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FERC Grid Resiliency Pricing Opposition underscores industry groups, RTOs, and ISOs rejecting DOE's NOPR, warning against out-of-market subsidies for coal and nuclear, favoring competitive markets, reliability, and true grid resilience.

Key Points

Coalition urging FERC to reject DOE's NOPR subsidies, protecting reliability and competitive power markets.

✅ Industry groups, RTOs, ISOs oppose DOE NOPR

✅ PJM reports sufficient reliability and resilience

✅ Reject out-of-market aid to coal, nuclear

A diverse group of a dozen energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies today submitted reply comments to the Federal Energy Regulatory Commission (FERC) continuing their opposition to the Department of Energy's (DOE) proposed rulemaking on grid resiliency pricing and electricity pricing changes within competitive markets, in the next step in this FERC proceeding.

Action by FERC, as lawmakers urge movement on aggregated DERs to modernize markets, is expected by December 11.

In these comments, this broad group of energy industry associations notes that most of the comments submitted initially by an unprecedented volume of filers, including grid operators whose markets would be impacted by the proposed rule, urged FERC not to adopt DOE'sproposed rule to provide out-of-market financial support to uneconomic coal and nuclear power plants in the wholesale electricity markets overseen by FERC.

Just a small set of interests - those that would benefit financially from discriminatory pricing that favors coal and nuclear plants - argued in favor of the rule put forward by DOE in its Notice of Proposed Rulemaking, or NOPR, as did coal and business interests in related regulatory debates. But even those interests - termed 'NOPR Beneficiaries' by the energy associations - failed to provide adequate justification for FERC to approve the rule, and their specific alternative proposals for implementing the bailout of these plants were just as flawed as the DOE plan, according to the energy industry associations.

'The joint comments filed today with partners across the energy spectrum reflect the overwhelming majority view that this proposed rulemaking by FERC is unprecedented and unwarranted, said Todd Foley, Senior Vice President, Policy & Government Affairs, American Council on Renewable Energy.

We're hopeful that FERC will rule against an anti-competitive distortion of the electricity marketplace and avoid new unnecessary initiatives that increase power prices for American consumers and businesses.'

In the new reply comments submitted in response to the initial comments filed by hundreds of stakeholders on or before October 23 - the energy industry associations made the following points: Despite hundreds of comments filed, no new information was brought forth to validate the assertion - by DOE or the NOPR Beneficiaries - that an emergency exists that requires accelerated action to prop up certain power plants that are failing in competitive electricity markets: 'The record in this proceeding, including the initial comments, does not support the discriminatory payments proposed' by DOE, state the industry groups.

Nearly all of the initial comments filed in the matter take issue with the DOE NOPR and its claim of imminent threats to the reliability and resilience of the electric power system, despite reports of coal and nuclear disruptions cited by some advocates: 'Of the hundreds of comments filed in response to the DOE NOPR, only a handful purported to provide substantive evidence in support of the proposal. In contrast, an overwhelming majority of initial comments agree that the DOE NOPR fails to substantiate its assertions of an immediate reliability or resiliency need related to the retirement of merchant coal-fired and nuclear generation.'

Grid operators filed comments refuting claims that the potential retirement of coal and nuclear plants which could not compete for economically present immediate or near-term challenges to grid management, even as a coal CEO criticism targeted federal decisions: 'Even the RTOs and ISOs themselves filed comments opposing the DOE NOPR, noting that the proposed cost-of-service payments to preferred generation would disrupt the competitive markets and are neither warranted nor justified.... Most notably, this includes PJM Interconnection, ... the RTO in which most of the units potentially eligible for payments under the DOE NOPR are located. PJM states that its region 'unquestionably is reliable, and its competitive markets have for years secured commitments from capacity resources that well exceed the target reserve margin established to meet [North American Electric Reliability Corp.] requirements.' And PJM analysis has confirmed that the region's generation portfolio is not only reliable, but also resilient.'

The need for NOPR Beneficiaries to offer alternative proposals reflects the weakness of DOE'srule as drafted, but their options for propping up uneconomic power plants are no better, practically or legally: 'Plans put forward by supporters of the power plant bailout 'acknowledge, at least implicitly, that the preferential payment structure proposed in the DOE NOPR is unclear, unworkable, or both. However, the alternatives offered by the NOPR Beneficiaries, are equally flawed both substantively and procedurally, extending well beyond the scope of the DOE NOPR.'

