Charlotte-area natural gas capacity: the main utility projects a coldest-day shortfall from winter 2027-28

By Sam Strong, Vice President of Business Development, Discovery Energy. Technical review by Tara Dugger, Chief Operating Officer. Updated October 2026.

Metro used: the Charlotte-Concord-Gastonia, NC-SC metropolitan statistical area, as the federal government defined it in OMB Bulletin No. 23-01 (July 21, 2023).¹ This page reads two gas utilities, whose counties we read from the service-area map of the North Carolina Utilities Commission (the Commission).² They are Piedmont Natural Gas Company, Inc. (Piedmont) and Public Service Company of North Carolina, Inc. (Enbridge Gas North Carolina). Each utility's figures are for its whole system. Municipal systems and South Carolina county gas authorities are gaps in this page.

Key takeaways

Who serves the Charlotte area?

Piedmont serves Mecklenburg, Union, Anson and Lincoln counties, and Enbridge Gas North Carolina serves Gaston, Iredell and Cabarrus counties.³ Piedmont says it serves about 830,000 customers in over sixty North Carolina counties.⁸ Rowan County is shown in both utilities' colors on the Commission's map, so this page does not assign it to either.²⁴ Neither utility publishes figures for the Charlotte area alone.²⁰ The figures on this page cover each utility's whole system.²¹ Chester, Lancaster and York counties in South Carolina are served by county natural gas authorities, according to our crosswalk of federal utility reporting (EIA-176), and this page read no records for them.²² Municipal systems in Monroe, Bessemer City and Kings Mountain also appear in the crosswalk, and this page read no records for them either.²³ Two facilities are not in the metro's counties but supply the systems that serve it: Pine Needle LNG, Piedmont's largest peaking source, and the Moriah Energy Center in Person County. Pine Needle's share on this page is measured against the design day of a utility that serves the metro.²⁵

Has Charlotte had gas supply problems since 2020?

Neither utility's testimony describes a service cut during the winter storms of early 2026. Piedmont said it did not need to interrupt or curtail service to any North Carolina customer in its review period, which included Winter Storms Gianna and Fern in January and February 2026.²⁶ It also said those conditions were not as severe as its design day. Enbridge Gas North Carolina said it used LNG withdrawals during the same storms to manage demand and avoid higher-priced purchases.²⁷ It described no curtailment. Piedmont said that constraints on the mainline of Transcontinental Gas Pipe Line Company, LLC ("Transco"), between East Tennessee's Cascade Creek interconnect and Piedmont's citygate (where the pipeline hands gas to the utility), prevented firm deliverability of East Tennessee supply.¹⁶ That led it to release that capacity. The testimony names no gate station inside the Charlotte metro, so it does not change the rating. Piedmont's testimony reports that the Public Staff recommended continued attention to dependence on Transco for delivery to North Carolina.²⁸

How much spare gas capacity does Charlotte have on the coldest day?

Piedmont's own schedule shows spare capacity on the coldest day shrinking each winter. The public record has no figure for Charlotte alone. Piedmont's schedule lists the same total capacity, 1,631,675 dekatherms per day, in every winter.²⁹ Its firm design day demand grows from 1,548,477 in 2026-27 to 1,681,699 in 2031-32.³⁰ So the margin over design day demand narrows each winter.

Piedmont's design day demand and supply for its whole Carolinas system (North Carolina and South Carolina), as filed in August 2026.¹⁰ Piedmont adds a 5% reserve on top of design day demand, which is 77,424 dekatherms per day in 2026-27, and arranges supply to cover it.³¹ The margin in this table leaves the reserve out and measures capacity against design day demand alone. Piedmont's own shortfall figure also subtracts the reserve. The last column shows Piedmont's figures, and our calculation of capacity less demand plus reserve gives the same values.³² The Public Staff recommended that Piedmont give the quantitative basis for the 5% reserve or stop presenting it as a required planning threshold.³³ Piedmont's 1-in-30-year design day condition is stated for three areas of its territory (North Carolina East, North Carolina West and South Carolina).³⁴ Its demand figures are for the whole Carolinas system.²⁰ So there is no figure for Charlotte alone in the filings read.

What is driving new natural gas demand?

