The EPA has misled the public by promising but failing to consult with the Federal Energy Regulatory Commission (FERC) on the impact of the coming slew of EPA utility rules (i.e., EPA Train Wreck) on electricity reliability.
In its May 3 utility MACT proposal, the EPA stated,
… EPA itself has already begun reaching out to key stakeholders including not only sources with direct compliance obligations, but also groups with responsibility to assure an affordable and reliable supply of electricity including state Public Utility Commissions (PUC), Regional Transmission Organizations (RTOs), the National Electric Reliability Council (NERC), the Federal Energy Regulatory Commission (FERC), and DOE. EPA intends to continue these efforts during both the development and implementation of this proposed rule… Between proposal and final, EPA will work with DOE and FERC to identify any opportunities offered by the authorities and policy tools at the disposal of DOE and/or FERC that can be pursued to further ensure that the dual goals of substantially reducing the adverse public health impacts of power generation, as required by the CAA, while continuing to assure electric reliability is maintained. EPA also intends to continue to work with DOE, FERC, state PUCs, RTOs and power companies as this rule is implemented to identify and address any challenges to ensuring that both the requirements of the CAA and the need for a reliable electric system are met. [Emphasis added]
Then on Aug. 3, an EPA spokesman told The Hill that,
… EPA has worked with FERC since we began developing these standards to ensure we maximize public health benefits while minimizing costs, including assessing any impacts they would have on electric reliability and affordability. Our comprehensive analysis indicates that the standards – which rely on pollution control technologies already in use at facilities across the country – would have minimal impact on reliability or affordability nationally.” [Emphasis added].
But in an August 1, 2011 letter to Sen. Lisa Murkowski, FERC Chairman Jon Wellinghoff admitted no consultation occurred on the cumulative impacts of the EPA rules on electricity reliability:
Commission staff has had numerous consultations with EPA concerning its proposed power sector rules. Staff also has participated in meetings attended by the Council on Environmental Quality (CEQ), Department of Energy, and the EPA. Each consultation generally concerned a single proposed rule, rather than the cumulative effect of all the EPA proposed rules. Commission staff’s discussions with EPA staff were primarily with EPA’s air quality staff and concerned EPA’s air quality rules. [Emphasis added]
One of FERC’s primary charges is to protect the reliability of our electricity grid. Major changes to parts of the electric grid can force power outages and increased rates for consumers. An informal analysis by FERC has estimated that 81 gigawatts of coal-fired generating capacity are either “very likely” or “likely” to be retired as a result of the EPA Train Wreck. This is a much larger amount than any EPA estimation and could only be replaced at massive cost increases to residential and industrial power consumers.
FERC Commissioner Philip Moeller told Sen. Murkowski on Aug. 1 that,
… The Commission has not engaged in efforts to explain the effect of potential [power plant] retirements on electric reliability… Concerning the impact of the listed EPA rules on electric reliability, the Commission has not acted or studied or provided assistance to any agency, including EPA… I believe the federaal government needs to convene an open and transparent process to assess the reilability implications of the EPA rules individually and in aggregate…”
Right-o, Commissioner Moeller, such a review of the EPA’s rules needs to happen ASAP before Obama broils Grandma with a brownout.