Date: Feb 27, 2023
Agency: North American Energy Standards Board
Summary: EPSA offers comments to the NAESB Gas-Electric Forum to suggest the most useful approach for the group’s development of recommendations for policymakers to improve the reliability of the natural gas infrastructure system necessary to support the Bulk Electric System. It is important to clearly identify the problems which need to be addressed in the short-term, prioritizing those which address gas and electric coordination during critical periods or emergency conditions. Further, while many solutions or approaches identified by the GEH forum will be widely applicable, there will be many which require deference to regional development and implementation, and in fact several are underway or are products and services developed by service providers rather than market rules or practices which can be reformed. EPSA defines numerous problems which require attention, highlights several priorities for action, and lists additional considerations that impact the feasibility or usefulness of the 120+ recommendations outlined by NAESB in its February 8th Survey.