The filings read show no planned gas-fired generator in the metro's counties and no data center load tied to gas. Piedmont says continuing customer and load growth in North Carolina, concentrated in the residential sector, is the primary driver of its increasing design day demand.³⁵ We searched the U.S. Energy Information Administration's (EIA) monthly generator inventory (EIA-860M, September 2026 Planned sheet) and found no planned natural gas-fired generator in the 11 metro counties.³⁶ We also searched the Federal Register for notices of the Federal Energy Regulatory Commission (FERC) since January 2025 naming the 14 counties of the two metros with a pipeline docket and found none.³⁷ Data centers: As of October 28, 2026, we found no gas-fired generation, fuel cell, pipeline lateral or gas utility special contract for a data center in the metro in the official sources we could search.⁶⁷ EIA's September 2026 generator inventory, still its latest edition, lists no planned natural gas unit in North Carolina.⁶⁸ The Commission's dockets could not be reviewed, so filings there may not be reflected, and the searches we could not run are in the notes. On October 7, 2026 Duke Energy said a settlement would add protections for existing electric customers from the cost of serving data centers and other large loads; it concerns electric service, not gas.⁶⁹ Nearby: Person County, where Moriah is under construction, is not in the metro. We read no filing about a gas load there, so we do not treat it as demand on the systems that serve Charlotte.⁷⁵

Are upgrades arriving in time?

On the record read for Piedmont, no upgrade is shown arriving before the projected shortfall begins. The projected shortfall begins in winter 2027-2028.⁵ Piedmont plans to decide on additional supply by the end of 2026, and it targets winter 2031-2032 for in-service.⁷ It plans short term peaking services such as delivered supply calls for the years between, and no contract for them is shown.¹³ The Public Staff recommended that Piedmont complete its evaluation of long-term options and present it to the Commission.¹² For the Enbridge Gas North Carolina counties, the utility's table shows shortfalls from 2026-27 before Moriah and Southgate.³⁸ Moriah is estimated in service in early 2027, and Southgate is targeted for mid-2028.³⁹ FERC approved Southgate on December 18, 2025.¹⁹

Winter and market context

Weather and market conditions do not change the outlook level. In the Charlotte region. The Charlotte metro spans North Carolina and South Carolina, both in EIA's East storage region. EIA's weekly table lists working gas for that region at 900 billion cubic feet for the week ending October 16, 2026.⁴⁵ The five-year comparison EIA states was not read. EIA's citygate tables list 6.01 dollars per thousand cubic feet for North Carolina and 6.96 for South Carolina for July 2026, the latest month saved.⁴⁶ Prices are commodity costs, not a measure of delivery constraint, so they do not enter the rating. National storage, El Nino, LNG export and Henry Hub figures are in the note.⁷⁶ Transco, which delivers to both utilities in the metro, posted imbalance operational flow orders (orders telling shippers to keep their gas flows in balance) for its Zone 5 in each of the last three winters.⁴⁸ Our counts are in the table below.⁴⁹ Transco's location list shows 9 active locations in the metro's counties, all in Zone 5.⁵¹ These are a different measure from critical days (urgent operating notices posted by the pipeline), which this page does not count because no critical-day count is available for this metro.⁵⁰ The Pine Needle, Enbridge LINK and Mountain Valley pages saved on October 27, 2026 list no notices in the pages as saved. So the public record doesn't show notices for those pipelines.⁵²

Our count of Transco's Zone 5 imbalance orders in each winter, from notices saved October 27, 2026.⁷⁴

Winter weather and NOAA's outlook

The three recent winters were milder than normal at the Charlotte Douglas Airport weather station; the table gives November to March heating degree days (a measure of how cold the weather was) and their share of the 1991-2020 normal.⁷⁰ On October 15, 2026, NOAA's Climate Prediction Center leaned slightly toward above-normal temperatures for the Charlotte area for both November 2026 to January 2027 and December 2026 to February 2027.⁷¹ These are NOAA's probabilities for a three-month average, not a forecast of specific days, and a lean toward warmer weather does not rule out cold days.

Heating degree days, November to March, with the share of the 1991-2020 normal in brackets. Source: NOAA ACIS, totals calculated by us.

Policy context

Two state items are listed: a North Carolina law on the choice of energy service and a joint cold-weather planning process. Neither is described with a gas supply or capacity figure, so neither changes the outlook level. North Carolina Session Law 2023-58 provides that a city shall not adopt an ordinance that prohibits, or has the effect of prohibiting, the connection of an energy service based on the type or source of energy, or the sale or installation of certain appliances.⁵⁶ The General Assembly's bill history records that House Bill 130 became law without the Governor's signature on June 26, 2023.⁵⁷ Piedmont's testimony says the Commission's December 9, 2024 order approved a joint planning process among Piedmont and the two Duke Energy electric utilities for extreme cold weather events.⁵⁸ It also says the Public Staff's July 30, 2026 analysis found the reporting parties satisfactorily addressed all reporting requirements.²⁸ The orders themselves were not read.

What is the outlook for Charlotte-area gas capacity through 2029?