Citing one example, the energy groups note that the detailed plan put forward by utility FirstEnergy Service Co. would provide preferential payments far more costly than those now provided to individual power plants needed for immediate reasons (and given a 'reliability must run' contract, or RMR): 'Compensation provided under [FirstEnergy's proposal] would be significantly expanded beyond RMR precedent, going so far as to include bailing [a qualifying] unit out of debt based on an unsupported assertion that revenues are needed to ensure long-term operation.'

Calling the action FERC would be required to take in adopting the DOE proposal 'unprecedented,' the energy industry associations reiterate their opposition: 'While the undersigned support the goals of a reliable and resilient grid, adoption of ill-considered discriminatory payments contemplated in the DOE NOPR is not supportable - or even appropriate - from a legal or policy perspective.

About ACORE

The American Council on Renewable Energy (ACORE) is a national non-profit organization leading the transition to a renewable energy economy. With hundreds of member companies from across the spectrum of renewable energy technologies, consumers and investors, ACORE is uniquely positioned to promote the policies and financial structures essential to growth in the renewable energy sector. Our annual forums in Washington, D.C., New York and San Franciscoset the industry standard in providing important venues for key leaders to meet, discuss recent developments, and hear the latest from senior government officials and seasoned experts.

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Muskrat Falls rate mitigation progresses as Newfoundland and Labrador and Ottawa align under the updated Atlantic Accord, targeting affordable electricity rates through federal involvement, PUB input, and potential financing solutions with Nalcor, Emera, and lenders.

Key Points

An initiative by NL and Ottawa to keep electricity rates affordable via federal support, PUB input, and financing options.

✅ Federal-provincial talks under the updated Atlantic Accord

✅ PUB process integrated for independent oversight

✅ Possible roles for Nalcor, Emera, and project lenders

At the announcement of an updated Atlantic Accord between the provincial and federal governments, Newfoundland and Larbrador Premier Dwight Ball gave notice federal Finance Minister Bill Morneau will be in St. John’s to talk about the cost of Muskrat Falls and how Labrador power flows through Quebec to market.

“We look forward to welcoming Minister Morneau and his team to advance discussions on federal financing and rate mitigation,” read a statement from the premier’s office Tuesday, in response to questions about that coming meeting and federal-provincial work on rate mitigation.

At the announcement, Ball specifically said the plan is to “finalize federal involvement for making sure electricity rates remain affordable,” such as shielding ratepayers from overruns through federal-provincial measures, with Ball and MP Seamus O’Regan trumpeting the provincial-federal relationship.

The provincial and federal governments are not the only two parties involved in provincial power rates and handling of Muskrat Falls, even as electricity users have started paying for the project across Newfoundland and Labrador, but The Telegram is told details of meetings on rate mitigation are not being released, down to the list of attendees.

The premier’s office was asked specifically about the involvement of Nalcor Energy, including a recent financial update during the pandemic, Emera, Goldman, TD or any others involved in project financing. The response was that the plan is not to indicate what is being explored and who might be involved, until there is something more concrete to speak about.

The government’s plan is to have something to feed into the ongoing work of the Public Utilities Board, to develop a more complete response for rate mitigation, including lump-sum credits on electricity bills and other tools, for the PUB’s final report, due in 2020, even as regulators in Nova Scotia weigh a 14% rate hike in a separate proceeding.

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Ottawa Sewage Energy Exchange System uses wastewater heat recovery and efficient heat pumps to deliver renewable district energy, zero carbon heating and cooling, cutting greenhouse gas emissions at LeBreton Flats and scaling urban developments.

Key Points

A district energy system recovering wastewater heat via pumps to deliver zero carbon heating and cooling.

✅ Delivers 9 MW heating and cooling for 2.4M sq ft at LeBreton Flats

✅ Cuts 5,066 tonnes CO2e each year, reducing greenhouse gases

✅ Powers Odenak zero carbon housing via district energy

Ottawa is embarking on a groundbreaking initiative to harness the latent thermal energy within its wastewater system, in tandem with advances in energy storage in Ontario that strengthen grid resilience, marking a significant stride toward sustainable urban development. The Sewage Energy Exchange System (SEES) project, a collaborative effort led by the LeBreton Community Utility Partnership—which includes Envari Holding Inc. (a subsidiary of Hydro Ottawa) and Theia Partners—aims to revolutionize how the city powers its buildings.

Harnessing Wastewater for Sustainable Energy

The SEES will utilize advanced heat pump technology to extract thermal energy from the city's wastewater infrastructure, providing both heating and cooling to buildings within the LeBreton Flats redevelopment. This innovative approach eliminates the need for fossil fuels, aligning with Ottawa's commitment to reducing greenhouse gas emissions and promoting clean energy solutions across the province, including the Hydrogen Innovation Fund that supports new low-carbon pathways.

