The coal industry and the environment

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The Ancient Greeks believed that everything in the world was composed of some combination of the four elements: earth, air, water and fire. These four elements still define our environment today.

As such, they provide a framework for the environmental issues being tackled by CanadaÂ’s coal industry.

Initiatives to address land use, waste, air and water quality, wildlife and even noise concerns are currently being implemented in coal-related activities across the country. CanadaÂ’s coal industry is actively seeking ways to address environmental concerns on three fronts: the first is at the mine site where mining and processing methods are designed to minimize local air, water, land and community impacts; the second is at the power plants where improved coal-burning technologies have reduced emissions and advanced technologies are promising even greater reductions; the third front addresses the challenges of global cooperation in order to minimize coalÂ’s environmental impact around the world.

On all of these fronts, the coal industry is working cooperatively with governments, communities and other stakeholders to ensure environmental initiatives are addressed. The following sections provide more information on some of these programs.

Clean Coal Technology (CCT) refers to technology that is being developed and used to reduce the environmental footprint of coal. Most of coalÂ’s impact occurs at the consumption end - power generation and cement manufacturing. Canada and the private sector have invested significant amounts of money in the development of CCTÂ’s designed to enhance both the efficiency and the environmental acceptability of coal extraction, preparation and consumption.

Currently the United States, Australia, Europe and Asia are leading the way in the development and use of CCTÂ’s. But Canada is not standing still.

For example: Natural Resources Canada (NRC) has developed a Clean Coal Technology Roadmap which provides an outlook to the future and identifies technology pathways needed to allow coal to be used as a competitive environmentally clean energy resource for the production of electricity.

NRC has also made financial contributions to projects by the Canadian Clean Power Coalition (CCPC). CCPC projects aim to demonstrate that coal-fired power can be produced with emission levels the same as a modern natural-gas-fired turbine plant and that CO2 can be captured and stored by applying commercial-scale technologies.

A $33 million research project aims to find the cleanest ways to generate electricity from AlbertaÂ’s vast reserves of coal. The three-year project is one of the first to be funded under AlbertaÂ’s new $200 million Energy Innovation Fund.

“With innovation and technology solutions, Alberta will be able to generate electricity from coal with near-zero emissions,” said George VanderBurg, Minister of Government Services and Acting Minister of Innovation and Science. “This research has the potential to develop an environmentally responsible and economic way to meet our province’s growing electricity demand.”

The Front-End Engineering Design (FEED) study is collaboration between the Alberta Energy Research Institute (AERI), the Canadian Clean Power Coalition (CCPC) and EPCOR. Using funding allocated under the new Energy Innovation Fund, AERI will provide $11 million, one third of the project costs, over three years. EPCOR and CCPC are responsible for the balance of the funding, and they are inviting participation by other stakeholders.

The study will research the best design for a power generation facility capable of removing significant percentages of emissions including nitrous oxide, sulfur dioxide, particulate matter, mercury and carbon dioxide, using Alberta coal as its feedstock. EPCORÂ’s Genesee site outside Edmonton will host the study.

“By converting coal into gas, and capturing carbon dioxide, we can create electricity that’s even cleaner than the best natural gas facility operating today,” noted CCPC Chair Dr. David Lewin.

The results of the study will be available to the members of Canadian Clean Power Coalition and Alberta companies. The FEED study will provide investors with information they need to make decisions regarding the construction of a commercial demonstration plant. If the results are positive, a demonstration facility may be built, with completion expected about 2015.

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California's Next Electricity Headache Is a Looming Shortage

California Electricity Reserve Mandate requires 3.3 GW of new capacity to bolster grid reliability amid solar power volatility, peak demand, and wildfire-driven blackouts, as CPUC directs PG&E, Edison, and Sempra to procure resource adequacy.

 

Key Points

A CPUC order for utilities to add 3.3 GW of reserves, safeguarding grid reliability during variable renewables and peaks

✅ 3.3 GW procurement to meet resource adequacy targets

✅ Focus on grid reliability during peak evening demand

✅ Prioritizes renewables, storage; limits new fossil builds

 

As if California doesn’t have enough problems with its electric service, now state regulators warn the state may be short on power supplies by 2021 if utilities don’t start lining up new resources now.

