Before each winter, many organizations responsible for overseeing North America's power grids release risk assessments. These reports primarily focus on reliability and resiliency, with less emphasis on wholesale prices. Although wholesale prices can indicate risk, forward prices do not always fully capture the potential risk of energy scarcity. Conversely, forward price volatility may sometimes reflect risks that are less likely than the prices suggest. This article summarizes some of these risk assessments and highlights the risks currently indicated by forward market prices for January and February 2025.

To start, the North American Electric Reliability Corporation (NERC) releases a Winter Reliability Assessment (WRA) each fall, covering key markets and regions across North America, including PJM, New York, New England, and Texas. This year’s report largely aligns with expectations, indicating that most deregulated regions face reliability risks during periods of "above-normal" load conditions. This risk summary is shown below in Figure 1.

Figure 1. Winter Reliability Risk Area Summary, by NERC

According to NERC, the primary risk facing most regions this winter is the availability of natural gas. While the power industry has made significant strides since 2021 to enhance power plant performance, much of this progress has focused on improvements in planning and forecasting. However, the most significant challenge remains the capacity of natural gas pipelines and maintaining adequate pipeline pressure levels during periods of extreme cold, which continue to pose the greatest threat to reliable power production during the winter months.

As we approach the end of August, the focus of the summer typically begins to shift towards things like kids returning to school, parents seeking a more normal schedule, the excitement and optimism of each football team’s upcoming season, and hopefully milder temperatures across our power grids.

Given this, we thought it would be appropriate to give a quick update of how the summer has played out so far, by region and commodity (gas and power).

Hurricane season officially began this month and in a report at the end of May, NOAA predicted between 17 and 25 named storms for the period between June 1 and November 30. According to NOAA, “The upcoming Atlantic hurricane season is expected to have above-normal activity due to a confluence of factors, including near-record warm ocean temperatures in the Atlantic Ocean, development of La Nina conditions in the Pacific, reduced Atlantic trade winds and less wind shear, all of which tend to favor tropical storm formation.” It is only three weeks into hurricane season and Tropical Storm Alberto has already pounded Mexico and parts of Texas with torrential rain and flooding. Many clients ask how hurricane and tropical storm activity affect energy prices. In the past, significant hurricane activity in the Gulf of Mexico had a major impact on natural gas prices. In the 1990’s, hurricane tracking was one of the most important fundamentals energy traders watched. The destructive capabilities of a powerful hurricane in the Gulf of Mexico heading towards the large production regions (Corpus Christi TX to Mobile AL) would cause drilling and production platforms in the Gulf to evacuate their personnel, typically requiring the well to be closed. This would result in a dramatic reduction in the amount of natural gas produced for a week or more if there was substantial damage to the platforms. As shown in Figure 1, the highest natural gas prices in the last thirty years occurred in the wake of Hurricanes Rita and Katrina in 2005. Both storms caused major disruptions to the production and flow of natural gas.   

On behalf of the team at 5, I am pleased to forward our May 2024 market letter.  In this edition, we discuss several interrelated topics.  First, we look at ongoing legal challenges to two new federal energy regulations, (i) the SEC’s climate change reporting rules, and (ii) the EPA’s new power plant emission standards. Second, we address a question we are hearing often from our clients, especially those faced with rising energy prices: “Could President Trump’s election reduce the price of electricity?”  

In late January, the Biden Administration paused all LNG export facility applications, so that the Department of Energy (DOE) can assess whether any additional LNG export capacity is in the public interest. There seems to be a little confusion in the general public as to what exactly this pause does to short-term and long-term LNG export capacity and therefore natural gas supply and price. We thought it would be helpful to illustrate what this suspension means in terms of actual natural gas supply and demand.

We will skip the politics of the decision for now and jump straight to the facts of the matter.

First, this suspension only impacts pending applications requesting to export to countries without a Free Trade Agreement in place with the US ¹. That’s the first carve out. Second, there is already 14.28 Bcf/day of export capacity in operation in North America (not affected by this order), and another 12 Bcf/day under construction (also not affected by this order). Finally, there is also another 22 Bcf/day of approved capacity not yet under construction (also not impacted by this order), most of which is still working toward a Final Investment Decision (FID), meaning the developers of the sites are still trying to gather enough long-term contracts to move forward with the construction phase of the project.

