AEE: NERC Clean Power Plan report flawed and outdated
April 22, 2015 | By
Barbara Vergetis Lundin
The North American Electric Reliability Corp. (NERC) has issued a follow-up report to its Initial Reliability Review (IRR), released last November, in which NERC raised a variety of concerns about the impact of U.S. Environmental Protection Agency's (EPA) Clean Power Plan -- which is intended to reduce the U.S. electric system's CO2 emissions by 30 percent from 2005 levels by 2030 -- on reliability. NERC's most recent assessment modeled scenarios focused on evaluating generation and transmission adequacy and potential reliability impacts.
The generation mix in the United States is going through a fundamental change. Policy considerations, such as the proposed CPP, impact and accelerate the transition through which the U.S. generation mix is going. According to NERC, the goal of its assessment, "Potential Reliability Impacts of EPA's Proposed Clean Power Plan: Phase I," is to call attention to potential areas of concern for reliability and identify challenges that, if addressed, could ease the transition and allow for both environmental and reliability goals to be achieved. NERC's assessment consisted of a three-part scenario analysis focused on resource and transmission adequacy and a review of existing studies by key reliability authorities. These key scenarios were designed to provide benchmarks and guidance during implementation of the proposed CPP rule and serve as a snapshot-in-time. Many, however, are disappointed in the results. "Much like its initial assessment, NERC's new assessment overstates the reliability issues associated with EPA's Clean Power Plan -- issues that can be managed by changes already under way," said Malcolm Woolf, senior vice president for policy and government affairs for Advanced Energy Economy (AEE). "The NERC assessment tells us very little about how to move forward other than to slow down." This most recent assessment of the CPP, AEE contends, makes some of the same mistakes it did in its initial reliability review. NERC's modeling suffers from four flaws, according to Woolf.
"As a result, NERC's analysis is not only flawed but already outdated," Woolf said. Despite all this, AEE says it is "confident that, with all the options available to them for compliance with EPA's final rule, states, working with their utilities, will be able to modernize their electric power systems and provide secure, clean, and affordable energy for the 21st century." A report by The Brattle Group providing a detailed analysis of NERC's initial reliability report ultimately concluded that "compliance with the CPP is unlikely to materially affect reliability." Commissioned by AEE, the report was designed as feedback for NERC on its IRR. "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," states The Brattle Group report. "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." A separate assessment of the Clean Power Plan, conducted by Analysis Group, reached a similar conclusion. "[A] recent survey of more than 400 utility executives nationwide found that more than 60 percent felt optimistic about the Clean Power Plan and felt that EPA should either hold to its current emissions reduction targets or make them more aggressive," the Analysis Group noted. Others in the industry agree. Cheryl Roberto, associate vice president of clean energy for the Environmental Defense Fund and former commission of the Public Utilities Commission of Ohio, said, "NERC fails to capture the great innovation happening now -- with major investments in renewables, efficiency, natural gas and transmission infrastructure. NERC's report also assumes flat-footed regulators, when the truth is regional and state-level regulators have repeatedly demonstrated they are up to the task of planning for future power needs." In short, she said that "NERC's assessment does not take into account the transformation unmistakably underway in our electric system." "Americans are innovators. We have already shown that we can reduce harmful carbon pollution while keeping our power system strong," Roberto said. "And history has demonstrated that clean air protections have never caused reliability problems." For more: - download the Brattle Group report
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