E.Southeast Region
While some participants in the Southeast Region had specific concerns about certain current gas scheduling rules, they generally did not believe that the reliability of natural gas service for electric generation was an issue in their region. Conference participants explained that in this region, most of the entities use integrated resource planning, examining both transmission and generation jointly with expected load growth to determine areas where either transmission or generation capacity is required. These studies also include fuel supply interactions for generation. Generators in this region typically have firm pipeline transportation service, and utilize a combination of released firm or IT service to meet peak needs. For example, a utility representative noted that it requires all new gas-fired generation capacity additions to have firm gas transportation and storage. A Florida utility representative noted that Florida entities use similar processes, although it was noted that a third natural gas pipeline into Florida would enhance reliability.
Many of the Southeast technical conference participants agreed that weather driven electric load variations will increasingly be supplied by gas generation. They also agreed that the need to rely upon gas-fired generation to meet daily and hourly variations is not consistent with interstate pipelines’ standard firm transportation service, including the timely nomination cycle and the no-bump rule. Some representatives of generation owners with firm pipeline capacity stated that they would like the ability to use the firm service as flexibly as possible. For example, one electric utility representative stated that it often is not able to use its firm capacity to make nomination changes because of the no-bump rule and other service priority rules. Other participants stated that they have not experienced the same limitations, in part due to completing their electric day analysis before gas prior day timely nominations must be submitted.
In contrast, representatives of some gas shippers, such as industrial users, argued in favor of retaining the no-bump rule. They stated loss of the no-bump rule could cause
fewer shippers to use IT, resulting in lower overall utilization of pipeline capacity and a greater share of fixed costs allocated to firm shippers.
A utility representative also asserted that the present analysis used to determine nominations in gas system operations (forward haul and back haul pipeline capacity, storage, and LDCs’ local capabilities) “leaves too much on the table” by not allowing utilization of dynamic gas system capabilities. The representative further stated that gas-fired electric generators need to supply the net electric demand over a short time frame without impacting operational flexibility on the gas system.
Several generator representatives stated that they rely upon marketers and asset managers, who hold a mix of firm and interruptible transportation and storage services to manage their load swings throughout the day. They believe that additional flexibility could be achieved through FERC changes to the capacity release rules, which in turn could result in more efficient pipeline capacity utilization.
Participants stated that communications between the major electric entities and pipelines in the region are robust. For example, during a cold weather event in January 2010, an electric utility shifted away from gas generation to allow pipeline packing for use on the coldest day. This allowed the utility to stay within its long term contractual withdrawal limits while allowing sufficient withdrawals to occur on the critical electrical demand day. Participants stated that gas and electric entities share locations of electric driven natural gas compressor stations, which account for usually less than 20% of the flow capacity on the pipelines. However, one participant identified that there are critical locations that are supplied by electric-only compressor stations.
Participants stated that maintenance outages on the electric and gas systems are informally coordinated between major entities, resulting in selected changes in the timing of maintenance on both systems. They state that this is accomplished through a number of informal meetings per year. Participants also agreed that the communications that take place between the pipelines and their customers, including power generators, have been adequate to address reliability concerns both day-to-day and during emergencies. No concerns were expressed regarding the Standards of Conduct.
One utility representative stated that his utility plans its system to include gas system limitations and selected contingencies. This includes the complete outage of a single pipeline (and all generation attached). This utility has sufficient generation supplied by other fuels and the transmission to deliver that generation to be able to supply firm load for at least one to two days.
Southeast Regional Initiatives
According to participants, the Florida Reliability Coordinating Council (FRCC) created a flow model of the pipelines in Florida. FRCC also created a Fuel Reliability Working Group (FRWG) that reports to the FRCC Operating Reliability Subcommittee on matters relating to fuel and impacts to Bulk Electric System reliability. Specifically, the FRWG provides the administrative oversight of a regional fuel reliability forum that studies the interdependencies of fuel availability and electric reliability and supports coordinated regional responses to fuel issues and emergencies.28
At least one pipeline in the region offers an enhanced nomination service, and others are contemplating a similar service.