All in all, by the end of 2026, North America will have a total daily output capacity of almost 25 billion cubic as shown in Figure 1. To put that into perspective, the total global LNG demand in 2023 was about 400 million tons, which is the equivalent of about 53 Bcf/day. The entire market demand is currently 53 Bcf/day, the US, Canada, and Mexico have 14 Bcf of active export capacity online and another 34 Bcf of capacity under construction, or approved (bringing the total to 48 Bcf). Given that the US is not the only game in town (Russia and Qatar also have another 27 Bcf/day in development), it seems as though our future LNG export capacity might exceed global demand, even with forecasted demand growth ².

While it has become common over the last few years for the bears of the natural gas market in the US to rule the month of December and drive down the coming winter’s (January and February) contract, this fall it seems like December came early. For almost the entire month of November, warmer-than-normal weather forecasts, both weekly and monthly, have been relentless for any traders holding on to long positions.  Since Halloween, the Dec. ’23 – Feb. ’24 strip has dropped about 75¢, from $3.65 down to $2.90 per MMBtu as shown in the blue line in Figure 1. This chart also shows that prices have fallen for the April 2024 to November 2024 strip (black line) over the last several weeks. 

On behalf of the team at 5, I am pleased to forward our September market letter. If you had any doubts that the energy transition is happening, recent events in Texas and New York confirm that the answer is yes. As discussed below, these states have very different approaches to energy regulation, and both have struggled to incorporate intermittent resources in the energy mix. For clients in Texas, New York, or any other deregulated market, planning for the challenges of the energy transition, including increased regulatory risk, should be a key component of your energy management strategy.

One of the most utilized pieces of fundamental analysis in the natural gas industry is the Energy Information Agency’s (EIA) Natural Gas Storage Report, which is released every Thursday morning at 10:30 ET.  This report summarizes the results of a weekly survey of most natural gas storage facilities across the US and shows how much natural gas the nation has in storage. It also gives a regional breakdown, along with a reference to normal storage levels for each week of the year as shown in Figure 1.  Many industry analysts use this data and the amount of natural gas in storage compared to what is normal (the 5-year average is commonly used) to understand and forecast natural gas prices.

On May 11, 2023, the U.S. Environmental Protection Agency (EPA) proposed new rules designed to limit emissions from existing and new coal and natural gas fired power plants. This is the EPA’s third swing at regulating CO2 emissions from power plants. Its first at-bat dates back to 2015 when the Obama Administration’s EPA introduced the Clean Power Plan (CPP). The CPP proposed state-by-state emissions limits. These limits were quickly challenged by numerous states, particularly those with significant amounts of coal-fired generation. While these legal challenges were ongoing, President Trump was elected. Trump scrapped the CPP and introduced the Affordable Clean Energy Rule (ACE), which overrode the CPP and gave the states more power to set their own emission limits. The ACE also faced challenges in the courts.

In June 2022, the Supreme Court issued a ruling in West Virginia v. EPA that significantly limited the ability of the EPA to regulate emissions without a clear mandate from Congress. This ruling assures that the EPA’s new proposed rules, if finalized, are likely to face a lengthy legal battle.

The latest EPA plan sets out aggressive emission reductions and is likely to further accelerate the retirement of fossil fuel generation units. By 2030, the EPA plan requires any coal plant that intends to operate past 2040 to use a carbon capture and storage (CCS) system to eliminate 90% of its CO2 emissions. Large natural gas generation units will also be required to install a CCS that captures 90% of their carbon emissions by 2035 or operate on clean hydrogen by 2038. While there are different restrictions for smaller generation units, the EPA’s rules lean heavily on carbon capture, clean hydrogen and in some instances, use of dual-fueled gas plants with both natural gas and green hydrogen. At the same time, the EPA has acknowledged that CCS and clean hydrogen are not yet in widespread commercial use.

As filed last week, the EPA plan is a proposed rule, and the EPA will need another year or so to issue a final version. Once the final version is issued, states will have another two years to submit plans to comply with the regulations. This timetable will be delayed further by the inevitable legal challenges. West Virginia Senator Shelley Moore Capito and Attorney General Patrick Morrisey have already vowed to lead congressional and legal efforts to kill the rule.

A few things are clear. First, if the rules are adopted, the cost of generating electricity from coal and natural gas plants will increase dramatically. Second, even if the prospects for the EPA’s new rule are limited by various challenges, the proposed rules will cast a shadow over new investments in existing and new fossil fuel generation. Testifying before FERC on May 4, 2023, a bipartisan panel of FERC commissioners (2 Democrats and 2 Republicans) raised their shared concern that the reliability of our electricity grid is challenged by the fact that we continue to see fossil plants retire at a rate far faster than they are replaced by new emission-free generation. Of course, we will continue to monitor this important regulation on behalf of our clients.