Grid operators sound alarm over EPA’s carbon power plant rules

A recent post by Energy Bad Boys Isaac Orr and Mitch Rolling, formerly of American Experiment, shared a piece of good news. Four Regional Transmission Organizations (RTOs), including MISO, filed an amicus brief last month to challenge the Environmental Protection Agency’s new rules regarding CO2 emissions from existing coal and new natural gas power plants.

The four RTOs filing the “friend of the court” brief — MISO, PJM, SPP, and ERCOT — serve 156 million customers together and are responsible for maintaining the safety and reliability of the grid.

From Orr and Rolling’s Substack post:

This move by the four RTOs is unprecedented. After reaching out to several regulatory attorneys, we were told they were not aware of any previous incidents of RTOs filing an Amicus Brief asking for the court to remand the regulations back to the agency, highlighting how worried the grid operators are about what they consider to be overly vague and unworkable rules.

The brief describes the “chilling impact” of the EPA’s reliability and resource adequacy rules:

EPA’s failure to address Amici’s proposed mitigation measures is exacerbated by the impact the Final Rule will have when analyzed in conjunction with the numerous other proposed, pending, or existing EPA regulations that impact grid reliability and resource adequacy—all of which are resulting in a decline in reserve margins and premature retirement of dispatchable “baseload” resources. Amici are also concerned about the chilling impact these collective rules will have on the investment required to retain and maintain existing generation units that are needed to provide key reliability attributes and grid services before the Final Rule’s compliance date.

American Experiment’s modeling on the proposed EPA rule projected rolling blackouts in the Midwest and compliance costs of $246 billion through 2055. EPA’s modeling used unrealistically high capacity factors for wind, solar, and battery and thermal resources and failed to evaluate reliability at all.

The RTOs’ “unprecedented” step to push back on this rule is a result of EPA’s unprecedented negative impact on resource adequacy and reliability.