Speaking to the Federal Energy Regulatory Commission (FERC) on behalf of America’s more than 900 not-for-profit electric cooperatives, Jay Morrison, Vice President of Regulatory Affairs at the National Rural Electric Cooperative Association (NRECA), outlined concerns that the Environmental Protection Agency’s (EPA) proposed Clean Power Plan (CPP) could affect the cost of and reliability of electricity.
In comments submitted for the record, Morrison reiterated “NRECA believes that the CPP is well outside the EPA’s legal authority under the Clean Air Act, and that the CPP should be withdrawn in its entirety. NRECA maintains that, at its core, EPA’s proposal is illegal and imprudent.”
Responding to FERC’s request for suggestions, Morrison noted, “FERC has a crucial role to play in ensuring that environmental regulation does not impair or impede grid reliability. … NRECA urges the Commission to adopt a Policy Statement through which the Commission will provide guidance and advice to EPA … The proposed CPP represents a considerable challenge to electric rates’ affordability and a conceivably overwhelming impact to reliability for the industry and especially rural electric cooperatives.”
If EPA does not withdraw the proposal, NRECA requests FERC to forward the following modifications to EPA to help mitigate the potential negative impacts to grid operations, reliability and affordability as states and regions develop their compliance plans.
- Eliminate the interim goal reduction requirements
- Adopt a dynamic (as opposed to static) reliability safety valve – one that provides states the ongoing flexibility they will need to ensure affordability and reliability
- Provide flexibility to extend the 2030 compliance deadline (to at least 2035) as required to preserve reliability, and to prevent the stranding of assets or unreasonable rate increases
The National Rural Electric Cooperative Association is the national service organization that represents the nation’s more than 900 private, not-for-profit, consumer-owned electric cooperatives, which provide service to 42 million people in 47 states.