Adelphia Gateway Notice 923
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POSTING DATE: January 26, 2026
Operating Conditions – System Wide Operational Flow Order Update
Supplemental to Critical Notice ID 919 posted on January 23, 2026
Effective January 26, 2026
On January 23, 2026, pursuant to Section 13 (Operational Flow Orders) of the General Terms and
Conditions of the Tariff, Adelphia issued an OFO in anticipation of the current intensely cold weather and
record levels of market demand on its system. The OFO directs Shippers to stay within their contractual
limitations and maintain ratable gas flows over a 24-hour day as required under their service agreements.
Because of the restrictions placed on Adelphia through OFOs issued by its upstream interconnecting
pipelines, unratable hourly takes, unauthorized overruns and operator underperformance by Adelphia’s
Shippers threatens Adelphia's ability to maintain its system integrity and meet its firm obligations to
Shippers.
Despite the restrictions and penalties already in place under its existing Tariff, Adelphia is increasingly
concerned that the current extreme elevated prices for electricity in the PJM wholesale power markets
and severe PJM penalties for non-performance by power generators may incentivize some of its Shippers
to deliberately overrun their firm entitlements on Adelphia if the penalties for such unauthorized flows
on Adelphia are not increased to a level sufficiently high to deter the unauthorized behavior. Adelphia
has very limited line pack and no storage, and therefore non-ratable takes, even by a single Shipper, could
jeopardize the operational integrity of Adelphia’s system. Thus, unauthorized overrun activity at this time
could cause Adelphia’s system to fail rapidly, with potentially severe consequences to other firm shippers
and the integrity of Adelphia's system. Further, because of the higher OFO penalty structures of
Adelphia’s upstream interconnecting pipelines relative to Adelphia’s OFO penalty structure, there is real
potential for Adelphia to suffer substantial damages in the event that Shippers were to engage in harmful
conduct. Adelphia’s current OFO penalty structure, as set forth in Section 13.8 of its Tariff, relies on Gas
Daily indices, which is unlikely to sufficiently deter harmful conduct given the economic considerations
described herein and the higher OFO penalty structures on Adelphia’s interconnecting pipelines discussed
below.
To ensure Shippers stay within contractual limitations, and refrain from unratable hourly takes and
unauthorized overruns or operator underperformance, on January 26, 2026, contemporaneously with this
OFO, Adelphia submitted a filing with the Federal Energy Regulatory Commission (FERC) to increase the
OFO penalties that Adelphia will impose. Specifically, Adelphia proposed with the Commission to modify
the OFO penalty price referenced in Section 13.8 of its Tariff to be the High Common price posted for the
Day on which the violation occurred as defined in its Tariff instead of the average cashout price which is
currently identified as the penalty price which is multiplied by 500% and each Dekatherm of Gas by which
Shipper/point operator deviated from the requirements of the OFO. In addition, Adelphia proposes new
language in Section 13.8 to give Adelphia the ability to recover any OFO penalties imposed on it by its
interconnecting pipelines that supply Adelphia due to Shipper violations of Adelphia’s OFO. Such
interconnecting pipelines vary by zone on Adelphia’s system: Zone North A (Texas Eastern Transmission,
LP, Columbia Gas Transmission, LLC or Transcontinental Gas Pipe Line Company, LLC), Zone North B
(Transcontinental Gas Pipe Line Company, LLC) and Zone South (Texas Eastern Transmission, LP). In the
event one or more of the aforementioned pipelines imposes OFO penalties on Adelphia because of an
Adelphia Shipper’s failure to abide by the restrictions in an Adelphia OFO, Adelphia proposes to charge
the higher of its own OFO penalty and the interconnecting pipeline’s OFO that Adelphia is subject to due
to the Shipper’s violation(s) of Adelphia’s OFO.
In addition, nothing in its Tariff precludes Adelphia from pursuing any and all remedies at law or equity
against any Shipper that knowingly and willfully disregards Adelphia's OFOs and causes damage to
Adelphia's system or impairs its ability to maintain the integrity of its system and meet its firm obligations
to other shippers.
If a Shipper/Point Operator fails to comply with this Operational Flow Order, the Shipper/Point Operator
shall be subject to the updated penalty as noted by revised Section 13.8 and as described herein and as
posted in the regulatory section of Adelphia’s EBB.
Contact your Transportation Services Representative should you have any questions.
