The RTO/ISO responses clearly confirm that there is not a nationwide problem during the morning electric ramp associated with the current start time of the Gas Day.
Moreover, no RTO or ISO has shown a causal link between generator de-rate issues and the current 9:00 am CT start of the Gas Day. Given that the responses fail to provide sufficient record evidence for the Commission to meet its burden under section 5 of the Natural Gas Act that the current 9:00 am CT Gas Day start time is no longer just and reasonable, and that a 4:00 am CT start of the Gas Day is just and reasonable, the NGC renews its request that the Commission retain the 9:00 am CT Gas Day as the national standard.
Please read the full comments above to learn more.
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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