The system operates by diverting sewage from the municipal collection network into an external well, where it undergoes filtration to remove large solids. The filtered water is then passed through a heat exchanger, transferring thermal energy to the building's heating and cooling systems. After the energy is extracted, the treated water is safely returned to the city's sewer system.

Environmental and Economic Impact

Once fully implemented, the SEES is projected to deliver over 9 megawatts of heating and cooling capacity, servicing approximately 2.4 million square feet of development. This capacity is expected to reduce greenhouse gas emissions by approximately 5,066 tonnes annually—equivalent to the electricity consumption of over 3,300 homes for a year. Such reductions are pivotal in helping Ottawa meet its ambitious goal of achieving a 96% reduction in community-wide greenhouse gas emissions by 2040, as outlined in its Climate Change Master Plan and Energy Evolution strategy, and they align with Ontario's plan to rely on battery storage to meet rising demand across the grid.

Integration with the Odenak Development

The first phase of the SEES will support the Odenak development, a mixed-use project comprising two high-rise residential buildings. This development is poised to be Canada's largest residential zero-carbon project, echoing calls for Northern Ontario grid sustainability from community groups, featuring 601 housing units, with 41% designated as affordable housing. The integration of the SEES will ensure that Odenak operates entirely on renewable energy, setting a benchmark for future urban developments.

Broader Implications and Future Expansion

The SEES project is not just a localized initiative; it represents a scalable model for sustainable urban energy solutions that aligns with green energy investments in British Columbia and other jurisdictions. The LeBreton Community Utility Partnership is in discussions with the National Capital Commission to explore extending the SEES network to additional parcels within the LeBreton Flats redevelopment. Expanding the system could lead to economies of scale, further reducing costs and enhancing the environmental benefits.

Ottawa's venture into wastewater-based energy systems places it at the forefront of a growing trend in North America. Cities like Toronto and Vancouver have initiated similar projects, while related pilots such as the EV-to-grid pilot in Nova Scotia highlight complementary approaches, and European counterparts have long utilized sewage heat recovery systems. Ottawa's adoption of this technology underscores its commitment to innovation and sustainability in urban planning.

The SEES project at LeBreton Flats exemplifies how cities can repurpose existing infrastructure to create sustainable, low-carbon energy solutions. By transforming wastewater into a valuable energy resource, Ottawa is setting a precedent for environmentally responsible urban development. As the city moves forward with this initiative, it not only addresses immediate energy needs but also contributes to a cleaner, more sustainable future for its residents, even as the province accelerates Ontario's energy storage push to maintain reliability.

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California Renewable Energy Curtailment highlights grid congestion, midday solar peaks, limited battery storage, and market constraints, with WEIM participation and demand response programs proposed to balance supply-demand and reduce wasted solar and wind generation.

Key Points

It is the deliberate reduction of solar and wind output when grid limits or low demand prevent full integration.

✅ Grid congestion restricts transmission capacity

✅ Midday solar peaks exceed demand, causing surplus

✅ Storage, WEIM, and demand response mitigate curtailment

California has long been a leader in renewable energy adoption, achieving a near-100% renewable milestone in recent years, particularly in solar and wind power. However, as the state continues to expand its renewable energy capacity, it faces a growing challenge: the curtailment of excess solar and wind energy. Curtailment refers to the deliberate reduction of power output from renewable sources when the supply exceeds demand or when the grid cannot accommodate the additional electricity.

Increasing Curtailment Trends

Recent data from the U.S. Energy Information Administration (EIA) highlights a concerning upward trend in curtailments in California. In 2024, the state curtailed a total of 3,102 gigawatt-hours (GWh) of electricity generated from solar and wind sources, surpassing the 2023 total of 2,660 GWh. This represents a 32.4% increase from the previous year. Specifically, 2,892 GWh were from solar, and 210 GWh were from wind, marking increases of 31.2% and 51.1%, respectively, compared to the first nine months of 2023.

Causes of Increased Curtailment

Several factors contribute to the rising levels of curtailment:

1. Grid Congestion: California's transmission infrastructure has struggled to keep pace with the rapid growth of renewable energy sources. This congestion limits the ability to transport electricity from generation sites to demand centers, leading to curtailment.
   
   

2. Midday Solar Peaks: Amid California's solar boom, solar energy production typically peaks during the midday when electricity demand is lower. This mismatch between supply and demand results in excess energy that cannot be utilized, necessitating curtailment.
   
   

3. Limited Energy Storage: While battery storage technologies are advancing, California's current storage capacity is insufficient to absorb and store excess renewable energy for later use. This limitation exacerbates curtailment issues.
   
