NERC Releases Guidance for States on Clean Power Plan Reliability Concerns

The Clean Power Plan requires states to demonstrate that they considered electric reliability issues in developing their State Implementation Plans (SIP).  At the end of January 2016, the North American Electric Reliability Corporation (NERC) released an assessment of reliability trends, issues, and considerations states should account for when developing their CPP compliance plans.  The assessment is intended to assist states in developing compliance plans by providing a technical framework of the reliability challenges presented by the Clean Power Plan and today’s evolving bulk power system.

Recommendations include:

Cooperation – NERC’s assessment highlights coordination between states, system planning entities, and utilities as paramount to ensuring continued reliability of the bulk power system.

Essential Reliability Services – In order to maintain system reliability in the face of an evolving resource mix, NERC highlights the importance of ensuring generators can provide sufficient voltage control, frequency support, and ramping capability.

Timing of Infrastructure Development – Because new generation and transmission capacity to accommodate resource additions and retirements can require substantial planning and time, NERC encourages states to work with system planning entities and other stakeholders to fully explore reliability issues caused by uncertainty and long lead times.

Operations & Maintenance Implications for Generators – NERC recommends that states consider changes in generators’ maintenance requirements as a result of new cycling patterns as well as fuel supply issues and the risk of increased forced outages, particularly for coal-fired plants, that may result from changes to which resources run, when, and at what output level.

Reserve Margin Assessment – NERC highlights the need for comprehensive assessments of resource adequacy and reserve margin considerations created by the integration of more variable and energy-limited resources and the changing circumstances of conventional generation.

Energy Efficiency Modeling – Because of limited visibility into the true level of capacity energy efficiency may displace, NERC suggests states analyze energy efficiency’s potential impacts on the load forecast.

Emissions TradingNERC encourages states to work with utilities and neighboring states to assess the reliability concerns associated with mass-based or rate-based compliance and to ensure the most beneficial and efficient trading approaches are considered.

Understanding the Reliability Safety Valve – NERC urges states to fully educate themselves on the purpose and use of the Reliability Safety Valve, meant as a backstop, emergency measure for unexpected delays or to address impacts from catastrophic events.

Previous Experience – NERC suggests states look to the Northeast’s Regional Greenhouse Gas Initiative and Canadian and European experience in transitioning toward renewable and distributed resources as case studies for potential compliance strategies.

NERC plans to release a detailed reliability assessment of the Clean Power Plan in March 2016.

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