The Interstate Natural Gas Association of America (INGAA) filed comments in response to the Federal Energy Regulatory Commission’s (FERC or Commission) February 13 technical conference on information sharing and communications between the natural gas and electric power industries and the April 25 technical conference on natural gas and electric scheduling in this docket. INGAA member companies actively participated at both conferences and appreciate the Commission’s continued interest in discussing gas-electric coordination issues with all stakeholders. INGAA is committed to working with FERC, our customers, the Independent System Operators (ISOs), Regional Transmission Organizations (RTOs) and other stakeholders to develop solutions to the challenges identified through this process.
In response to discussions at these conferences, and as the pipeline industry’s thinking about these issues has developed, INGAA’s comments signaled the pipeline industry’s willingness to consider the following positions to support the reliability of the bulk power system:
(1) modifying the Timely nomination cycle;
(2) adding an additional standardized intraday nomination cycle; and
(3) changing the start of the Gas Day.
INGAA stated that the benefits, however, of any proposal will be realized fully only if the ISOs/RTOs that administer organized wholesale electric power markets review their timelines and similarly adjust their relevant schedules to make dispatch decisions prior to the pipelines’ standardized nomination cycles.
In addition, with respect to communication between electric grid operators and pipelines, INGAA reiterated its and others’ requests that FERC clarify what non-public information pipelines should and can share with electric grid operators (both ISOs/RTOs and electric utilities in bilateral electric markets) without violating the undue discrimination provisions of section 4(b) of the Natural Gas Act.
While INGAA member companies are open to considering changes to gas scheduling and communication protocols, INGAA cautioned that such short-term changes will not solve fundamental electric reliability issues. The ISOs/RTOs, in conjunction with FERC, must begin addressing necessary long-term changes to the restructured wholesale electric power market rules to ensure that generators can secure, and be compensated for, adequate supply and transportation, regardless of fuel choice, needed to ensure the reliability of the bulk power system.
Related
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
