Opponents of the Environmental Protection Agency’s recent “Good Neighbor” Plan claim that these important standards for so-called wandering ozone could destabilize the electric power system by, for instance, retiring coal-fired plants too soon. The rule does no such thing, according to some of the nation’s leading engineers and analysts with expertise in the operation, structure, economics, regulation, and reliability of the U.S. power system. 

Frank G. Wells Environmental Law Clinic Co-Directors Cara Horowitz and Julia Stein and Shapiro Fellow Ruthie Lazenby submitted an amicus brief on behalf of these grid experts in the consolidated cases involving petitions to review the EPA’s final “Good Neighbor” Plan for the 2015 Ozone National Ambient Air Quality Standards. The case is before the U.S. Court of Appeals for the D.C. Circuit.

“The record supports EPA’s well-founded conclusion that the Plan poses no material risk to electric system reliability, as grid operators and regulators continue to prioritize resilient distribution and transmission alongside operational reliability and load balancing,” the brief states. 

This brief is on behalf of Benjamin F. Hobbs, Brendan Kirby, Kenneth J. Lutz, and Susan F. Tierney, who are among the nation’s leading engineers and analysts with expertise in the operation, structure, economics, regulation, and reliability of the U.S. power system. The brief aims to aid the Court’s understanding of the highly technical matters at issue as well as how and why the grids are designed as they are and how they are being impacted by the energy transition. 

Download the brief.