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Crosbie Hydro Energy Action Plan outlines rate mitigation for Muskrat Falls, leveraging Nalcor oil revenues, export sales, Holyrood savings, and potential Hydro-Quebec taxation to keep Newfoundland and Labrador electricity rates near 14.67 cents/kWh.

Key Points

PC plan to cap post-Muskrat rates by using Nalcor revenues, exports, and savings, with optional Accord funds.

✅ $575.4M yearly to hold rates near 14.67 cents/kWh

✅ Sources: Nalcor oil $231M, Holyrood $150M, rates/dividends $123.4M

✅ Options: export sales, restructuring, Atlantic Accord, HQ tax

Newfoundland and Labrador PC Leader Ches Crosbie says Muskrat Falls won't drive up electricity rates, a goal consistent with an agreement to shield ratepayers from cost overruns, if he's elected premier.

According to Crosbie, who presented the party's Crosbie Hydro Energy Action Plan — acronym CHEAP — at a press conference Monday, $575.4 million is needed per year in order to keep rates from ballooning past 14.67 cents per kilowatt hour.

Here's where he thinks the money could come from:

• Hydro rates and dividends — $123.4 million
• Export sales — $40.1 million
• Nalcor restructuring — $30 million
• Holyrood savings — $150  million
• Nalcor oil revenue — $231 million

The oil money, Crosbie said, isn't going into government coffers but being invested into the offshore which, he said, is a good place for it.

"But the plan from the beginning around Muskrat Falls was that if there was need for it — for mitigation for rates — that those revenues and operating cash flows from Nalcor oil and gas would be available to be recycled into rate mitigation, as reflected in a recent financial update on the pandemic's impact. and that's what we're going to have to do," he said.

According to Crosbie, his numbers come from the preliminary stage of the Public Utilities Board process, even as rate mitigation talks have lacked public details.

This is a recent aerial view of the Muskrat Falls project in central Labrador. The project is more than 90 per cent complete, with first power forecast for late 2019, alongside Ottawa's $5.2B support for the project. (Nalcor)

"I'm telling you this is the best information available to anyone outside of government," he said. "We're working on what we can."

The PUB estimated Nalcor restructuring could save between $10 million and $15 million, according to Crosbie, but he figures there's "enough duplication and overpayment involved in the way things are now set up that we can find $30 million there."

Currently, provincial ratepayers pay about 12 cents per kilowatt hour as electricity users have started paying for Muskrat Falls costs.

Crosbie's $575.4-million figure would put rates at 14.67 cents per kilowatt-hour in 2021, where his plan pledges to keep them.

A recent Public Utilities Board Report says there's a potential $10 million to $15 million in savings from Nalcor, but Crosbie says he can find $30 million. (CBC)

"The promise is that Muskrat Falls, when it comes online — comes in service — will not increase your rates. Between now and when that happens there are rate increases already in the pipeline up to that level of [14.67 cents per kilowatt-hour] … so that is the baseline target rate at which rates will be kept.

"In other words, Muskrat will not drive up prices for electricity to consumers beyond that point."

In addition to those savings, Crosbie's plan outlined two further steps.

"We think it could be done out of the resources that I've just identified now, but if there's a problem with that, and as a temporary measure, we can use a modest amount of the Atlantic Accord review, fiscal review, revenues," he said.

Plan 'nothing new'

Premier Dwight Ball slammed the plan at the House of Assembly on Monday, saying it lacked insight.

"It was a copy and paste exercise," he told reporters. "There's nothing new in that plan. Not at all."

"We're not leaving any stone unturned of where the opportunity would be to actually generate revenue," he said.  "We are genuinely concerned about rate mitigation and we've got to get a plan in place."

Potential to tax Hydro-Québec

Crosbie also said there's potential to tax Hydro-Québec.

According to Crosbie, tax exemptions that expired in 2016 allow the province to tax exports from the Upper Churchill, which, he said, could result in "hundreds of millions or billions" in revenue.

