ARTICLE
23 February 2015

The Impact Of The Clean Power Plan On Reliability: Now We Have Dueling Assessments

FH
Foley Hoag LLP

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In November, the North American Electric Reliability Corporation provided its " Initial Reliability Review" of EPA's Clean Power Plan.
United States Energy and Natural Resources

In November, the North American Electric Reliability Corporation provided its " Initial Reliability Review" of EPA's Clean Power Plan.  NERC raised a number of concerns about the impact of the CPP on reliability.

Now the Advanced Energy Economy Institute – you can guess its perspective – has engaged the Brattle Group to provide an assessment of NERC's IRR.  Not surprisingly, the Brattle Group is more sanguine about EPA's ability to implement the CPP without adversely impacting reliability.

I am not an expert in electric system reliability.  I will say only this – the historical record of environmental regulation since 1970 is replete with incorrect predictions of doom about the impact of environmental regulation.  Time after time, EPA's large regulatory programs have been implemented at lower cost and with fewer problems than were predicted in advance.

Why?

Because markets do work.  Once the regulations are really in effect, creative people will start figuring out ways to comply that are cheaper and more efficient than the static analyses performed prior to promulgation could ever have imagined.

(Sure hope that the same holds true this time around.)

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