FERC Dissects Gas Unreliability

The U.S. natural gas system – from production, to pipelines, to customers, including electric generating plants – is unable to provide reliable electric service during winter storms. That’s the unavoidable conclusion of a joint Federal Energy Regulatory Commission-North American Electric Reliability Corp. analysis of 2022 “Winter Storm Elliott” unveiled at the commission’s meeting yesterday (Sept. 21).

“The event is the fifth in the past 11 years in which unplanned cold weather-related generation outages jeopardized bulk-power system reliability”

The FERC staff briefing on its findings on the Christmas outage that affected much of the eastern U.S. (the full report will be released later) noted: “The event is the fifth in the past 11 years in which unplanned cold weather-related generation outages jeopardized bulk-power system reliability:2011 – 29,700 MW; 2014 – 19,500 MW; 2018 – 15,800 MW; 2021 – 61,300 MW; 2022 –90,500MW. The 90,500 MW of incremental coincident unplanned outages during Winter Storm Elliott represented 13% of the U.S. portion of the anticipated resources.”

The repeated failure of the gas industry to reliably supply electric generators prompted FERC Chairman Willie Phillips to quip that it reminded him of the film Groundhog Day and Commissioner Mark Christie to quote the great American baseball player and philosopher Yogi Berra that it is “déjà vu all over again.”

During Elliott, domestic gas production dropped 16% on Dec. 24 compared to Dec. 2 and 1,702 individual generating units faced freezing and mechanical issued leading to 3,565 outages, derates, or failures to start, of which 825 units were natural gas-fired generators. Pipelines froze or suffered mechanical issues, leading to curtailments of firm supply contracts to “63 natural gas-fired generating unit outages/derates, totaling 10,038 MW.” Of the generating units that suffered freezing, “nearly 80% occurred at ambient temperatures that were above their documented minimum operating temperatures.” Several grid operators had to shed load in order to prevent grid collapse due to low frequency conditions.

One of the most chilling tales from Elliott came from Consolidated Edison, which is the local gas distribution company for Manhattan, the Bronx, and portions of Queens and West Chester County, which faced low pressure on its retail delivery pipelines. The LDC had to declare an emergency and access its own liquified natural gas facility. Should ConEd have lost gas pressure, “Restoring service to impacted customers would have required entering each customer site and manually re-lighting gas appliance pilots. Even with assistance of mutual assistance resources, this process could have taken several months.”

The report makes 11 recommendations, the most sweeping that “legislation by Congress and state legislatures (and/or regulation by entities with jurisdiction over natural gas infrastructure reliability) is needed to establish reliability rules for natural gas infrastructure necessary to support the grid and natural gas LDCs.”

The report also recommends hiring an independent organization, perhaps one of the Department of Energy’s national laboratories, “to analyze whether additional natural gas infrastructure, including interstate pipelines and storage, is needed to support the reliability of the electric grid and meet the needs of LDCs. The study would include information about the cost of the infrastructure buildout.”

FERC Chairman Willie L. Phillips Jr.

Phillips commented, “It’s abundantly clear that we must make major improvements to the cold-weather reliability of both the natural gas and electricity production and grid systems. I have said repeatedly: someone – it doesn’t have to be FERC – must have authority to establish and enforce natural gas reliability standards.” NERC CEO Jim Robb said, “This sobering report underscores the need to take urgent action on the interdependence between the bulk electric and natural gas systems, including the need for sufficient and reliable gas and electric infrastructure to sustain energy reliability.”

Commissioner Christie went beyond the recommendations to take a more fundamental look at the relationships between the gas and electric industries. The report, he said, “doesn’t address two big, overriding issues.” The first is market design. “We’re going to make you winterize,” he said, adding that in a lot of the regional transmission organizations, the generators are independent power producers, which are merchant generators. “If the market design doesn’t support winterization, if you can’t get revenue to winterize,” the generators will retire the plants.

The second issue, Christie said, is the inherent conflict between the gas and electric industries. In 1990, he noted, two-thirds of electricity was produced by gas and coal. The same is true today, but the relative roles of the fuels have flipped. In 1990, the role of gas was in peakers. “Now gas is running at baseload,” while the gas business was set up to serve local customers through the local distribution companies.

New infrastructure is necessary, Christie said, but the question is how to take a system designed to serve retail customers and adapt that to a system that now provides baseload electric. He said it will need more pipeline infrastructure, noting how difficult that has proven to accomplish. “It may take Congress” to address this issue.

–Kennedy Maize

kenmaize@gmail.com

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