Pursuant to the Notice issued on October 2, 2017, by the Federal Energy Regulatory Commission (FERC or the Commission) in response to the Department of Energy (DOE) direction on September 28, 2017, under Section 403 of the Department of Energy Organization Act (DOE Act) (42 U.S.C. § 7173) that FERC consider a notice of proposed rulemaking (NOPR) the Interstate Natural Gas Association of America (INGAA) respectfully submits these initial comments.
INGAA is a trade organization that advocates regulatory and legislative positions of importance to the natural gas pipeline industry in North America. INGAA’s 26 members represent the majority of the interstate natural gas transmission pipeline companies in the United States. Its United States members are regulated by the Commission pursuant to the Natural Gas Act (NGA), 15 U.S.C. §§ 717-717w. INGAA’s members, which operate approximately 200,000 miles of pipelines, serve as an indispensable link between natural gas producers and consumers.
As an industry whose core mission is the safe and reliable delivery of natural gas to meet the nation’s energy needs, INGAA supports efforts by the Commission to enhance grid reliability and resilience. Wholesale electricity markets can, and should, value and incent reliability and resilience. FERC should direct regional transmission organizations (RTOs) and independent system operators (ISOs) to examine whether, and if so how, they value reliability and resilience and report their findings to the Commission within 90 days.
However, the Commission should neither adopt the NOPR, nor use it as a point of departure from which to construct any additions or modifications to wholesale electricity market rules. Instead, based on its analysis of the RTOs’ and ISOs’ responses, the Commission should develop promptly a new proposal to determine how best to value and incent reliability and resilience in wholesale electricity markets on a fuel-neutral basis, tailored to meet the needs of the market, which may vary by region.