In the hopes of heading off a shortfall as America goes electric, the California Public Utilities Commission has ordered the state’s electricity providers to secure 3.3 additional gigawatts of reserve supplies. That’s enough to power roughly 2.5 million homes. Half of it must be in place by 2021 and the rest by August 2023.

The move comes as California is already struggling to accommodate increasingly large amounts of solar power that regularly send electricity prices plunging below zero and force other generators offline so the region’s grid doesn’t overload. The state is also still reeling from a series of deliberate mass blackouts that utilities imposed last month to keep their power lines from sparking wildfires amid strong winds. And its largest power company, PG&E Corp., went bankrupt in January.

Now as natural gas-fired power plants retire under the state’s climate policies, officials are warning the state could run short on electricity on hot evenings, when solar production fades and commuters get home and crank up their air conditioners. “We have fewer resources that can be quickly turned on that can meet those peaks,” utilities commission member Liane Randolph said Thursday before the panel approved the order to beef up reserves.

The 3.3 gigawatts that utilities must line up is in addition to a state rule requiring them to sign contracts for 15% more electricity than they expect to need. Some critics question the need for added supplies, particularly after the state went on a plant-building boom in the 2000s.

But California’s grid managers say the risk of a shortfall is real and could be as high as 4.7 gigawatts, especially during heat waves that test the grid again. Mark Rothleder, with the California Independent System Operator, said the 15% cushion is a holdover from the days before big solar and wind farms made the grid more volatile. Now it may need to be increased, he said.

“We’re not in that world anymore,” said Rothleder, the operator’s vice president of state regulatory affairs. “The complexity of the system and the resources we have now are much different.”

The state’s three major utilities, PG&E, Edison International and Sempra Energy, will be largely responsible for securing new supplies. The commission banned fossil fuels from being used at any new power generators built to meet the requirement — though it left the door open for expansions at existing ones.

Some analysts argue California is exporting its energy policies to Western states, making electricity more costly and less reliable.

PG&E said in an emailed statement that it was pleased the commission didn’t adopt an earlier proposal to require 4 gigawatts of additional resources. Edison similarly said it was “supportive.” Sempra didn’t immediately respond with comment.

 

Extending Deadlines

The pending plant closures are being hastened by a 2020 deadline requiring California’s coastal generators to stop using aging seawater-cooling systems. Some gas-fired power plants have said they’ll simply close instead of installing costly new cooling systems. So the commission on Thursday also asked California water regulators to extend the deadline for five plants.

The Sierra Club, meanwhile, called on regulators to turn away from fossil fuels altogether, saying their decision Thursday “sets California back on its progress toward a clean energy future.”

The move to push back the deadline also faces opposition from neighboring towns. Redondo Beach Mayor Bill Brand, whose city is home to one of the plants in line for an extension, told the commission it wasn’t necessary, since California utilities already have plenty of electricity reserves.

“It’s just piling on to that reserve margin,” Brand said.

 

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Enel Starts Operations of 450 MW Wind Farm in U.S

High Lonesome Wind Farm powers Texas with 500 MW of renewable energy, backed by a 12-year PPA with Danone North America and a Proxy Revenue Swap, cutting CO2 emissions as Enel's largest project to date.

 

Key Points

A 500 MW Enel wind project in Texas, supplying renewable power via PPAs and hedged by a Proxy Revenue Swap.

✅ 450 MW online; expanding to 500 MW in early 2020

✅ 12-year PPA with Danone North America for 20.6 MW

✅ PRS hedge with Allianz and Nephila stabilizes revenues

 

Enel, through its US renewable subsidiary Enel Green Power North America, Inc. (“EGPNA”), has started operations of its 450 MW High Lonesome wind farm in Upton and Crockett Counties, in Texas, the largest operational wind project in the Group’s global renewable portfolio, alongside a recent 90 MW Spanish wind build in its European pipeline. Enel also signed a 12-year, renewable energy power purchase agreement (PPA) with food and beverage company Danone North America, a Public Benefit Corporation, for physical delivery of the renewable electricity associated with 20.6 MW, leading to an additional 50 MW expansion of High Lonesome that will increase the plant’s total capacity to 500 MW. The construction of the 50 MW expansion is currently underway and operations are due to start in the first quarter of 2020.

