On January 19, 2016, FERC Staff issued a white paper entitled, “Guidance Principles for Clean Power Plan Modeling.” Additionally, on January 27, 2016, NERC issued a special reliability assessment entitled, “Reliability Considerations for Clean Power Plan Development.” Each document is aimed at assisting various industry stakeholders with the implementation of EPA’s Clean Power Plan while maintaining grid reliability.
The FERC Staff white paper identifies four guiding principles that may assist transmission planning entities in conducting an effective analysis of the Clean Power Plan and associated state, federal, or multi-state compliance plans. The four guiding principles focus on: (1) transparency and stakeholder engagement; (2) study methodology and interactions between studies; (3) study inputs, sensitivities, and probabilistic analysis; and (4) tools and techniques. FERC Staff explains that focusing on these guiding principles may assist transmission planning entities by: helping identify policy alternatives and effectively evaluating assumptions, while also improving coordination across regions; providing more effective assessments of the impacts of the Clean Power Plan and associated compliance plans; and using appropriate study inputs, methodologies, tools, and techniques that may help entities better assess the overall impact of the Clean Power Plan and associated compliance plans.
The NERC special reliability assessment focuses on identifying aspects of compliance plan design that should be considered to reliably accommodate the transition to implementing the Clean Power Plan. As states seeks to develop their compliance plan, NERC’s assessment emphasizes that they should consider: (1) how to coordinate with system planning entities such as utilities, ISO/RTOs, and regional planning entities; (2) the need for generation to provide certain essential reliability services like voltage control, frequency support, and ramping capability; (3) timing considerations for energy infrastructure development; (4) how to coordinate the impacts associated with electricity imports and exports; (5) changes in maintenance requirements due to changes in generator cycling and operations; (6) how to assess reserve margins and resource adequacy obligations; (7) how to evaluate different ways to take advantage of energy efficiency measures; (8) how to coordinate the consideration of emissions trading programs; (9) how the reliability safety valve works and its limits; and (10) other North American and European precedents for potential lessons learned and implementation strategies. NERC’s assessment also indicates that NERC is preparing a report that will evaluate various scenarios showing potential effects related to the Clean Power Plan. NERC indicates that it expects to release this report near the end of the first quarter of 2016.