Clean or Dirty? Fighting Over the EPA Clean Power Plan Gets Messy

, , senior energy analyst, Climate & Energy Program | November 6, 2014, 5:41 pm EDT
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What should we think when two grid reliability authorities look at large-scale adoption of renewable energy and come to opposite conclusions? This isn’t pretty and we need to get to the bottom of it.

Operator control room. Credit: Midcontinent ISO

Operator control room. Credit: Midcontinent ISO

The North American Electricity Reliability Corp. (NERC) and the Midcontinent Independent System Operator (MISO) conducted and released reports on the impacts of reducing reliance on fossil-fuel power plants and increasing renewable energy production. NERC describes its report as “initial, high-level” and reflects the most negative assumptions when assessing the electricity supply after 2020 and the start of the EPA CO2 measurements.

In contrast, MISO made contributions to Minnesota’s full-on engineering study that includes the plans for transmission necessary for 40% – 50% renewable energy in Minnesota and 15% – 25% renewable energy in that portion of the MISO region.

How different can these be?

The NERC report is all about adding up the total generator capacity. However, when focusing on the EPA’s example renewable energy building block, NERC failed to include additional renewable generation, which despite variability in output, does contribute to the total capacity available to meet demand. This was recognized in the MISO-Minnesota study, which calculated the contribution at peak times in that region as approximately 12% of the wind generator capacity, and 40% of solar installations. Thus, NERC writes that there will be significant increases in wind and solar generation, but ignored the capacity contribution from that additional generation.

This difference also extends to how the two treat conventional generation additions. Both organizations assume that demand for electricity continues to grow through 2030, and yet only one of them includes a combination of energy efficiency, demand response, and new power plants to meet the demand. The MISO-Minnesota study adds a variety of new supply types across MISO. NERC, even when describing MISO, suggests no new supplies of any kind will be added.

Even transmission isn’t the problem NERC says it might be

The Minnesota study found that transmission needs could be met with renovations of existing transmission facilities. No new lines were required for MISO to have 15% energy from wind and solar, and Minnesota to have 40%. NERC admits it hasn’t studied the need for new lines, and is just saying that they expect new lines will be both needed, and difficult to permit and build. NERC gives the lead time for new transmission as “typically 10–15-years.”


This post is part of a series on the EPA Clean Power Plan.

NERC’s discussion of renewable energy emphasizes the need for transmission, especially in MISO and the Southwest Power Pool (SPP). Fortunately for grid reliability, consumers, and the expansion of wind, these two regions have been pro-active in building transmission.

In the SPP region, details belie NERC’s assumptions. For example, there was news last week of the completion of a major new 108 mile-long transmission line completed ahead of schedule and 30% under budget. This transmission line was built by a company that was only formed in May 2008 to work in SPP. It applied for permit to build with Kansas authorities in Feb 2011, and received approval in June 2011. Six years and five months after starting, this company has a new 345-kV line up and ready.

NERC makes reliability assessments all the time, but NERC has been warned by the Federal Energy Regulatory Commission, its supervisor, not to advocate for changes in clean air policy. The contrast between these two organizations that are both responsible for reliability demonstrates how attitude and assumptions can affect what the studies say.

Earlier, MISO made a quick review of the costs to comply with EPA’s proposed CO2 rules and used assumptions that confounded the results. We knew MISO could do better, if they were really looking at the whole question. This week, we have those better results. We look forward to the next time MISO addresses the EPA Clean Power Plan, hoping they use the lessons of this recent study and the comments and changes that have been seen in discussions with MISO stakeholders. Hopefully, when NERC makes its more careful assessments of the EPA power plant rule, which NERC is promising to do, we will see they can do better, too.

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  • Dr. Luis Contreras

    Dear Mike,

    Thank you for your great article and for your comments.

    I am grateful to President Obama and EPA Administrator Gina McCarthy, and I am
    excited with the report today on the U.S. and China agreement to limit greenhouse gases.

    At state level, I am frustrated, with all due respect, with AR Congressman John
    Boozman and most of our state representatives openly endorsing the coal cartel.

    I would like to send you an editorial that should be out today on our Eureka
    Springs, AR newspaper.

    I joined your mailing list and will send a contribution shortly.

    Kind regards, Luis

  • Dr. Luis Contreras

    How to lie with reliability analysis.

    Making different assumptions reliability studies show different results. There is nothing surprising about this.

    The October 8, 2014 SPP Reliability Analysis claiming “lack of time” assumed the worst scenario: shutting down coal-fired power plants and ignoring, energy conservation, energy efficiency, new distributed solar generation, wind, and natural gas. SPP wanted to “prove” transmission line expansion and bulk power generation are needed to meet EPA requirements.

    Why are NERC, MISO and SPP allowed to make different assumptions, ignoring the building blocks of the EPA Clean Power Plan (CPP)? Ignoring any one of the building blocks makes the NERC, MISO and SPP “studies” invalid, a lame way to “prove” whatever they want to find, and a waste of time for everyone.

    Why not simply say: SPP opposes the EPA CPP; transmission line expansion and bulk power generation are needed to help American Electric Power build new transmission lines and bulk power plants!

    When dealing with catastrophic effects of climate change, denials, deception and delays are heinous games played by immoral and unethical organizations. We are running out of time; honesty, integrity and responsibility are essential.

    • Mike Jacobs

      Dr. Contreras- Thank you for contribution to this. I too have been very disappointed with these organizations, and I am making myself heard. When these organizations accept the authority from the federal government to plan for reliability of the grid, they have to acknowledge the responsibility that goes with that authority. In the past weeks, FERC as supervisor of these organizations has warned them that they must stay within their authority and not comment on what the rule should say. EPA came out with criticisms of NERC’s “report” along the same lines as I described here. Thank you again.