Washington, D.C., December 1, 2011 — Clair Moeller, MISO Vice President of Transmission Asset Management, warned the Federal Energy Regulatory Commission that the timing of proposed Environmental Protection Agency air emission rules poses threats to power reliability.
In comments submitted for FERC's technical conference this week on reliability risks related to compliance with new EPA air emissions regulations, Moeller said the new regulations will require simultaneous generator outages that may jeopardize electric reliability in the Midwest.
In particular, MISO's concerns center on the 2014/2015 compliance deadline for the EPA's proposed mercury rule. The compliance time allowed by the proposed rule and the time required to accomplish the installation of new control equipment or capacity replacement is exactly the same, Moeller said in MISO's filed comments, meaning owners of all these units must remove them from service simultaneously leaving inadequate generation resources to sustain reliable electricity supply.
"As a result, 62,000 MW of coal units could potentially be unavailable for reliability purposes — all at the same time," Moeller said.
This scenario underscores the need for customers to access all available generation — including generation that meets the EPA criteria. As one immediate mitigation measure, MISO — in a separate filed response to questions from Commissioner Philip D. Moeller — called on the Commission to direct regional transmission organizations to work together to ensure that physically available transfer capability across regions is accessible to those who need and can provide excess power.
"The pending EPA regulations and potential impact on generator operations highlights the need for coordinated planning between generator owners and market transmission providers," the filing states.
Clair Moeller appeared before the Commission on a panel of electric industry panelists invited to present comments on multi-jurisdictional processes related to implementation of the EPA regulations.
In his remarks, he expressed MISO's support with other ISOs and RTOs in seeking flexibility from the EPA on implementation of the regulations. On Aug. 4, 2011, the ISOs/RTOs formally asked the EPA to consider an extension process as a "safety valve" to ensure grid reliability.
MISO also supports alternative proposals to mitigate any potential for decreased reliability such as a targeted "reliability-only dispatch" approach in which units run when no other resource is available to meet electricity needs.