Contracts Counsel describes a gas transportation agreement
as follows:
“A gas transportation agreement is a contract between a
buyer and an interstate gas pipeline that allows the buyer to use pipelines to
transport natural gas. In exchange for receiving access to the pipeline, the
buyer agrees to pay a certain, pre-determined price for the duration of the use
of the pipeline. This price typically reflects the cost to pay employees that
work on the pipeline, as well as any maintenance costs that regularly occur.”
Firm service, or firm
capacity, refers to the sale and purchase of an uninterruptible natural gas
supply. Firm transportation means that it will be prioritized over
interruptible supply when needed. It is more expensive to purchase firm
capacity, but it ensures a reliable gas supply for those customers. Below is a
section from FERC that describes firm vs. interruptible natural gas supply, how
they are charged, and also describes the primary and secondary markets for
pipelined gas.
Unused firm capacity may also
be released for sale to other entities, and this is done according to FERC
rules. FERC’s Order No. 636 provides for the reallocation of interstate
pipeline capacity. The method of capacity release is described by FERC below.
FERC also has further rules meant to avoid other problems, such as “flipping”
the gas volumes for profit or “tying” the release to specific events and
contingencies.
A recent opinion piece by
Shelley Hudson Robbins, senior decarbonization manager for the Southern
Alliance for Clean Energy, argues that the current trend of Southeastern
utilities entering into gas capacity contracts, or firm transportation
contracts, will be paid for by ratepayers, unnecessarily burdening them. She
writes about the latest example and the trend:
“…EQT is seeking firm transportation customers for a
500,000 dekatherm (Dth) per day compression expansion of the Mountain Valley
Pipeline that connects Appalachian Basin fracked natural gas to the massive
Williams Transco pipeline. This project is the latest in a deluge of pipeline
expansion projects that are backed by long-term contracts with Southeastern
electric utilities such as Duke Energy in the Carolinas, Dominion and Santee
Cooper in South Carolina, Oglethorpe Power in Georgia, and Southern Company in
Georgia, Alabama, and Mississippi. These companies have contracted for more
than 3 million Dth on three pipeline expansions currently underway at the
Federal Energy Regulatory Commission: Transco Southeast Supply Enhancement
Project, MVP Southgate, and Kinder Morgan’s South System Expansion 4.”
The author's affiliation with
a clean energy group and her use of the term “fracked gas” give her away as a
fossil fuel opposer, and thus, we must take that into account when evaluating
her argument. She acknowledges that the firm transportation agreements are for
existing and planned baseload gas additions, but she argues that those
additions won’t make the power grid more reliable, citing the potential for
wellhead freeze-offs and pipeline outages. These are generally not large
concerns, so I would certainly question her argument as lacking any
likelihood.
Below, she argues that
ratepayers will be burdened by having to pay for gas that will not be used.
“The contracting utilities will pay for this pipeline
capacity every month and every year for 20 years, regardless of how much gas
they actually use for power burn. These costs are passed directly to ratepayers.”
However, if they could sell
any unused volumes to other parties, then that argument is more or less voided.
I don't know of any instances where utilities are paying for gas that they
don't use or sell. They may end up selling some unused gas at a loss, but other
than that, I don't see an issue, and I find the argument faulty.
“Before encouraging any more firm capacity contracts,
utility commissioners should consider the costs of each potential contract and
compare that to the cost of the new gas generation unit that supports the FT
contract. Last year, SACE used National Renewable Energy Laboratory Annual
Technology Baseline data to estimate that a 1,360-MW combined cycle plant could
cost $1.96 billion just for construction. A plant of this size would burn about
250,000 Dth at peak. Peak burn requirements are what utilities are currently
using to guide FT contracting, even though peak burn rarely happens. Utility
commissioners and the public staff often have access to the confidential
pipeline contracts. Because the cost of these contracts is passed straight
through to ratepayers, the utilities shoulder none of the cost risk, creating a
moral hazard where utilities have no financial incentive to negotiate with
consumer bills in mind.”
She calculates the present
net value (NPV) of the contracts using a common 7-year discount rate for
utilities. She calculates the cost of the gas at nearly $42 million per year.
But, as noted, any unused volumes could be sold to other entities. Thus, the
utilities are well aware of the total costs and the potential burden for
ratepayers and are still seeing these as good and necessary investments that
provide necessary grid reliability assurance. Her alternative solution is solar
and storage, including long-duration storage. While this is technologically
feasible, with the addition of battery storage, the most likely storage source,
that alternative scenario becomes prohibitively expensive. The area will also
require gas combustion turbine resources to back up growing solar penetration on
Southeastern grids. The region is already seeing “duck curves” that must be
smoothed out by gas peaking plants. Her given solution in the op-ed is ripe
with unnecessary and incorrect judgments about gas and unreliable suppositions
and hype about renewables and storage. She does not consider the added costs of
grid integration of solar, grid growth and upgrade requirements, and
overgeneration management.
“Gas is expensive. Gas is not reliable. Solar is the
cheapest energy there is, even after Congress increased its costs, and
batteries can store excess solar and wind. Longer duration storage is available
now and advancing rapidly. Grid-forming inverters provide voltage support and
other ancillary services, and batteries ramp up and down to follow changes in
electricity load faster than any combustion turbine ever could. The sun and
wind are not commodities. They are free and homegrown. Given these facts, adding
even one more dekatherm of gas commitment to the Southeast is senseless. Let’s
do the math.”
I believe the fully accounted
math would show that her proposed solution would be far less reliable and far
more expensive than adding and contracting more gas pipeline capacity. Duke
Energy and others in the region are also utilizing the largest, most advanced,
and most efficient combined cycle gas turbines on the planet for some of their
projects. While there is certainly a need for and a place for renewable energy
on Southeastern power grids, there is also a very strong need for baseload
natural gas power, especially to replace baseload coal power, but also demand
response gas power to back up that growing amount of renewable energy. It also
seems that, perhaps, clean energy advocates have too much influence in the
region’s power grid policy dynamics.
References:
Southeast
utilities are signing gas capacity contracts that will burden ratepayers for
decades. Shelley Hudson Robbins. Utility Dive. Opinion. August 26, 2025. Southeast
utilities are signing gas capacity contracts that will burden customers for
decades | Utility Dive
Gas
Transportation Agreement: Definition, Terms, Example. Contracts Counsel. What
is a Gas Transportation Agreement? (Key Terms + Sample)
Fact
Sheet | Capacity Release. Federal Energy Regulatory Commission (FERC). Fact Sheet | Capacity
Release | Federal Energy Regulatory Commission
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