“The start of operations of Enel’s largest wind farm in the world marks a significant achievement for our company and reinforces our global commitment to accelerated renewable energy growth,” said Antonio Cammisecra, CEO of Enel Green Power, referencing the largest wind project constructed in North America as evidence of market momentum. “This milestone is matched with a new partnership with Danone North America to support their renewable goals, a reinforcement of our continued commitment to provide customers with tailored solutions to meet their sustainability goals.”

The agreement between Enel and Danone North America will provide enough electricity to produce the equivalent of almost 800 million cups of yogurt1 and over 80 million gallons2 of milk each year and support the food and beverage company’s commitment to securing 100% of its purchased electricity from renewable sources by 2030, in a market where North Carolina’s first wind farm is now fully operational and expanding access to clean power.

Mariano Lozano, president and CEO of Danone North America, added:“This is an exciting and significant step as we continue to advance our 2030 renewable electricity goals. As a public benefit corporation committed to balancing the needs of our business with those of society and the planet, we truly believe that this agreement makes sense from both a business and sustainability point of view. We’re delighted to be working with Enel Green Power to expand their High Lonesome wind farm and grow the renewable electricity infrastructure, such as New York’s biggest offshore wind projects, here in the US.”

In addition, as more US wind projects come online, such as TransAlta’s 119 MW project, the energy produced by a 295 MW portion of the project will be hedged under a Proxy Revenue Swap (PRS) with insurer Allianz Global Corporate & Specialty, Inc.'s Alternative Risk Transfer unit (Allianz), and Nephila Climate, a provider of weather and climate risk management products. The PRS is a financial derivative agreement designed to produce stable revenues for the project regardless of power price fluctuations and weather-driven intermittency, hedging the project from this kind of risk in addition to that associated with price and volume.

Under the PRS agreement, and as other projects begin operations, like Building Energy’s latest plant, High Lonesome will receive fixed payments based on the expected value of future energy production, with adjustments paid depending on how the realized proxy revenue of the project differs from the fixed payment. The PRS for High Lonesome, which is the largest by capacity for a single plant globally and the first agreement of its kind for Enel, was executed in collaboration with REsurety, Inc.

The investment in the construction of the 500 MW plant amounts to around 720 million US dollars. The wind farm is due to generate around 1.9 TWh annually, comparable to a 280 MW Alberta wind farm’s output, while avoiding the emission of more than 1.2 million tons of CO2 per year.

 

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18% of electricity generated in Canada in 2019 came from fossil fuels

EV Decarbonization Strategy weighs life-cycle emissions and climate targets, highlighting mode shift to public transit, cycling, and walking, grid decarbonization, renewable energy, and charging infrastructure to cut greenhouse gases while reducing private car dependence.

 

Key Points

A plan to cut transport emissions by pairing EV adoption with mode shift, clean power, and less private car use.

✅ Prioritize mode shift: transit, cycling, and walking.

✅ Electrify remaining vehicles with clean, renewable power.

✅ Expand charging, improve batteries, and manage critical minerals.

 

California recently announced that it plans to ban the sales of gas-powered vehicles by 2035, a move similar to a 2035 electric vehicle mandate seen elsewhere, Ontario has invested $500 million in the production of electric vehicles (EVs) and Tesla is quickly becoming the world's highest-valued car company.

It almost seems like owning an electric vehicle is a silver bullet in the fight against climate change, but it isn't, as a U of T study explains today. What we should also be focused on is whether anyone should use a private vehicle at all.
 
As a researcher in sustainable mobility, I know this answer is unsatisfying. But this is where my latest research has led.

