NERC

The national reliability overseer, reviewing EPA’s proposed GHG controls, describes planned reliability assessments as part of its ongoing analysis of potential implications. The North American Electric Reliability Corporation raises concerns about the ability of power generators to meet proposed timelines, saying “compliance levels and timelines in the final plan should be harmonized with the timeline necessary to develop and implement the resources and infrastructure changes” that emerge in state and regional plans. It tells the Federal Energy Regulatory Commission that it endorses a “reliability safety valve” as an “assurance mechanism,” believes reliability services “may be strained” and thinks “more transmission and new operating procedures may be needed to address risks to reliability.” And it describes an ongoing a three-part “detailed reliability assessment,” targeted for release early spring – a sensitivity analysis using a variety of scenarios “to identify resource adequacy needs as well as the timeline associated with reliability reinforcement”;  a “transmission adequacy assessment,” including identification of needed infrastructure upgrades; and “independent evaluation of existing studies by industry stakeholders,” to determine “cumulative impacts on a region-wide basis.” NERC also plans two additional assessments: a December 2015 report, described as a “conventional reliability assessment based on known requirements,” to help states and regions as they develop plans; and a report, after state implementation plans have been filed with EPA, to include “a more granular reliability-focused cross-section of regional and single-state” plans. Target date if December 2016, “subject to change if EPA’s schedule shifts.”