Discovery Energy rates the outlook for Charlotte-area natural gas capacity through 2029 as Elevated (confidence: Medium): by our calculation, Piedmont's margin over firm design day demand falls below the 5% thin-margin threshold in 2027-28.⁹ Piedmont itself projects a shortfall against its 5% reserve target from that winter.⁵ The record read shows no approved or scheduled fix, only an evaluation and a later target (see 'Are upgrades arriving in time?').⁷ Documented risk factors: concentration, because by our calculation Pine Needle LNG is 17% of Piedmont's 2026-27 firm design day demand.⁶ One factor is not enough to raise the level. Three developments would change the assessment: first, Piedmont's evaluation, due by the end of 2026, ending in an approved or scheduled project with a date and a budget, or the contracts it holds for short-term peaking services; second, the Commission's decision on the 5% reserve margin, or a revised Piedmont schedule in its next annual review showing a different margin; and third, a Charlotte-area or South Carolina county gas authority record, or a filing-confirmed large gas load, in the metro's counties. This rating rests on Piedmont's schedule for its whole Carolinas system, the closest figures available for the counties that hold 55% of the metro's population.²⁰ Enbridge Gas North Carolina's whole-system table (24% of the population) shows a thin or negative margin in every winter before Moriah and Southgate, consistent with the level.³⁸ No records were read for the South Carolina counties and municipal systems, so they are gaps in this assessment.

Outlook levels, from least to most concern: Stable, Watch, Elevated, High, Severe. Levels describe the public record of capacity and supply risk; confidence is reported separately. They are qualitative assessments, not forecasts of outages.

What's new (as of October 28, 2026)

On August 25, 2026 Transco filed with FERC a rate filing titled "DPEs--Piedmont (Hicks Cross and Charlotte)," to be effective October 1, 2026; the public notice gives only the title.⁷² In August 2026 Williams listed in a project fact sheet one 15,900-horsepower compressor unit to be installed at Transco's existing Compressor Station 150 in Iredell County, North Carolina, as part of its Southeast Supply Enhancement expansion.⁷³

What should Charlotte-area facilities check now?

• Tariffs and charges, through a utility audit. Confirm each account is on the right rate class and tariff, and that riders, demand charges and capacity-related charges are billed correctly. Over 70% of the clients Discovery Energy has audited were billed incorrectly. An audit verifies tariffs and charges and recovers overcharges before winter costs rise.
• Which utility and rate. Confirm whether each site is served by Piedmont, Enbridge Gas North Carolina, a municipal system or a South Carolina county gas authority, and which rate class it is on, because the filings read do not show which serves which community inside a county.
• Backup plans and fuel. Check that alternate-fuel and curtailment plans are current and feasible, and that fuel inventories and resupply arrangements are in place before December.
• Upcoming proceedings. Track Piedmont's end-of-2026 evaluation and its next annual review of gas costs before the Commission.

Frequently asked questions

Related case studies

Discovery Energy publishes gas capacity case studies for other metros, using the same method and outlook scale.

• Raleigh natural gas capacity case study (outlook: Elevated)
• Hampton Roads natural gas capacity case study (outlook: Elevated)
• Pennsylvania UGI Gas territory natural gas capacity case study (outlook: Elevated)
• Philadelphia area natural gas capacity case study (outlook: Elevated)
• Brooklyn, Queens, Staten Island and Long Island natural gas capacity case study (outlook: Elevated)

