Posts filed under Reliability

FERC Conferences Underscore Mounting Concerns with EPA’s Clean Power Plan

As the Federal Energy Regulatory Commission wraps up the final of three regional technical conferences today in St. Louis, Missouri we thought it would be interesting to take a look at what others have said at previous conferences.

I don’t think you’ll be surprised that cost and reliability are chief among the growing chorus of concerns coming from experts and stakeholders in the states.

  • In February, at the FERC regional conference in Denver, Michael Hummel of Arizona’s Salt River Project testified that, “the Clean Power Plan as currently drafted will have a disproportionate impact on Arizona and threatens our ability to reliably maintain the electric grid.”
  • The next month in Washington, D.C., Jeff Burleson, Vice President of System Planning of Southern Company, warned that the CPP, “unlike past environmental requirements… is a major overhaul of the electric system that will potentially put serious reliability and operational pressures on the grid.”
  • Ross Eisenberg of the National Association of Manufacturers told FERC, “[the CPP] and its massive redesign of the energy system threatens secure, affordable supply of energy.”
  • National power groups have also implored FERC to play an active role in fixing EPA’s flawed proposal. In Washington, D.C., Jay Morrison, vice president for regulatory affairs at the National Rural Electric Cooperative urged FERC, “Please do not be a potted plan in this instance.  Please be very active.”

Regulators and energy industry experts will likely echo these concerns before FERC in St. Louis.  As this is the final FERC technical conference, we hope all parties are listening closely and are prepared to take appropriate action by withdrawing the CPP.


What do Indiana, Wisconsin and Wyoming have in Common? They Oppose EPA’s Overreach

Officials from Indiana, Wisconsin and Wyoming are on Capitol Hill today to testify about the consequences of the Environmental Protection Agency’s Clean Power Plan.

While we don’t know what these officials will say, we know from previous comments that they are united in their opposition to the CPP and share many of the same concerns:

Last September, Tom Easterly, commissioner of the Indiana Department of Environmental Management, shared his concerns with the House Committee on Energy and Commerce, saying “Hoosiers know that coal means jobs and coal means low-cost energy […] In examining how the proposed 111(d) regulations further our mission, I have come to the conclusion that the proposal will cause significant harm to Hoosiers and most residents of the U.S.”

Ellen Nowak, commissioner with the Wisconsin Public Service Commission says when it comes to EPA’s CPP – projected to cost the state of Wisconsin between $3 billion and $13 billion – she “wouldn’t put that in the ‘reasonable’ category.”

Todd Parfitt, director of the Wyoming Department of Environmental Quality, said in the Department’s comments that “WDEQ’s review finds that the Proposed Rule is fundamentally flawed and should be withdrawn principally because EPA lacks statutory authority to proceed with this rulemaking.”

We’ll certainly hear more of these concerns today and in the coming weeks. When we do, it’s important to remember these three states have more in common than their participation in this morning’s hearing. Coal-based power supports job creation, economic growth and low-cost electricity in each of these states. EPA’s proposal seeks to diminish the use of affordable, reliable electricity from coal and place the costly consequences squarely on the shoulders of consumers in Indiana, Wisconsin, Wyoming and every other state in the nation.


The Morning Consult: EPA’s Clean Power Plan Threatens to Turn the Lights Out on America

This column originally appeared in The Morning Consult on March 3, 2015.

The Washington Post profiled Sharon Garcia, a single mom from Pueblo, Colorado, last year who suffers from a state policy that shuttered coal plants in favor of costlier, less reliable fuel sources. Ms. Garcia and her family – emblematic of so many other U.S. families – are forced to live in darkness at times, just to conserve energy so as not to face yet another sky-high electricity bill.

As of last July, the Environmental Protection Agency’s power plant regulations have led to the announced retirement or conversion of more than 350 coal-fueled generating units throughout the country. Now, EPA’s most disastrous, not to mention costliest, regulatory measure yet – the Clean Power Plan – threatens to shut down even more of our nation’s coal-based power plants, limiting our supply of affordable electricity and severely impacting the reliability of our electric grid.

EPA wants to supplant coal with resources like natural gas, which poses significant transport issues and price volatility concerns, as well as more renewable resources that are nowhere near “mission ready.” To transform our nation’s power delivery system to fully utilize these unpredictable fuel sources will be a massive, time-consuming and expensive undertaking, projected to cost more than $1 trillion. In the short-term, American consumers will suffer the immediate consequences of power outages and forced electricity conservation.

