Chapter 8

John Moore
Clean Power
Published in
6 min readJul 15, 2015

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The Grid Will Remain Strong

The Clean Power Plan doesn’t threaten the reliability of our electric system. It enhances it.

“Over the U.S. Environmental Protection Agency’s long history of developing Clean Air Act pollution standards for the electric-power sector, including the proposed Clean Power Plan, the agency has consistently treated electric-system reliability as absolutely critical…at no time in the more than 40 years that the EPA has been implementing the Clean Air Act has compliance with air-pollution standards resulted in reliability problems.”

— EPA acting assistant administrator for air Janet McCabe, February 19, 2015

We can continue to reduce climate-altering carbon pollution from our power supply while protecting the grid reliability. The U.S. Environmental Protection Agency’s Clean Power Plan, in fact, is likely to make the grid stronger.

Studies support it.

The Brattle Group, a consulting firm specializing in energy, concluded that the plan is “unlikely to materially affect reliability.” The Analysis Group, another respected energy consulting firm, said there are “many reasons why carbon pollution at existing power plants can be controlled without adversely affecting electric-system reliability.”

Additionally, three experts with more than 100 years of combined experience in the power sector — Susan Tierney, Eric Svenson, and Brian Parsons — said in an April 2015 report that they “are confident that we can achieve a lower-emissions electricity grid while maintaining reliability.”

The real potential threat to reliability is climate change and the “more frequent and intense heat waves, higher sea levels, and more intense storms that will strain our electricity infrastructure,” according to the Center for Climate and Energy Solutions. Severe weather is the leading cause of U.S. power outages, a 2013 White House report notes.

Dark Manhattan after Superstorm Sandy (Photo: Alec Perkins/Flickr)

The Clean Power Plan gives states and utilities plenty of time and flexibility to devise and implement their own carbon-reduction plans to meet relatively modest targets while maintaining reliability.

“There is absolutely no scenario, no standard, no compliance strategy that I will accept where reliability comes into question. Period. End of statement,” EPA administrator Gina McCarthy recently assured energy executives.

A number of utilities and state regulators — whose job it is to keep the lights on — have studied the plan and concluded that its flexibility provides the tools to make the transition to a cleaner and reliable electric system.

A recent survey found that more than 60 percent of utility executives said the EPA should stick to the implementation timetable or make it more aggressive.

We are confident that we can achieve a lower-emissions electricity grid while maintaining reliability.

“….Doomsday predictions are simply not correct,’’ said Kathleen Barrón, senior vice president of federal regulatory affairs and wholesale market policy for Exelon, one of the nation’s largest power generators. She expressed confidence that the industry can “immediately begin to control carbon pollution while maintaining electric reliability.”

Some states are already cutting carbon pollution without any impact on reliability. Nine Northeast and Mid-Atlantic states that make up the Regional Greenhouse Gas Initiative have demonstrated that states “can achieve greater emission reductions at a lower cost, all while creating jobs, maintaining grid reliability, and improving the regional economy,” the states wrote in a letter to the EPA in support of the Clean Power Plan.

In California, which has moved aggressively to cut carbon pollution, Michael Gibbs, assistant executive officer of the state Air Resources Board, reported that it “has not experienced any significant reliability challenges or market disruptions associated with our carbon programs and pricing efforts.” With California on schedule to reduce greenhouse gas emissions to 1990 levels by 2020, Governor Jerry Brown moved to step up efforts in April 2015, setting a goal of reducing carbon pollution to 40 percent below 1990 levels by the year 2030.

Frank P. Prager, Xcel Energy’s vice president of policy strategy, said his Minneapolis-based company, which operates in eight Midwestern and Western states, has reduced carbon emissions by 20 percent since 2005 and is on track to reach 31 percent below 2005 levels by 2020 “while ensuring a safe and reliable electric system and maintaining electricity rates in all our operating regions below the national average.”

Renewable energy and energy efficiency already are changing the face of the grid while maintaining reliability.

Horse Hollow Wind Energy Center in Texas. (Photo: The Danish Wind Industry Association/Flickr)

“As wind energy has grown to provide a larger share of our electricity mix, wind-turbine technology has matured so that modern wind plants are able to provide the same grid reliability services as conventional generators,” said the American Wind Energy Association. ”At times, wind has supplied more than 60 percent of the electricity on the main utility system in Colorado, nearly 40 percent of the main Texas power system, and 33 percent in the Southwest Power Pool, all without any reliability problems.”

“We’re already seeing higher levels of renewable generation than the Clean Power Plan anticipates — with no negative impacts on reliability,” reported the Center for Climate and Energy Solutions.

Critics of the Clean Power Plan have exaggerated its threat to reliability. In fact, the grid can handle much higher levels of zero-carbon wind and solar power, far more than what’s necessary to achieve the relatively modest carbon emission reductions in the EPA’s plan to limit pollution from existing plants, according to an NRDC analysis.

“There is absolutely no scenario, no standard, no compliance strategy that I will accept where reliability comes into question. Period. End of statement.”

The electric grid is a dynamic and continually evolving system that can handle the incremental changes required over time to reflect new energy resources and economic conditions. When systems have encountered reliability problems, it generally has been the result of extreme weather events, human error, and accidents.

“The polluters’ pollsters tell them that what will grab the public’s attention is the threat that the lights will go out,” said Mary Nichols, chairman of the California Air Resources Board. “But time and again, this threat has proven to be overblown. In fact, state air regulators can be expected to design their compliance plans in coordination with their energy-agency partners and have more than a decade to fine-tune plan implementation.”

As I told a House Energy and Commerce subcommittee, “We have a 40-plus-year track record showing that environmental progress and electric reliability are compatible. States have kept the lights on through every pollution-cutting program.’’

Opponents’ arguments “presume inflexible implementation, are based on worst-case scenarios, and assume that policy makers, regulators, and market participants will stand on the sidelines until it is too late to act,” according to the Analysis Group. “There is no historical basis for these assumptions.”

Photo: Jack Haskell/Flickr

The Clean Power Plan is likely to make the grid more reliable by increasing the use of wind and solar power as well as energy efficiency, and modernizing our power-delivery system, NRDC found.

The nation’s aging electricity system has become increasingly vulnerable to extreme weather events, according to a study by the Union of Concerned Scientists, which said greater energy efficiency and use of renewable energy would make the system more resilient and reliable.

The Clean Power Plan does not require a choice between fighting climate change and keeping the lights on, I told a Federal Energy Regulatory Commission conference in February 2015. “Building on the momentum of proven, reliable, and affordable energy such as wind, solar, and energy efficiency, and giving the states many compliance options, the plan will preserve and even strengthen reliability while cutting carbon pollution.”

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John Moore
Clean Power

Senior Attorney for @NRDC’s Sustainable FERC Project