Four of the largest grid operators in the US are raising concerns about guidelines proposed by the US Environmental Protection Agency (EPA) to reduce carbon emissions from power plants.
PJM Interconnection LLC, Electric Reliability Council of Texas (ERCOT), Southwest Power Pool (SPP), and Midcontinent Independent System Operator (MISO) submitted comments on EPA’s proposed rule on new source performance standards for greenhouse gas emissions, highlighting concerns with grid reliability. , according to a Tuesday press release from PJM.
“As the penetration of renewable resources continues to increase, the grid will need to rely even more on generation capable of providing critical reliability attributes. With the continued and potentially accelerating retirements of dispatchable generation, the provision of these reliability attributes will be reduced to worrying levels,” the group of network operators said in their joint comments.
“New technologies and industry practices are being developed to enable the integration of significant inverter-based generation that provides the essential reliability services required, but joint ISO/RTO [independent system operators/regional transmission organizations] they are concerned about a scenario where, similar to the one mentioned above, the necessary technologies are not widely commercialized in time to balance large amounts of retirements,” the network operators said.
They also said the rule would have a “chilling impact” on the “investment required to retain and maintain existing units that are needed to provide key attributes and network services before the compliance date required by the rule.”
The group also expressed concern with the EPA’s finding that “commissioning with hydrogen or deploying carbon capture and sequestration [CCS] is economically and technically viable enough to be considered the Best Emissions Reduction System”, according to the statement.
The group urged the EPA to include several additional features to help mitigate reliability impacts. One of the suggested features included specifying a new subcategory for existing units, “providing a time-limited means for ISOs and RTOs to designate classes of units that are necessary to maintain local or regional reliability until alternatives are available to address the specific reliability need identified,” the statement said.
Another suggested feature is to create a process to monitor and adjust the compliance schedule applied to existing gas and coal units based on an examination of whether CCS and hydrogen co-firing infrastructure is being developed at a pace sufficient to allow implementation within the time frame. allowed by the new rule. The integrated ongoing review “will ensure a better balance of the pace of retirement of dispatchable generation required to provide critical network services,” the statement said.
Other suggested features include “providing specific recognition of the availability of copyright trading at the regional or national level to allow for greater flexibility and to incentivize early and effective ‘over-compliance’ by units that are able to do so” and “update the definition of ‘System Emergency’ to reduce uncertainty about when a unit can be called upon for reliability,” according to the statement.
The group urged EPA not to adopt the rule before allowing “more thorough exploration of the reliability impacts of the proposed rule and its impact on investment decisions, and discussing those findings with ISO/RTOs.”
In May, the EPA proposed new carbon pollution standards for coal and natural gas power plants to “protect public health, reduce harmful pollutants, and deliver up to $85 billion in climate and public health benefits over the next two decades,” according to a report. agency’s previous press release.
The proposed limits and guidelines would require carbon pollution reductions “based on proven and cost-effective control technologies that can be applied directly to power plants,” such as CCS and clean hydrogen, the EPA said, adding that the guidelines also provide power plant owners and operators ample lead time and substantial compliance flexibility. The proposed guidelines also allow electric utilities and grid operators to make long-term planning and investment decisions and support the power sector’s ability to continue to provide reliable and affordable electricity, the agency said.
The EPA’s proposed technology-based standards include strengthening current new source performance standards for new-build fossil fuel-fired stationary combustion turbines by establishing emission guidelines that states must follow to limit carbon pollution from existing fossil fuel steam power generation units. , and establishing emissions guidelines for large and frequently used stationary fossil fuel combustion turbines, according to the release.
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