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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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Hydropower Covid-19 Resilience highlights clean, reliable energy and flexible grid services, with pumped storage, automation, and affordability supporting climate action, decarbonization, and recovery through sustainable infrastructure, policy incentives, and capacity upgrades.

Key Points

Hydropower Covid-19 Resilience is the sector's ability to ensure clean, reliable, flexible power during crises.

✅ Record 4,306 TWh in 2019, avoiding 80-100 Mt CO2e emissions.

✅ 1,308 GW installed; 15.6 GW added; flexibility and storage in demand.

✅ Policy, tax incentives, and fast-track approvals to spur projects.

The Covid-19 pandemic has underlined hydropower's resilience and critical role in delivering clean, reliable and affordable energy, especially in times of crisis, as highlighted by IAEA lessons for low-carbon electricity. This is the conclusion of two new reports published by the International Hydropower Association (IHA).

The 2020 Hydropower Status Report presents latest worldwide installed capacity and generation data, showcasing the sector's contribution to global carbon reduction efforts, with low-emissions sources projected to cover almost all demand increases in the next three years. It is published alongside a Covid-19 policy paper featuring recommendations for governments, financial institutions and industry to respond to the current health and economic crisis.

"Preventing an emergency is far better than responding to one," says Roger Gill, President of IHA, highlighting the need to incentivise investments in renewable infrastructure, a view echoed by Fatih Birol during the crisis. "The events of the past few months must be a catalyst for stronger climate action, including greater development of sustainable hydropower."

Now in its seventh edition, the Hydropower Status Report shows electricity generation hit a record 4,306 terawatt hours (TWh) in 2019, the single greatest contribution from a renewable energy source in history, aligning with the outlook that renewables to surpass coal by 2025.

The annual rise of 2.5 per cent (106 TWh) in hydroelectric generation - equivalent to the entire electricity consumption of Pakistan - helped to avoid an estimated additional 80-100 million metric tonnes of greenhouse gases being emitted last year.

The report also highlights:

* Global hydropower installed capacity reached 1,308 gigawatts (GW) in 2019, as 50 countries completed greenfield and upgrade projects, including pumped storage and repowering old dams in some regions.

* A total of 15.6 GW in installed capacity was added in 2019, down on the 21.8 GW recorded in 2018. This represents a rise of 1.2 per cent, which is below the estimated 2.0 per cent growth rate required for the world to meet Paris Agreement carbon reduction targets.

* India has overtaken Japan as the fifth largest world hydropower producer with its total installed capacity now standing at over 50 GW. The countries with the highest increases in were Brazil (4.92 GW), China (4.17 GW) and Laos (1.89 GW).

* Hydropower's flexibility services have been in high demand during the Covid-19 crisis, even as global demand dipped 15% globally, while plant operations have been less affected due to the degree of automation in modern facilities.

* Hydropower developments have not been immune to economic impacts however, with the industry facing widespread uncertainty and liquidity shortages which have put financing and refinancing of some projects at risk.

In a companion policy paper, IHA sets out the immediate impacts of the crisis on the sector, noting how European responses to Covid-19 have accelerated the electricity system transition, as well as recommendations to assist governments and financial institutions and enhance hydropower's contribution to the recovery.

The recommendations include:

• Increasing the ambition of renewable energy and climate change targets which incorporate the role of sustainable hydropower development.
• Supporting sustainable hydropower through introducing appropriate financial measures such as tax incentives to ensure viable and shovel-ready projects can commence.
• Fast-tracking planning approvals to ensure the development and modernisation of hydropower projects can commence as soon as possible, in line with internationally recognised sustainability guidelines.
• Safeguarding investment by extending deadlines for concession agreements and other awarded projects.
• Given the increasing need for long-duration energy storage such as pumped storage, working with regulators and system operators to develop appropriate compensation mechanisms for hydropower's flexibility services.

