MAINTAINING A RELIABLE GRID UNDER EPA’S PROPOSED 111 RULES RESTRICTING

As the National Rural Electric Cooperative Association (NRECA) observes in its comments to the EPA, recent reliability assessments by the North American Electric Reliability Corporation (NERC) have “pointed to the disorderly retirement of traditional generation (with its inherent ability to provide [ERS] and balance energy reserves) as one of the biggest challenges facing the grid.”7 The rule has. [...] The 2022 Princeton study, “Cleaner, Faster, Cheaper—Impacts of the Inflation Reduction Act and a Blueprint for Rapid Decarbonization in the PJM Interconnection,” limits its geographic scope to the PJM Interconnection power market, assessing impacts of the IRA and other potential policies on this coal-heavy region.26 The study finds that the IRA paired with a market-wide GHG cap-and-trade policy wo. [...] RTOs recognize markets may need to be developed to ensure new and existing resources are adequately compensated and incented to provide ERS embedded in the existing coal fleet, meaning that utilities, RTOs, and NERC likely have more work to do to map out an orderly transition.50 The EPA designed the proposed rules to allow utilities and system operators the flexibility they need to maintain and en. [...] Currently in most parts of the country, when resources try to connect to the grid, the grid operator determines what grid upgrades are necessary to guarantee a certain level of access to the grid. [...] Most of these policies, from reforming interconnection processes and using new technologies to increase transmission capacity in the short term, to proactively planning the grid around the retirement of fossil plants that will continue under the proposed rules, are within the purview of grid operators and utilities.