NMA said, "Five alarming facts have emerged from this new information that compel EPA to reconsider and stay the rule" [as follows]:
- EPA failed to consider the cumulative impact of its power sector regulations on grid reliability, as recommended by Federal Energy Regulatory Commission (FERC) staff. Even after FERC staff estimated possible retirement of as much as 40 percent of the entire coal-based generation fleet, EPA did not pursue a rigorous analysis of reliability impacts;
- EPA incorrectly assumed power can be transmitted freely within broad geographic regions of the countrydiscounting cautions raised by FERC, Regional Transmission Organizations (RTO) and Independent System Operators (ISO);
- FERC has only provided "preliminary" and "tentative" analysis to EPA that is "inadequate to use as a basis for decision making," according to FERC Chairman Jon Wellinghoff and contrary to EPA's assertions;
- FERC staff have questioned whether the compliance deadlines set forth in EPA's regulations were too expedited to allow utilities sufficient lead-time to replace retiring resources -- raising additional reliability concerns; and
- EPA disclosed none of the consultations that occurred with FERC or other agencies responsible for grid reliability, nor is there a public record of those consultations, contrary to EPA's assertion it would operate in a "fishbowl" and in violation of EPA's rulemaking responsibilities.
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