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White Pines Project cancellation highlights Ontario's wind farm contract dispute in Prince Edward County, involving IESO approvals, Progressive Conservatives' legislation, potential court action, and costs to ratepayers amid green energy policy shifts.

Key Points

The termination effort for Ontario's White Pines wind farm contract, triggering legal, legislative, and cost disputes.

✅ Contract with IESO dates to 2009; final approval during election

✅ PCs seek legislation insulating taxpayers from litigation

✅ Cancellation could exceed $100M; cost impact on ratepayers

Cancelling an eastern Ontario green energy project that has been under development for nearly a decade could cost more than $100 million, the president of the company said Wednesday, warning that the dispute could be headed to the courts.

Ontario's governing Progressive Conservatives said this week that one of their first priorities during the legislature's summer sitting would be to cancel the contract for the White Pines Project in Prince Edward County.

Ian MacRae, president of WPD Canada, the company behind the project, said he was stunned by the news given that the project is weeks away from completion.

"What our lawyers are telling us is we have a completely valid contract that we've had since 2009 with the (Independent Electricity System Operator). ... There's no good reason for the government to breach that contract," he said.

The government has also not reached out to discuss the cancellation, he said. Meanwhile, construction on the site is in full swing, he said.

"Over the last couple weeks we've had an average of 100 people on site every day," he said. "The footprint of the project is 100 per cent in. So, all the access roads, the concrete for the base foundations, much of the electrical infrastructure. The sub-station is nearing completion."

The project includes nine wind turbines meant to produce enough electricity to power just over 3,000 homes annually, even as Ontario looks to build on an electricity deal with Quebec for additional supply. All of the turbines are expected to be installed over the next three weeks, with testing scheduled for the following month.

MacRae couldn't say for certain who would have to pay for the cancellation, electricity ratepayers or taxpayers.

"Somehow that money would come from IESO and it would be my assumption that would end up somehow on the ratepayers, despite legislation to lower electricity rates now in place," he said. "We just need to see what the government has in mind and who will foot the bill."

Progressive Conservative house leader Todd Smith, who represents the riding where the project is being built, said the legislation to cancel the project will also insulate taxpayers from domestic litigation over the dismantling of green energy projects.

"This is something that the people of Prince Edward County have been fighting ... for seven years," he said. "This shouldn't have come as a surprise to anybody that this was at the top of the agenda for the incoming government, which has also eyed energy independence in recent decisions."

Smith questioned why Ontario's Independent Electricity System Operator gave the final approval for the project during the spring election campaign.

"There's a lot of questions about how this ever got greenlighted in the first place," he said. "This project was granted its notice to proceed two days into the election campaign ... when (the IESO) should have been in the caretaker mode."

Terry Young, the IESO's vice president of policy, engagement and innovation, said the agency could not comment because of the pending introduction of legislation to cancel the deal, following a recent auditor-regulator dispute that drew attention to oversight.

NDP Leader Andrea Horwath said the new Tory government is behaving like the previous Liberal government by cancelling energy projects and tearing up contracts amid ongoing debates over Ontario's hydro mess and affordability. She likened the Tory plan to the Liberal gas plant scandal that saw the government relocate two plants at a substantial cost to taxpayers.

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Ukraine's EU Energy Integration aims for ENTSO-E synchronization, electricity market liberalization, EU Green Deal alignment, energy efficiency upgrades, hydrogen development, and streamlined grid connections to accelerate reform, market pricing, and sustainable growth.

Key Points

Ukraine's EU Energy Integration syncs with ENTSO-E, liberalizes power markets, and aligns with the EU Green Deal.

