ACCCE Writes to PJM Responding to “Evolving Resource Mix and System Reliability” Study

Electricity grid operator PJM released a report entitled “PJM’s Evolving Resource Mix and System Reliability” that underscores the importance of reliability, resilience, and fuel diversity. We recently sent a letter endorsing PJM’s recommendation that criteria be established for evaluating grid resilience, which means being able to maintain a reliable electricity grid even during major disturbances that could happen, such as polar vortex conditions and gas pipeline disruptions.

Unfortunately, some have misinterpreted the report as endorsing an overreliance on a single fuel, natural gas, by assuming that all coal-fired and nuclear power plants in the PJM region retire. However, coal-fired generation plays a crucial role in PJM and other parts of the country by helping ensure grid reliability, grid resilience, and fuel diversity.

In order to develop sound criteria for evaluating grid resilience, we believe that a number of questions, such as the ones below, need to be answered:

1) Is the natural gas infrastructure system in PJM resilient enough to support an electricity grid that relies almost exclusively on natural gas-fired generation, especially under an assumption that all coal-fired and nuclear generation retires?

2) In evaluating resilience, what weight should be given to the advantages of the infrastructure system for coal-fired generation (85-day stockpile of coal onsite and long term fuel contracts) versus the natural gas infrastructure system (just-in time delivery of fuel and non-firm service)?

3) In terms of a path forward, what roles will PJM, FERC, and NERC play in developing resilience criteria that take into account potential disruptions such as polar vortex conditions, failure of a major natural gas storage field, rupture of a major gas pipeline, or other high impact, low frequency disturbances?

We plan to work with PJM to ensure that the electricity grid remains reliable and resilient and that PJM maintains a diverse mix of electricity sources.

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