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On November 1, APGA submitted comments in response to a proposed rule issued by the Railroad Commission of Texas (TX RRC) pertaining to the critical designation of natural gas infrastructure. While APGA does not typically engage at the state-level, identification of natural gas infrastructure in Texas is critical to ensure that electric curtailments during a weather emergency are appropriately planned to minimize impacts to gas supply for utilities and customers in or out of the state.

Through the comments, APGA supports the general idea of the rulemaking, but offers suggestions on how to improve the rule, such as requiring reporting to counterparties and making clear what factors would allow a facility to qualify for an exemption to the rule. During Winter Storm Uri, the state grid operator cut power to certain natural gas production facilities, which further reduced production capacity and hindered repairs at a time of already constrained supply. The TX RRC’s proposed rule, if amended, has the potential to alleviate some of the supply issues related to electric curtailments that the central U.S. experienced in February but making clear what facilities are critical to natural gas supply and are capable of operating during severe weather.

A copy of the comment letter is available here.

For questions on this article, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at rlani@apga.org.