In its primer on the Clean Power Plan, EPA claims the measure “provides enough time for utilities to make changes without affecting reliability.” EPA Administrator McCarthy also alleges that “EPA is not going to threaten energy reliability.” Electric grid operators, state officials and energy industry experts, however, paint a very different picture of the plan’s impact on electric reliability.

The Southwest Power Pool was among the first grid operators to release a study detailing major concerns with EPA’s proposed regulations, warning of “voltage collapse and blackout conditions” if the plan proceeds as scheduled. The Electric Reliability Council of Texas, the main grid operator serving 23 million Texans, also issued an analysis of the proposal, which found EPA’s proposal could result in “transmission reliability issues due to the loss of fossil fuel-fired generation resources in and around major urban centers.”

Seventeen former and current public utility and public service commissioners – officials that, unlike EPA, possess substantial knowledge about electricity generation – also joined the chorus of alarmed experts, stating that “Our concern with the EPA’s proposed carbon rules is that they fail to adequately forecast the serious economic and reliability impacts of dramatically reduced or even elimination of coal-fired generation.”

The Electric Reliability Coordinating Council summarized it best in a recent paper, saying “Unfortunately, preliminary analyses released by qualified experts point to one inescapable conclusion: EPA’s proposal puts the reliability of our nation’s electricity supply at risk.”

As a nation, we should be pursuing a smart “all of the above” energy strategy that allows us to protect our environment and harness cleaner energy, but that doesn’t undermine energy reliability in the process. EPA’s dangerous plan must be stopped, before Americans are left without the low-cost, dependable power we need, when we need it the most.


Will EPA Ignore FERC Again?

Independent grid operators, elected officials and public utility commissioners have all raised concerns about the potential for power outages if states are forced to comply with the Environmental Protection Agency’s costly and overreaching Clean Power Plan.

Thus far, and not surprisingly, EPA has turned a deaf ear. They do, after all, have a habit of listening only to those whose opinions with which they are comfortable.


At the request of congressional leaders, the Federal Energy Regulatory Commission—the agency charged with protecting the reliability of our nation’s energy generation and supply system—will host a series of technical conferences weighing the impact of compliance with EPA’s proposal on the electric grid. The conferences kick off today in Washington, D.C.

You would think, as EPA’s Clean Power Plan is more akin to a national energy policy (the job of Congress) than it is to a plan to protect public health (EPA’s actual job), that FERC would be heavily involved with the planning and crafting of the proposal. Not so, according to FERC Commissioner Tony Clark. In a letter to the House Energy and Commerce Committee, Clark wrote, “With regard to FERC staff generally, I believe it unreasonable to conclude that FERC meaningfully or substantially participated in the [Clean Power] plan’s development.” 

EPA has shown little regard for reliability concerns in the past and likely fears that FERC’s direct involvement may interfere with the agency’s knack for employing fuzzy math to underestimate the impacts of its regulations.

While finalizing the Mercury Air and Toxic Standards, EPA claimed that MATS (along with the Cross-State Air Pollution Rule, which was later remanded back to EPA) would cause 9,500 megawatts of coal unit retirements. In contrast, utilities have announced the retirement of 389 coal units—more than 61,000 MW and almost 20 percent of the U.S. coal fleet—as a result of EPA policies. 50,000 MW can be directly attributed to MATS.  You read that right. EPA’s projection for coal retirements due to MATS/CSAPR was only 1/5th the number of actual retirements caused by MATS.

During last year’s “polar vortex,” major utility companies like American Electric Power had to run 89 percent of its soon-to-be-retired coal capacity just to meet demand and avoid cascading power outages. Shortly thereafter, FERC Commissioner Philip Moeller issued a wake-up call before the Senate Committee on Energy and Natural Resources, stating, “I was, and remain concerned that EPA’s analysis greatly underestimated the amount of power production that would be retired due to these rules.” Moeller continued, “The experience of this winter strongly suggests that parts of the nation’s bulk power system are in a more precarious situation than I had feared in the past.”

According to EPA’s own projections, the Clean Power Plan will cause significantly more coal retirements than what the agency projected for MATS. An analysis conducted by NERA Economic Consulting projected that at least 45,000 MW more would be forced to retire. That is greater than the entire electricity supply of New England.