   

4. Regulatory and Market Constraints: Existing market structures and regulatory frameworks may not fully accommodate the rapid influx of renewable energy, leading to inefficiencies and increased curtailment.

Economic and Environmental Implications

Curtailment has significant economic and environmental consequences. For renewable energy producers, curtailed energy represents lost revenue and undermines the economic viability of new projects. Environmentally, curtailment means that clean, renewable energy is wasted, and the grid may rely more heavily on fossil fuels to meet demand, counteracting the benefits of renewable energy adoption.

Mitigation Strategies

To address the rising curtailment levels, California is exploring several strategies aligned with broader decarbonization goals across the U.S.:

• Grid Modernization: Investing in and upgrading transmission infrastructure to alleviate congestion and improve the integration of renewable energy sources.
  
  

• Energy Storage Expansion: Increasing the deployment of battery storage systems to store excess energy during peak production times and release it during periods of high demand.
  
  

• Market Reforms: Participating in the Western Energy Imbalance Market (WEIM), a real-time energy market that allows for the balancing of supply and demand across a broader region, helping to reduce curtailment.
  
  

• Demand Response Programs: Implementing programs that encourage consumers to adjust their energy usage patterns, such as shifting electricity use to times when renewable energy is abundant.

Looking Ahead

As California continues to expand its renewable energy capacity, addressing curtailment will be crucial to ensuring the effectiveness and sustainability of its energy transition. By investing in grid infrastructure, energy storage, and market reforms, the state can reduce curtailment levels and make better use of its renewable energy resources, while managing challenges like wildfire smoke impacts on solar output. These efforts will not only enhance the economic viability of renewable energy projects but also contribute to California's 100% clean energy targets by maximizing the use of clean energy and reducing reliance on fossil fuels.

While California's renewable energy sector faces challenges related to curtailment, proactive measures and strategic investments can mitigate these issues, as scientists continue to improve solar and wind power through innovation, paving the way for a more sustainable and efficient energy future.

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Ontario TOU Electricity Rate Relief offers 24/7 fixed off-peak pricing at 10.1¢/kWh, suspending time-of-use tiers to support residential customers, small businesses, and farms, coordinated by the Ontario Energy Board during COVID-19.

Key Points

A 45-day policy fixing TOU power at 10.1¢/kWh 24/7 off-peak to ease costs for residents, small businesses, and farms.

✅ Applies 24/7 off-peak 10.1¢/kWh to all TOU electricity customers.

✅ Automatic bill credit; no application or enrollment required.

✅ Covers residential, small businesses, and farms; OEB coordination.

To support Ontarians through the rapidly evolving COVID-19 situation, the Government of Ontario is providing immediate electricity rate relief for families, small businesses and farms paying time-of-use (TOU) rates.

For a 45-day period, the government is working to suspend time-of-use electricity rates, holding electricity prices to the off-peak rate of 10.1 cents-per-kilowatt-hour. This reduced price will be available 24 hours per day, seven days a week to all time-of-use customers, who make up the majority of electricity consumers in the province. By switching to a fixed off-peak rate, time-of-use customers will see rate reductions of over 50 per cent compared to on-peak rates now in effect.

To deliver savings as quickly and conveniently as possible, this discount will be applied automatically to electricity bills without the need for customers to fill out an application form.

"During this unprecedented time, we are providing much-needed relief to Ontarians, specifically helping those who are doing the right thing by staying home and small businesses that have closed or are seeing fewer customers," said Premier Doug Ford. "By adopting a fixed, 24/7 off-peak rate, aligned with ultra-low overnight pricing options, we are making things a little easier during these difficult times and putting more money in people's pockets for other important priorities and necessities."

The Government of Ontario issued an Emergency Order under the Emergency Management and Civil Protection Act to apply the off-peak TOU electricity rate for residential, small businesses, and farm customers who currently pay TOU rates.

"Ontario is fortunate to have a strong electricity system we can rely on during these exceptional times, even as Ottawa's electricity consumption decreased during the pandemic, and our government is proud to provide additional relief to Ontarians who are doing their part to stay home," said Greg Rickford, Minister of Energy, Northern Development and Mines.

"We thank the Ontario Energy Board and our partners at local distribution companies across the province, including initiatives like Hydro One's Ultra-Low Overnight Price Plan that support customers, for taking quick action to make this change and provide immediate support for hardworking people of Ontario," said Bill Walker, Associate Minister of Energy.

Visit Ontario's website to learn more about how the province continues to protect Ontarians from COVID-19.