All gas capacity ratings by U.S. metro

Notes

1. Office of Management and Budget, OMB Bulletin No. 23-01, Revised Delineations of Metropolitan Statistical Areas, Micropolitan Statistical Areas, and Combined Statistical Areas, July 21, 2023. The counties are Anson, Cabarrus, Gaston, Iredell, Lincoln, Mecklenburg, Rowan and Union counties, North Carolina; and Chester, Lancaster and York counties, South Carolina.
2. North Carolina Utilities Commission, Natural Gas Service Areas in North Carolina (map, May 2025); county classes are read by eye from the map, and a county shown partly in one color is treated as unclear. Discovery Energy's EIA-176 crosswalk, which lists Piedmont for two counties and Enbridge Gas North Carolina for two counties of the Charlotte metro, was not relied on for assignment.
3. North Carolina Utilities Commission, Natural Gas Service Areas in North Carolina (map, May 2025); county classes are read by eye from the map, and a county shown partly in one color is treated as unclear. Discovery Energy's EIA-176 crosswalk, which lists Piedmont for two counties and Enbridge Gas North Carolina for two counties of the Charlotte metro, was not relied on for assignment. ↩
4. Piedmont Natural Gas Company, Inc., Direct Testimony and Exhibits of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, Exhibit JCP-4C, total firm design day demand and total capacity rows (PDF 41); margins are calculated. A utility filing for the whole Carolinas system. ↩
5. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 17; repeated in Patton rebuttal testimony (September 25, 2026), PDF 5. A utility statement. ↩
6. Piedmont Natural Gas Company, Inc., Direct Testimony and Exhibits of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, Exhibit JCP-4C, Pine Needle peaking capacity row and Total Firm Design Day Demand row (PDF 41); the 17% share is calculated. ↩
7. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 18. A utility statement. ↩
8. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 8. A utility filing. ↩
9. Piedmont Natural Gas Company, Inc., Direct Testimony and Exhibits of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, Exhibit JCP-4C, total firm design day demand and total capacity rows (PDF 41); margins are calculated. A utility filing for the whole Carolinas system. ↩
10. Piedmont Natural Gas Company, Inc., Direct Testimony and Exhibits of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, Exhibit JCP-4C (PDF 41): total firm design day demand, 5% reserve margin, total capacity and capacity-less-demand-plus-reserve rows; margins calculated from the printed rows. A utility filing for the whole Carolinas system. The formula is capacity minus firm design day demand, divided by firm design day demand; the margins are 2.07% in 2028-29 and 0.40% in 2029-30, with capacity constant at 1,631,675 dekatherms per day. ↩
11. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 17. A utility statement. ↩
12. Public Staff of the North Carolina Utilities Commission, Testimony of Neha R. Patel (corrected public version, September 23, 2026), NCUC Docket G-9, Sub 1082, PDF 6 and PDF 7. Staff analysis; not a Commission finding. ↩
13. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 18; the record read shows no contract for those services. ↩
14. Piedmont Natural Gas Company, Inc., Direct Testimony and Exhibits of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, Exhibit JCP-4C, Pine Needle peaking capacity row (PDF 41). A utility filing for the whole Carolinas system. ↩
15. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 18, on its release of East Tennessee Natural Gas capacity effective December 1, 2025. ↩
16. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 19, on Transco mainline constraints and firm deliverability of East Tennessee supply; the testimony names no gate station inside the Charlotte metro. ↩
17. Public Service Company of North Carolina, Inc., d/b/a Enbridge Gas North Carolina, Jackson Direct Exhibit 1 (June 1, 2026), NCUC Docket G-5, Sub 699, PDF 44, Reserve Margin row. A utility filing for its whole system. ↩
18. Public Service Company of North Carolina, Inc., d/b/a Enbridge Gas North Carolina, Jackson Direct Exhibit 1 (June 1, 2026), NCUC Docket G-5, Sub 699, PDF 44, footnote to the table. A utility filing for its whole system. ↩
19. Federal Energy Regulatory Commission, Order Amending Certificate, Mountain Valley Pipeline, LLC, Docket No. CP25-60-000 (issued December 18, 2025), PDF 1 and PDF 2. A Commission order. The testimony's mid-2028 target is the utility's; the order's own text on construction authorization (the order notes no request to begin construction had been submitted) and later FERC construction letters and court actions were not read, and news reports of them are leads only. ↩
20. Piedmont Natural Gas Company, Inc., Direct Testimony and Exhibits of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, Exhibits JCP-4A to JCP-4C (PDF 37 to 41), including Exhibit JCP-4C, Carolinas Design Day Demand and Supply Schedule for winter 2026-2027 (PDF 41). A utility filing; the schedule is for the whole Carolinas system (North Carolina and South Carolina). ↩
21. Public Service Company of North Carolina, Inc., d/b/a Enbridge Gas North Carolina, Direct Testimony of Rose M. Jackson and Jackson Direct Exhibit 1 (June 1, 2026), NCUC Docket G-5, Sub 699, PDF 44, design-day demand requirements and available assets table. A utility filing; the exhibit is for its whole system. ↩
22. North Carolina Utilities Commission, Natural Gas Service Areas in North Carolina (map, May 2025); county classes are read by eye from the map, and a county shown partly in one color is treated as unclear. Discovery Energy's EIA-176 crosswalk, which lists Piedmont for two counties and Enbridge Gas North Carolina for two counties of the Charlotte metro, was not relied on for assignment. ↩
