Advanced Energy Perspectives

The EPA’s proposed Clean Power Plan (CPP), which will set limits on carbon emissions from existing power plants, is set to be finalized this summer. The North American Electric Reliability Corp. (NERC) has released two assessments so far, each of them raising concerns about the potential impact of the CPP on reliability. One of the challenges to reliability identified by NERC has to do with the increased deployment of variable renewable energy - namely wind and solar - in the power system. However, many states are already seeing unprecedented levels of variable renewable generation and successfully integrating them into the power system without impeding reliability. As renewable energy production across the country continues to increase due to the rapidly declining cost of these resources and state policies requiring utilities to use more renewables, integration is likely to be even easier when the CPP takes effect in 2020.

All links to bills lead to AEE’s PowerSuite. Click to sign up for a free 14-day trial. This blog post is excerpted from a newsletter that went out to members in late May. For the most up-to-date information on what's passing through legislatures, check them out in PowerSuite!

As legislative sessions start to wrap up in some states, AEE continues to track legislation that may impact compliance strategies. ALEC bills — legislation that requires approval of state implementation plans by the legislature — were introduced in 27 states so far. Ten bills were passed, but most of them with  language weaker than when they were initially introduced. Even in states hostile to the Clean Power Plan, stakeholders and regulators are quietly exploring compliance options. And some states are making moves toward greater use of advanced energy, which would make CPP compliance easy.

This photo of the Hoover Dam intake towers was taken by Raquel Baranow in 2014. Water elevation on that day at noon: 1086.39 ft.

As the saying goes, in the West, the whiskey’s for drinking and the water’s for fighting. While much of the attention related to EPA’s Clean Power Plan is focused, appropriately, on the emissions and economic benefits of the new standards, a report just released by the CNA Corporation identified another benefit that may end up being worth more than all the other impacts combined: water.

While policy wonks wait with bated breath for release of EPA’s final Clean Power Plan, some of us in the advanced energy industry are just as eagerly awaiting EPA’s draft Federal Plan for compliance, which will be revealed at the same time. Why the excitement about a Federal Plan? Because the stakes are high: Not only will the Federal Plan serve as a model for states as they begin to consider compliance options for the final CPP, it will apply to any state that does not submit a plan that passes muster with EPA. Questions have been raised about whether EPA can incorporate advanced energy options like energy efficiency and demand response, renewable energy, and advanced grid technologies into a Federal Plan for compliance. Our answer: Yes, it can.

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.