PJM Presents Grid Operator Recommendations for Proposed Greenhouse Gas Rule


PJM outlined concerns and recommendations related to potential reliability impacts of EPA’s proposed greenhouse gas rule at the FERC 2023 Annual Reliability Technical Conference.

PJM’s perspective presented at the Nov. 9 technical conference echoed the combined work of PJM, MISO, ERCOT and SPP in joint comments (PDF) submitted in August on EPA’s New Source Performance Standards for Greenhouse Gas Emissions.

“Through the accelerating shift to renewable resources, maintaining an adequate level of generation resources with operational and physical characteristics that support reliability will be crucial for PJM’s ability to reliably serve electrical demand,” Michael Bryson, Sr. Vice President – Operations, said. “Certain revisions to the Rule, if adopted, would help to mitigate, although not eliminate, our reliability concerns.”

In his submitted statement, Bryson cited PJM’s report Energy Transition in PJM: Resource Retirements, Replacements & Risks (PDF) in discussing trends affecting resource adequacy ahead into 2030:

  • Sustained demand growth
  • Sustained thermal generator retirements
  • Policy-driven generation retirements before replacements become available
  • Requirements for multiple megawatts of new resources to replace retiring generation

Should the EPA rule go forward, PJM and the joint grid operators propose additional actions to ease reliability impacts:

  • Undertake additional reliability analysis reflecting supply chain constraints, siting and permitting expense and timelines, infrastructure expansion and maintenance.
  • Create a subcategory within the Rule that RTOs/ISOs could populate with specific units (or megawatt amounts) that they project will be needed to maintain reliability but otherwise would become unavailable, in whole or in part, by the Proposed Rule.
  • Establish a “regulatory check-in” that would allow for EPA, with industry input, to re-examine whether there are technology implementation barriers that call into question the original compliance deadlines in the Rule.
  • Provide clear guidance to states and stakeholders that would allow for the development of a robust interstate allowance trading market that would provide additional compliance flexibility.

In addition to the two sessions focused on the proposed EPA rule, the FERC conference also covered the agility of the rapidly shifting power generation mix as the grid undergoes significant change and evolving grid cybersecurity needs.