Abby L. Harvey
GHG Monitor
2/13/2015
Risks to the reliability of the electric grid due to the Environmental Protection Agency’s proposed carbon emissions reductions standards for existing coal-fired power plants were exaggerated in a November report by the North American Electric Reliability Corporation (NERC), according to an analysis of the NERC study by The Brattle Group, commissioned by the Advanced Energy Economy Institute and released this week. The proposed regulation, dubbed the Clean Power Plan (CPP), requires states to develop action plans to meet EPA set emissions reduction goals. “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 Brattle analysis says.
The NERC report found that a more timely approach should be taken in implementing the proposed rule in order to address potentially significant false assumptions made by EPA in developing the rule concerning infrastructure, time constraints and reliability impacts. The proposed regulations consist of four “building blocks” which compose the best system of emissions reductions. These “building blocks” are efficiency improvements at the plants, switching to lower emitting energy sources, building additional zero emission generation and demand side energy efficiency. “NERC’s primary concerns are that in the relatively short run, high levels of coal (and oil) retirements, combined with lack of natural gas pipeline infrastructure, could make maintaining adequate reserve margins and achieving interim emissions rate targets incompatible. Over the long run, NERC is concerned that limits to achievable emissions reductions in Building Blocks [one, two and four] will require significantly higher reliance on [Variable Energy Resources] VERs, which, combined with potentially ongoing natural gas supply bottlenecks, could create reliability challenges related to VER integration.,” according to the Brattle Analysis.
The Brattle analysis finds that the rule has enough built in flexibility to address these concerns. “Our primary conclusion is that the CPP is unlikely to cause such foreseeable reliability concerns. We find that current actions by system operators to respond to the ongoing fundamental transformation of the U.S. power system, a quickly expanding mix of technology options and available/possible changes to operational procedures, market and regulatory rules likely provide enough flexibility to maintain reliability, at least in expectation,” the analysis says.