✅ ENTSO-E grid synchronization and cross-border trade readiness

✅ Electricity market liberalization and market-based pricing

✅ EU Green Deal alignment: efficiency, hydrogen, coal regions

Ukraine's goal in the energy sector is to ensure the maximum integration of energy markets with EU markets, and in line with the EU plan to dump Russian energy that is reshaping the region, synchronization of Ukraine's integrated energy system with ENTSO-E while leaning on electricity imports as needed to maintain stability. Prime Minister Denys Shmyhal emphasized in his statement at the Fourth Ukraine Reform Conference underway through July 7-8 in Vilnius, the Republic of Lithuania.

The Head of Government presented a plan of reforms in Ukraine until 2030. In particular, energy sector reform and environmental protection, according to the PM, include the liberalization of the electricity market, with recent amendments to the market law guiding implementation, the simplification of connection to the electrical grid system and the gradual transition to market electricity prices, alongside potential EU emergency price measures under discussion, and the monetization of subsidies for vulnerable groups.

"Ukraine shares and fully supports the EU's climate ambitions and aims to synchronize its policies in line with the EU Green Deal, including awareness of Hungary's energy alignment with Russia to ensure coherent regional planning. The interdepartmental working group has determined priority areas for cooperation with the European Union: energy efficiency, hydrogen, transformation of coal regions, waste management," said the Prime Minister.

According to Denys Shmyhal, Ukraine has supported the EU's climate ambitions to move towards climate-neutral development by 2050 within the framework of the European Green Deal and should become an integral part of it in order not only to combat the effects of climate change in synergy with the EU but, as the country prepares for winter energy challenges and strengthens resilience, within the economic strategy development aimed to enhance security and create new opportunities for Ukrainian business, with continued energy security support from partners bolstering implementation.

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Ontario Pickering Nuclear Closure will shift supply to natural gas, raising emissions as the electricity grid manages nuclear refurbishment, IESO planning, clean power imports, and new wind, solar, and storage to support electrification.

Key Points

Ontario will close Pickering and rely on natural gas, increasing emissions while other nuclear units are refurbished.

✅ 14% of Ontario electricity supplied by Pickering now

✅ Natural gas use rises; grid emissions projected up 375%

✅ IESO warns gas phaseout by 2030 risks blackouts, costs

The Ontario government will not reconsider plans to close the Pickering nuclear station and instead stop-gap the consequent electricity shortfall with natural gas-generated power in a move that will, as an analysis of Ontario's grid shows, hike the province’s greenhouse gas emissions substantially in the coming years.

In a report released this week, a nuclear advocacy group urged Ontario to refurbish the aging facility east of Toronto, which is set to be shuttered in phases in 2024 and 2025, prompting debate over a clean energy plan after Pickering as the closure nears. The closure of Pickering, which provides 14 per cent of the province’s annual electricity supply, comes at the same time as Ontario’s other two nuclear stations are undergoing refurbishment and operating at reduced capacity.

Canadians for Nuclear Energy, which is largely funded by power workers' unions, argued closing the 50-year-old facility will result in job losses, emissions increases, heightened reliance on imported natural gas and an electricity supply gap across Ontario.

But Palmer Lockridge, spokesperson for the provincial energy minister, said further extending Pickering’s lifespan isn’t on the table.

“As previously announced in 2020, our government is supporting Ontario Power Generation’s plan to safely extend the life of the Pickering Nuclear Generating Station through the end of 2025,” said Lockridge in an emailed response to questions.

“Going forward, we are ensuring a reliable, affordable and clean electricity system for decades to come. That’s why we put a plan in place that ensures we are prepared for the emerging energy needs following the closure of Pickering, and as a result of our government’s success in growing and electrifying the province’s economy.”

The Progressive Conservative government under Premier Doug Ford has invested heavily in electrification, sinking billions into electric vehicle and battery manufacturing and industries like steel-making to retool plants to run on electricity rather than coal, and exploring new large-scale nuclear plants to bolster baseload supply.

