The National Mining Association last week asked the Obama EPA to reconsider its Cross-State Air Pollution Rule (CSAPR) citing the agency’s failure to adequately consider electric reliability. While this may sound boring, if you like electricity and don’t want to be without air conditioning in future heat waves, you ought to read it.
NMA made five points in its petition:
- EPA failed to assess the cumulative impacts of all its power sector rules;
- The Federal Energy Regulatory Commission (FERC) says EPA wrongly assumes that power flows freely within broad geographic regions of the country;
- FERC has not yet assessed the impacts of the EPA’s rules;
- FERC says that, because of the EPA’s expedited compliance timeframe (i.e., Jan. 1, 2012), utilities may not have enough lead-in time to replace lost generation capacity;
- There is no public record of any substantive discussions EPA staff held with agenices responsible for grid reliability like FERC, state public utilities commissions and the North American Electric Reliability Council.
Unfortunately, the [EPA] appears unwilling to legitimately grapple with the reliability issue and the predictable results of its deliberate policy to reduce the usage of coal as a fuel source — that is a weakened, less reliable and more expensive electric supply for this country. The recent events that led to widespread outages for about 1.5 million people across portions of Arizona, Southern California and Northern Mexico, following widespread outages in the Southwest because of cold conditions last winter, underscore that the electric grid is frailer than EPA appreciates and that local impacts could have cascading effects. It is bad enough when the light go off because of a natural disaster such as Hurricance Irene; it would be a failing of of government regulation of the first order if the country experiences blackouts because EPA did not take the time to consult with FERC and others to adequately consider the reliability of its regulations.