In association with the Federal Energy Regulatory Commission’s (FERC or Commission) November 29-30, 2011 Reliability Conference, Commissioner Philip Moeller posed several questions on whether certain rules under consideration by the Environmental Protection Agency (EPA) could impact the reliability of electric supply. With regard to natural gas pipelines, the Commissioner asked whether “natural gas pipelines can be authorized and built in a manner that will allow new gas plants to enter service when needed for reliability.”
In its Post-technical Conference Comments, INGAA responds to this question stating that the answer is unequivocally yes. There is no question that natural gas pipeline infrastructure can be expanded in a timely, market-responsive manner provided shippers make the firm contractual commitments to natural gas transportation service necessary to finance and receive approval for the addition of new pipeline capacity. INGAA states that the natural gas industry has a proven track record of building infrastructure on a timely and environmentally responsible basis to meet increased natural gas demand. In addition, INGAA states that the FERC processes natural gas pipeline certificate applications efficiently and on a Reasonably Standardized Time Frame.
Further, interstate pipelines have served electric generators successfully for many years and readily will build infrastructure to provide additional pipeline capacity based on the customer’s firm contractual commitments and reasonable rates of return on investment. If a generator anticipates a change to its generation fleet and the need for additional interstate natural gas pipeline capacity and/or a transportation contract, INGAA encourages the generator to talk to its pipeline(s) about their service needs early in the planning process.
Finally, while INGAA believes the current pipeline certificate authorization process is working well, INGAA supports the Commission’s prompt review of any additional refinements in order to advance the certificate process, including expanding the scope of its blanket certificate regulations and improving interagency coordination in order to expedite the permitting timeline. Should the electric market feel that this time frame is too long to meet the needs of the growing gas-fired generation market or is otherwise unworkable, then INGAA suggests that the Commission, industry and other agencies involved in the permitting process work to increase transparency and predictability of its certificate process and identify areas where the process could be expedited.
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