"It's not my philosophy to immediately go and do that because that would generate litigation — who needs more of that? — but we do need to let Quebec know that we're very aware of that, and aware of that opportunity, and invite them to come talk about a whole host of issues," Crosbie said.

Crosbie said the tax would also have to be applied to domestic consumption.

"But so massive is the potential revenue from the Upper Churchill export that there would be ways to mitigate that and negate the effect of that on consumers in the province."

Crosbie said with the Atlantic Accord revenue, he could still present a balanced budget by 2022.

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Germany's Economic Downturn reflects an energy crisis, deindustrialization risks, export weakness, and manufacturing stress, amid Russia gas loss, IMF and EU recession forecasts, and debates over electricity price caps and green transition.

Key Points

An economic contraction from energy price shocks, export weakness, and bottlenecks in manufacturing and digitization.

✅ Energy shock after loss of cheap Russian gas

✅ Exports slump amid China slowdown and weak demand

✅ Policy gridlock on power price cap and permits

Germany went from envy of the world to the worst-performing major developed economy. What happened?

For most of this century, Germany racked up one economic success after another, dominating global markets for high-end products like luxury cars and industrial machinery, selling so much to the rest of the world that half the economy ran on exports.

Jobs were plentiful, the government’s financial coffers grew as other European countries drowned in debt, and books were written about what other countries could learn from Germany.

No longer. Now, Germany is the world’s worst-performing major developed economy, with both the International Monetary Fund and European Union expecting it to shrink this year.

It follows Russia’s invasion of Ukraine and the loss of Moscow’s cheap Russian gas that underpinned industry — an unprecedented shock to Germany’s energy-intensive industries, long the manufacturing powerhouse of Europe.

The sudden underperformance by Europe’s largest economy has set off a wave of criticism, handwringing and debate about the way forward.

Germany risks “deindustrialization” as high energy costs and government inaction on other chronic problems threaten to send new factories and high-paying jobs elsewhere, said Christian Kullmann, CEO of major German chemical company Evonik Industries AG.

From his 21st-floor office in the west German town of Essen, Kullmann points out the symbols of earlier success across the historic Ruhr Valley industrial region: smokestacks from metal plants, giant heaps of waste from now-shuttered coal mines, a massive BP oil refinery and Evonik’s sprawling chemical production facility.

These days, the former mining region, where coal dust once blackened hanging laundry, is a symbol of the energy transition, as the power sector’s balancing act continues with wind turbines and green space.

The loss of cheap Russian natural gas needed to power factories “painfully damaged the business model of the German economy,” Kullmann told The Associated Press. “We’re in a situation where we’re being strongly affected — damaged — by external factors.”

After Russia cut off most of its gas to the European Union, spurring an energy crisis in the 27-nation bloc that had sourced 40% of the fuel from Moscow, the German government asked Evonik to turn to coal by keeping its 1960s coal-fired power plant running a few months longer.

The company is shifting away from the plant — whose 40-story smokestack fuels production of plastics and other goods — to two gas-fired generators that can later run on hydrogen amid plans to become carbon neutral by 2030 and following the nuclear phase-out of recent years.

One hotly debated solution: a government-funded cap on industrial electricity prices to get the economy through the renewable energy transition, amid an energy crisis that even saw a temporary nuclear extension to stabilize supply.

The proposal from Vice Chancellor Robert Habeck of the Greens Party has faced resistance from Chancellor Olaf Scholz, a Social Democrat, and pro-business coalition partner the Free Democrats. Environmentalists say it would only prolong reliance on fossil fuels, while others advocate a nuclear option to meet climate goals.

Kullmann is for it: “It was mistaken political decisions that primarily developed and influenced these high energy costs. And it can’t now be that German industry, German workers should be stuck with the bill.”

The price of gas is roughly double what it was in 2021, with a senior official arguing nuclear would do little to solve that gas issue, hurting companies that need it to keep glass or metal red-hot and molten 24 hours a day to make glass, paper and metal coatings used in buildings and cars.

A second blow came as key trade partner China experiences a slowdown after several decades of strong economic growth.

These outside shocks have exposed cracks in Germany’s foundation that were ignored during years of success, including lagging use of digital technology in government and business and a lengthy process to get badly needed renewable energy projects approved.

