The Federal Energy Regulatory Commission Looks at EPA’s Proposed Carbon Rule During 2023 Reliability Technical Conference 

The Federal Energy Regulatory Commission (FERC) held its annual Reliability Technical Conference in early November 2023. The day-long meeting included a session on the “Reliability Implications of EPA’s Proposed Rule on Greenhouse Gas Standards and Guidelines for Fossil Fuel-Fired Power Plants,” and featured an Electric Industry Stakeholders panel and a Regional, State, and Local Regulatory Entities panel to examine the reliability impacts of the proposed Clean Power Plan 2.0.   

Here are a few highlights from the panel discussions:  

America’s Power President and CEO Michelle Bloodworth talked about what the Carbon Rule will mean for the U.S. coal fleet, pointing out that, according to EPA’s own predictions, the coal fleet would stand at 58 gigawatts in 2030, a reduction of 69% from current capacity:  

  • “In 2035, the coal fleet would virtually be eliminated. They are estimating only 12 gigawatts of coal would be left, which is a 94% reduction.” 

The Carbon Rule would not only undermine reliability by forcing the premature retirement of coal plants, but also eliminate essential reliability services such as those that were crucial during periods of extreme weather, like Winter Storms Uri and Elliott and other events: 

  • “The Carbon Rule would basically put the entire coal fleet… with many fuel-secure and other essential reliability attributes, at risk of prematurely retiring.” 

President Bloodworth also discussed EPA’s lack of proper analysis on resource adequacy. She said that EPA does not have the expertise of grid operators, FERC, and NERC. Also, the IPM model EPA uses projects resource adequacy into the future either by using existing resources or the construction of new ones that may never exist: 

Michael Bryson, Senior Vice President of Operations, PJM Interconnection, expressed reservations about the pace of retirements, stating that the RTO has been wrong on their estimates:   

  • “We released a paper back in February about retirements. And we made a number of assumptions about retirements and came to a number of 40,000 megawatts between now and 2030. We’ve already been wrong about that in a number of either faster retirements or retirements that we didn’t even see on the table… the balance between what’s retiring and what is being replaced is something that concerns me very much on the reliability perspective.” 

Anthony Campbell, President & CEO, East Kentucky Power Cooperative, characterized EPA’s proposal as unlawful and unworkable and called for the proposal to be withdrawn:   

  • “EPA’s proposal is not salvageable. The real question is whether reliability might be salvageable. First, even if we put aside the enormous cost involved, the proposed rule relies on CCS and clean hydrogen, neither of which are ready at levels and scales for a sound economy that requires certainty and not in all regions of the country. The infrastructure needed for both technologies is not now and will not be in place at the scale to meet EPA’s deadlines.” 

Julie Fedorchak, Commissioner, North Dakota Public Service Commission, spoke to America’s abundant, affordable, and reliable energy resources but questioned what the energy transition will cost: 

  • “When I read some of the EPA documents when they were releasing the rule, one thing really struck me – a quote that said the power sector has a broad set of tools to deploy clean, affordable energy, take advantage of ready to go advance pollution technology, create and retain good paying jobs, and reduce energy costs for families and businesses. Now you can debate many of the things in that quote, but to suggest that this rule or the energy transition as a whole is going to reduce energy costs for Americans? That’s just irresponsible.”