Quick Facts

• The Ontario Energy Board sets time-of-use electricity rates for residential and small business customers through the Regulated Price Plan, and provides stable electricity pricing for industrial and commercial companies through separate programs.
• Time-of-use prices as of November, 2019 ― Off-Peak: 10.1₵/kWh, Mid-Peak: 14.4₵/kWh, On-Peak: 20.8₵/kWh
• Depending on billing cycles, some customers will see these changes on their next electricity bill. TOU customers whose billing cycle ended before their local distribution company implemented this change will receive the reduced rate as a credit on a future bill.
• The Ontario Electricity Rebate (OER) will continue to provide a 31.8 per cent rebate on the sub-total bill amount for all existing Regulated Price Plan (RPP) consumers.
• There are approximately five million residential consumers, farms and some small businesses billed using time-of-use (TOU) electricity prices under the RPP.
• The Ontario Energy Board has extended the winter ban on disconnections to July 31st.

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Canada 2035 Gasoline Car Ban accelerates EV adoption, zero-emission transport, and climate action, with charging infrastructure, rebates, and industry investment supporting net-zero goals while addressing affordability, range anxiety, and consumer acceptance nationwide.

Key Points

A federal policy to end new gas car sales by 2035, boosting EV adoption, emissions goals, and charging infrastructure.

✅ Ends new gas car and light-truck sales by 2035

✅ Expands charging infrastructure and grid readiness

✅ Incentives, rebates, and industry investment drive adoption

Canada has set its sights on a bold and transformative goal: to ban the sale of new gasoline-powered passenger cars and light-duty trucks by the year 2035. This ambitious target, announced by the federal government, underscores Canada's commitment to combating climate change and accelerating the adoption of electric vehicles (EVs) nationwide, supported by forthcoming EV sales regulations from Ottawa.

The Federal Initiative

Under the leadership of Prime Minister Justin Trudeau, Canada aims to significantly reduce greenhouse gas emissions from the transportation sector, which accounts for a substantial portion of the country's carbon footprint. The initiative aligns with Canada's broader climate objectives, including achieving net-zero emissions by 2050.

Driving Forces Behind the Decision

The decision to phase out internal combustion engine vehicles reflects growing recognition of the urgency to transition towards cleaner transportation alternatives, even as 2019 electricity from fossil fuels still powered a notable share of Canada's grid. Minister of Environment and Climate Change Jonathan Wilkinson emphasizes the environmental benefits of electric vehicles, citing their potential to lower emissions and improve air quality in urban centers across the country.

Challenges and Opportunities

While the move towards electric vehicles presents promising opportunities for reducing emissions, it also poses challenges. Key considerations include infrastructure development, affordability, and consumer acceptance of EV technology, amid EV shortages and wait times that can influence buying decisions. Addressing these hurdles will require coordinated efforts from government, industry stakeholders, and consumers alike.

Industry Response

The automotive industry plays a crucial role in realizing Canada's EV ambitions. Automakers are increasingly investing in electric vehicle production and innovation to meet evolving consumer demand and regulatory requirements, including cross-border Canada-U.S. collaboration on supply chains. The transition offers opportunities for job creation, technological advancement, and economic growth in the clean energy sector.

Provincial Perspectives

Provinces across Canada are pivotal in facilitating the transition to electric vehicles. Some provinces have already implemented incentives such as rebates for EV purchases, charging infrastructure investments, and policy frameworks to support emissions reduction targets, even as Quebec's EV dominance push faces scrutiny from experts. Collaborative efforts between federal and provincial governments are essential in ensuring a cohesive approach to achieving national EV goals.

Consumer Considerations

For consumers, the shift towards electric vehicles represents a paradigm shift in transportation choices. Factors such as range anxiety, charging infrastructure availability, and upfront costs, with one EV cost survey citing price as the main barrier, remain considerations for prospective buyers. Government incentives and subsidies aim to alleviate some of these concerns and promote widespread EV adoption.

Looking Ahead

As Canada navigates towards a future without gasoline-powered vehicles, stakeholders must work together to overcome challenges and capitalize on opportunities presented by the electric vehicle revolution, even as critics of the 2035 mandate question its feasibility. Continued investments in infrastructure, innovation, and consumer education will be critical in paving the way for a sustainable and prosperous automotive industry.

Conclusion

Canada's commitment to phasing out gasoline-powered vehicles by 2035 marks a pivotal moment in the country's climate action agenda. By embracing electric vehicles, Canada aims to lead by example in combatting climate change, fostering innovation, and building a greener future for generations to come. The success of this ambitious initiative hinges on collective efforts to transform the automotive landscape and accelerate towards a sustainable transportation future.

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