In comments before regulators, TCAP and other city coalitions identified the lack of critical facility designations as a top system failure during this year’s blackouts.
Although beneficial, proposed Public Utility Commission rules to set critical designations for natural gas energy facilities—when considered in conjunction with related rules proposed by the Texas Railroad Commission — might not provide the level of power reliability sought by both agencies.
That was among the key points made by the Texas Coalition for Affordable Power and other city organizations in comments filed with the PUC this month. The comments were part of an ongoing proceeding at the agency to enact new legislation from the 87th Texas Legislature relating to the designation of critical gas infrastructure for electric reliability purposes. Both the PUC and the Railroad Commission are coordinating efforts in creating rules for those facilities.
Jointly sponsored by the Oncor Cities Steering Committee, the Atmos Cities Steering Committee and the Gulf Coast Coalition of Cities, the comments can be found in PUC Docket No. 52345. They were filed on Oct. 7.
Attorneys Thomas Brocato and Taylor Denison, writing on behalf of TCAP and the separate municipal coalitions, noted that the lack of critical facility designations for natural gas suppliers during Winter Storm Uri represented one of the largest underlying failures of both the electric and gas industries during the event. The attorneys expressed general support for the PUC’s proposed approach to critical facility designations, although they also enumerated a few caveats and made additional recommendations. Among them:
The definition of “critical natural gas” in the proposed PUC rule should not include an exception for a critical gas supplier who is “not prepared to operate during a weather emergency” if that exception is related to weatherization requirements. Such an exception is under consideration at the Railroad Commission.
Under proposed Railroad Commission rules, all natural gas facilities would receive critical designations unless they file for a waiver. Cities recommend that the PUC should instead collaborate with the Railroad Commission and utilities to identify a more manageable list of natural gas facilities eligible for inclusion in the statewide list of “critical natural gas” facilities. The PUC also should consider implementing a size threshold for critical natural gas facilities in coordination with the Railroad Commission and utilities.
The PUC should provide industry-wide guidance on the prioritization of critical natural gas facilities to ensure uniformity and effective execution of the proposed rule. The rule should take into account that without natural gas supply, other critical loads cannot receive electric service. In the alternative, the PUC should direct ERCOT to do so through the creation of new rules at that organization.
The PUC has stated it plans to adopt rules in Docket No. 52345 on November 4.
Is a policy analyst consultant for TCAP, a coalition of political subdivisions in Texas that purchase electricity in the deregulated market for their own governmental use. Because energy costs are typically a significant budget item to our members, TCAP is consistently looking for ways to save our members money, through cost-saving contracts, energy efficiency or demand response programs.