By Suzanne Herel and Rich Heidorn Jr.
Like the ISO/RTO Council, PJM called for a reliability “safety valve” in the Environmental Protection Agency’s proposed Clean Power Plan to ensure that the final rule and state implementation plans include provisions for minimizing reliability impacts on the grid.
The idea is similar to a provision included in the agency’s mercury and air toxics standards (MATS). Such a safety valve might allow delaying a plant’s retirement until transmission upgrades can be completed.
PJM said its recommendations aim to ensure “overall reliability of the bulk power system” and promote regional coordination in grid operations while also respecting states’ rights to establish individual plans.
PJM also said EPA should:
- Change aspects of the proposed rule that discourage regional coordination on implementation;
- Include a measure to encourage coordination and consistency of compliance measurement and verification protocols;
- Propose an approach for flexibility in the determination of “at-risk” nuclear units in a state; and
- Clarify the term “under construction” in the EPA target-setting. PJM suggested that the term be tied to readily identified benchmarks.
The council also called on the EPA to expand its “glide path” flexibility proposal to allow for construction of gas pipelines and new electric system infrastructure.
PJM said the rule leaves little leeway for conditions arising during the 2020-2029 compliance period.
It suggested “case-by-case relief” in addressing a demonstrated reliability issue. That would allow a state or region to adopt a less strict averaging requirement if it met the 2030 compliance target and took affirmative steps to address the identified reliability issues.
PJM also proposed relief based on “triggering events” to allow for exceptions to meeting the state-specific average interim target.
In addition, it noted that the proposed rule does not define the term “backsliding.”
“Technically, retaining generators otherwise slated for retirement through ‘Reliability Must Run’ contracts, although limited and justified only for local reliability needs, could well be deemed ‘backsliding’ and thus in violation,” PJM said, noting that RTOs and federal and state regulators often are faced with making spot decisions on whether to allow a generator to run in this manner.