It’s no wonder that in Kansas last week, FERC Commissioner Clark, a former legislator and utility regulator in North Dakota, said complying with EPA’s mandate is a “huge decision to make,” and “a little bit like the Affordable Care Act…play ball, and potentially get caught up in it in a way that you may regret later on.”

We’ve already seen the impact of EPA’s regulations on our supply of reliable electricity. Will EPA listen to the experts this time around?


Regulators, Legislators and Energy Industry Experts Agree: EPA’s Carbon Plan is Unworkable

Public service and utility commissioners from across the country are in Washington, D.C. this week to attend the National Association of Regulatory Utility Commissioners Winter Meeting. Without question, the Environmental Protection Agency’s Clean Power Plan will be a central topic of discussion as its chief proponent, Administrator McCarthy, will be on hand to tout her usual misleading claims.

Ms. McCarthy’s audience at NARUC, however, may not be inclined to swallow her claims of lower energy bills and a stable grid, hook, line and sinker as her Clean Power Plan is being met with growing concern and criticism. Legislators, regulators and energy industry leaders alike are pointing out major flaws in EPA’s proposal. Today, we’re taking a look at what experts are saying about three core tenets of the CPP: reliability impacts, cost increases and unrealistic assumptions.

Regardless of what Ms. McCarthy may say, here are two facts she can’t escape:

  1. EPA’s plan jeopardizes the reliability of our electric grid.
  1. EPA failed to consult the Federal Energy Regulatory Commission, the federal regulatory body in charge of monitoring America’s electric grid.

Don’t take my word for it though – let’s hear directly from the experts:

“SPP’s transmission system impact evaluation indicates serious, detrimental impacts on the reliable operation of the bulk electric system in the SPP region, introducing the very real possibility of rolling blackouts or cascading outages that will have significant impacts on human health, public safety and economic activity within the region.” – Southwest Power Pool

“The weather events experienced this [2014] winter provided an early warning about serious issues with electric supply and reliability. This country did not just dodge a bullet – we dodged a cannonball.” – Nick Akins, AEP

“I believe it unreasonable to conclude that FERC meaningfully or substantially participated in the [Clean Power Plan’s] development.” – Tony Clark, FERC Commissioner

Here’s another inescapable fact: The CPP will result in significant electricity price increases across the board.

“We must realize that utility rates are not within the jurisdiction of EPA.” – Lisa Edgar, NARUC President and Florida Public Service Commissioner

“Plant retirements are higher than projected. Electricity prices are rising. Even factors beyond our control – such as last winter’s [2014] weather – are on a collision course with the shutdowns caused in part by new federal regulations.” – Senator Lisa Murkowski (R-AK)

And, yet another: EPA has created a flawed and unworkable rule based on unrealistic assumptions.

EPA has set mandatory emissions reductions “with no analysis by EPA as to whether that actually makes sense or is economically reasonable for each state.” – Robert J. Martineau, Tennessee Department of Environment and Conservation Commissioner

“NCDENR believes EPA’s proposed rule … is legally and technically flawed… In defining a specific rate for each state and then mandating each state meet that predetermined rate, EPA runs counter to the U.S. Constitution.” – John E. Skvarla, North Carolina Department of Environment and Natural Resources Secretary

“The proposal assumes that Arizona can completely be off coal in 2020. The fact is that it gets hot in Arizona and there are periods in the summer in which we are utilizing every possible source of electricity, from natural gas to nuclear and coal.” – Henry Darwin, Arizona Department of Environmental Quality Director

To learn more about the impacts of EPA’s regulations, visit today and get the facts.


Lights Out: New Video Shows How EPA Will Leave American Families in the Dark

America’s Power released a new video today highlighting the serious threat the Environmental Protection Agency’s regulations pose to our electric reliability. The video follows a family’s journey through a winter storm to learn why power outages have occurred at a time when reliable electricity is needed the most. What they discover is that coal-based power plants, which provide our base-load electricity and keep our homes and businesses powered during winter storms and throughout the year, have been forced offline due to EPA’s misguided and politicized energy policies.

The latest addition to our #ColdInTheDark campaign, this video drives home a crucial point – EPA’s overreaching and dangerous regulations will indeed turn the lights off on American families if left unchallenged.

EPA is clearly living in a fantasy world where they believe intermittent energy sources can make up for the nearly 49,000 MW of generating capacity from coal plants set to be shut down by the end of this year. Even though EPA prefers to dwell in dreamland, we hope our video wakes Americans up to the harsh reality these regulations will impose.

