TXOGA Statement on Public Utility Commission’s E3 Report

November 10, 2022

The following statement can be attributed to Todd Staples, president of the Texas Oil & Gas Association:

“The E3 report released today by the Public Utility Commission (PUC) recommends the implementation of a forward reliability market—a capacity market for the ERCOT system. Total system cost, cost to consumers—industrial and residential—and timeframes of implementation remain of great concern for the Texas oil and natural gas industry with this type of design.

“To attain both reliability and affordability, our priorities for electricity market design are to ensure that our system is market-based, risk is not shifted to consumers, and that additional revenue to the system results in actual dispatchable energy that is used and that benefits consumers.

“In particular, the report notes a need to address fuel security issues, and that a lack of access to fuel supplies has led to correlated outages during past weather conditions. We recognize that ERCOT is working to continue to purchase adequate ancillary services and update its market structure to be able to procure Firm Fuel Supply Service, which will encourage generators to preplan and have the necessary fuel during an emergency. In addition, new legislative weatherization requirements for generators and critical customer designations will greatly improve deliverability during cold weather events.

“We look forward to commenting and continuing to work with the PUC to ensure that the best electricity market design for Texas is chosen.”


Founded in 1919, TXOGA is the oldest and largest oil and gas trade association in Texas representing every facet of the industry.

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