Natural gas now provides about seven per cent of the province’s energy, a piece of the pie that will rise significantly as nuclear energy dwindles. Emissions from Ontario’s electricity grid, which is currently one of the world’s cleanest with 94 per cent zero-emission power generation, are projected to rise a whopping 375 per cent as the province turns increasingly to natural gas generation. Those increases will effectively undo a third of the hard-won emissions reductions the province achieved by phasing out coal-fired power generation.

The Independent Electricity System Operator (IESO), which manages Ontario’s grid, studied whether the province could phase out natural gas generation by 2030 and concluded that “would result in blackouts and hinder electrification” and increase average residential electricity costs by $100 per month.

The Ontario Clean Air Alliance, however, obtained draft documents from the electricity operator that showed it had studied, but not released publicly, other scenarios that involved phasing out natural gas without energy shortfalls, price hikes or increases in emissions.

The Ontario government will not reconsider plans to close the Pickering nuclear station and instead stop-gap the consequent electricity shortfall facing Ontario with natural gas-generated power in a move that will hike the province’s greenhouse gas emissions.

One model suggested increasing carbon taxes and imports of clean energy from other provinces could keep blackouts, costs and emissions at bay, while another involved increasing energy efficiency, wind generation and storage.

“By banning gas-fired electricity exports to the U.S., importing all the Quebec water power we can with the existing transmission lines and investing in energy efficiency and wind and solar and storage — do all those things and you can phase out gas-fired power and lower our bills,” said Jack Gibbons, chair of the Ontario Clean Air Alliance.

The IESO has argued in response that the study of those scenarios was not complete and did not include many of the challenges associated with phasing out natural gas plants.

Ontario Energy Minister Todd Smith asked the IESO to develop “an achievable pathway to zero-emissions in the electricity sector and evaluate a moratorium on new-build natural gas generation stations,” said his spokesperson. That report, an early look at halting gas power, is expected in November.

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Rolls-Royce SMR UK Approval underscores nuclear innovation as regulators review a 470 MW factory-built modular reactor, aiming for grid power by 2029 to boost energy security, cut fossil fuels, and accelerate decarbonization.

Key Points

UK regulatory clearance for Rolls-Royce's 470 MW modular reactor, targeting grid power by 2029 to support clean energy.

✅ UK design approval expected by mid 2024

✅ First 470 MW unit aims for grid power by 2029

✅ Modular, factory-built; est. £1.8b per 10-acre site

A Rolls-Royce (RR.L) design for a small modular nuclear reactor (SMR) will likely receive UK regulatory approval by mid-2024, reflecting progress seen in the US NRC safety evaluation for NuScale as a regulatory benchmark, and be able to produce grid power by 2029, Paul Stein, chairman of Rolls-Royce Small Modular Reactors.

The British government asked its nuclear regulator to start the approval process in March, in line with the UK's green industrial revolution agenda, having backed Rolls-Royce’s $546 million funding round in November to develop the country’s first SMR reactor.

Policymakers hope SMRs will help cut dependence on fossil fuels and lower carbon emissions, as projects like Ontario's first SMR move ahead in Canada, showing momentum.

Speaking to Reuters in an interview conducted virtually, Stein said the regulatory “process has been kicked off, amid broader moves such as a Canadian SMR initiative to coordinate development, and will likely be complete in the middle of 2024.

“We are trying to work with the UK Government, and others to get going now placing orders, echoing expansions like Darlington SMR plans in Ontario, so we can get power on grid by 2029.”

In the meantime, Rolls-Royce will start manufacturing parts of the design that are most unlikely to change, while advancing partnerships like a MoU with Exelon to support deployment, Stein added.

Each 470 megawatt (MW) SMR unit costs 1.8 billion pounds ($2.34 billion) and would be built on a 10-acre site, the size of around 10 football fields, though projects in New Brunswick SMR debate have prompted questions about costs and timelines.

Unlike traditional reactors, SMRs are cheaper and quicker to build and can also be deployed on ships and aircraft. Their “modular” format means they can be shipped by container from the factory and installed relatively quickly on any proposed site.

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