On April 21, the North American Electric Reliability Corp. (NERC) released its “Phase I” assessment of the reliability impacts of EPA’s Clean Power Plan. The Phase I report is a follow-up to NERC’s Initial Reliability Review, and NERC indicates there will be more to come. This is in keeping with NERC’s vital role in informing policymakers and grid operators about issues in maintaining reliable electric service across the country. Precisely because of NERC’s role as guardian of electric reliability, it’s important to point out where analyses commissioned by NERC fall short.
The Phase I modeling of the Clean Power Plan (CPP) as proposed – which is now under revision at EPA, in preparation for the final rule due this summer – projects an electric power system of the future that is inconsistent with the technology and market trends of today, let alone tomorrow. Taking into account the more likely result of ongoing developments in the electric power sector, especially those that will be accelerated by the CPP, the reliability concerns raised in the Phase I report largely disappear.