Winter Storms Gerri and Heather
It has been a week of weather. I think the wind chill in Montana got down to negative 70 degrees. That’s pretty intense. As recent experiences have taught us, it is imperative that the electricity system remains resilient in the face of this extreme weather. I am happy that for the most part this week that was the case.
I want to pause and thank our system operators and workers around the country. I also want to especially thank David Ortiz and his team at the Office of Electric Reliability who kept us and our teams informed throughout the storm so that we knew what was going on. That was really important, and we appreciated it.
Anecdotally, at least, it appears that lessons learned from Winter Storm Uri and changes that have happened since that time did contribute to supporting the system this week, appreciating that the weather was smaller scale and moved more quickly than Winter Storm Uri. For example, since 2021, ERCOT has tripled its battery storage online. There is now 5 GW of available storage. They have doubled demand response availability. There are now 4 GW of demand response available. During this week’s record peak demand of over 78,000 MW in EROCOT, initial reports suggest that there was an improved performance of the thermal fleet. Wind was able to provide 30% of the peak demand supply. Solar hit a new record in supplying another 14,000 MW. Batteries also contributed to keeping prices low during the morning ramps in ERCOT on Monday and Tuesday.
Elsewhere, we saw the value of interregional transmission transfers. PJM reported that it was able to export 12,000 MW of energy to its neighbors during the cold Wednesday morning. This is a nice story to tell. Of course, it does not suggest we’re in the clear or that our work is done, but it is worth taking a moment to consider the encouraging aspects of this week’s experience. We can meet the challenges of extreme weather with proactive steps. The landscape in which our policy discussion continues is not static and the actions that we are taking now are important to help ensure the reliability and resiliency of our system going forward.
C-2
On the agenda, I will speak to one item, C-2. I am dissenting from the Order granting Transco a certificate for its Texas to Louisiana Pathway Project. Although I have voted for the large majority of certificate orders that have come before me, I cannot support this one for two reasons: First, as I have done before, I disagree with this Order’s determination that there are no tools available to assess a project’s greenhouse gas emissions. The Commission has not considered that question carefully enough to support the Order’s conclusion. Second, and critically, there is insufficient record evidence to support the finding that the project is required by the public convenience and necessity. It thereby contravenes the governing 1999 Certificate Policy Statement.
That statement places the evidentiary burden on the project sponsor to show a project will benefit the public, not just benefit the private signatories to a precedent agreement. Literally the only evidence in this record is Transco’s precedent agreement with a gas producer seeking to move gas to a pooling point. The source of gas, the ultimate customers, and their planned uses for the gas are all unknown. There is no market study or even market growth projections supporting the application. Although precedent agreements are of course evidence of project need, per the Certificate Policy Statement they are not necessarily sufficient evidence. In this case, there is a lack of evidence of public benefits. I have consistently advocated for the Commission to update what is now a quarter-century-old Certificate Policy Statement to address the complexities of the momentous energy transition now underway. While I look forward to modernizing the policy, the Commission must at least adhere to the existing policy if we are serious about ensuring the continuing orderly development of natural gas infrastructure. Therefore, I am dissenting.