermore, the Commission has not extended the Safe Harbor provided earlier in Order 704-A. However, as stated in Order 704-C, the Commission will focus any enforcement efforts on instances of intentional submission of false, incomplete, or misleading information to the Commission, of failure to report in the first instance, or of failure to exercise due diligence in compiling and reporting data.
In addition, upon discovering missing data, the Respondent should promptly refile a corrected Form No. 552 by selecting the "Resubmission" feature.
In addition, upon discovering missing data, the Respondent should promptly refile a corrected Form No. 552 by selecting the "Resubmission" feature.
4. Must individual subsidiaries of a Respondent submit information on Form No. 552?
A Respondent may aggregate volumes for its affiliates into a single form. If this method of reporting is chosen, then all affiliates that must report are required to aggregate their volumes with the Respondent's and all affiliates must be identified. Alternately, each affiliate of a Respondent (including subsidiaries) may submit Form No. 552 as an individual Respondent if the affiliate's reportable volumes exceed the 2.2 million MMBtu threshold.
5. Are affiliates allowed to aggregate their reporting information under corporate parent?
Yes. Companies have the ability to report under a corporate parent; however, they are required to list the subsidiaries reported under that corporate parent on Page 3 "Schedule of Reporting Companies", just as they are for other affiliates. (Order No. 704, paragraph 60(c))
6. Are fixed price trades done in 2008 for January 2009 reportable?
Yes, monthly January 2009 fixed priced transactions done during the December 2008 bid week for physical obligations are reported in Form No. 552 to be filed by May 1, 2010. In particular, the Commission stated, "Unlike in the NOPR, Form No. 552 now requires reporting based on date of contracted delivery and not date of execution." (See, Order No. 704 P. 99.)
7. If an end-user filing Form No. 552 purchases natural gas at retail, must it report the purchase of the natural gas?
Yes, unless the transaction neither uses an index nor could contribute to the formation of a gas index. One example of a transaction that does not use an index and cannot contribute to the formation of an index is a transaction in which a local distribution company is the seller, the transaction bundles commodity and transportation costs, the purchaser is a retail end-user, and the transaction is priced at a retail tariff rate.
8. If a public joint action agency separately purchases and then resells natural gas to its members as separate, independent transactions, are both of those transactions reportable?
Yes, both transactions are reportable, if they either use a index or could contribute to the formation of a gas index.
9. If a company holds an energy management agreement (EMA) and sells and purchases physical natural gas on behalf of other companies, is it required to file Form No. 552?
Where a company does not take title to natural gas in a transaction, it is neither a buyer nor seller and, therefore, need not report the transaction; its client should report the transaction. However, if under the EMA the company takes title to the natural gas it should report volumes that can contribute to a gas index or uses an index.
10. Can an asset manager file Form No. 552 on behalf of another company?
Provided a responsible company officer (of the buyer/seller respondent) signs the form, an asset manager may complete and file the form on behalf of an entity for which it manages assets (Form No. 552 - General Information section). Under these circumstances, the asset manager must follow the aggregation rules outlined in the Commission's orders (for example, an asset manager cannot aggregate volumes for all of its customers). (Order No. 704, paragraphs 97-98)
11. If a parent company chooses to aggregate volumes for reporting on Form No. 552, must it list affiliates that have blanket certificates but have no reportable volumes?
No. Order 704-C exempted entities who were obligated to report solely by virtue of possessing a blanket sales certificate issued under § 284.402 or §284.284 and struck the form's references to the blanket sales certificate.
12. Is a fixed price contract (that can not contribute to an index, reference an index, or use an index) but has a GDD knockout provision - that is the contract can be canceled for a period of time based on daily index prices - is this reportable?
Under these circumstances because the fixed price contract can not contribute to an index, reference an index, or use an index, the fixed price portion of the contract is not reportable. The GDD knockout provision in and of itself does not make this contract reportable. In fact, if the GDD knockout provision is triggered then there is no sale or purchase and, therefore, no volumes to report.
