Time and Flexibility: Keys to Ensuring Reliable, Affordable Electricity

In the EPA’s 40-year history, emissions from power plants have decreased dramatically, improving public health protection for all Americans, all over a period when the U.S. economy has grown dramatically. Throughout this entire period, there has never been an instance in which Clean Air Act standards have caused the lights to go out. During the development of power sector air emissions rules, including the proposed Clean Power Plan, EPA has devoted significant attention to ensuring that important public health and environmental protections are achieved without interfering with the country’s reliable and affordable supply of electricity.

From day one in the development of the Clean Power Plan, reaching out and engaging with the public, industry, environmental groups, other federal agencies, and state and regional energy reliability officials has been the agency’s top priority. EPA also worked with technical staff at FERC and the Department of Energy in crafting the proposal and we continue to consult with those agencies. For years we’ve heard from the utility sector that what they need from EPA is enough time, plenty of flexibility, and clear and certain emission reduction requirements in order to plan for and fulfill the country’s electricity needs. Thanks to the ideas, suggestions and information we gleaned from our public engagement, we were able to build broad flexibility into the proposed Clean Power Plan. For example, our proposal includes:

• A 10-year compliance timeline (beginning in 2020) that allows states and authorities to plan compliance strategies that work to ensure reliability: The Clean Power Plan’s compliance period plays out over a ten-year horizon and begins five years from now; thus, system operators, states and utilities will have the time to do what they are already doing – looking ahead to spot the potential changes and contingencies that pose reliability risks and identify the actions needed to mitigate those risks.

• A system-wide approach to emissions reductions that provides a wide range of options to meet the state targets: From plant-specific efficiency improvements, to increased dispatch of cleaner units, to the building out of renewable sources of generation, to transmission system upgrades, to modulating demand via energy efficiency programs, states and utilities can adopt emissions reductions strategies that in and of themselves help mitigate reliability risks or that allow states and utilities the latitude to accommodate the dual emissions reduction and reliability objectives.

• An approach that maintains the full-range of tools states and planning authorities have available to them: State and regional organizations responsible for ensuring reliability, as well as utilities, enjoy a large and diverse toolbox that they have been using, and can and will continue to use, in carrying out their collective mission. The Clean Power Plan’s approach is designed to ensure that the full toolbox can continue to be used by the system’s operators.

As of the December 1 deadline for submitting comments on the proposed Clean Power Plan, EPA received more than 2 million comments, covering a wide range of issues including system reliability, and we are absolutely committed to reviewing those comments and ensuring that the final Clean Power Plan reflects and responds to them. In fact, EPA continued its outreach and engagement process after we issued the proposal in June and received significant response and information from states and stakeholders during the summer and fall, including suggestions that the agency consider certain changes to the timing of the plan’s compliance period so that the program could better succeed in affording states and utilities the intended flexibility. Thanks in part to this information, EPA issued a notice in late October presenting for public comment several ideas, including ways to ensure that states and utilities could develop their own “glide paths” for complying with their emissions reductions obligations while managing costs and further addressing reliability needs.

Over the years, we have heard critics claim that regulations to protect our health and the environment would cripple our economy, turn the lights out, or cause the sky to fall. Time after time, EPA has obeyed the law, followed the science, protected public health, and fortified a strong American economy. And over the past four decades, none of these doomsday predictions came true. In fact, just the opposite happened—we have been able to cut air pollution by nearly 70 percent, while our economy has tripled in size.

Thanks to this experience and to the rich record of public comments we are already turning to for ideas and information, we remain confident in the conclusion we reached when we proposed the Clean Power Plan in June: that the emissions reductions called for in what will be the Clean Power Plan will be able to be achieved while preserving a reliable and affordable supply of electricity for all Americans.