America’s Power, the only national trade organization whose sole mission is to advocate at the federal and state levels on behalf of the U.S. coal fleet, submitted comments on EPA’s Supplemental Proposal requesting public comments on the reliability impacts of the Carbon Rule the agency proposed in May.

The Carbon Rule requires the reduction of carbon dioxide emissions from coal-fired and gas-fired power plants. Many refer to the Carbon Rule as Clean Power Plan 2.0. America’s Power President and CEO Michelle Bloodworth issued the following statement on the comments the organization filed today with EPA:

“We filed comments with EPA in May on the Carbon Rule explaining that the agency had not done proper reliability analysis, even though EPA claimed otherwise. It seems that EPA has finally admitted the rule could cause grid reliability problems. With plans to finalize the rule early next year, EPA is now trying to determine at the eleventh hour what to do to prevent the reliability problems we and many others have warned EPA about. Our comments on this new Supplemental Proposal point out that more than half the existing coal fleet is at risk of premature retirement because of the Carbon Rule. Massive coal retirements will cause electricity shortages and other reliability problems that cannot be fixed with the band aids that have been used in the past to prevent electricity shortages.

“EPA should have paid attention to warnings about coal retirements and reliability problems that had been issued over the years prior to the Carbon Rule. For example, the North American Electric Reliability Corporation has issued more than 20 reports warning of potential reliability problems due primarily to the retirement of coal and other dispatchable resources.  Ignoring these warnings, EPA has continued to develop and implement rules that cause coal retirements.
“Our comments on the Supplemental Proposal urge EPA to withdraw its harmful Carbon Rule and repropose a new rule that does not cause reliability problems and corrects the many other problems with the rule.  We also urge EPA to provide maximum flexibility in any Carbon Rule for states to design implementation plans that are sensible and avoid reliability problems.”

Brief Summary of America’s Power's Comments to EPA

• Coal retirements are increasing the prospect of an electric reliability crisis. Already, utilities have announced plans to retire some 81,000 megawatts (MW) of coal-fired generation (almost half the existing coal fleet) within the next six years.
• As currently designed, the Carbon Rule will cause even more coal retirements, further exacerbating reliability risks. We estimate that more than 100,000 MW of coal are at risk of retiring prematurely because of the Carbon Rule’s requirements to limit capacity factors, co-fire substantial amounts of natural gas, or install carbon capture technology by January 1, 2030.
• Various warnings about coal retirements and potential reliability problems extend as far back as 10 years prior to EPA proposing its Carbon Rule. In particular, the North American Electric Reliability Corporation (NERC) has issued at least 21 reports warning of potential reliability problems due largely to the retirement of coal and other dispatchable resources. Despite these warnings, EPA has continued to develop and implement rules that will cause more coal retirements.
• Existing mechanisms, such as reliability-must-run agreements or Department of Energy 202(c) orders under the Federal Power Act, are not adequate to mitigate reliability problems resulting from a large number of coal retirements.
• EPA should withdraw the Carbon Rule and repropose a new rule that corrects the rule’s myriad flaws, that is supported by solid reliability analysis, and that does not cause electricity shortages or operating reliability problems.
• Any Carbon Rule should provide maximum flexibility for states to design implementation plans so as to prevent reliability problems. Such flexibility includes allowing states to establish alternate, less stringent emission reduction requirements and compliance deadlines that take into account “remaining useful life and other factors.” States should be allowed to implement these measures through an informal and expedited administrative process.