Item A-3 | Presentation
Good morning, Chairman and Commissioners,
In November 2022, the team began its study into one of the worst-case scenarios for the Texas Interconnection—a blackout. Any blackout imposes profound effects upon industry, business, community, and life, which would be compounded during an extreme cold weather event. During extreme cold weather events, both the electric and natural gas systems are more likely to be stressed and vulnerable to outages. Blackstart system restoration plans are dependent upon blackstart resources, which are primarily generators capable of starting up without relying on power from the grid. These blackstart resources, and associated next-start resources, are therefore critical components of a restoration plan for restarting electric service after a blackout. Ensuring their availability is paramount.
This study was recommended by the 2021 report on Winter Storm Uri, which identified instances where blackstart resources were rendered unavailable during the event. The study focused on nine, voluntary industry participants made up of electric and natural gas entities that operate in the Texas Interconnection. These participants were, without exception, exemplary in their cooperation and the team commends them for their feedback, involvement, and contributions to the study.
The blackstart availability study, which FERC, NERC, and the Regional Entities are jointly releasing today, assessed: (1) the characteristics of blackstart and next-start resources; (2) the characteristics of natural gas supply contracts and delivery infrastructure for blackstart and next-start resources relied upon in blackstart system restoration plans; (3) the testing of blackstart resources and their fuel switching capabilities where applicable; and (4) the blackstart and system restoration operating personnel training practices, procedures, and resources.
The team studied the participants’ blackstart resource testing, fuel-switching, fuel delivery infrastructure, fuel supply contracts, and coordination between electric and natural gas entities. From these study observations, the team identified beneficial observed practices for consideration and made recommendations aimed at improving winterization and blackstart system restoration overall. The team views the study’s recommendations as proactive, to help all necessary entities preemptively plan for recovering from a blackout. While the recommendations in this study are voluntary and the study imposes no obligations beyond those required by the relevant Reliability Standards, the team strongly urges all entities that play a role in blackstart system restoration to implement the study’s recommendations and observed beneficial practices.
I will now pass it on to David Till, from NERC, to discuss the observed beneficial practices for consideration seen by the team.
David Till, NERC:
For the purposes of this study, observed beneficial practices for consideration refer to actions currently being performed by at least some of the participants in this study, whereas the recommendations refer to actions that are either not currently being performed or could be enhanced. The team observed that the participants have many practices and procedures pertaining to blackstart resource availability, testing, communication and coordination, and training that serve to enhance their preparations for a blackout. While they may not be universally applicable to all electric and natural gas entities, incorporating these observed beneficial practices, where appropriate, could add significant value and resilience to the electric and natural gas infrastructure. Some examples of these beneficial practices observed by the team include:
- Installing permanent winterization measures to minimize the use of temporary measures, such as portable space heaters, at generating resources. Permanent mitigation could limit the amount of annual maintenance required.
- Maintaining a list of blackstart-capable resources not identified in blackstart system restoration plans that could be used during a blackout if other blackstart resources become unavailable. These blackstart-capable units add resiliency, flexibility, and redundancy to blackstart system restoration plans.
- Performing expanded testing, where feasible, could confirm the viability of blackstart capability through coordination between blackstart resources and transmission entities. Expanded testing could be used to update system models and blackstart system restoration training programs.
- Considering the impacts of extreme cold weather on the operability and performance of backup batteries located on key communication paths and at critical transmission substations, and how battery life is impacted by cold weather.
The study discusses these, and additional beneficial practices observed by the team.
I will now pass it on to Robert Clark from FERC for a more in-depth review of the study’s recommendations.
Robert Clark, FERC:
This study has seven total recommendations; these recommendations focus on (1) blackstart system restoration planning and testing; (2) an assessment of natural gas availability to blackstart and next-start resources, as well as improved electric and natural gas coordination; and (3) the prioritization of natural gas supply and transportation to blackstart and next-start resources.