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Nissan V2G Parking lets EV drivers pay with electricity via bidirectional charging at the Yokohama Nissan Pavilion, showcasing vehicle-to-grid, smart energy trading, and integrated mobility experiences like Ariya rides and Formula E simulators.

Key Points

A program where EV owners use V2G to pay for parking by discharging power at Nissan's Yokohama Pavilion.

✅ Pay for parking with EV energy via V2G

✅ Powered by Nissan LEAFs and solar at the Pavilion

✅ Showcases Ariya, Formula E, ProPILOT, and I2V tech

Nissan is letting customers pay for parking with electricity by discharging power from their electric car’s battery pack, a concept similar to how EV owners sell electricity back to the grid in other programs. In what the company claims to be a global first, owner of electric cars can trade energy for a parking space at Nissan Pavilion exhibition space in Yokohama, Japan, echoing how parked EVs earn from Europe's grids in comparable schemes.

The venue that showcases Nissan's future technologies, opened its doors to public on August 1 and will remain so through October 23, underscoring how stored EV energy can power buildings in broader applications. “(It) is a place where customers can see, feel, and be inspired by (the company's) near-future vision for society and mobility," says CEO Makoto Uchida. “As the world shifts to electric mobility, EVs will be integrated into society in ways that go beyond just transportation."

Apart from the innovate parking experience, people visiting the pavilion can also virtually experience the thrill of Formula E electric street racing or go for a ride in the all-new Ariya electric crossover, similar to demos at the Everything Electric show in Vancouver. Other experiences include ProPILOT advanced driver assistance system as well as Nissan’s Invisible-to-Visible (I2V) technology, which combines information from the real and virtual worlds to assist drivers, themes also explored at an EV education centre in Toronto for public outreach.

A mobility hub in front of the Pavilion offers a variety of services including EV car-sharing. The Pavilion also operates a cafe operated on power supplied by Nissan LEAF electric cars and solar energy, showcasing vehicle-to-building charging benefits on site.

As part of its Nissan NEXT transformation plan, the company plans to expand its global lineup of EVs and aims to sell more than 1 million electrified vehicles a year by the end of fiscal 2023, aligning with the American EV boom and the challenge of scaling charging infrastructure.

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Alberta Energy-Only Electricity Market faces capacity market debate, AESO price cap review, and coal-to-gas shifts by TransAlta and Capital Power, balancing reliability with volatility as investment signals evolve across Alberta's grid.

Key Points

An energy market paying generators only for electricity sold, with AESO oversight and a price cap guiding new capacity.

✅ AESO reviewing $999 per MW-h wholesale price cap.

✅ UCP retained energy-only; capacity market plan cancelled.

✅ TransAlta and Capital Power shift to coal-to-gas.

The Kenney government’s decision to cancel the redesign of Alberta’s electricity system to a capacity market won’t side-track two of the province’s largest power generators from converting coal-fired facilities to burn natural gas as part of Alberta’s shift from coal to cleaner energy overall.

But other changes could be coming to the province’s existing energy-only electricity market — including the alteration of the $999 per megawatt-hour (MW-h) wholesale price cap in Alberta.

The heads of TransAlta Corp. and Capital Power Corp. are proceeding with strategies to convert existing coal-fired power generating facilities to use natural gas in the coming years.

Calgary-based TransAlta first announced in 2017 that it would make the switch, as the NDP government was in the midst of overhauling the electricity sector and wind generation began to outpace coal in the province.

At the time, the Notley government planned to phase out coal-fired power by 2030, even as Alberta moved to retire coal by 2023 in practice, and shift Alberta into an electricity capacity market in 2021.

Such a move, made on the recommendation of the Alberta Electric System Operator (AESO), was intended to reduce price volatility and ensure system reliability.

Under the energy-only market, generators receive payments for electricity produced and sold into the grid. In a capacity market, generators are also paid for having power available on demand, regardless of how often they sell energy into the provincial grid.

The UCP government decided last month to ditch plans for a capacity market after consulting with the sector, saying it would be better for consumers.

