MAINTAINING A RELIABLE GRID UNDER EPA’S PROPOSED 111 RULES RESTRICTING POWER PLANT EMISSIONS

The report asserts that the EPA's proposed rules for coal and gas power plants are technically feasible and will not threaten resource adequacy or operational reliability. It synthesizes six industry-standard studies showing that the U.S. grid can remain stable even if all unabated coal is retired by 2035. The authors argue that reliability risks are institutional rather than technical, stemming from slow interconnection processes and inadequate transmission planning. To manage the transition, the report recommends adopting 'connect-and-manage' interconnection processes, deploying grid-enhancing technologies, and proactively planning transmission for coal retirements.

• Six industry-standard studies indicate that the U.S. electricity system can maintain resource adequacy even if all unabated coal generation is retired by 2035, while operating existing gas plants at or below current average capacity factors.
• The proposed rules for existing natural gas plants are unlikely to cause widespread retirements because many plants already operate below the 50 percent capacity factor threshold that triggers emissions reductions.
• Essential reliability services (ERS) provided by retiring fossil plants can be replaced by a variety of resources, including coal plants retrofitted as synchronous condensers, new gas-fired peakers, nuclear, hydro, and inverter-based resources (IBRs) like wind, solar, and battery storage.
• Inverter-based resources (IBRs) can provide frequency responses faster than synchronous generators and can offer 'synthetic inertia' through programmable inverters.
• The primary risk to grid reliability is institutional rather than technical, specifically the inability of grid operators and utilities to bring new resources online fast enough to replace retiring fossil assets due to interconnection and transmission bottlenecks.
• To accelerate clean energy deployment, the report recommends that RTOs adopt a 'connect-and-manage' interconnection approach, similar to the model used in Texas, where developers accept curtailment risks to avoid paying for all necessary grid upgrades upfront.
• Grid-enhancing technologies (GETs), such as dynamic line ratings and power flow controllers, could potentially double the capacity to add renewable energy on existing transmission lines.
• Twenty-five large U.S. utilities, representing approximately 19 percent of U.S. electricity demand and 21 percent of operating coal capacity, already have plans to be coal-free by 2035 or sooner.

APA

O’BOYLE, M., ESPOSITO, D., SOLOMON, M., & PIERPONT, B. (2023). MAINTAINING A RELIABLE GRID UNDER EPA’S PROPOSED 111 RULES RESTRICTING POWER PLANT EMISSIONS. Energy Innovation. https://energyinnovation.org/wp-content/uploads/Maintaining-a-Reliable-Grid-Under-EPAs-Proposed-111-Rules.pdf

Chicago

O’BOYLE, MIKE, DAN ESPOSITO, MICHELLE SOLOMON, and BRENDAN PIERPONT. MAINTAINING A RELIABLE GRID UNDER EPA’S PROPOSED 111 RULES RESTRICTING POWER PLANT EMISSIONS. Energy Innovation, 2023. https://energyinnovation.org/wp-content/uploads/Maintaining-a-Reliable-Grid-Under-EPAs-Proposed-111-Rules.pdf.

Wikipedia

{{cite report |last1=O’BOYLE |first1=MIKE |last2=ESPOSITO |first2=DAN |last3=SOLOMON |first3=MICHELLE |last4=PIERPONT |first4=BRENDAN |title=MAINTAINING A RELIABLE GRID UNDER EPA’S PROPOSED 111 RULES RESTRICTING POWER PLANT EMISSIONS |publisher=Energy Innovation |date=November 2023 |url=https://energyinnovation.org/wp-content/uploads/Maintaining-a-Reliable-Grid-Under-EPAs-Proposed-111-Rules.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{oboyle2023maintaining, author = {O’BOYLE, MIKE and ESPOSITO, DAN and SOLOMON, MICHELLE and PIERPONT, BRENDAN}, title = {{MAINTAINING A RELIABLE GRID UNDER EPA’S PROPOSED 111 RULES RESTRICTING POWER PLANT EMISSIONS}}, institution = {Energy Innovation}, year = {2023}, month = nov, url = {https://energyinnovation.org/wp-content/uploads/Maintaining-a-Reliable-Grid-Under-EPAs-Proposed-111-Rules.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }