In the final Clean Power Plan, EPA was critical of North American Electric Reliability Corporation (NERC) analyses of its proposed rule, stating that NERC “assumes considerably less flexibility than actually is provided to states and EGUs” in the final rule and that there are “real world solutions to NERC’s concerns.” It will be interesting to see NERC’s analysis of the final rule, which is expected by the second quarter of 2016.
In NERC’s initial review of the proposal in November 2014, it looked at the four assumptions in EPA’s proposed building blocks and identified a list of items requiring additional reliability consideration. NERC’s broad recommendations were that it should continue its assessment of potential reliability impacts, coordinated planning and analysis should immediately begin evaluations, and EPA should consider timing issues that address reliability concerns and infrastructure deployments.
In its April 2015 Phase I review, NERC’s key findings included that the Clean Power Plan is expected to fundamentally change electricity generation mix in the U.S., industry needs more time to address shifts in generation and accompanying transmission issues, coal use may change from baseload to seasonal peaking, and the shift of energy and capacity to gas-fired generation will require additional infrastructure.