POSTING DATE: January 26, 2026
Operating Conditions – System Wide Operational Flow Order Update
Supplemental to Critical Notice ID 919 posted on January 23, 2026
Effective January 26, 2026
On January 23, 2026, pursuant to Section 13 (Operational Flow Orders) of the General Terms and
Conditions of the Tariff, Adelphia issued an OFO in anticipation of the current intensely cold weather and
record levels of market demand on its system. The OFO directs Shippers to stay within their contractual
limitations and maintain ratable gas flows over a 24-hour day as required under their service agreements.
Because of the restrictions placed on Adelphia through OFOs issued by its upstream interconnecting
pipelines, unratable hourly takes, unauthorized overruns and operator underperformance by Adelphia’s
Shippers threatens Adelphia's ability to maintain its system integrity and meet its firm obligations to
Shippers.
Despite the restrictions and penalties already in place under its existing Tariff, Adelphia is increasingly
concerned that the current extreme elevated prices for electricity in the PJM wholesale power markets
and severe PJM penalties for non-performance by power generators may incentivize some of its Shippers
to deliberately overrun their firm entitlements on Adelphia if the penalties for such unauthorized flows
on Adelphia are not increased to a level sufficiently high to deter the unauthorized behavior. Adelphia
has very limited line pack and no storage, and therefore non-ratable takes, even by a single Shipper, could
jeopardize the operational integrity of Adelphia’s system. Thus, unauthorized overrun activity at this time
could cause Adelphia’s system to fail rapidly, with potentially severe consequences to other firm shippers
and the integrity of Adelphia's system. Further, because of the higher OFO penalty structures of
Adelphia’s upstream interconnecting pipelines relative to Adelphia’s OFO penalty structure, there is real
potential for Adelphia to suffer substantial damages in the event that Shippers were to engage in harmful
conduct. Adelphia’s current OFO penalty structure, as set forth in Section 13.8 of its Tariff, relies on Gas
Daily indices, which is unlikely to sufficiently deter harmful conduct given the economic considerations
described herein and the higher OFO penalty structures on Adelphia’s interconnecting pipelines discussed
below.
To ensure Shippers stay within contractual limitations, and refrain from unratable hourly takes and
unauthorized overruns or operator underperformance, on January 26, 2026, contemporaneously with this
OFO, Adelphia submitted a filing with the Federal Energy Regulatory Commission (FERC) to increase the
OFO penalties that Adelphia will impose. Specifically, Adelphia proposed with the Commission to modify
the OFO penalty price referenced in Section 13.8 of its Tariff to be the High Common price posted for the
Day on which the violation occurred as defined in its Tariff instead of the average cashout price which is
currently identified as the penalty price which is multiplied by 500% and each Dekatherm of Gas by which
Shipper/point operator deviated from the requirements of the OFO. In addition, Adelphia proposes new
language in Section 13.8 to give Adelphia the ability to recover any OFO penalties imposed on it by its
interconnecting pipelines that supply Adelphia due to Shipper violations of Adelphia’s OFO. Such
interconnecting pipelines vary by zone on Adelphia’s system: Zone North A (Texas Eastern Transmission,
LP, Columbia Gas Transmission, LLC or Transcontinental Gas Pipe Line Company, LLC), Zone North B
(Transcontinental Gas Pipe Line Company, LLC) and Zone South (Texas Eastern Transmission, LP). In the
event one or more of the aforementioned pipelines imposes OFO penalties on Adelphia because of an
Adelphia Shipper’s failure to abide by the restrictions in an Adelphia OFO, Adelphia proposes to charge
the higher of its own OFO penalty and the interconnecting pipeline’s OFO that Adelphia is subject to due
to the Shipper’s violation(s) of Adelphia’s OFO.
In addition, nothing in its Tariff precludes Adelphia from pursuing any and all remedies at law or equity
against any Shipper that knowingly and willfully disregards Adelphia's OFOs and causes damage to
Adelphia's system or impairs its ability to maintain the integrity of its system and meet its firm obligations
to other shippers.
If a Shipper/Point Operator fails to comply with this Operational Flow Order, the Shipper/Point Operator
shall be subject to the updated penalty as noted by revised Section 13.8 and as described herein and as
posted in the regulatory section of Adelphia’s EBB.
Contact your Transportation Services Representative should you have any questions.