FERC Filings

EPSA's Comments on Natural Gas Council’s White Papers

The Importance of Gas Quality to EPSA

EPSA members are significant users of natural gas, and quality is a critical aspect of a generator’s operations, thereby directly impacting a generating unit’s reliability and competitiveness. Natural gas costs represent approximately 90 percent of the marginal cost of power production for gas-fired generation. Hence, generators maintain a strong interest in developing and maintaining adequate gas supplies. Electricity generators recognize that natural gas producers and pipelines need flexibility to maintain adequate market supply and to keep prices low. In addition, the development of new supply sources, such as LNG and Artic natural gas, is important in moderating these costs. However, these new supply sources also bring operational challenges for generators, given the narrow range of variability in gas quality that modern gas turbines can tolerate without impacting both operational reliability and environmental compliance. While generators are concerned with the price paid for delivered fuel, units must also be sure to maintain their operational integrity – both are critical to the financial viability of plant output.

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