13. Are "Exchange for Physical" transactions included in Form No. 552?
Exchange for Physical transactions are those transactions that involve an exchange of a futures contract and a related equivalent but opposite physical obligation. As defined by CME/NYMEX rule 868.12, exchange-traded natural gas futures contracts are not reportable because the physical obligation is strictly related to the futures contract, the physical obligation's price cannot contribute to an index, and the physical obligation does not use an index for its price.
14. How are prepays reported in Form No. 552?
If the fixed price prepay transaction uses or could contribute to an index, then it is reportable in the year of delivery.
15. Does a Local Distribution Company (LDC) that buys natural gas for consumption by its own generation units report those volumes in Form No. 552?
Yes, so long as the transaction either uses an index or could contribute to the formation of a gas index. (Order No. 704-A, paragraph 30)
16. What are physical basis transactions?
Staff understands that a physical basis transaction involves the forming of a price for a physical delivery obligation which is dependent on a NYMEX futures contract final settlement price.
As an example of a publisher describing physical basis transactions that can contribute to an index see The Platts' Methodology Guidelines (November 2008) which states, "report all physical basis transactions in which the basis value is negotiated on one of the first three days of bidweek and the price is set by the final closing value of the near-month NYMEX futures contract plus or minus the negotiated basis." Therefore, NYMEX last day settlement and a differential (premium or discount) are physical basis transactions and are reportable on page 4, line 7 of Form No. 552.
As an example of a publisher describing physical basis transactions that can contribute to an index see The Platts' Methodology Guidelines (November 2008) which states, "report all physical basis transactions in which the basis value is negotiated on one of the first three days of bidweek and the price is set by the final closing value of the near-month NYMEX futures contract plus or minus the negotiated basis." Therefore, NYMEX last day settlement and a differential (premium or discount) are physical basis transactions and are reportable on page 4, line 7 of Form No. 552.
17. What are NYMEX trigger transactions and are these transactions reportable?
A NYMEX trigger transaction is a transaction contingent upon a futures contract that trades on an exchange, resulting in an automatic physical trade at an agreed upon price. If such a Fixed Price physical transaction was triggered or originated by a NYMEX futures contract that can contribute to a monthly gas index, it is reportable on page 4, line 6 of Form No. 552.
18. What are NYMEX Plus transactions and are these transactions reportable?
NYMEX Plus transactions are monthly transactions that use a NYMEX price and a differential (premium or discount) to establish a Fixed Price.
For any of these transactions to be reportable they must be able to contribute to a monthly gas index. If they cannot contribute to an index they are not reportable. All NYMEX Plus transactions that can contribute to a monthly gas index are reportable on page 4, line 6 of Form No. 552. Only NYMEX Plus transactions contracted during bidweek are reportable in the Form No. 552.
19. Would a transaction that is priced at "index + 10 cents" be considered a "physical basis transaction" to be reported on page 4, line 6 of the form?
The example of an index plus 10 cents transaction is not referring to physical basis because it does not include the NYMEX futures final settlement price. NYMEX final settlement plus 10 cents is by definition a physical basis transaction.
However, regardless of the fact that such a transaction is not a "physical basis transaction," it is a reportable transaction to the extent it uses an index and should be reported on page 5 in lines 3 or 5.
However, regardless of the fact that such a transaction is not a "physical basis transaction," it is a reportable transaction to the extent it uses an index and should be reported on page 5 in lines 3 or 5.
20. How are transactions that involve differing pricing structures and/or include a blended pricing mechanism reported?
Form No. 552 is designed to capture volumes of natural gas that contribute to, could contribute to, or use an index price. Staff recommends that for these types of complex structured transactions, companies report their good faith estimates. To the extent that a company has and exercises the option on the pricing mechanism for physical gas and cannot predict how it will price its obligation prior to delivery, Staff recommends these companies use actual volumes as opposed to contracted volumes in the year the delivery occurred.
21. Must a Respondent report cash-out transactions if those transactions are not Next-Day Delivery or Next-Month Delivery?
No. The Commission in Order 704-C stated that Respondents are no longer required to report cash-out and imbalance transactions.
