Clean Power Plan is a Manageable Challenge

Much has been made of the recent North American Electricity Reliability Council (NERC) catalog of challenges states face in complying with the EPA's Clean Power Plan emission reduction requirements. Over the last month, the Federal Energy Regulatory Commission (FERC) has held a series of workshops to explore the matter further.

To listen to many critics, meaningfully reducing CO2 emissions from the electricity sector is a nearly impossible task and an untenable reliability risk. But is it really? Haven't we learned anything from integrating large amounts of renewable power into the nation's grid? Is compliance so terribly hard?

Well, no, it isn't, according to a number of recent (and not so recent) studies that have shown that transforming the electricity system form dirty fossil generation to zero-pollution renewables not only can be done reliably, it is already being done in many parts of the country. The managers of some of the largest parts of the U.S. grid believe it is manageable, and though they may advocate tinkering with the timelines a bit, believe that the task is not all that formidable. Other analyses maintain that delays are not even needed.

At the recent National Association of Regulatory Utility Commissioners (NARUC) meeting in Washington DC, Michael Kormos, executive vice president of the PJM Interconnection, operating the high-voltage grid between New Jersey and Illinois, the nation's largest electricity market, said. "Given enough time ... we don't necessarily foresee a reliability problem."

A recent report by the highly respected Analysis Group that said that PJM, the largest competitive wholesale electricity market region in the U.S., touching 13 states and the District of Columbia, should not be overly challenged in complying with the Clean Power Plan.

"PJM is well positioned to lower carbon pollution from existing power plants while relying on the reliability tools and operating procedures it uses with great success. "

In other words, PJM is already doing it.

In a February report on reliability and the Clean Power Plan, the Brattle Group agreed, concluding:

"Following a review of the reliability concerns raised and the options for mitigating them, we find that compliance with the CPP is unlikely to materially affect reliability. The combination of the ongoing transformation of the power sector, the steps already taken by system operators, the large and expanding set of technological and operational tools available and the flexibility under the CPP are likely sufficient to ensure that compliance will not come at the cost of reliability."

The American Wind Energy Association and the Solar Energy Industry Association have jointly released a handbook for states to consider when crafting compliance plans that highlighted the strategies already known and available that allow for compliance with the Clean Power Plan.

Some, like the WIRES organization and Americans for a Clean Energy Grid (ACEG), are advocating that transmission be emphasized as a compliance strategy as either part of EPA's third "building block (ACEG)" or as a separate fourth building block (WIRES). No matter how you slice it, the right transmission can cost-effectively unlock access to low-cost renewables, greatly aiding multi-state compliance strategies. It takes time to build transmission though, so planning for it is essential. WIRES, NRDC, ACEG and many others are advocating that FERC ensure that transmission for Clean Power Plan compliance be prioritized as "needed" to meet public policy goals in the agency's "Order 1000" regional planning process.

Despite the rhetoric that the Clean Power Plan presents some sort of unprecedentedly complex morass of red tape, my former colleague David Weiskopf has insightfully blogged that the Clean Power Plan presents regulators with a fairly simple and familiar set of tools with which to attack the carbon pollution problem. Tools they already know and use, and which make the grid more, not less reliable.

Here are some reasons the Clean Power Plan is a manifestly manageable challenge:

Flexibility ensures reliability. Because of its flexible design, the Clean Power Plan ensures electric grid reliability.

  • The Clean Power Plan is more flexible than any prior clean air rules, providing many compliance options to maintain reliability.
  • States have the tools to keep "reliability must-run" plants running.
    • The Clean Power Plan encourages states to use either rate-based or mass-based approaches, under which averaging and trading of credits or allowances allows flexibility for plants to run if needed to address a local reliability concern (such as a new plant construction delay), while maintaining the overall emission reductions of the program.
  • FERC's role in ensuring reliability. FERC can play an extremely valuable role in helping power sector stakeholders understand the interplay between the Clean Power Plan's flexible design and grid planning and operational procedures to assure reliability.
  • FERC and EPA responsibilities. Throughout the Plan's implementation process, FERC and EPA should follow their well-established, complementary roles: FERC (and the grid planners it regulates) reviews the reliability aspects of the Plan, while EPA, with input from FERC, approves or adjusts state plans on reliability or other grounds.