23. North Carolina Utilities Commission, Natural Gas Service Areas in North Carolina (map, May 2025); county classes are read by eye from the map, and a county shown partly in one color is treated as unclear. Discovery Energy's EIA-176 crosswalk, which lists Piedmont for two counties and Enbridge Gas North Carolina for two counties of the Charlotte metro, was not relied on for assignment. ↩
24. North Carolina Utilities Commission, Natural Gas Service Areas in North Carolina (map, May 2025); county populations are the Census Bureau's Vintage 2025 county estimates; the metro delineation is OMB Bulletin No. 23-01 (July 21, 2023). ↩
25. Pine Needle: Piedmont Natural Gas Company, Inc., Exhibit JCP-4C, Pine Needle peaking capacity row (PDF 41), NCUC Docket G-9, Sub 1082. Moriah Energy Center: Public Service Company of North Carolina, Inc., d/b/a Enbridge Gas North Carolina, Direct Testimony of Rose M. Jackson (June 1, 2026), NCUC Docket G-5, Sub 699, PDF 40, which says the facility is under construction in Person County, North Carolina. ↩
26. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 9, on reliable service to North Carolina customers during the review period. ↩
27. Public Service Company of North Carolina, Inc., d/b/a Enbridge Gas North Carolina, Direct Testimony of Rose M. Jackson (June 1, 2026), NCUC Docket G-5, Sub 699, PDF 36, on the January 2026 winter storms. A utility filing. ↩
28. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 21, reporting the Public Staff's July 30, 2026 analysis of the May 2026 winter report in NCUC Docket M-100, Sub 217; the analysis itself was not read. ↩
29. Piedmont Natural Gas Company, Inc., Direct Testimony and Exhibits of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, Exhibit JCP-4C, Total Capacity row (PDF 41). A utility filing for the whole Carolinas system. ↩
30. Piedmont Natural Gas Company, Inc., Direct Testimony and Exhibits of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, Exhibit JCP-4C, Total Firm Design Day Demand row (PDF 41). A utility filing for the whole Carolinas system. ↩
31. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 12, on the 5% reserve margin, and Exhibit JCP-4C, reserve margin row (PDF 41). ↩
32. Piedmont Natural Gas Company, Inc., Direct Testimony and Exhibits of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, Exhibit JCP-4C, line below Total Capacity (PDF 41); the listed values equal total capacity less total firm sales demand including the 5% reserve. ↩
33. Public Staff of the North Carolina Utilities Commission, Testimony of Neha R. Patel (corrected public version, September 23, 2026), NCUC Docket G-9, Sub 1082, PDF 8. Staff analysis; not a Commission finding. ↩
34. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 10, on the 1-in-30-year design day condition for North Carolina East, North Carolina West and South Carolina. ↩
35. Piedmont Natural Gas Company, Inc., Rebuttal Testimony of Jeffrey Patton (September 25, 2026), NCUC Docket G-9, Sub 1082, PDF 5, on customer and load growth in North Carolina. ↩
36. Lines computed from the U.S. Energy Information Administration EIA-860M (September 2026, Planned sheet), by county. The sheet lists no planned natural gas-fired generator in North Carolina at all. ↩
37. Lines computed from the Federal Register search of Federal Energy Regulatory Commission notices since January 1, 2025, by county. ↩
38. Public Service Company of North Carolina, Inc., d/b/a Enbridge Gas North Carolina, Jackson Direct Exhibit 1 (June 1, 2026), NCUC Docket G-5, Sub 699, PDF 44, Surplus (Shortage) and Reserve Margin rows and table footnote. A utility filing for its whole system. ↩
39. Public Service Company of North Carolina, Inc., d/b/a Enbridge Gas North Carolina, Direct Testimony of Rose M. Jackson (June 1, 2026), NCUC Docket G-5, Sub 699, PDF 40 (Moriah Energy Center estimated in-service date) and PDF 38 (Southgate targeted completion). The mid-2028 target is the utility's. ↩
40. NOAA Climate Prediction Center, Prognostic Discussion for Long-Lead Seasonal Outlooks, issued October 15, 2026 (temperature outlook).
41. NOAA Climate Prediction Center, Prognostic Discussion for Long-Lead Seasonal Outlooks, issued October 15, 2026 (El Nino outlook).
42. U.S. Energy Information Administration, press release, October 6, 2026 (EIA expects a mixed picture for winter fuel costs this year).
43. U.S. Energy Information Administration, Short-Term Energy Outlook, October 2026 (natural gas storage).
44. U.S. Energy Information Administration, Short-Term Energy Outlook, October 2026; the claim register records the same export figures from EIA's October 2026 indicator table (EIA press release, October 6, 2026).
45. U.S. Energy Information Administration, Weekly Working Gas in Underground Storage, release of October 22, 2026 (East region, week ending October 16, 2026). ↩
46. U.S. Energy Information Administration, Natural Gas Citygate Price in North Carolina and in South Carolina, monthly tables (July 2026, the latest month saved); context only. ↩
47. U.S. Energy Information Administration, Henry Hub Natural Gas Spot Price, daily, release of October 21, 2026; context only.
48. Transcontinental Gas Pipe Line Company, LLC, Operational Flow Order Notices (Zone 5 imbalance orders), saved October 27, 2026: winter 2023-24, Notice 14034522 (October 30, 2023) through Notice 14419032 (March 26, 2024); winter 2024-25, Notice 15139001 (November 19, 2024) through Notice 15434250 (February 27, 2025), also Notice 14994057 (October 2, 2024); winter 2025-26, Notice 16336705 (December 11, 2025) through Notice 16661354 (March 16, 2026). Counts are Discovery Energy's own, built; a run is a continuous stretch of days under one or more orders. Imbalance orders are a different measure from critical days. ↩
