Gas-electric information-sharing is needed, but so is new infrastructure, APPA tells FERC
Originally published August 28, 2013
APPA supports information-sharing among independent system operators, gas pipelines and electric generators to the extent that such sharing can improve reliability, the association said in response to a Federal Energy Regulatory Commission notice of proposed rulemaking. FERC’s proposal would allow pipelines and transmission owners to share non-public, operational information with each other for the purpose of promoting reliable service or operational planning.
In many regions, gas coordination issues are physical in nature and will not be resolved without the construction of additional interstate pipeline infrastructure and the fair allocation of the costs and capacity associated with that construction, APPA said in Aug. 26 comments. Nonetheless, sharing non-public, operational information (both real-time and longer-term) among generators, pipelines and transmission lines to coordinate outages and address potential shortages "will be essential to maintaining the reliability of these systems," APPA said.
Assuming FERC moves forward with its proposed definition of "non-public, operational information" and voluntary approach to information-sharing, the commission "should nevertheless closely monitor this information-sharing to ensure compliance with the no-conduit rule, market behavior rules, and anti-manipulation rule," APPA said. After some time, the commission could determine whether it needs to further define the term "non-public, operational information" and evaluate how the voluntary approach is working.
Reports by the California Independent System Operator on how its voluntary approach to electric-gas coordination is working suggest that the voluntary approach proposed by FERC "may be viable to spur the appropriate types of increased communications in other regions of the country," APPA said.
The commission should encourage voluntary information-sharing between generators and their electric transmission system operators, APPA said in response to a FERC query, noting that generators "are often in the best position to be able to assess whether or not they will be able to run in a given situation." To the extent that needed information-sharing does not take place between generators and electric transmission operators voluntarily, the commission "should take appropriate steps to ensure that electric transmission operators obtain all information necessary to ensure system reliability."
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