Abby L. Harvey
GHG Monitor
5/22/2015
The Federal Energy Regulatory Commission could assist with the application of a reliability safety valve and reliability monitoring as the Environmental Protection Agency implements proposed carbon emission standards for existing coal fired power plants, FERC commissioners said in a letter sent late last week to the EPA. Under the EPA’s proposed regulation, states would be required to develop action plans to meet federally set emissions reduction goals. The FERC commissioners’ letter draws on comments received during a series of four technical sessions held in the last several months. “EPA is committed to continuing the dialogue with FERC, as well as with DOE [Department of Energy], to safeguard public health and the environment and maintain a strong electric grid. Over the past 45 years, EPA has never issued a rule that has threatened the delivery of affordable and reliable electricity to American families and the Clean Power Plan will not change that,” EPA spokeswoman Liz Pruchia said in a statement.
Since the regulation was proposed in June 2014, those who oppose the rule have expressed concerns that the timeline of the rule and the potential loss of base-load coal generation could result in reliability issues. These issues could be addressed through the implementation of a reliability safety valve. The idea of such a mechanism has been brought up regularly throughout the rule making process, though what that safety valve might look like in the final rule remains to be seen.
Such a “valve” would be a process through which states could petition the EPA for a temporary waiver or adjustment to the emissions requirements or the timeline for compliance in order to preserve Bulk-Power System reliability. In such a process FERC could play a role in verifying these petitions, the letter suggests. “The Commission could review a petitioner’s claims that unforeseen or emergency system conditions will result in violation of a Commission-approved Reliability Standard or reserve margin deficiency, unless a compliance obligation is adjusted. In addition … we could identify issues, pursuant to our other areas of authority, such as requirements in a Commission-approved tariff. Similarly, the Commission could review the petitioner’s proposed mitigation as to whether it will resolve the Reliability Standard violation or reserve margin deficiency,” the commissioners wrote.
FERC Suggests It Could Review State Plans for Reliability Risks
The commissioners also suggested a system of reliability monitoring in which FERC would review state plans to identify any reliability risks. “Various panelists at our conferences advocated a process that takes place prior to, or in parallel with, EPA’s review of state plans to identify and potentially mitigate potential reliability concerns. Industry participants suggested that this oversight consists of Commission and/or North American Electric Reliability Corporation (NERC) review of all state plans to ensure that the combined effects of state plans do not negatively impact electric reliability,” the commissioners wrote. They went on to note that “if requested by EPA, the Commission could provide formal input on a particular plan or set of plans, subject to resource availability. In any event, the Commission’s role generally should focus on the regional aspects of Clean Power Plan compliance. Our staff is prepared to work with EPA staff to provide this Reliability Monitoring and Assistance.”