49. Transcontinental Gas Pipe Line Company, LLC, Operational Flow Order Notices (Zone 5 imbalance orders), saved October 27, 2026: winter 2023-24, Notice 14034522 (October 30, 2023) through Notice 14419032 (March 26, 2024); winter 2024-25, Notice 15139001 (November 19, 2024) through Notice 15434250 (February 27, 2025), also Notice 14994057 (October 2, 2024); winter 2025-26, Notice 16336705 (December 11, 2025) through Notice 16661354 (March 16, 2026). Counts are Discovery Energy's own, built; a run is a continuous stretch of days under one or more orders. Imbalance orders are a different measure from critical days. ↩
50. Transcontinental Gas Pipe Line Company, LLC, Operational Flow Order Notices (Zone 5 imbalance orders), Notice 14034522 (October 30, 2023) through Notice 16661354 (March 16, 2026), saved October 27, 2026; the count is of imbalance operational flow orders, a different measure from critical days, and no critical-day count is available for this metro. ↩
51. Transcontinental Gas Pipe Line Company, LLC, location list accessed October 27, 2026: every North Carolina and South Carolina location on it is in Zone 5, with nine active locations in the metro's counties; applied to the metro by Discovery Energy. Counts of the Zone 5 Operational Flow Order Notices are in the earlier footnote (Notice 14034522, October 30, 2023, through Notice 16661354, March 16, 2026). ↩
52. Pipeline posting pages for Transco 1Line, Pine Needle LNG, Enbridge LINK and Mountain Valley Pipeline, saved October 27, 2026; none lists notices in its static page (JavaScript portals or no notice list). ↩
53. Transcontinental Gas Pipe Line Company, LLC, Operational Flow Order Notice 14034522 (October 30, 2023) through Notice 14419032 (March 26, 2024), Zone 5 imbalance orders; 12 separate runs over 119 days, Discovery Energy's own count. ↩
54. Transcontinental Gas Pipe Line Company, LLC, Operational Flow Order Notice 15139001 (November 19, 2024) through Notice 15434250 (February 27, 2025); also Notice 14994057 (October 2, 2024); Zone 5 imbalance orders; 6 separate runs over 85 days, Discovery Energy's own count. ↩
55. Transcontinental Gas Pipe Line Company, LLC, Operational Flow Order Notice 16336705 (December 11, 2025) through Notice 16661354 (March 16, 2026), Zone 5 imbalance orders; 5 separate runs over 19 days, Discovery Energy's own count. ↩
56. North Carolina General Assembly, Session Law 2023-58 (House Bill 130), Section 1(a), PDF 1, saved October 27, 2026. State law, context only. ↩
57. North Carolina General Assembly, Bill Lookup, 2023 House Bill 130 (history), saved October 27, 2026. State law, context only. ↩
58. Piedmont Natural Gas Company, Inc., Direct Testimony of Jeffrey Patton (August 3, 2026), NCUC Docket G-9, Sub 1082, PDF 19, describing the Commission's December 9, 2024 order in NCUC Docket M-100, Sub 217; stated through a utility filing, and the order itself was not read. ↩
59. Piedmont's rebuttal testimony and the Public Staff testimony are described in the Patton rebuttal and Patel footnotes above. Piedmont's Direct Testimony of Todd Breece, Pia K. Powers, Mandi King and its cover letter, and Public Staff testimony of Sonja R. Johnson, were saved and keyword-scanned and add no capacity figure. Registered as.
60. EIA-860M is a preliminary monthly inventory of utility-scale generators and does not list data centers or gas-fired units not yet reported to EIA; absence from it is not proof that none is planned. The Duke Energy Carolinas and Duke Energy Progress integrated resource plan and North Carolina Department of Environmental Quality air permit filings were not searched (no scriptable search found).
61. New-load search partly established: the EIA-860M sheet and the Federal Register FERC search were read; the PJM and Duke queues, state air permits, North Carolina Utilities Commission and economic development filings for data centers or large gas loads, and municipal records were not searched. News reports (not claimed) mention a Duke Energy gas-fired plant in Person County that Enbridge Gas North Carolina would serve through its Moriah project; Person County is outside both metros and no filing was read, so it is a lead, not a claim.
62. Not established, and left out of the page: who pays (cost allocation among customer classes); tariff interruption priorities and penalties for both utilities; delivery-point utilization from pipeline postings (next capture about March 2027); Moriah's budget and Commission approval (the Commission's September 22, 2026 order has none); the amount and winter of the capacity need the Commission found; contract end dates for either utility's firm capacity (none appear in the public testimony read); Piedmont's South Carolina operations and any county gas authority or municipal system record; and the design day calculations behind either utility's schedule.
63. County classes are read by eye from the Commission's "Natural Gas Service Areas in North Carolina" map (May 2025), whose legend names Piedmont Natural Gas Company, Inc., Enbridge Gas North Carolina, Frontier Natural Gas Company, LLC and Toccoa Natural Gas; they, and a county that the map shows partly in one color is treated as unclear. County populations are the Census Bureau's Vintage 2025 county estimates. Discovery Energy's EIA-176 crosswalk, which lists Piedmont for two counties and Enbridge Gas North Carolina for two counties of the Charlotte metro and no utility for the Raleigh metro, was not relied on for assignment.
