By Rich Heidorn Jr.

FERC staff last week released a white paper identifying what it called “four guiding principles” that may help RTOs and other transmission planning entities analyze compliance with EPA’s Clean Power Plan.

Although the commission has no direct role in CPP compliance, it may be called on to evaluate the impacts of plant retirements and other responses on reliability.

Staff said modeling of the CPP should address: transparency and stakeholder engagement; study methodology and interactions between studies; study inputs, sensitivities and probabilistic analysis; and tools and techniques. The white paper borrows from a 2015 report by M.J. Bradley & Associates cited by EPA.

“Incorporating these guiding principles in the modeling of the CPP compliance plans is one way to promote a robust analysis of the reliability impacts of the CPP,” the commission said, adding that it may conduct additional technical conferences on the rule. (See MISO, SPP Stakeholders Developing Trading Plan to Comply with EPA Carbon Rule.)

“State-by-state variations in compliance approaches may add additional uncertainty and complexity, particularly for transmission planning entities that cover multiple states or states with multiple transmission planning entities,” FERC said. “Further, the use of inconsistent models, or inconsistent modeling inputs, may suggest reliability problems where none exist, or may mask problems that do exist. If models and modeling inputs are not transparent, it will be difficult for stakeholders, state commissions, planning authorities or the commission to identify, understand or address potential problems.”

FERC said the impacts of CPP compliance plans can be evaluated through a combination of studies, including resource adequacy, production cost, integrated gas-electric systems simulations and power flow and transient stability analyses.

“Incorporating the results of one study into a subsequent study can result in a more robust analysis,” the white paper says. “For example, the results of a resource adequacy analysis can be used to define the assumptions for the composition of the generation fleet used in a production cost or natural gas infrastructure study. This iterative process can lead to more robust results than using static assumptions.”

It also called for use of new tools to measure the impact of increased renewable and natural gas generation.