On September 20, 2011, the Southwest Power Pool, Inc. (“SPP”), wrote to Administrator Lisa Jackson at the Environmental Protection Agency (“EPA”) in its capacity as a FERC approved Regional Transmission Organization (“RTO”) and Regional Entity, requesting a delay of the Cross-State Air Pollution Rule (“CSAPR”).  SPP expressed concerns that the CSPAR would force the RTO to “choose between” compliance with the reliability standards set forth by FERC and North American Electric Reliability Coordinator (“NERC”) or EPA’s CSAPR.

SPP ran a reliability model based upon the CSAPR Integrated Planning Model (“IPM”) provided by the EPA.  Through this exercise, SPP discovered that based upon the IPM, SPP will likely be out of compliance with NERC reliability standards in 2012.  This is due in large part to 5.4 gigawatts (“GW”) from 48 generation units identified by EPA with a zero fuel burn in 2012 that would have dispatched in 2012.  SPP further discovered that there were 1047 circumstances in different locations on its transmission system where voltage was below the lower limit of 90% of the nominal rating.  Further, SPP noted that 30 “contingency scenarios” did not solve, indicating that the system faced “extreme constraints” which could lead to localized rolling black-outs to avoid uncontrolled and more widespread blackouts.

In its letter to Administrator Jackson, SPP’s main concern is that the time period between finalizing the CSAPR and the effective date of the rule is too short and does not allow SPP and its members or registered entities to “appreciate the effects of the rule” and to take actions that will ensure reliability.  Failure to comply with reliability standards will subject SPP to financial penalties, and affect the reliability of the power grid.  SPP supports a flexible approach to meeting emissions requirements under CSAPR, and implored Administrator Jackson not to force SPP to choose between compliance with the EPA’s rules and compliance with FERC’s rules.

A copy of SPP’s letter is available here.