EL26-67-000 · 2026-08-10 · NATURAL GAS SUPPLY ASSOCIATION (DC)

Comments of the Natural Gas Supply Association on the Informational Reports re Resource Adequacy Measures and Proposals, PJM Interconnection L.L.C., et al

August 10, 2026 
 
 
 
The Honorable Laura Swett, Chairman 
Federal Energy Regulatory Commission 
888 First Street, NE 
Washington, D.C. 20426  
 
Re:  Informational Reports Regarding Resource Adequacy Measures and Proposals, 
PJM Interconnection L.L.C., Docket No. EL26-67-000; Southwest Power Pool, Inc., Docket 
No. EL26-68-000; New York Independent System Operator, Inc., Docket No. EL26-69-000; 
Midcontinent Independent System Operator, Inc., Docket No. EL26-70-000; California 
Independent System Operator Corporation, Docket No. EL26-71-000; ISO New England 
Inc., Docket No. EL26-72-000  
 
Dear Chairman Swett:  
 
The Natural Gas Supply Association (NGSA) appreciates the opportunity to comment on the 
Informational Reports directed by the Commission’s June 18, 2026, orders in the above-
captioned dockets.  
 
As industry participants who produce, ship, and deliver U.S. natural gas, NGSA members view 
these reports as vital tools for tracking resource adequacy across regional operators. However, to 
ensure a complete picture of grid reliability, the Commission should direct regional transmission 
organizations (RTOs) and independent system operators (ISOs) to supplement these reports with 
an assessment of whether existing natural gas infrastructure and fuel supply arrangements are 
sufficient to support anticipated growth in electricity demand. 
 
I. 
Natural Gas is Critical to Supporting Large Load Growth  
 
Because of its scalability, reliability, and rapid dispatchability, natural gas will remain a 
significant fuel source to support much of this new electrical demand. As noted in an article by 
Data Center Dynamics, natural gas is uniquely suited to meet the immediate needs of data

2 
 
centers because it is the most dispatchable fuel source available, can run at capacity factors 
exceeding 80 percent, and can be ramped up within minutes to meet demand. 1 
 
In fact, there has been a dramatic uptick in new gas generation in the interconnection queues 
across the country. For example, the amount of natural gas generation in PJM’s interconnection 
queue has increased by a staggering 1,458% (surging from approximately 6,800 MW to 106,000 
MW, where it now represents 48% of the total queue volume) over the past two years. Similarly, 
there has been an incredible shift in MISO, where gas requests have spiked over the last 24 
months to now dominate the fast-track Expedited Resource Addition (ERAS) queue, capturing 
75% of the new expedited capacity requests. The need for new natural gas infrastructure built in 
tandem to support this magnitude of growth in gas generation cannot be ignored.  
 
The United States is uniquely positioned to meet this demand as the largest net producer of dry 
natural gas, supported by a vast pipeline network spanning more than three million miles. The 
upstream natural gas system possesses ample productive capacity to supply this growing market. 
NGSA member companies are already actively partnering with data center developers and power 
generation entities to create tailored commercial solutions underpinned by natural gas services to 
support this evolving market.  
 
II. 
Infrastructure Constraints Threaten Reliability Efforts  
 
While much attention has been focused on ensuring adequate power generation to meet rapid 
demand from data centers and other large loads, and rightly so, we are concerned that the 
magnitude of new pipeline capacity to support that growing load may not be fully appreciated. 
Despite the robust gas supply, regional energy security is increasingly limited by the delivery 
infrastructure "straw"—rather than the wellhead. Multiple interstate pipeline mainlines currently 
run near maximum capacity during peak periods.  
 
If left unaddressed, localized infrastructure shortfalls will directly limit a region's ability to 
develop and dispatch new gas generation when and where it is needed most, particularly during 
extreme winter weather. Furthermore, the interdependence between the gas and electric sectors 
continues to grow as upstream and midstream operations become increasingly electrified, 
requiring more transmission. Failing to account for the full energy ecosystem—including 
necessary pipeline infrastructure—limits the regional operators’ ability to achieve full success in 
these critical resource adequacy initiatives.  Simply put, generation cannot be separated from fuel 
assurance. 
 
III. 
Conclusion and Specific Request for Supplemental Reporting  
 
NGSA does not ask the Commission or RTOs to reprioritize their current, complex workloads 
regarding large load integration. Rather, we urge the Commission to ensure that fuel availability 
is explicitly recognized as a core component of the total grid reliability equation.  
 
1 See Data Center Dynamics, Welcome to Gas Land: How Natural Gas is Powering the US AI Boom (May 2025), 
https://www.datacenterdynamics.com/en/analysis/welcome-to-gas-land-how-natural-gas-is-powering-the-us-ai-
boom/

3 
 
To that end, we ask the Commission to issue a directive requiring regional operators to 
supplement their informational filings with a dedicated section detailing:  
 
1. How they assess whether regional natural gas infrastructure can support the expected 
growth in natural gas for power generation.  
2. What regional initiatives or stakeholder processes are underway to address any identified 
natural gas infrastructure shortfalls.  
3. Their efforts to support generator fuel adequacy, such as ensuring power market reforms 
that encourage strong natural gas contracting practices. 
 
At a minimum, such information should be mandated in any updates or future Informational 
Reports required by the Commission.  
 
Respectfully submitted,  
 
 
Dena Wiggins 
President & CEO 
Natural Gas Supply Association  
 
cc: Commissioner David Rosner 
     Commissioner Judy W. Chang 
     Commissioner Lindsay S. See 
     Commissioner David A. LaCerte