But Will the Lights Go Out in Georgia?

The EPA’s Clean Power Plan is feeling a bit of early summer heat. The Federal Energy Regulatory Commission (FERC) and the Energy Information Administration (EIA), neither one a lightweight, have recently questioned whether or not the rule adequately protects grid reliability.

FERC held a series of regional workshops on the Clean Power Plan this spring. Many participating stakeholders raised grid reliability as a concern, and EPA’s Janet McCabe told the commission that grid reliability is a priority for her agency. As a result, FERC commissioners recently sent the EPA a joint letter asking that the final rule include a reliability safety valve, which FERC defines as, “A process through which effected entities  can petition the EPA for temporary waiver or adjustments to the emissions requirements or compliance timelines in an approved state plan to preserve Bulk-Power System reliability.” This process would be administered by the FERC. There is precedent for such a Reliability Safety Valve under the Clean Air Mercury Rule (CAMR), which has led to utilities closing a number of antiquated, “big and dirty” coal fired plants and a reduction in coal-fired power generation. FERC and EPA coordinated carefully to develop the CAMR safety valve. FERC, in its letter,  once again offered its resources to EPA to help protect grid reliability in the context of the Clean Power Plan. FERC also offered to assist EPA with ongoing grid reliability monitoring.

EIA issued a report on the Clean Power Plan that, like FERC, raises reliability questions. EIA’s analysts found that the rule, as proposed, will double the number of coal plant shutterings by 2020 than otherwise expected: 90 gigawatts according to EIA, versus EPA’s 40 gigawatt estimate. The loss of this much power generation capacity no small matter for reliability when coal accounts for 329.8 gigawatts of power generation at this time, also per the EIA report. EPA spokesperson Liz Purchia says the agency will take the EIA research into consideration as it prepares to promulgate the final Clean Power Plan rules later this summer.

FERC and EIA are simply the most recent parties to note the potential grid reliability impacts of the Clean Power Plan. Many of the millions of comments received by EPA during the rule making raise reliability concerns. Earlier studies from Nera Economic Consulting and the North American Electric Reliability Corporation also found that the Clean Power Plan, as proposed, will pose a challenge to grid reliability.