22. Are cash-out transactions priced at pipeline tariff rates reportable?
No. The Commission in Order 704-C stated that Respondents are no longer required to report cash-out and imbalance transactions.
23. Are daily Fixed Price physical natural gas transactions that are executed after 11:30 AM Central Prevailing Time reportable?
No, they are not reportable.
24. What is the meaning of "control" as that word is utilized in the definition of "Affiliate" in Form No. 552?
"Control" as used in this definition means the direct or indirect authority, whether acting alone or in conjunction with others, to direct or cause to direct the management policies of an entity. A voting interest of 10 percent or more creates a rebuttable presumption of control.
25. How should joint ventures report their volumes in Form No. 552?
The rule allows for companies to report all affiliates in aggregate or for each affiliate to report its own ownership interests. Either method is acceptable for reporting of joint venture-related volumes. In particular, when reporting volumes associated with joint ventures, companies should report volumes pursuant to their equity interest.
26. What effect does a planned merger have on the reporting requirement?
Transactions between non-affiliated companies prior to the consummation of a merger are reportable; once the merger is consummated the companies are affiliated and transactions between them are no longer reportable.
27. Are transactions involving unprocessed gas reportable in Form No. 552?
Order 704-C clarifies that unprocessed gas transactions are not reportable. Unprocessed gas transactions are defined as both involving gas that has not yet been processed (that is, natural gas liquids have not been removed) and also are upstream of a processing facility (such that the volumes are reasonably expected to travel through a processing facility before consumption).
Some volumes of natural gas may emerge from the wellhead sufficiently "lean" that it may never need processing to remove natural gas liquids before being consumed. A transaction involving this "lean" natural gas is reportable if it uses an index or it contributes to or may contribute to the formation of a gas index in the reporting year. Please see Order No. 704-C at paragraphs 38 and 39.
"Percentage of proceeds" contracts that involve unprocessed gas continue to be exempt from reporting in Form No. 552.
Some volumes of natural gas may emerge from the wellhead sufficiently "lean" that it may never need processing to remove natural gas liquids before being consumed. A transaction involving this "lean" natural gas is reportable if it uses an index or it contributes to or may contribute to the formation of a gas index in the reporting year. Please see Order No. 704-C at paragraphs 38 and 39.
"Percentage of proceeds" contracts that involve unprocessed gas continue to be exempt from reporting in Form No. 552.
28. How does a company determine whether or not it is operating under a blanket market certificate?
Respondents are longer required to make this determination. Order 704-C exempted entities who were obligated to report solely by virtue of possessing a blanket sales certificate issued under § 284.402 or § 284.284 and struck the form's references to the blanket sales certificate.
29. In Order No. 704-A, P 87, it is unclear what is meant by the last line: "....the year in which the index is referenced." Does it mean the year in which the index is published, or the year the index is used?
The statement is intended to reference the date of contracted delivery. In Order No. 704, the Commission stated, "Unlike in the NOPR, Form No. 552 now requires reporting based on date of contracted delivery and not date of execution." (See Order No. 704, Paragraph 99 and FAQ Question 6.)
30. Pre-bid week transactions. Pursuant to Line No. 5 of the "Purchase and Sales Information" portion of Form No. 552 and the definition of "Next-Month Delivery," please confirm that quantities contracted for prior to the last five (5) business days of the month for uniform physical delivery the next month are not to be reported. Since many monthly index deals are prior to the five (5) business day period, this definition will exclude a number of transactions from reporting on Form No. 552.
Order 704-C eliminates the references to "Next-Day Delivery" and "Next-Month Delivery" in page 4, lines 3 and 5 of the 2008 version of Form No. 552 and revises the question on page 4, line 3 to ask for "quantities that were contracted at Prices that Refer to published Daily Indices*". The question on page 4, line 5 is similarly revised to ask for "quantities that were contracted at Prices that Refer to published Monthly Indices*"
Therefore, all physical natural gas transactions that use daily or monthly indices to set the price of natural gas must be reported on the Form No. 552, no matter when they were contracted. Order 704-C also clarifies that in those cases where a gas index is a part of a basket of indices that includes non-gas indices, the transactions should be reported in lines 3 or 5 and the non-gas indices identified on page 4 in lines 8 or 9.