64. Calculations from the exhibits' printed rows: margin = (assets - requirement) / requirement. For Enbridge Gas North Carolina's 2027-28 winter the printed surplus line is (20,166) while total assets less the design-day requirement is -21,166; the printed reserve margin of -2.27% matches the calculated value, so the surplus line is read as differing by 1,000 dekatherms per day. Piedmont's printed capacity-less-demand-plus-reserve line equals the calculated difference for every year.
65. Supply-event search not fully established: no federal or state event report or EIA weekly archive keyword search was read for Raleigh or Charlotte. Pipeline notice counts partly established: Transco's critical notices were counted (Zone 5 imbalance operational flow orders, described in the Transco Zone 5 note below), but the Pine Needle, Enbridge LINK and Mountain Valley pages saved October 27, 2026 list no notices in their static pages (JavaScript portals); Columbia Gas Transmission's host could not be reached. The Public Staff's July 30, 2026 analysis and the utilities' May 15, 2026 post-season report in Docket M-100, Sub 217 were not read (see the note above on the other Piedmont and Public Staff testimony).
66. Transco Zone 5 imbalance operational flow order counts are Discovery Energy's own, built from Transco critical notices saved on October 27, 2026 and applied to this metro through Transco's location list: every North Carolina and South Carolina location on it is in Zone 5, with nine active locations in the metro's counties. A run is a continuous stretch of days under one or more orders; an open-ended order is closed by the matching terminate notice or, if there is none, by the next order notice. Notices are paraphrased and not quoted. Other Transco notice types (delivery location reductions, force majeure, alerts) were not counted for this metro. The difference between winters partly reflects how Transco wrote its notices: long orders in 2023-24 and 2024-25 and many short orders in 2025-26.
67. Searches of October 28, 2026: EIA-860M September 2026 (eight North Carolina and three South Carolina metro counties); Federal Register FERC notices July 30 to October 28, 2026 for the county names and the pipelines serving the area; Duke Energy newsroom; Williams project page and fact sheet. Not reviewed: North Carolina Utilities Commission dockets (names AI crawlers), FERC eLibrary, Transco and East Tennessee postings, grid queues. ↩
68. U.S. Energy Information Administration, EIA-860M, September 2026 inventory, Planned sheet, filtered to North Carolina (40 rows, no natural gas unit); saved October 28, 2026. Government data; the October-labelled file was not available. ↩
69. Duke Energy, Duke Energy protects customers from data center costs (news release, October 7, 2026), NCUC (docket not stated in release), dated 2026-10-07, saved 2026-10-28; News release, first paragraph. The settlement parties include the North Carolina Public Staff, Amazon, Google, Meta, Microsoft and others. ↩
70. NOAA Regional Climate Centers, Applied Climate Information System (ACIS) StnData web service, monthly heating degree days (base 65F) and 1991-2020 normals, November to March of winters 2023-24 to 2025-26, retrieved October 26 to 28, 2026: CHARLOTTE DOUGLAS AIRPORT. Sums computed. Heating degree days are November to March, with the share of the 1991-2020 normal in brackets; totals are calculated by us. ↩
71. NOAA Climate Prediction Center, seasonal temperature outlook issued October 15, 2026, shapefiles lead1 (November to January) and lead2 (December to February) from ftp.cpc.ncep.noaa.gov/GIS/us_tempprcpfcst/seastemp_202610.zip, read at each metro's coordinates. The map gives the favored category and the lower edge of its probability band; NOAA's own explanation (Link) keeps near-normal at 33.3% and gives the opposite category the rest, so the above-normal figure is a floor and the below-normal figure a ceiling. For both periods the outlook gives the Charlotte area at least a 33% chance of above-normal temperatures (a slight lean), about 33% near-normal and no more than 34% below-normal. ↩
72. Federal Register / FERC, Combined Notice of Filings (FR Doc 2026-17727), published 2026-08-31, RP26-1093-000, dated 2026-08-31, saved 2026-10-28; Federal Register Vol. 91, No. 167 (Monday, August 31, 2026), page 55850. ↩
73. Williams Companies (Transco operator), Southeast Supply Enhancement fact sheet, August 2026 update, CP25-10-000 (per operator page), dated 2026-08, saved 2026-10-28; PDF page 2. ↩
74. A run is a continuous stretch of days under one or more Zone 5 imbalance orders. The table counts imbalance operational flow orders, not critical days. Counts are Discovery Energy's own, built from Transco notices saved October 27, 2026. ↩
75. News reports (not claimed) mention a Duke Energy gas-fired plant in Person County that Enbridge Gas North Carolina would serve through its Moriah project; Person County is outside both metros and no filing was read, so it is a lead, not a claim. Enbridge Gas North Carolina's Moriah Energy Center is under construction in Person County. ↩
76. National figures not tied to the Charlotte metro. NOAA's Climate Prediction Center said on October 15, 2026 that near-normal seasonal average temperatures are favored for much of the Southeast, and that the probability of at least a strong El Nino event continuing through January to March 2027 is 80%. EIA said on October 6, 2026 that it expects U.S. natural gas inventories to enter the winter 2% above the previous five-year average. EIA's October 2026 Short-Term Energy Outlook says prolonged cold could increase withdrawals beyond its forecast, and lists U.S. liquefied natural gas gross exports of 15, 18 and 19 billion cubic feet per day for 2025, 2026 and 2027. EIA's Henry Hub table lists 3.28 and 3.10 dollars per million Btu for the first days reported of the week of October 19, 2026. These are commodity and national figures, shown for reference only. Sources: notes 40 to 44 and 47. ↩