What can you do to help prevent Americans from going without power when they need it most? Sign up for the America’s Power Army, and learn more at


Newly Launched #ColdInTheDark Campaign Highlights Reliability Concerns with EPA Regulations

This week, America’s Power launched a new campaign—#ColdInTheDark—to highlight the high costs and significant electric reliability impacts that will result from the Environmental Protection Agency’s proposed carbon regulations. The initiative offers a glimpse into the reality American consumers will face under the Clean Power Plan: less affordable and less reliable electricity, especially during times of critical demand.

EPA’s regulations are forcing coal-based power plants to shut down, threatening our supply of reliable electricity and elevating the risk of power outages for years to come. Last winter’s polar vortex revealed an already-strained electric grid, and major grid operators, regulators, elected officials, energy experts and other concerned Americans from coast to coast have sounded the alarm.

#ColdInTheDark is the inaugural installment of, a new initiative that will include several themed campaigns throughout 2015. The site will serve as an online hub that includes news articles, expert takes, infographics, social media share graphics, and resources related to electric grid reliability.

It’s time to expose EPA’s regulations for what they are, before Americans are left #ColdInTheDark – without the low-cost, dependable power we need, when we need it the most. Visit to learn more.  

Protecting Our Electricity Grid

Last week, I penned a response to National Journal’s “Energy Insiders” on the important topic of securing America’s electricity grid. While we certainly must protect our grid from cyber and physical attacks, we must also be concerned about another critical threat to the grid: power outages and electricity shortages due to reliability.

FERC Commissioner Philip Moeller has been vocal recently about these impending energy shortages. At a U.S. Energy Association meeting last week, he warned that the grid will likely stay reliable during mild weather, assuming we don’t experience periods of extreme hot or cold, but this is “not a sound basis of planning,” to hope the thermometer doesn’t tip either direction. This is an important point that should not be lost and something I discussed in my National Journal response.

Here is what I wrote:


Grid security has become a hot topic in Washington. Unfortunately, the discussion has focused on just one aspect—cyber security—of a much broader issue. Indeed, there is another security threat to our electric grid that has been downplayed by this administration; a threat that, ironically, has a common-sense and achievable solution.

This past winter brought historically cold temperatures to many parts of the country that resulted in widespread concerns with electric grid reliability. These concerns were well founded as we saw firsthand what happens when politically driven, costly regulations are imposed on coal-based industries that exclude the use of coal from our energy portfolio.

As natural gas price spikes and infrastructure and transport concerns strained the grid, prompting fears of blackouts and brownouts, it is not surprising that utilities turned to coal to ensure the power stayed on. In fact, AEP was running nearly 90 percent of its coal plants currently slated for closure just to help meet demand for power during the coldest days.

EPA Administrator Gina McCarthy claims that coal will “play a critical role in a diverse U.S. energy mix for years to come” and also alleges her agency is focused on protecting electric reliability. A recent study from ACCCE, however, projects that 25 to 40 percent of the nation’s coal fleet could be shuttered depending on the stringency of EPA’s forthcoming 111(d) proposal, costing consumers $13 billion to $17 billion per year in higher electricity and natural gas prices.

Administrator McCarthy and others in this administration have so far only offered misleading statements about reliability concerns, maintaining that EPA’s regulations will not impact coal usage and that the agency will work to protect and preserve reliability.

We know these claims to be untrue, as EPA greenhouse gas regulations will impose a de facto ban on new coal-fueled power plants and likely force retirements of existing plants across the country which will, in fact, cause serious reliability issues that still haven’t been addressed by this administration.

Last week, the Senate Committee on Energy and Natural Resources hosted a hearing on grid reliability, but no representative from the Environmental Protection Agency (EPA) testified about these very real reliability concerns associated with the agency’s regulatory assault on coal.

Some members of the committee, like Senators Manchin and Murkowski, raised concerns about how EPA regulations play into the broader grid security issue. Unfortunately, it seems that this administration is doing all it can to quell such concerns and continue leading America toward an energy policy that wholly disregards cost and reliability consequences.

Diminished electric reliability is certainly a threat to our well-being, to our economy and to our national security. It makes America less competitive, and it puts us all in harms’ way. In order to make headway on protecting grid security, we must have a more comprehensive and candid dialogue about all the looming threats.