Tri-State Generation and Transmission Association told the Federal Energy Regulatory Commission in Feb. 24 comments that the U.S. Environmental Protection Agency’s Clean Power Plan, designed to reduce CO2 emissions from existing power plants by 30% by 2030, is unworkable in its current form.
Tri-State, which operates in the western U.S. and relies heavily on coal-fired power, was providing comments under a FERC review of the Clean Power Plan’s (CPP) grid impacts.
“The impacts from the CPP, if implemented as proposed, are staggering and will have a significant impact on the reliability and affordability of electricity for Tri-State and our Member Owners,” said the cooperative. “The time and investment needed to comply with the rule is vastly underestimated by the EPA and if not addressed will jeopardize the reliability of the power system and needlessly raise rates across the nation.”
Among other issues, Tri-State said it strongly believes the following must be addressed – at a minimum – in the final version of the plan to safeguard reliability and affordability:
- Revised Timing – Remove the interim 2020 goals and timeframe. There is a strong argument that the 2030 timeframe is also unrealistic.
- Regional Nature of the System – The rule does not adequately account for or address the regional nature of the Western Interconnection and utilities that serve multiple states.
- Lack of Flexibility – The plan does not provide the needed flexibility to address emergency and operational realities of the complex networks it will significantly impact.
It is critical that FERC engage with the EPA to address the significant flaws and erroneous assumptions as they pertain to reliability within the CPP, Tri-State said.
“The EPA proposal suggests the use of four building blocks to meet the reduction in carbon dioxide emissions required by the CPP,” Tri-State wrote. “It has become apparent from the comments and subsequent analysis that that while all of the building blocks have issues, Building Blocks 1 and 4 are seriously flawed, based on inaccurate assumptions and will do little to meet the EPA reduction goals. This will force states and utilities to rely solely on Building Blocks 2 and 3 to meet state goals, which will require increased use of existing gas fired generating units and non-carbon emitting generation to replace the reductions from other sources, respectively. Analysis has also determined that increasing the run time of the existing gas fired generation is not feasible in many cases, especially in light of the EPA’s proposed Ozone Rule.”
Tri-State noted that one issue is that grid changes to meet this plan will mean that time-consuming grid upgrades will need to be made. “Tri-State has experienced firsthand that the process to plan, route, permit, and obtain land rights for new transmission lines – as well as upgrades or rebuilding existing facilities – can take many years. In some cases, approvals can’t be secured despite years of effort and investment.”