Battery EVs, such as the Tesla Model 3 - the best selling EV in Canada in 2020 - have no tailpipe emissions. But they do have higher production and manufacturing emissions than conventional vehicles, and often run on electricity that comes from fossil fuels.

Almost 18 per cent of the electricity generated in Canada came from fossil fuels in 2019, and even as Canada's EV goals grow more ambitious today, the grid mix varies from zero in Quebec to 90 per cent in Alberta.
 
Researchers like me compare the greenhouse gas emissions of an alternative vehicle, such as an EV, with those of a conventional vehicle over a vehicle lifetime, an exercise known as a life-cycle assessment. For example, a Tesla Model 3 compared with a Toyota Corolla can provide up to 75 per cent reduction in greenhouse gases emitted per kilometre travelled in Quebec, but no reductions in Alberta.

 

Hundreds of millions of new cars

To avoid extreme and irreversible impacts on ecosystems, communities and the overall global economy, we must keep the increase in global average temperatures to less than 2 C - and ideally 1.5 C - above pre-industrial levels by the year 2100.

We can translate these climate change targets into actionable plans. First, we estimate greenhouse gas emissions budgets using energy and climate models for each sector of the economy and for each country. Then we simulate future emissions, taking alternative technologies into account, as well as future potential economic and societal developments.

I looked at the U.S. passenger vehicle fleet, which adds up to about 260 million vehicles, while noting the potential for Canada-U.S. collaboration in this transition, to answer a simple question: Could the greenhouse gas emissions from the sector be brought in line with climate targets by replacing gasoline-powered vehicles with EVs?

The results were shocking. Assuming no changes to travel behaviours and a decarbonization of 80 per cent of electricity, meeting a 2 C target could require up to 300 million EVs, or 90 per cent of the projected U.S. fleet, by 2050. That would require all new purchased vehicles to be electric from 2035 onwards.

To put that into perspective, there are currently 880,000 EVs in the U.S., or 0.3 per cent of the fleet. Even the most optimistic projections, despite hype about an electric-car revolution gaining steam, from the International Energy Agency suggest that the U.S. fleet will only be at about 50 per cent electrified by 2050.

 

Massive and rapid electrification

Still, 90 per cent is theoretically possible, isn't it? Probably, but is it desirable?

In order to hit that target, we'd need to very rapidly overcome all the challenges associated with EV adoption, such as range anxiety, the higher purchase cost and availability of charging infrastructure.
 
A rapid pace of electrification would severely challenge the electricity infrastructure and the supply chain of many critical materials for the batteries, such as lithium, manganese and cobalt. It would require vast capacity of renewable energy sources and transmission lines, widespread charging infrastructure, a co-ordination between two historically distinct sectors (electricity and transportation systems) and rapid innovations in electric battery technologies. I am not saying it's impossible, but I believe it's unlikely.

Read more: There aren't enough batteries to electrify all cars - focus on trucks and buses instead

So what? Shall we give up, accept our collective fate and stop our efforts at electrification?

On the contrary, I think we should re-examine our priorities and dare to ask an even more critical question: Do we need that many vehicles on the road?

 

Buses, trains and bikes

Simply put, there are three ways to reduce greenhouse gas emissions from passenger transport: avoid the need to travel, shift the transportation modes or improve the technologies. EVs only tackle one side of the problem, the technological one.

And while EVs do decrease emissions compared with conventional vehicles, we should be comparing them to buses, including leading electric bus fleets in North America, trains and bikes. When we do, their potential to reduce greenhouse gas emissions disappears because of their life cycle emissions and the limited number of people they carry at one time.

If we truly want to solve our climate problems, we need to deploy EVs along with other measures, such as public transit and active mobility. This fact is critical, especially given the recent decreases in public transit ridership in the U.S., mostly due to increasing vehicle ownership, low gasoline prices and the advent of ride-hailing (Uber, Lyft)

Governments need to massively invest in public transit, cycling and walking infrastructure to make them larger, safer and more reliable, rather than expanding EV subsidies alone. And we need to reassess our transportation needs and priorities.

The road to decarbonization is long and winding. But if we are willing to get out of our cars and take a shortcut through the forest, we might get there a lot faster.

