FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE SCOPE OF THE RTO ENVIRONMENTAL ASSESSMENT
COMPETITION HAS DEMONSTRATED ENVIRONMENTAL BENEFITS
Over the past two decades, powerful market incentives for innovative technologies and practices have allowed competitive power suppliers to generate electricity more cheaply, efficiently and cleanly than ever before. As a direct result of these incentives, such suppliers have led a dramatic trend toward the improved environmental performance of the nation's installed generating capacity.
Specifically, competitive suppliers have succeeded in generating electricity more efficiently while meeting or exceeding federal and state environmental standards. They have employed innovative practices and advanced combustion technologies, including clean coal gasification, advanced solid fuel boilers (such as circulating fluidized bed combustors), high-efficiency, gas-fired combined cycle systems, low water-consuming cooling equipment, and advanced emission-reduction technologies and strategies. In addition, market competition has created efficiency incentives for cogeneration, which serves the energy needs of plants' industrial or commercial hosts. Market incentives have also allowed competitive suppliers to respond to market demand for renewable power, thus reducing the overall environmental impact of meeting the nation's electricity needs. The NOPR may actually provide greater support for renewables, which are relatively remotely located and site-limited, by eliminating pancaked rates and reducing their disproportionately high transmission costs.
In short, it is the success of competitive suppliers in producing power more efficiently-while meeting newer, much more stringent environmental standards-that has given momentum to the restructuring of U.S. electricity markets. Even indirect impacts of the proposed rulemaking on generation would, accordingly, be environmentally beneficial, as RTOs will simply reinforce the efficient functioning of the increasingly competitive electricity market.