IPAA Joins with Other Gas Trade Associations in Submitting Comments to PJM Interconnection, LLC, on Study of Fuel SecurityLetters and Comments Mar 11, 2019
IPAA joined with API, INGAA, and NGSA in March 7 comments to PJM Interconnection, LLC (PJM) on its Valuing Fuel Security Initiative. The initiative is part of PJM’s ongoing fuel security study, which has indicated that PJM’s system is “reliable today and will remain reliable into the future,” even with increased reliance on natural gas generation. However, the reliability and resiliency of natural gas for electric generation continue to be targeted by groups that would advance coal and nuclear generation at the expense of natural gas.
In the joint comments, the associations urged PJM to: (1) provide time for a more deliberative process; (2) avoid assumptions about what market and operation changes, if any, will result from the task force efforts; (3) revise the review parameters to encompass all risks that threaten electric grid stability, not just fuel security; (4) explain why current reserve margin levels and successful capacity performance program are insufficient for addressing outages that may occur with increased reliance on natural gas; (5) ensure fuel neutrality when developing criteria for defining a “fuel secure” resource; and (6) recognize that all fuel sources have vulnerabilities and not single out natural gas for special attention.