How Standards Enhance Energy Competition by Chris Trayhorn, Publisher of mThink Blue Book, November 15, 2000 Birth of the GISB The creation of this new, cooperative organization not only made good business sense, but it also addressed concerns raised by the Federal Energy Regulatory Commission (FERC), which regulates interstate pipelines. FERC had made it clear that if the industry was unable to reach agreement on voluntary electronic commerce standards on its own, the regulatory agency was fully prepared to impose them on the industry. The standards organization that resulted from these industry efforts, the Gas Industry Standards Board (GISB), was viewed at first with skepticism by some market participants who feared that standards would delay and discourage innovation and hamper competition. They reasoned that standards would lead to a cookie-cutter approach to business decisions, limiting choice for both buyers and sellers. But GISB’s accomplishments since its founding in 1994 demonstrate that standards, if created within the proper framework, can actually enhance competition, spur creativity, and even lead to the development of new markets. Decisions about Governance GISB’s success is not an accident but the direct result of a series of decisions made when the organization’s governance was being determined. Mindful of the industry’s history of internecine squabbling, a careful set of rules was painstakingly crafted by GISB’s founders. Five membership segments were established: the traditional four of producers, distributors, pipelines, and end users, and a fifth – service providers – to include such new industry participants as brokers, marketers, financial services companies, consultants, law firms, computer firms, and other businesses. Chosen to govern the new organization were two 25-member governing boards with five members from each segment: the Board of Directors, with responsibility for administrative and financial matters; and the Executive Committee, which was given the responsibility of developing the standards themselves. (Later, numerous working groups and task forces were formed to assist the Executive Committee.) GISB’s voting rules were devised to promote “inclusivity,” protect the interests of even the smallest segments of the industry from the “tyranny of the majority,” and ensure that all decisions were the result of a genuine industry consensus. Prospective standards must get at least 17 affirmative votes in the Executive Committee, and there must be at least two affirmative votes from each segment. Standards must then be ratified by the GISB membership; a 67 percent affirmative vote of those submitting ballots is required for a standard to get final approval. On the Board of Directors, changes in bylaws or articles of incorporation need at least 19 affirmative votes, with at least two affirmative votes from each segment. The new organization also made an early commitment to openness and the broadest possible industry participation. All meetings are open to the public, and while GISB’s dues have been intentionally kept at a reasonable level to encourage companies to join, even non-members are welcome to propose and comment on prospective standards and to vote on all but Board of Directors, Executive Committee, and standards-ratification initiatives. GISB maintains a small staff in Houston, but the organization’s work is principally carried out by a large cadre of volunteers from member companies. GISB’s governance made sense on paper to most members of the gas industry, but there was real doubt during the first months after the organization’s incorporation in 1994 as to whether its goal of achieving a voluntary, industry-driven standards regime would ever be realized. There were fears that the intricate voting mechanism wouldn’t work in practice or that federal regulators would attempt to second-guess GISB or even take over the standards-setting function altogether. In 1995, FERC issued an advanced notice of proposed rulemaking setting a March 15, 1996, deadline for comments “containing detailed proposals for the standard set of information that the commission should require all pipelines to use” in conducting business electronically, “as well as for standard nomenclature and standards for any associated business practices and procedures.” While the commission said it expected GISB “may become a forum through which these industry efforts may be coordinated,” FERC made it clear that it was ready to step in if the industry couldn’t accomplish the task itself. As the result of a substantial effort involving hundreds of volunteers, GISB managed to meet FERC’s deadline, and on March 15, 1996, the organization submitted 140 proposed standards to the commission. The fears that GISB would die a premature death were largely laid to rest on April 24, 1996, when FERC issued its notice of proposed rulemaking (NOPR) on business practices standards for the natural gas industry. The NOPR proposed that interstate pipelines adopt the 140 standards that GISB had submitted to the commission and commended the gas industry and GISB for the work they put into developing the standards “and the significant progress they have made toward standardization.” The commission said GISB’s standards “regularize the means by which the entire industry will conduct business across the interstate pipeline grid.” Declaring that GISB’s standards “represent a formidable step towards improved efficiency and competitiveness in the gas industry,” FERC proposed that interstate pipelines comply with the GISB definitions, standards, and data sets by January 1, 1997. Since that time, the pace of work at GISB has not slowed. FERC and GISB have maintained a collegial relationship that has enabled the two organizations to create a unique public-private partnership. In a six-year period, GISB for its part has created a body of over 400 standards. Most recently, the organization has concentrated on standards designed to ease the inevitable move of electronic commerce in natural gas to the Internet. GISB has also been considering, at the request of another industry organization, whether to change its governing documents to enable it to develop wholesale and retail standards for the electric industry. The extensive discussions that GISB has conducted with the electric industry have produced one near-consensus: that whether GISB changes so that it develops electricity standards itself or some other organization is entrusted with this task, the standards-setting process would be well served by following the GISB model, which has proved to be both fair and effective. A Seamless Marketplace What has been the effect on the natural gas industry of five years of GISB standards? A former board chairman declared that GISB’s goal is to create a “seamless natural gas marketplace,” and there is every indication that this is becoming a reality. Standardization, coupled with the use of electronic commerce, has improved communication between multiple trading partners, made information necessary for business transactions less ambiguous, allowed transactions to be completed more quickly, and provided more accountability. It has also facilitated tighter coordination between trading partners and automated the business process. As an example of the tangible benefits of this process, the Commodity Futures Trading Commission has attributed to GISB standards the reduction in the New York Mercantile Exchange trading cycle for gas futures from five days to three