Effective blackstart system restoration requires the necessary electric and natural gas entities to work collaboratively across multiple jurisdictions and functional responsibilities to restore the system. The recommendations in this study are tailored to apply to all entities that play a role in blackstart system restoration, understanding that some entities may have a larger role than others in the development and implementation of a blackstart system restoration plan. While this study was focused on the Texas Interconnection, the team believes that many of the study’s recommendations could be beneficial to regions and entities outside of this Interconnection.
Recommendations 1a, 1b, 1c, and 1d apply to the entities responsible for developing and implementing a blackstart system restoration plan.
Recommendation 1a advises these entities to examine the diversity of fuel, single points of failure, fuel arrangements, and other limitations of each blackstart resource. Fully understanding these elements would provide entities with insight into the likelihood of blackstart resource availability. This assessment could also help entities prepare for, mitigate, and respond to a blackout.
Recommendation 1b states that these entities should evaluate and incorporate a wide variety of options into their blackstart system restoration plans. For example, entities should consider the use of electrical bypasses, high voltage direct current ties, variable frequency transformers, block load transfers, and non-fuel energy resources. During a blackout, these alternatives could add diversity and resilience, particularly if natural gas to blackstart and next-start resources is limited or unavailable.
Recommendation 1c suggests that these entities incorporate off-site natural gas storage in their blackstart system restoration plans. The natural gas supply chain may be severely stressed or completely unavailable during a blackout. Stored natural gas may increase the likelihood of blackstart and next-start resources being able to secure fuel more quickly and reliably in the event of a blackout.
Recommendation 1d states that these entities should implement a testing requirement for blackstart resources to perform alternate fuel startup tests completely on alternate fuel. Performing these alternate fuel startup tests would confirm that dual-fuel capable blackstart resources are able to start on alternate fuel during a blackout when external electricity sources and primary fuel is unavailable. Additionally, if the testing requirements are already in effect, these entities should ensure that the requirements are clearly defined so that the blackstart resources are able to perform these tests effectively.
I will now pass it on to Mark Henry from Texas RE to discuss recommendations 2a, 2b, and 3.
Mark Henry, Texas RE:
Recommendations 2a, 2b, and 3 address an assessment of natural gas availability to blackstart and next-start resources, improved coordination between the electric and natural gas entities, and the prioritization of natural gas supply and transportation.
Recommendation 2 states that the appropriate state and other authorities with jurisdiction should facilitate and moderate engagement among the entities responsible for developing and implementing a blackstart system restoration plan.
Recommendation 2a suggests that these authorities should assess the impact of a blackout on the natural gas supply chain with a focus on natural gas availability to blackstart and next-start resources. This assessment could help the electric and natural gas industries better understand what action is required in a blackout and which electric and natural gas entities are vital for blackstart system restoration.
Recommendation 2b states that the entities necessary for blackstart system restoration should develop a coordinated blackstart system restoration plan that incorporates the needs of both the electric and natural gas industries. The entities should work collaboratively to develop this plan and should prioritize the natural gas infrastructure required to supply natural gas to the blackstart, next-start, and other essential resources. This plan could help ensure a more coordinated blackstart system restoration between the electric and natural gas industries.
Recommendation 3 proposes that the appropriate state and other authorities with jurisdiction over developing and defining natural gas curtailment plans and standards should evaluate elevating the priority of natural gas supply and transportation to blackstart and next-start resources. The curtailment of natural gas to these resources could lead to their unavailability. Such an evaluation would help entities ensure that natural gas supplies are prioritized and thus, available to blackstart and next-start resources when natural gas supplies are limited.
I will now pass it back to Chanel Chasanov from FERC to give concluding remarks.
Chanel Chasanov, FERC:
The team recognizes that there is a shared responsibility and need for the electric and natural gas industries to work together to plan for a blackout and to identify the necessary electric and natural gas entities that would need to perform a synchronized blackstart system restoration. To that end, the study’s observed beneficial practices and recommendations aim to improve this coordination, collaboration, and planning between all the entities necessary for blackstart system restoration.
This concludes our presentation. The blackstart study will be published later today and posted on the Commission’s, NERC’s, and Texas RE’s websites. We are happy to take any questions you may have.