Index Methodology

1. Scope & Purpose

This document describes the methodology used by AmpedUp Energy LLC (the "Administrator") to calculate and publish natural gas price indices and related market intelligence products. It is intended to satisfy:

• FERC Policy Statement PL03-3-000 ("Price Index Formation") — the five standards governing price-reporting agencies;
• FERC Policy Statement PL20-3-000 (Revised, 2020) — enhanced transparency expectations;
• IOSCO Principles for Financial Benchmarks (July 2013) — governance, quality, and accountability of the benchmark determination process;
• Anti-Manipulation Rule under the Natural Gas Act, 15 U.S.C. § 717c-1.

2. The Five FERC Standards — How We Comply

3. Data Sources

Our indices draw on three tiers of input data:

1. Enrolled Data Providers — producers, marketers, pipelines, LDCs, end-users, and financial participants who submit transaction data under a Data Provider Agreement. Each submission is subject to the 11 FERC eligibility checks and is attested to be arms-length, firm, non-affiliated, and in compliance with the Safe Harbor under 18 CFR §284.288(a).
2. Publicly available reference data — NYMEX/ICE settlements (Henry Hub), EIA Weekly Natural Gas Storage Report, EIA daily spot prices, EIA Form 552 published aggregates, CENAGAS SISTRANGAS operations bulletins, Baker Hughes rig counts, NOAA forecasts.
3. Operator-submitted pipeline pressure readings — voluntarily supplied by enrolled pipeline operators under a separate Operator Agreement. Used for the Pipeline Pressure Intelligence product only; not an input to price indices.

4. Publication Schedule

All indices publish on the schedule shown at /gas/publishing-calendar, subject to:

• NatGasIQ Daily Price Index — 09:30 Central each business day (next-day flow).
• Intraday Survey — 5 cycles (C1 08:00 CT, C2 10:30 CT, C3 13:30 CT, C4 16:30 CT, C5 19:30 CT).
• Bidweek Survey — first business day of each month, 10:30 CT.
• Forward Look — 12:00 CT each business day, 120-month strip.
• Pipeline Pressure Intelligence — hourly during business hours based on operator submissions.
• Duck Curve, PNW Corridor, Mexico, Flow — on the NatGasIQ Daily publication cycle.
• Storage Balance — Thursday 10:35 CT, tracking the EIA release.

5. Eligibility — The 11 FERC Exclusion Checks

Every submitted transaction is evaluated against the following eligibility rules before inclusion. Any single failure removes the trade from the index. Each check is logged with the submission record for audit.

1. Affiliate trades — excluded if counterparty is affiliated with the submitter (per attestation + Form 552 cross-check).
2. Non-firm physical gas — only firm, physical delivery included. Interruptible and financial-only excluded.
3. Non-arms-length pricing — excluded when price is not independently determined (e.g., formula-tied to another index).
4. Out-of-window trades — trades executed outside the defined trading window for the cycle.
5. Duplicate submissions — detected by hashed counterparty + volume + price + flow date.
6. Out-of-range price — filtered against the contemporaneous ICE bid-ask range for the hub/date.
7. Statistical outlier — three-sigma filter against the moving mean of valid submissions at the same hub/cycle.
8. Insufficient volume — minimum volume threshold per transaction (currently 2,500 MMBtu).
9. Form 552 category mismatch — trade's reported category must reconcile to the submitter's Form 552 filing.
10. Incomplete trade record — missing required fields (counterparty-hashed, volume, price, hub, delivery date, cycle).
11. Attestation failure — missing or stale provider attestation (re-signed annually).

6. Index Calculation

Unless otherwise noted, all AmpedUp price indices are computed as a volume-weighted average price (VWAP) of eligible transactions:

Where the sum runs only over transactions passing all 11 eligibility checks (§5). We also publish trade count, aggregate volume, high/low/mid, and a "liquidity tier" flag (1 = deep, 2 = standard, 3 = thin).

When fewer than 3 qualifying trades are received at a hub/cycle, the index is marked Indicative and is not eligible for use as a settlement reference.

7. Liquidity Monitoring (Rolling 180 Days)

Per PL20-3-000, we continuously monitor liquidity over the prior 180 calendar days. A hub/cycle is Tradable-Grade when it meets: (a) distinct counterparties ≥ 3, (b) average daily volume ≥ 50,000 MMBtu, and (c) publication availability ≥ 95%. Tradable-Grade status is shown on each index page and in the API response.

8. Governance

Index integrity is overseen by a three-tier governance structure:

• Index Committee — three members (internal), meets monthly. Approves methodology changes, reviews exception reports, ratifies corrections.
• External Advisory Panel — five independent members (academic, two practitioners, legal, exchange). Reviews committee decisions quarterly. Charter at /gas/governance .
• Compliance Officer — day-to-day compliance. [email protected].

9. Record Retention

All submitted transaction records, calculation inputs, exception logs, and published values are retained for seven (7) years. Archives are stored in immutable form and are available to regulators on request.

10. Conflicts of Interest

AmpedUp Energy LLC does not itself trade natural gas. No employee involved in index determination holds a position in any NYMEX, ICE, or OTC natural gas contract. Board members disclose financial interests annually. Full policy: /gas/governance .

11. Complaints and Correction Procedures

Market participants who believe a published index contains a material error may submit a correction request to [email protected]. The Administrator will investigate within two (2) business days. If a correction is warranted, prior and revised values are preserved.

12. Changes to This Methodology

Material methodology changes are previewed for at least 30 days before taking effect and are logged with version date. Non-material clarifications may be issued without the 30-day preview but are still versioned. Full change log at /gas/corrections .