On January 19, 2016, FERC staff issued a white paper entitled “Guidance Principles for Clean Power Plan Modeling,” in Docket No. AD16-14-000. In the white paper, FERC staff recognizes that the “CPP assigns no direct role to the Commission,” but that the Commission “may be called upon” to address CPP-implementation related reliability concerns. Accordingly, it provides four “guiding principles” to assist transmission planning entities (including RTOs/ISOs, utilities, and other stakeholders) and NERC and its regional reliability entities with performing robust analyses of the reliability impacts of the CPP. A brief summary of each guiding principle is provided below:
Guiding Principle 1: Transparency and Stakeholder Engagement.
Entities conducting CPP modeling studies should be transparent about and incorporate early stakeholder engagement into the development of the models, model inputs, and study designs to help ensure that the studies are vigorous, and that assumptions used in the models are reasonable. Entities are also encouraged to “provide sufficient access to information” so that stakeholders and other third parties may easily replicate the results.
Guiding Principle 2: Study Methodology and Interactions Between Studies.
To better understand the various impacts the CPP may have on the electric grid, studies should use multiple modeling tools, the results from one study should be incorporated into subsequent studies, and study methodologies should be continued to be refined.
Guiding Principle 3: Study Inputs, Sensitivities, and Probabilistic Analysis.
Studies should include a base case that “accurately reflect[s] the current and future state of the electric grid under business as usual conditions.” Studies should also quantify the impact of uncertainties, and be based on inputs that account for a full range of probable outcomes.
Guiding Principle 4: Tools and Techniques.
Entities are encouraged to assess their current modeling capabilities, and, as necessary, develop new modeling tools to better analyze the “complex interactions between various decisions.”
The white paper appendix provides a description of various types of studies that may assist with CPP planning and implementation, including resource adequacy planning studies, production cost studies, integrated gas-electric systems simulations, powerflow and transient stability analyses, and frequency response studies.
The white paper is just the tip of the iceberg. FERC staff and/or the Commission may be contemplating further pronouncements on or involvement in CPP implementation.
