Large Public Power Council Urges NERC and FERC Review of State Implementation Plans for Clean Power Plan to Maintain Grid Reliability, March 11, 2015

March 11, 2015
Contact: Lawrence Pacheco
(202) 346-8855

Washington, D.C. — Large Public Power Council (LPPC) President John Di Stasio today asserted that State Implementation Plans (SIPs) for the EPA’s clean power plan (CPP) should be reviewed by both the North American Electric Reliability Corporation (NERC) and the Federal Energy Regulatory Commission (FERC) before they are finalized in order to maintain reliability of the electric grid.  DiStasio was a speaker at FERC’s conference in Washington, D.C. addressing the reliability impact of the proposed EPA rule.

Di Stasio advocated bringing NERC’s expertise to bear in evaluating the CPP. He commented that NERC has an obligation to undertake reliability assessments under the law and FERC has an important role in reviewing this work, yet currently, neither NERC nor FERC have identified roles under EPA’s proposed regulation in connection with the development or implementation of the CPP.

“NERC and FERC must have a central role in evaluating SIPs, or any EPA-devised plans governing state-based activity, before they are finalized and approved by the EPA. I strongly believe that NERC should have ‘first chair’ responsibility. NERC is uniquely situated to perform a comprehensive analysis of these issues and is best positioned to do so from an unbiased perspective, without promoting a specific agenda. We ask FERC to endorse this role,” said Di Stasio.

Di Stasio acknowledged that FERC’s role is also critical. It will be important for FERC to review and express its judgment with respect to NERC’s work, and to the extent it agrees with NERC’s assessment, “the Commission’s sign-off will carry a good deal of weight as the EPA considers any necessary adjustments to assure reliability.”

Following approval of the state plans, LPPC supports ongoing evaluation of the plans as they evolve so that they reflect the study of interregional reliability impacts.

Di Stasio also detailed several LPPC member concerns associated with CPP implementation including shortcomings in natural gas pipeline capacity sufficient to serve expected demand during the compliance period; concern regarding the vulnerability of off-shore electric transmission that would be needed to accommodate the development of offshore wind to satisfy requirements; and concern regarding the lead time for these and other needed transmission facilities.

Click here for Di Stasio’s full testimony.