In an effort to reform the rules following Winter Storm Uri last February, the Railroad Commission of Texas (RRC) has proposed changes to designate critical natural gas infrastructure during energy emergencies.

Proposed rule 3.65 specifies the process under which entities that provide natural gas would be designated as critical customers or gas suppliers during an energy emergency. Facilities designated as critical by the RRC include wells that produce gas or casinghead gas, gas processing plants, gas pipelines and pipeline/compressor facilities. Local distribution company pipelines, gas storage facilities and natural gas liquids transportation/storage facilities also are among the proposed designated facilities.

The RRC “chose to include these facility types, located up and down the entire natural gas supply chain, because the statistics from Winter Storm Uri reveal that during the storm, every molecule of natural gas was important,” according to the proposed rulemaking.

“Each piece of the supply chain” contributes to deliver gas downstream, the RRC said. “If one piece of the supply chain cannot operate, then the gas cannot be delivered for electric generation or other important uses. Further, daily gas production alone may not be adequate for peak demand during a weather emergency, which makes gas storage an important source of natural gas.”

The RRC estimated that 6,200 operators would be required to comply with the proposed rulemaking.

As part of the rulemaking process, the RRC also worked with the Public Utility Commission of Texas (PUCT) to define what constitutes an energy emergency. The emergencies would be tied to an event that results in or has the potential to result in an electric outage. The definition, according to RRC, reflects the purpose of House Bill 3648 and sections of Senate Bill 3 to prevent the loss of power to critical natural gas facilities and other entities.

More than 30 GW of generation went offline during the weeklong February freeze. The widespread blackouts came as temperatures plunged to single digits in parts of Texas. The Electric Reliability Council of Texas, the grid operator for 90% of the state, along with the PUCT, came under fire following the storm. Multiple bankruptcies and lawsuits followed.

The RRC said designated critical customers are required to provide electric power providers with critical customer information.

The proposal does not prioritize the critical facilities for load-shed purposes, however. Electric entities have the discretion to prioritize power delivery and restoration among the facilities and entities designated as critical.

The RRC said designating a critical facility would not guarantee it would receive power during an energy emergency. Facilities also could file an exemption to not be deemed as critical.

If implemented as proposed, the new rules would cost an estimated $7.2 million over the first five fiscal years. The regulator also is considering other amendments.

A workshop to allow the RRC and members of the public to discuss the changes is scheduled for 9:30 a.m. CT on Oct. 5. Comments may be submitted to Rules Coordinator, Office of General Counsel, Railroad Commission of Texas, P.O. Box 12967, Austin, TX 78711-2967. Comments also can be submitted online or emailed. Comments are due by Nov. 1.