National Climate Coalition

This coalition of power suppliers and corporations addresses reliability issues in the context of the Clean Power Plan and says EPA should “preauthorize a practical, self-executing reliability safety valve when a designated reliability oversight entity” makes a determination that power delivery is threatened. In comments to the Federal Energy Regulatory Commission, in the context of FERC’s ongoing inquiry into reliability issues raised by EPA’s proposed GHG controls, NCC argues that “the problem with existing authority” is that neither the Clean Air Act nor the proposed CPP connects reliability authority and the ability to “deviate” from State Implementation Plan commitments. “Instead,” the group says, “existing authority appears to set an impractically high bar for reliability-related relief.” NCC, comprising big power generators and corporations (AES, NRG, Boeing, and 3M among them) plus the American Public Power Association, says that “in the final CPP, EPA should identify the appropriate reliability entities that would be authorized to make a reliability need determination that would automatically trigger” a reliability assurance mechanism. And, it says, “EPA must provide in the final CPP” that state plans “presumptively waive any compliance obligation for any incremental excess emissions attributable to the must-run” electric generating unit’s “required operation.”