We are issuing four orders approving natural gas and LNG infrastructure projects today. The separate statements that I and other Commissioners are issuing in these four matters reflect rather different perspectives on difficult legal and policy questions.
Specifically, I continue to disagree with my colleague’s conclusion, without considering the record we have developed on the subject, that it is impossible to determine the significance of greenhouse gas emissions. I believe we are required under both the Natural Gas Act and NEPA to try to fully assess and consider climate impacts in our public interest determinations.
Rather than looking for reasons the Commission cannot assess climate impacts, we should objectively evaluate ways that we can. And we have a record with which to do that. I am hopeful that by addressing the hard issues surrounding climate impacts in a generic proceeding, the Commission will improve the quality and legal durability of its future decisions.
A-3 | FERC-NERC-Regional Entity Joint Inquiry Into Winter Storm Elliott
This is a really important analysis and a really important set of recommendations. Thanks to all of you for the presentation and for the work that has gone into this. I commend Chairman Phillips and Jim Robb on how you were able to get this out quickly, and I’m so glad it’s out now today.
As you just said, Winter Storm Elliott is the fifth event in the past eleven years in which cold weather outages jeopardized bulk-power system reliability. That’s the part the Commission has jurisdiction for – the bulk electric system. That’s almost a flip of a coin each year as to whether or not we’re going to have one of these events. And we’re just not sufficiently weatherized. The whole system is not sufficiently weatherized.
There are some strikingly similar lessons learned emerging from Uri and Elliott. This data reinforces the amount of widespread unplanned outages. In Elliott, 13% of anticipated resources in the entire Eastern Interconnection failed to deliver energy at some point during the storm. That’s an astounding figure. Total outages in megawatts were 50% higher than they were in Winter Storm Uri.
I want to repeat some of the things that Kiel and Matthew said about three main causes: (1) mechanical and electrical failures, (2) freezing, and (3) fuel problems. This is despite the fact that many of these units subject to these three types of problems had “minimum operating temperatures” that were well below the temperatures that were actually experienced during the storm. That’s troubling.
One of the repeated recommendations from Uri to Elliott is about whether these cold weather reliability standards, including generator weatherization requirements, are sufficient to meet our new weather realities. You may recall that in February we asked NERC to propose stronger reliability standards for generator weatherization. Having now affirmed the criticality of stronger standards related to both storms in addition to previous events, I am very eager for the results of this effort early next year.
I want to pause on this recommendation related to establishing a gas system reliability framework. As the Chairman said, someone needs to do it. The LDCs didn’t have heat for 8 days, in some cases. Congress needs to give us instructions on how to ensure that our natural gas infrastructure can withstand this collective stress. Short of that, the burden is on us. We could come in and say we need more infrastructure, but the infrastructure that was there didn’t work. From the production head through generation, we saw failures. We need to focus on the part we have jurisdiction over now, and industry needs to lean in, whichever part of the industry you’re in, to cut through some of these problems.
Of course, my biggest concern is that these recommendations are going to sit on a shelf. We can’t do that, and I know that Chairman Phillips has been clear about making that a priority.
Finally, I’ll close on a potential happy note on the benefits of interregional transmission. It was highlighted briefly today, but it is a key factor in how well regions perform under extreme weather stress. PJM has stated that its ability to import power from its northern neighbors and MISO allowed it to avoid load shedding during Elliott. That was during the time when 13% of the resources across the Interconnection were not available at some point, so it’s so impressive they were able to avoid that. I urge the Commission to take a holistic approach to our reliability responsibilities and to consider prompt action in our open interregional transfer capability docket.
I want to thank you all for your good work.