Therefore, all physical natural gas transactions that use daily or monthly indices to set the price of natural gas must be reported on the Form No. 552, no matter when they were contracted. Order 704-C also clarifies that in those cases where a gas index is a part of a basket of indices that includes non-gas indices, the transactions should be reported in lines 3 or 5 and the non-gas indices identified on page 4 in lines 8 or 9.
31. Take or Release Contracts. Gas is sometimes purchased under long-term contracts that offer an option to take or release up to the contract maximum quantity on a monthly or daily basis. The contract price is mutually agreed upon at the time the monthly or daily option is exercised. Please confirm that only those purchases that are actually exercised during the reporting year are to be included on Form No. 552, and that supplies released back to the supplier are not reportable because the option was not exercised.
Order 704-C clarifies that only volumes actually delivered pursuant to the option in a Take or Release Contract should be reported on the form if they use an index, or that contribute to or may contribute to gas index formation. If the take option was not exercised and the supplies were released back to the supplier, then those volumes are not reportable.
32. Is NYMEX considered an "index" publisher for the purposes of Order No. 704?
No. However, any number of physical natural gas obligations reference the settlement price of the NYMEX Natural Gas Futures contract during bidweek and are reportable (e.g., NYMEX Trigger, Physical Basis, NYMEX Plus). (See NYMEX related FAQs 16, 17, and 18).
33. Please explain the fundamental difference between a physical basis transaction and a NYMEX Plus transaction.
A physical basis transaction always uses the final NYMEX Natural Gas Futures settlement price which is defined on the third day at 2:30 p.m. A NYMEX Plus transaction never uses the final NYMEX settlement price. For example, a NYMEX Plus transaction could use the settlement price on the day preceding the final NYMEX settlement price. (See also FAQs 16, 17, and 18).
34. Are all physical natural gas sales and purchases reportable on the Form No. 552?
No. The Commission is only collecting data on arms-length transactions that use indices to price physical natural gas or that do or may contribute to gas prices indices. These reportable transactions are listed in the definitions on the form and on page 4, lines 2 through 7. For purposes of the form, line 1 on page 4 entitled Physical Natural Gas is equal to the sum of lines 2 through 7. See definitions for a list of transactions that should be included and excluded from the form.
35. What transactions are often not reported correctly on the Form No. 552?
Several transactions are often misreported on the form:
- Long dated deals that use a strip of NYMEX Plus or Physical Basis to price natural gas are often misreported in line 6 and 7, respectively. These transactions are not reportable in Form No. 552 at all, because they would not be acceptable to an Index Publisher and would not contribute to monthly gas index formation.
- Transactions that use a weekly index are often not reported. A closer inspection of the methodology used to compute the weekly index usually shows that a "weekly" index is normally formed by averaging multiple daily indices. Therefore, these kinds of transactions should be reported on page 4, line 3 as referencing a daily index.
- Balance of month transactions that use a daily index to set the price of natural gas are reportable on page 4 line 3.
36. Why is the Commission requiring Respondents to report the use of indices instead of just gas indices used to set the price of natural gas?
The Commission is requiring this so that it can monitor changes in the natural gas markets. In Order 704-C, the Commission clarified that the referenced index need not be solely a gas index. Thus, a transaction that relies on a basket of indices which includes a gas index and other daily or monthly indices such as coal, petroleum, LNG, inflation, etc. would also be reportable on Lines 3 and 5 of the Form No. 552.
The Commission is asking Respondents that use a basket of daily or monthly indices that includes gas and other indices to identify the names of the indices used on page 4 in lines 8 or 9 However, transactions that use a "basket of indices" that only contains non-gas price indices are not reportable.
The Commission is asking Respondents that use a basket of daily or monthly indices that includes gas and other indices to identify the names of the indices used on page 4 in lines 8 or 9 However, transactions that use a "basket of indices" that only contains non-gas price indices are not reportable.