days. This is Economics 101: more information in the marketplace leads to less uncertainty and ambiguity, thus reducing arbitrage. Besides enhancing efficiency, electronic commerce and standardization are leading to increased competition. The more relevant information that is made available to market participants in a timely manner, the better the marketplace functions. And standards for electronic communication make doing business in the gas marketplace considerably simpler. This helps to level the playing field for smaller players, who previously did not have the staff to devote to learning each pipeline’s way of doing business, as well as to improve efficiency for larger firms. A recent FERC order incorporating into the commission’s regulations the latest version of GISB’s standards declared, “GISB’s ability to reach consensus regarding contentious issues such as multi-tiered allocations and title transfer tracking demonstrates that industry self-regulation can successfully bridge gaps between industry members in order to implement policies that improve the efficiency and competitiveness of the gas industry.” The current movement toward the Internet is destined to continue these trends. FERC has mandated that pipeline websites have a “common look and feel,” further increasing their ease of use. State public utility commissions, which have jurisdiction over retail natural gas and electricity restructuring in their states, have increasingly been recognizing the need for standards for electronic transactions. GISB standards are being specified in a growing number of states, even for electricity-only open access programs. Security concerns are being addressed at the same time the Internet standards are being developed. The U.S. Department of Energy (DOE) was one of GISB’s first members, and its close relationship with DOE has enabled GISB to work with the Sandia and Lawrence Livermore National Laboratories to ensure that the Internet remains a secure and reliable communications medium for the gas industry. The transformation of the gas market from its traditional way of doing business – with its mounds of paper and faxes and countless phone calls – to an almost instantaneous Web-based process has happened in a relatively short period of time, and naturally it has not been an easy transition for all market participants. Smaller companies in particular have had difficulty finding sufficient in-house resources to prepare to buy and sell gas on the Internet. But as so frequently happens when industries undergo major changes, some companies’ problems become other companies’ opportunities. Dozens of firms, some of them start-ups and others veteran players in the business of electronic commerce, have emerged to offer products and services to help small – and large – gas companies meet GISB’s standards and FERC’s deadlines. What has occurred is nothing less than the birth of a new industry, an event that has made GISB’s services segment, to which these new companies belong, the fastest-growing part of the organization. An Industry Forum It is possible that this gas market evolution would have taken place if GISB had never been created, but the chances that this would actually have happened seem very small. FERC would certainly have tried to write electronic standards on its own, but the historical divisions in the gas industry would in all likelihood have reasserted themselves. Without GISB’s ability to function as a forum for working out differences before standards are even proposed, the commission’s rulemakings would have been greeted with objections, rehearing petitions, and lawsuits by companies and trade associations that felt they had been disadvantaged by the proposed rules. Eventually, some standards might have made it through the legal process and achieved implementation. But they would likely have been too little and too late for the gas industry to take advantage of an expanding economy and a growing need for new electric generation capacity. Competing fuels like coal, unconstrained by regulation, would undoubtedly have moved to take away many promising markets. Because some of the FERC-imposed standards would have been diluted because of the need for compromises either at the regulatory or the judicial level, there are no assurances that the standards would have functioned properly once they were imposed. And because the prospects for future new electronic standards or changes in existing standards would have been cloudy at best, many companies that had been poised to serve the new natural gas market would have decided that the risks were just too great. The industry would have been left with fewer choices, and far less satisfactory ones. Far from harming the natural gas industry by impeding competitiveness and causing delays in the development of needed standards, GISB has led the industry toward a highly competitive and highly efficient future. It has, in fact, gone faster than some market participants would prefer, but by setting a level of expectation that is reasonably congruent with the state of available technology, it has shown companies what it takes to compete successfully in the new natural gas industry. And by stressing that its standards represent only minimum levels of performance, it has allowed truly innovative companies to take full advantage of their creativity. As for the argument that standards hurt creativity and innovation, GISB’s experience demonstrates that quite the opposite is true. In the words of the American National Standards Institute (ANSI), the nation’s most prestigious standards organization, “Far from impeding business, standards actually break down barriers to trade, provide industry stability, and encourage commerce. Standards are the foundation for innovation, so they hasten the rate of implementation of new technology.” One way to approach this issue is to consider whether a novelist would be likely to complain that his creativity is hampered by the existence of standardized spelling in the form of a dictionary. Like words, GISB’s technical standards are building blocks to be used by creators and innovators to advance an industry that has been renewed and invigorated by technological change. Conclusion GISB’s experience in creating electronic commerce standards for the natural gas industry demonstrates that standards organizations, properly constituted, can enhance industry competitiveness and encourage innovation. GISB’s success is attributable to its carefully balanced structure, with its complex but highly effective voting procedure, its two distinct governing boards, and its other attempts to ensure that the interests of all market participants are given the proper weight. With its ability to create and maintain public-private partnerships and its success in achieving consensus on often divisive and controversial industry issues, GISB is uniquely positioned to help facilitate the transformation of the natural gas industry through electronic commerce and the Internet. Filed under: White Papers Tagged under: Utilities About the Author Chris Trayhorn, Publisher of mThink Blue Book Chris Trayhorn is the Chairman of the Performance Marketing Industry Blue Ribbon Panel and the CEO of mThink.com, a leading online and content marketing agency. He has founded four successful marketing companies in London and San Francisco in the last 15 years, and is currently the founder and publisher of Revenue+Performance magazine, the magazine of the performance marketing industry since 2002.