“This position paper identifies specific recommendations along with suggested specific action steps to be undertaken respectively by the RTOs, gas producers, marketers and pipelines, and/or federal and state regulators corresponding to each recommendation.”
The four RTOs represent areas serving 40% of the US population in 35 states and the District of Columbia-- PJM, ISO-New England, Midcontinent Independent System Operator and Southwest Power Pool.
“The Joint RTOs have no pecuniary interest in any particular type of generation resource. However, given our growing reliance on gas-fired generation, our role as reliability coordinators for over two-thirds of the nation compels us to keenly focus on effective gas-electric coordination.
“Electric reliability is increasingly reliant on the inter-relationship between the electric markets and well-functioning gas markets as well as the availability of adequate natural gas infrastructure.
“This reliance on gas-fired generation necessitates heightened flexibility and efficiency from gas supply and pipeline operations.
“However, in certain parts of the country, the pipeline system faces constraints due to challenges building new infrastructure.
“The rising demand for increased throughput and more flexible use of the pipeline system by thermal generation clashes with both the necessary new infrastructure and certain traditional regulatory rules governing pipelines and gas markets.”
Recommendations were made in three broad areas--
-- Gas Market Enhancements That Help To Improve Supply and Pricing Options To Ensure Reliability.
Given a Rapidly Evolving Electric Generation Fleet: This focus is on enhancing gas commodity and transportation market liquidity and transparency, especially during weekends and holidays, as well as scheduling flexibility through the availability and expansion of flexible transportation products, such as no-notice services.
-- Operational Enhancements That Proactively Address Specified Reliability Needs and Identified Vulnerabilities:
The Joint RTOs urge reforms to address gas and electric infrastructure co-dependent vulnerabilities (such as electric-fueled compressor stations and wellhead weatherization to support extreme weather supplies) and provide comment herein on proposals for additional changes to match the electric and gas day.
-- Regulatory Coordination of State and Federal Authority To Address Emergencies:
The Joint RTOs outline the need for specific reforms to address the Department of Energy’s authority to address fuel emergencies as well as the need for better alignment of curtailment priorities at both the state and federal level.
Among the specific recommendations are--
-- Wellhead Gas Producer Weatherization: FERC’s jurisdiction does not extend to the wellhead, there should be further discussion with state and federal regulators as to whether the state regulatory role should be extended to address the reliability of service from wellheads within their jurisdiction that enhances their present jurisdiction over the safety of such facilities
-- Enhancing Weekend and Holiday Gas Commodity Trading Supply and Liquidity: FERC with the states should consider leading industry dialogue to further investigate opportunities that would enable an end to multiday trading requirements of natural gas over weekends and holidays that significantly strain natural gas/power coordination and dispatch.
-- Targeted Permitting Reforms: Permitting reforms are actively under consideration in Congress and at the state level. However, permitting reforms for transmission vs. pipelines are being considered in separate silos that largely ignore the interdependent nature of these two systems. The electric industry and gas pipeline industry should coordinate so as to better educate policymakers on the interdependencies of these two systems and the need for permitting reform to address these co-dependencies in a comprehensive manner.
Click Here for a copy of the recommendations.
NewsClips - Natural Gas Vulnerability:
-- Utility Dive: PJM, 3 Other RTOs Propose Steps To Improve Gas-Electric Sector Coordination, Boost Reliability
-- TribLive: Natural Gas Odor Again Forces Evacuation Of Riverview H.S. In Allegheny County; Gas Leak Was Reported There Monday
Related Articles - Natural Gas Vulnerability:
-- PJM Reports Natural Gas Power Plants Were Over Half The Forced Outages During Winter Storm Gerri In January; Special Procedures Used For Gas Generators Raised Questions About Market Impacts [PaEN]
Related Articles This Week- Gas:
-- Penn State Study: Conventional Oil & Gas Wastewater Fails To Meet Beneficial Reuse Recommendations For Use As A Dust Suppressant [PaEN]
-- Western PA Residents Comment After A Year Of Shell Petrochemical Plant Operations [PaEN]
-- Citizen Complaint Leads DEP To Breakout Of Mariner East Pipeline Drilling Mud That Contaminated The Lake At Marsh Creek State Park, Chester County; Sunoco Pipeline Starts Cleanup [PaEN]
-- PUC Adopts Final Regulations Strengthening Operation, Construction Requirements For Intrastate Hazardous Liquids Pipelines [PaEN]
-- PJM, Electric Grid Operators Recommend Additional Steps To Overcome Vulnerabilities In Natural Gas Infrastructure To Ensure More Reliable Grid Operation [PaEN]
[Posted: February 22, 2024] PA Environment Digest
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