37. When must physical natural gas that requires international transportation be reported on the form?
The Commission clarifies this in Order 704-C at paragraph 26 as follows:
Thus, any volumes that either originate in or are delivered into the lower 48 states should be reported to the same extent as purely domestic volumes. (See questions 38 and 39 for further guidance)
Staff is providing additional guidance on reporting international natural gas transactions on Form No. 552. Respondents should use the following guidance to report their 2010 calendar year Form No. 552 data. Respondents are not required to revise or correct data for prior reporting periods.
- Volumes originating outside the lower 48 states and delivered at locations outside the lower 48 states should not be reported.
- Volumes originating from inside the lower 48 states and delivered outside the lower 48 states are reportable; and
- Volumes originating outside the lower 48 states and delivered inside the lower 48 states are reportable.
Thus, any volumes that either originate in or are delivered into the lower 48 states should be reported to the same extent as purely domestic volumes. (See questions 38 and 39 for further guidance)
Staff is providing additional guidance on reporting international natural gas transactions on Form No. 552. Respondents should use the following guidance to report their 2010 calendar year Form No. 552 data. Respondents are not required to revise or correct data for prior reporting periods.
38. What should be considered when reporting sales or purchases of natural gas that are transported between the U.S. and Canada or the U.S. and Mexico?
Respondents should report only volumes actually delivered by import into or export from the United States, if they use an index, contribute to, or may contribute to natural gas index formation.
Example A
A U.S. LDC purchases 10 TBtu of natural gas from a supplier in Canada using a monthly index price. Subsequent to the initial purchase from the Canadian supplier, the LDC resells the entire 10 TBtu to a Canadian power generator and none of the gas is delivered/imported into the U.S.
The U.S. LDC would not report the 10 TBtu of gas that was purchased in Canada or the sale to the Canadian power generator, because the natural gas was not delivered/imported into the U.S. The Canadian supplier would not report the sale and the Canadian power generator would not report the purchase for the same reason.
Example B
A Canadian marketer purchases 2.5 TBtu of shale gas from a producer in Pennsylvania. The gas does not require processing and the purchase price is based on fixed price next month delivery during bidweek. 1.5 TBtu are exported and delivered to Canada, with the remainder sold by the Canadian marketer to a U.S. wholesale customer using an index.
The Canadian marketer reports all 2.5 TBtu of the purchase, including the 1.5 TBtu delivered/imported into Canada and the 1TBtu sold to a U.S. customer. The shale gas producer would report 2.5 TBtu as a sale, and the U.S. customer would also report the purchase of 1.0 TBtu, following the procedures for domestic purchases and sales.
Example C
A U.S. LDC purchases 30 TBtu of natural gas in Canada using a monthly index, stores the gas in Canada, and does not take delivery in the U.S. until the following year.
Natural gas that is purchased and stored in Canada and not delivered into the U.S. until the following year is not reportable as a purchase on Form No. 552 because the volumes did not enter the U.S. in the reporting year. Volumes taken out of storage by the LDC and delivered into the U.S. in the following year are not reportable as a purchase in the following year's Form No. 552 because the purchase did not occur in the reporting year.
Natural gas that is purchased out of storage from a third party and imported into the U.S. is reportable as both a sale by the third party and purchase by the LDC in the reporting year in which the transaction occurred to the extent the transaction otherwise meets the reporting criteria. Sales made by the LDC in the U.S. are reportable to the same extent as volumes that were sourced domestically.
Example D
An LDC purchases 12 TBtu of natural gas in Canada using a monthly index in a 6 month period over two calendar years. Deliveries into the U.S. will be made in equal volumes beginning in December of year 1 and end in May of year 2.
The LDC and Seller must report only the volumes that were delivered in year 1, i.e. 2 TBtu that rely on a monthly index. The remaining volume of 10 TBtu that are delivered in year 2 should be reported in year 2.
See reporting over multiple calendar years in XI. of the General Instructions of Form No. 552:
"Regarding reportable transactions that involve deliveries that occur or may occur over multiple calendar years, only volumes for delivery that use, contribute to, or may contribute to the formation of an index during the subject calendar year should be reported. For a multi-year contract that relies on an index to establish a natural gas price, volumes should be reported in the year in which the index is referenced."
