APPA CEO Calls on FERC to Shape Final EPA Carbon Rule

February 19, 2015

Press Release

Washington, D.C., February 19, 2015 – American Public Power Association President and CEO Sue Kelly today called for the Federal Energy Regulatory Commission to take several actions to keep energy costs down, maintain reliability, and limit overreliance on natural gas in the face of the Environmental Protection Agency’s proposed rule to limit CO2. Kelly’s comments came before FERC at its national overview Technical Conference on the EPA’s Clean Power Plan.

Specifically, APPA recommends that FERC take the following actions prior to and/or after the issuance of EPA’s final rule:

  • Support the North American Electric Reliability Corporation’s ongoing analysis of EPA’s proposal and any recommendations that NERC may offer in its report, which is due this spring.
  • Support the inclusion of a “reliability safety valve” in the final rule.
  • Support APPA’s recommendations to EPA (echoed by many states and other stakeholders) for changes to the proposal to give states more time and more discretion in implementing the final rule.
  • Continue to seek improvements and efficiencies in coordination between the natural gas and electricity sectors.
  • Expedite approvals for new infrastructure necessary to implement the final rule.
  • Review RTO market structures, rules, and operations to retain the features that support and facilitate implementation of the final rule and to modify those features that impede economical and reliable implementation.
  • Provide guidance to the states and other stakeholders on how to reflect public policy requirements associated with state implementation of the final rule in the regional and interregional transmission planning required by Order No. 1000.

A complete copy of Kelly’s testimony is available at

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