Author: Alexandre Milovanoff - Postdoctoral Researcher, Environmental Engineering, University of Toronto The Conversation

 

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Europe's Renewables Are Crowding Out Gas as Coal Phase-Out Slows

EU Renewable Energy Shift is cutting gas dependence as wind and solar expand, reshaping Europe's power mix, curbing emissions, and pressuring coal use amid a supply crisis and rising natural gas prices.

 

Key Points

An EU trend where wind and solar growth reduce gas reliance, curb coal, and lower power-sector emissions.

✅ Wind and solar displace gas in EU power mix

✅ Coal use rises as gas prices surge

✅ Emissions fall, but not fast enough for 1.5 C target

 

The European Union’s renewable energy sources are helping reduce its dependence on natural gas, under the current European electricity pricing framework, that’s still costing the region dearly.

Renewables growth has helped reduce the EU’s dependence on gas, as wind and solar outpaced gas across the bloc last year, which has soared in price since the middle of last year as the region grapples with a supply crisis that’s dealt blows to industries as well as ordinary consumers’ pockets. More than half of new renewable generation since 2019 has replaced gas power, according to a study by London-based climate think tank Ember, with the rest replacing mainly nuclear and coal sources.

“These are moments and paradigm shifts when governments and businesses start taking this much more seriously,” said Charles Moore, the lead author on the study, amid Covid-19 responses accelerating the transition across Europe. “The alternatives are available, they are cheaper, and they are likely to get even cheaper and more competitive. Renewables are now an opportunity, not a cost.”

The high price of gas relative to coal has meant utilities are leaning more on coal as a back-up for renewable generation, as stunted hydro and nuclear output has constrained low-carbon alternatives in parts of Europe, which risks the trajectory of Europe’s phase-out of the dirtiest fossil fuel. Last year, the EU’s coal use jumped disproportionately high relative to the rise in power generation as high gas prices boosted the relative profitability of burning coal instead.


Europe Coal Use Jumps as Costly Gas Turns Firms to Dirty Fuel
EU power generation from renewables reached a record high in 2021 of 547 terawatt-hours last year, accounting for an 11% increase compared to two years before, according to Ember’s Europe Electricity Review. It’s more than doubled in a decade, representing a 157% increase since 2011. 

Gas use declined last year for the second year in a row, as Europe explores storing electricity in gas pipelines to leverage existing infrastructure, reaching a level 8.1% lower than 2019. By contrast, coal use fell just 3.3% in the same period. Put simply, wind and solar did a great job of replacing coal during 2011-2019 but since then renewables have mostly been nudging out gas-fired power stations.

Ember’s Moore warned that the slowing phase-out of coal might require legislation to accelerate. The International Energy Agency recommends OECD countries cease using coal by the end of the decade to ensure alignment with the Paris Agreement target of keeping the world’s temperature increase below 1.5 Celsius, with renewables poised to eclipse coal globally by the mid-2020s lending momentum. 

“Europe can accelerate the phasing out of coal by building more renewable energy and faster,” said Felicia Aminoff,  an energy-transition analyst at BloombergNEF. “Wind and solar have no fuel costs, so as soon as you have made the initial investments to build wind and solar capacity it will start replacing generation that uses any kind of fuel, whether it is coal or gas.”

Overall, EU power sector emissions fell at less than half the rate required to hit that target, Ember’s report said. Spain produced the largest emissions reduction in the last two years, with renewables adding about 25 TWh and gas falling 15 TWh, and in Germany renewables topped coal and nuclear for the first time to support the shift. In contrast, heavy use of coal dragged down the bloc’s climate progress in Poland, where coal use rose about 8 TWh and renewables gained only 4 TWh.

 

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Ontario's Clean Electricity Regulations: Paving the Way for a Greener Future

Ontario Clean Electricity Regulations accelerate renewable energy adoption, drive emissions reduction, and modernize the smart grid with energy storage, efficiency targets, and reliability upgrades to support decarbonization and a stable power system for Ontario.

