The Federal Energy Regulatory Commission (FERC) sent a four-page letter to the U.S. Environmental Protection Agency (EPA) suggesting that the EPA include an electricity “reliability safety valve” in its final Clean Power Plan rules. FERC argues that such a safety mechanism could help resolve conflicts in complying with both Clean Power Plan rules and FERC standards for electric reliability. In the letter, FERC suggests that greater flexibility is needed in the early years of the plan in order to modify compliance obligations “when unforeseen delays in implementation efforts could otherwise risk harm to reliability” (see our May 8, 2015 blog post for more on this). Additionally, FERC recommends a process in which either FERC or the North American Electric Reliability Corp. reviews states' plans for CPP compliance to look for reliability risks. To read the full letter, click here.