E²SHI Director Among Grid Experts Filing Support for EPA’s Clean Power Plan

The U.S. EPA’s new Clean Power Plan aims to regulate carbon dioxide emissions from existing fossil-fuel-fired electric generating units under the Clean Air Act. The agency faces several litigations over the plan. However, a wide range of groups have filed support of the U.S. EPA for the plan to reduce greenhouse gases from the power sector, including technology companies, a handful of utilities, and grid experts. Among the grid experts is Ben Hobbs, E²SHI Director.

On April 1, 2016, a team at the UCLA Law School’s Emmett Institute on Climate Change and the Environment filed an amici curiae (or friend of the court) brief on behalf of five electric grid experts in support of the Clean Power Plan. The brief argues that the Clean Power Plan respects and effectively harnesses the unique features of the electric grid and is consistent with the twin aims of the grid: power reliability and affordability for all consumers. In particular, the brief seeks to aid the D.C. Circuit Court in understanding the unique physical features of electricity and the electric grid, and the relevance of those features to the Clean Power Plan.

The grid experts who participated in the brief include: Dr. Benjamin F. Hobbs (Johns Hopkins), Brendan Kirby, P.E. (Electric Power System Consulting), Professor Kenneth J. Lutz (Univ. Delaware/AMR Strategies), Dr. James D. McCalley (Iowa State Univ.), and Brian Parsons (Western Grid Group/NREL ret.).

The brief emphasizes two key points:

1. Shifting generation among various sources is characteristic of routine grid operations, and is a long-used method to reduce harmful emissions. All grid operators use the basic principles of “Constrained Least-Cost Dispatch” - utilizing the lowest-cost generators first, unless operational needs take precedence - to balance supply and demand. All power-sector environmental regulations affect the relative costs of different generators, just as changing fuel prices, generator efficiency, and other variables do; consequently, all power-sector environmental regulations result in relatively greater use of some generators than others. While the [Clean Power Plan] may alter the relative costs of various generators, it does not change the framework that has long guided grid operations. The Rule will integrate seamlessly into existing Constrained Least-Cost Dispatch processes with no adverse reliability impacts.

2. Shifting from higher-emitting to lower-emitting generation is a well-demonstrated, cost-effective method to reduce CO2 emissions. EPA recognized this in determining that the “best system of emission reduction” … for power-sector CO2 includes reducing coal generation and increasing natural gas and renewable energy generation…. Because all generators deliver undifferentiated power to a regional grid that operates as a single machine, it would make no sense for the Rule to consider only CO2 emissions reductions that could be achieved through technologies installed within the ephemeral boundaries of individual facilities.

Read a summary of the Amicus Brief 

Read the Amicus Brief filed with the D.C. Circuit Court 

A wind farm in Brazos, Texas. 

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— Thomas Fuller, Gnomologia, 1732