While some participants in the Southeast Region had specific concerns about certain current gas scheduling rules, they generally did not believe that the reliability of natural gas service for electric generation was an issue in their region. Conference participants explained that in this region, most of the entities use integrated resource planning, examining both transmission and generation jointly with expected load growth to determine areas where either transmission or generation capacity is required. These studies also include fuel supply interactions for generation. Generators in this region typically have firm pipeline transportation service, and utilize a combination of released firm or IT service to meet peak needs. For example, a utility representative noted that it requires all new gas-fired generation capacity additions to have firm gas transportation and storage. A Florida utility representative noted that Florida entities use similar processes, although it was noted that a third natural gas pipeline into Florida would enhance reliability.Many of the Southeast technical conference participants agreed that weather driven electric load variations will increasingly be supplied by gas generation. They also agreed that the need to rely upon gas-fired generation to meet daily and hourly variations is not consistent with interstate pipelines’ standard firm transportation service, including the timely nomination cycle and the no-bump rule. Some representatives of generation owners with firm pipeline capacity stated that they would like the ability to use the firm service as flexibly as possible. For example, one electric utility representative stated that it often is not able to use its firm capacity to make nomination changes because of the no-bump rule and other service priority rules. Other participants stated that they have not experienced the same limitations, in part due to completing their electric day analysis before gas prior day timely nominations must be submitted.
In contrast, representatives of some gas shippers, such as industrial users, argued in favor of retaining the no-bump rule. They stated loss of the no-bump rule could cause
fewer shippers to use IT, resulting in lower overall utilization of pipeline capacity and a greater share of fixed costs allocated to firm shippers.
A utility representative also asserted that the present analysis used to determine nominations in gas system operations (forward haul and back haul pipeline capacity, storage, and LDCs’ local capabilities) “leaves too much on the table” by not allowing utilization of dynamic gas system capabilities. The representative further stated that gas-fired electric generators need to supply the net electric demand over a short time frame without impacting operational flexibility on the gas system.
Several generator representatives stated that they rely upon marketers and asset managers, who hold a mix of firm and interruptible transportation and storage services to manage their load swings throughout the day. They believe that additional flexibility could be achieved through FERC changes to the capacity release rules, which in turn could result in more efficient pipeline capacity utilization.
Participants stated that communications between the major electric entities and pipelines in the region are robust. For example, during a cold weather event in January 2010, an electric utility shifted away from gas generation to allow pipeline packing for use on the coldest day. This allowed the utility to stay within its long term contractual withdrawal limits while allowing sufficient withdrawals to occur on the critical electrical demand day. Participants stated that gas and electric entities share locations of electric driven natural gas compressor stations, which account for usually less than 20% of the flow capacity on the pipelines. However, one participant identified that there are critical locations that are supplied by electric-only compressor stations.
Participants stated that maintenance outages on the electric and gas systems are informally coordinated between major entities, resulting in selected changes in the timing of maintenance on both systems. They state that this is accomplished through a number of informal meetings per year. Participants also agreed that the communications that take place between the pipelines and their customers, including power generators, have been adequate to address reliability concerns both day-to-day and during emergencies. No concerns were expressed regarding the Standards of Conduct.
One utility representative stated that his utility plans its system to include gas system limitations and selected contingencies. This includes the complete outage of a single pipeline (and all generation attached). This utility has sufficient generation supplied by other fuels and the transmission to deliver that generation to be able to supply firm load for at least one to two days.
Southeast Regional Initiatives
According to participants, the Florida Reliability Coordinating Council (FRCC) created a flow model of the pipelines in Florida. FRCC also created a Fuel Reliability Working Group (FRWG) that reports to the FRCC Operating Reliability Subcommittee on matters relating to fuel and impacts to Bulk Electric System reliability. Specifically, the FRWG provides the administrative oversight of a regional fuel reliability forum that studies the interdependencies of fuel availability and electric reliability and supports coordinated regional responses to fuel issues and emergencies.28
At least one pipeline in the region offers an enhanced nomination service, and others are contemplating a similar service.
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