PJM on January 21 submitted comments to the Environmental Protective Agency regarding the Federal Clean Power Plan. The EPA had asked regional transmission organizations and independent system operators to review the plan and develop questions and comments
In a separate filing, PJM also submitted joint comments with the CAISO, MISO and Southwest Power Pool. In addition, PJM-Environmental Information Services filed comments regarding the Generation Attribute Tracking System.
PJM offered recommendations on:
- Emission trading – tracking systems
- Requirement for power purchase agreements crediting resources across state lines
- Eligibility of new technologies to receive emission rate credits
- Timing of emission rate credit distribution
- Rate-based versus mass-based federal plans
In the joint comments, the RTOs recommended the following improvements to the federal plan:
- Requiring reliability reviews during the development of a federal plan
- Coordinating the timing and scope of the plan’s reliability reviews with reliability reviews of other relevant state plans or the federal plan (as practical)
- Including an appropriately structured reliability safety valve mechanism to address unanticipated immediate reliability impacts
The RTOs believe that these processes will mitigate the potential risk to the electric grid that could occur from the implementation of a federal plan.
PJM-EIS pointed out that the established Generator Attribute Tracking System, which converts megawatt-hours into renewable energy certificates, can play an important role in implementation of the Clean Power Plan