FERC will host a discussion Thursday on the potential impacts of EPA’s proposed rule for power plant emissions as part of its annual technical conference on grid reliability, and parties have laid out the arguments they want addressed at the forum. (See EPA Power Plant Proposal Gets Mixed Reception in Comments.) 

The think tank Energy Innovation Policy & Technology released a report and hosted a webinar arguing that EPA’s proposal can be met while maintaining reliability. 

The rule would require fossil fuel-fired power plants to install emissions-mitigation technologies depending on when they plan to retire and how often they run. Coal plants that want to keep operating beyond 2040 need to install carbon capture and storage (CCS) technology that eliminates 90% of their emissions, Harvard University Environmental & Energy Law Program Executive Director Carrie Jenks said on the webinar. 

Baseload natural gas plants would either need CCS or blended hydrogen, though the rule would require less investment for plants that run on an intermediate basis or as peakers, Jenks said. 

The rule would effectively retire uncontrolled coal plants and largely leave a system with natural gas and storage balancing higher levels of renewables, which is already largely the case in California, New England and the U.K., said GridLab Executive Director Ric O’Connell. 

“Adding clean resources and using the gas fleet as a balancing resource is a pretty well-known playbook,” O’Connell said. 

Sens. John Barrasso (R-Wyo.) and Shelley Moore Capito (R-W.Va.) — the ranking members of the Energy & Natural Resources and Environment & Public Works committees, respectively — wrote FERC a letter urging it do more than the tech conference. The senators, whose committees oversee FERC and EPA, had urged the commission to hold the tech conference this summer. (See GOP Senators Call for FERC Conferences on EPA Power Plant Rule.) 

“Unless the EPA withdraws or significantly revises its proposed Clean Power Plan 2.0, the EPA will unnecessarily and significantly increase risks to electric reliability,” the senators said. “It will also increase dramatically the costs of generating electric power and make electricity less affordable for American families.” 

If FERC does not bring to bear its expertise and fact-based analysis “to dissuade the EPA” from continuing with the rule, it would be partially responsible for the resulting blackouts, they added. The senators urged FERC to gather comments and submit that record to EPA before the rule is finalized. 

While the rule does have requirements on how long uncontrolled natural gas plants can run if they operate more than 50% of the time, as long as EPA allows averaging, that should not be an issue, Jenks said during the webinar. 

Power plants can run at their full capacity during emergencies, such as Winter Storm Uri in February 2021 or the 2014 polar vortex, and then make up the difference in the rest of the year, she said. 

Another worry that opponents have brought up is the lack of “essential reliability services” such as frequency response, regulation reserves, operating reserves and voltage regulation that are provided for free because of the way traditional power plants work, said O’Connell. Grids do not need all their power plants to provide such services, with O’Connell saying a grid like MISO with about 200 GW of supply needs an “order of magnitude less” than that. 

“It turns out that clean resources, especially batteries with grid-forming inverters, can absolutely provide essential reliability services,” O’Connell said. “In fact, batteries have been providing regulation services in PJM for a long time now, closing in on a decade.” 

California is already rapidly decarbonizing its generation fleet, and CAISO is looking ahead to meet the state’s goals of eliminating emissions from electricity by 2045, said Cristy Sanada, regulatory affairs senior manager for the ISO. 

“The state policies have driven kind of where California is right now,” Sanada said. “California was very early to move on RPS standards and battery mandates. And, you know, we’ve already surpassed a lot of those early kind of RPS targets that were set out.” 

California’s own policies are driving the grid there to change more than a pending EPA proposal, but O’Connell noted that more is at play than just policy when it comes to the energy transition. 

“Let’s look at a state like Texas that doesn’t have any kind of clean energy goals at all, right?” O’Connell said. “Last year, wind energy exceeded both nuclear and coal and provided 25% of Texas’ electricity. Solar came on really strong this year. We saw a huge amount of solar being installed – it’s likely going to be 10% of the state’s electricity next year, if not more. And so, this is happening in states and locations that aren’t necessarily policy-driven like California. It’s really economically driven.”