Summary: The Electric Power Supply Association sent a letter to the U.S. House of Representatives Committee on Energy and Commerce Subcommittee on Environment, Manufacturing, & Critical Materials to discuss the impacts to power system reliability stemming from the U.S. Environmental Protection Agency’s (EPA) proposed rulemaking further limiting carbon emissions from new and existing natural gas and coal power plants under Section 111 of the Clean Air Act (“proposed 111 rule”). The letter voices concern that aspirational policy goals are ahead of the operational realities of what electric grids require to meet reliability needs.
Date Submitted: November 28, 2023
EPSA members support both the nation’s clean energy expansion and electric grid reliability, and reject the narrative that climate goals can only be achieved by retiring or restricting existing fossil generation.
- Dispatchable, flexible, ramping resources – which are vital to electric grid reliability – are retiring too quickly and are not being replaced by capacity with similar attributes (or not being replaced at all).
- Public policy should work to both retain our current flexible capacity assets and encourage investment in new resources, both renewable and dispatchable, to meet our future energy needs.
The keystone of the proposed 111 Rule is technology that is neither widespread nor commercially available, and would require historic investment in infrastructure to achieve.
- The proposed 111 rule relies heavily on the ability of certain generation owners to invest in either carbon capture and sequestration (CCS) or hydrogen cofiring technologies to limit carbon emissions.
- Successful implementation of the proposed 111 rule is inseparably tied to the ability of United States asset owners to retrofit a large number of the nation’s power plants, and successfully site and permit thousands of miles of pipelines and storage caverns to support the necessary investment in carbon capture and hydrogen cofiring infrastructure within the timeline established in the proposed rule.
- If the EPA finalizes the proposed 111 rule as written, insisting that CCS and hydrogen cofiring are “adequately demonstrated,” many generation owners will be forced to choose between retiring interconnected, operational facilities that are flexible and can ramp output to match power demands, or proactively limiting their runtime to avoid being exposed to any final rule. Either way, the likely result, particularly during a time of steadily increasing demand for electricity, is an electric grid that is less reliable, more expensive, and ultimately emits at a higher level – the exact opposite outcome EPA aims to deliver.
Siting and permitting are only part of the challenges to deploying a nationwide, commercial scale carbon capture or hydrogen regime.
- The development of a nascent industry like CCS or hydrogen cofiring requires an adequate supply chain of physical materials. This supply chain does not exist today.
- Further, a skilled, trained workforce must be developed and available during periods when generators prepare for scheduled outages (typically during shoulder seasons in the Spring and Fall).
View letter here.