 

Key Points

Standards to cut emissions, grow renewables, improve efficiency, and modernize the grid with storage and smart systems.

✅ Phases down fossil generation and invests in storage.

✅ Sets utility efficiency targets to curb demand growth.

✅ Upgrades to smart grid for reliability and resiliency.

 

Ontario has taken a significant step forward in its energy transition with the introduction of new clean electricity regulations. These regulations, complementing federal Clean Electricity Regulations, aim to reduce carbon emissions, promote sustainable energy sources, and ensure a cleaner, more reliable electricity grid for future generations. This article explores the motivations behind these regulations, the strategies being implemented, and the expected impacts on Ontario’s energy landscape.

The Need for Clean Electricity

Ontario, like many regions around the world, is grappling with the effects of climate change, including more frequent and severe weather events. In response, the province has set ambitious targets to reduce greenhouse gas emissions and increase the use of renewable energy sources, reflecting trends seen in Alberta’s path to clean electricity across Canada. The electricity sector plays a central role in this transition, as it is responsible for a significant portion of the province’s carbon footprint.

For years, Ontario has been moving away from coal as a source of electricity generation, and now, with the introduction of these new regulations, the province is taking a step further in decarbonizing its grid, including its largest competitive energy procurement to date. By setting clear goals and standards for clean electricity, the province hopes to meet its environmental targets while ensuring a stable and affordable energy supply for all Ontarians.

Key Aspects of the New Regulations

The regulations focus on encouraging the use of renewable energy sources such as wind, solar, hydroelectric, and geothermal power. One of the key elements of the plan is the gradual phase-out of fossil fuel-based energy sources. This shift is expected to be accompanied by greater investments in energy storage solutions, including grid batteries, to address the intermittency issues often associated with renewable energy sources.

Ontario’s new regulations also emphasize the importance of energy efficiency in reducing overall demand. As part of this initiative, utilities and energy providers will be required to meet strict energy-saving targets and participate in new electricity auctions designed to reduce costs, ensuring that both consumers and businesses are incentivized to use energy more efficiently.

In addition, the regulations promote technological innovation in the electricity sector. By supporting the development of smart grids, energy storage technologies, and advanced power management systems, Ontario is positioning itself to become a leader in the global energy transition.

Impact on the Economy and Jobs

One of the anticipated benefits of the clean electricity regulations is their positive impact on Ontario’s economy. As the province invests in renewable energy infrastructure and clean technologies, new job opportunities are expected to arise in industries such as manufacturing, construction, and research and development. These regulations also encourage innovation in energy services, which could lead to the growth of new companies and industries, while easing pressures on industrial ratepayers through complementary measures.

Furthermore, the transition to cleaner energy is expected to reduce the long-term costs associated with climate change. By investing in sustainable energy solutions now, Ontario will help mitigate the financial burdens of environmental damage and extreme weather events in the future.

Challenges and Concerns

While the new regulations have been widely praised for their environmental benefits, they are not without their challenges. One of the primary concerns is the potential cost to consumers, and some Ontario hydro policy critique has called for revisiting legacy pricing approaches to improve affordability. While renewable energy sources have become more affordable over the years, transitioning from fossil fuels could still result in higher electricity prices in the short term. Additionally, the implementation of new technologies, such as smart grids and energy storage, will require substantial upfront investment.

Moreover, the intermittency of renewable energy generation poses a challenge to grid stability. Ontario’s electricity grid must be able to adapt to fluctuations in energy supply as more variable renewable sources come online. This challenge will require significant upgrades to the grid infrastructure and the integration of storage solutions to ensure reliable energy delivery.

The Road Ahead

Ontario’s clean electricity regulations represent an important step in the province’s commitment to combating climate change and transitioning to a sustainable, low-carbon economy. While there are challenges to overcome, the benefits of cleaner air, reduced emissions, and a more resilient energy system will be felt for generations to come. As the province continues to innovate and lead in the energy sector, Ontario is positioning itself to thrive in the green economy of the future.

 

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ACORE tells FERC that DOE Proposal to Subsidize Coal, Nuclear Power Plants is unsupported by Record

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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