Market and weather sources

Public web sources saved and hashed on October 27, 2026. They are context, separate from the regulatory record cited in the Notes. The Climate Prediction Center issues its seasonal outlook once each month near mid-month; this section is refreshed on the publication date.

1. A1. U.S. Energy Information Administration, press release, "EIA expects a mixed picture for winter fuel costs this year," October 6, 2026. Link
2. A2. U.S. Energy Information Administration, Short-Term Energy Outlook, October 2026 (natural gas storage). Link
3. B1. NOAA Climate Prediction Center, Prognostic Discussion for Long-Lead Seasonal Outlooks, issued October 15, 2026. Link
4. C1. U.S. Energy Information Administration, Weekly Working Gas in Underground Storage, release of October 22, 2026. Link
5. C2. U.S. Energy Information Administration, Natural Gas Citygate Price in North Carolina, monthly. Link
6. C3. U.S. Energy Information Administration, Henry Hub Natural Gas Spot Price, daily, release of October 21, 2026. Link
7. C4. U.S. Energy Information Administration, Natural Gas Citygate Price in South Carolina, monthly. Link
8. D2. Transcontinental Gas Pipe Line Company, LLC, Operational Flow Order Notices (Zone 5 imbalance orders), notices posted October 2023 to March 2026, and Transco location list, accessed October 27, 2026. Link
9. D1. Pipeline posting pages (Transco 1Line, Pine Needle LNG, Enbridge LINK, Mountain Valley Pipeline), saved October 27, 2026; none lists notices in its static page. Link

Policy sources

Official sources saved and hashed on October 27, 2026. They are context, separate from the regulatory record cited in the Notes.

1. P1. North Carolina General Assembly, Session Law 2023-58 (House Bill 130), saved October 27, 2026. Link
2. P2. North Carolina General Assembly, Bill Lookup, 2023 House Bill 130, saved October 27, 2026. Link

Sources

1. North Carolina Utilities Commission, Docket G-5, Sub 699, Public Service Company of North Carolina, Inc., annual review of gas costs (2026). Link
2. North Carolina Utilities Commission, Docket G-9, Sub 1082, Piedmont Natural Gas Company, Inc., annual review of gas costs (2026). Link
3. Federal Energy Regulatory Commission, Docket CP25-60-000, Mountain Valley Pipeline, LLC, Order Amending Certificate, December 18, 2025. Link
4. North Carolina Utilities Commission, Natural Gas Service Areas in North Carolina (map, May 2025). Link
5. Office of Management and Budget, OMB Bulletin No. 23-01, Revised Delineations of Metropolitan Statistical Areas, Micropolitan Statistical Areas, and Combined Statistical Areas, July 21, 2023.

Sources: Discovery Energy compilation from public FERC-required pipeline operational notices, capacity reports, and Indexes of Customers postings as published by the interstate pipelines serving this metro, and from public gas-utility documents. Discovery Energy is not affiliated with, endorsed by, or sponsored by any pipeline, utility, or regulator named on this page. All trademarks and names remain the property of their respective owners. Counts, summaries, tables, and charts are original Discovery Energy compilations; readers should verify against the cited notices. Data current as of October 27, 2026. For information only and not a guarantee of future pipeline operations, capacity, or pricing.