Example A
A U.S. LDC purchases 10 TBtu of natural gas from a supplier in Canada using a monthly index price. Subsequent to the initial purchase from the Canadian supplier, the LDC resells the entire 10 TBtu to a Canadian power generator and none of the gas is delivered/imported into the U.S.
The U.S. LDC would not report the 10 TBtu of gas that was purchased in Canada or the sale to the Canadian power generator, because the natural gas was not delivered/imported into the U.S. The Canadian supplier would not report the sale and the Canadian power generator would not report the purchase for the same reason.
Example B
A Canadian marketer purchases 2.5 TBtu of shale gas from a producer in Pennsylvania. The gas does not require processing and the purchase price is based on fixed price next month delivery during bidweek. 1.5 TBtu are exported and delivered to Canada, with the remainder sold by the Canadian marketer to a U.S. wholesale customer using an index.
The Canadian marketer reports all 2.5 TBtu of the purchase, including the 1.5 TBtu delivered/imported into Canada and the 1TBtu sold to a U.S. customer. The shale gas producer would report 2.5 TBtu as a sale, and the U.S. customer would also report the purchase of 1.0 TBtu, following the procedures for domestic purchases and sales.
Example C
A U.S. LDC purchases 30 TBtu of natural gas in Canada using a monthly index, stores the gas in Canada, and does not take delivery in the U.S. until the following year.
Natural gas that is purchased and stored in Canada and not delivered into the U.S. until the following year is not reportable as a purchase on Form No. 552 because the volumes did not enter the U.S. in the reporting year. Volumes taken out of storage by the LDC and delivered into the U.S. in the following year are not reportable as a purchase in the following year's Form No. 552 because the purchase did not occur in the reporting year.
Natural gas that is purchased out of storage from a third party and imported into the U.S. is reportable as both a sale by the third party and purchase by the LDC in the reporting year in which the transaction occurred to the extent the transaction otherwise meets the reporting criteria. Sales made by the LDC in the U.S. are reportable to the same extent as volumes that were sourced domestically.
Example D
An LDC purchases 12 TBtu of natural gas in Canada using a monthly index in a 6 month period over two calendar years. Deliveries into the U.S. will be made in equal volumes beginning in December of year 1 and end in May of year 2.
The LDC and Seller must report only the volumes that were delivered in year 1, i.e. 2 TBtu that rely on a monthly index. The remaining volume of 10 TBtu that are delivered in year 2 should be reported in year 2.
See reporting over multiple calendar years in XI. of the General Instructions of Form No. 552:
"Regarding reportable transactions that involve deliveries that occur or may occur over multiple calendar years, only volumes for delivery that use, contribute to, or may contribute to the formation of an index during the subject calendar year should be reported. For a multi-year contract that relies on an index to establish a natural gas price, volumes should be reported in the year in which the index is referenced."
39. My company purchased 50 TBtu of natural gas from Canada in a calendar year and all of it was delivered into the U.S. Do I have to examine all of my transactions and allocate the volumes to the various transactions types reportable in the form? Is there another approach I could use to allocate the 50 TBtu to the transaction types on the form?
A company may estimate the allocation of purchases among transactions types based on how it prices natural gas historically for its Canadian purchases. For example, if historically, the Company uses monthly indices to price 75 percent of the purchases and 25 percent using fixed price next month delivery contracts completed during bidweek, then it may use those percentages to allocate the 50TBtu to the appropriate transaction types on the form.
If the Company delivers only a portion of the natural gas purchased in Canada in a calendar year, the Company may apply the allocation percentages to the volumes delivered into the U.S. during the calendar year to determine the transaction types on the form under which the volumes should be included.
If the Company delivers only a portion of the natural gas purchased in Canada in a calendar year, the Company may apply the allocation percentages to the volumes delivered into the U.S. during the calendar year to determine the transaction types on the form under which the volumes should be included.