On a conference call, TransAlta CEO Dawn Farrell said the company will convert coal-fired generating plants to burn gas, although it may alter the mix between simple conversions and switching to so-called “hybrid” plants.

(A hybrid conversion is a larger and more-expensive switch, as it includes installing a new gas turbine and heat-recovery steam generator, but it creates a highly efficient combined cycle unit.)

“Our view is fundamentally that carbon will be priced over the next 20 years no matter what,” she said Friday.

“We cannot get off coal fast enough in this company, and gas right now in Alberta is extremely inexpensive…

“So our coal-to-gas strategy is completely predicated on our belief that it’s not smart to be in carbon-intensive fuels for the future.”

Elsewhere in Canada, the Stop the Shock campaign has advocated for reviving coal power, underscoring ongoing policy debates.

The company said it’s planning the coal-to-gas conversion and re-powering of some or all of the units at its Keephills and Sundance facilities to gas-fired generation sometime between 2020 and 2023.

Similarly, Capital Power CEO Brian Vaasjo said the Edmonton-based company is moving ahead with a project that will allow it to burn both coal and natural gas at its Genesee generating station, even as Ontario’s energy minister sought to explore a halt to natural gas generation elsewhere.

In June, the company announced it would spend an estimated $50 million between 2019 and 2021 to allow it to use gas at the facility.

“What we’re doing is going to be dual fuel, so we will be able to operate 100 per cent natural gas or 100 per cent coal and everything in between,” Vaasjo said in an interview.

“You can expect to see we will be burning coal in the winter when natural gas prices are high, and we will be burning natural gas in summer when gas prices are real low.”

The transition comes as the government’s decision to stick with the energy-only market has been welcomed by players in the industry, and as Alberta's electricity future increasingly leans on wind resources.

A study by electricity consultancy EDC Associates found the capacity market would result in consumers paying an extra $1.4 billion in direct costs in 2021-22, as it required more generation to come online earlier than expected.

These additional costs would have accumulated to $10 billion by 2030, said EDC chief executive Duane-Reid Carlson.

For Capital Power, the decision to stick with the current system makes the province more investable in the future. Vaasjo said there was great uncertainty about the transition to a capacity market, and the possibility of rules shifting further.

Officials with Enmax Corp. said the city-owned utility would not have invested in future generation under the proposed capacity market.

“There is no short-term need (today) for new generation, so we’re just looking at the market and saying, ‘OK, as it evolves, we will see what happens,’” said Enmax vice-president Tim Boston.

Sticking with the energy-only market doesn’t mean Alberta will keep the existing rules.

In a July 25 letter, Alberta Energy Minister Sonya Savage directed AESO chair Will Bridge to examine if changes to the existing market are needed and report back by July 2020.

AESO, which manages the power grid, has been asked to investigate whether the current price cap of $999 per megawatt-hour (MW-h) should be changed.

The price ceiling hasn’t been altered since the energy-only market was implemented by the Klein government about two decades ago.

While allowing prices to go higher would increase volatility, reflecting lessons from Europe’s power crisis about scarcity pricing, during periods of rising demand and limited supply, it would send a signal to generators when investment in new generation is required, said Kent Fellows, a research associate at the University of Calgary’s School of Public Policy.

“Keeping the price (cap) too low could end up costing us more in the long run,” he said.

In a 2016 report, AESO said the province examined raising the price cap to $5,000 per MW-h, but “determined that it was unlikely to be successful in attracting investment due to increased price volatility.”

However, the amount of future generation that will be required in Alberta has been scaled back by the province.

In the United States, the Electricity Reliability Council of Texas (ERCOT) allows wholesale power prices in the state to climb to a cap of $9,000 per megawatt hours as demand rises — as it did Tuesday in the midst of a heat wave, according to Bloomberg.

Jim Wachowich, legal counsel for the Consumers’ Coalition of Alberta, said while few players are exposed to spot electricity prices, he has yet to be convinced raising the cap would be good for Albertans.

“Someone has to show me the evidence, and I suspect that’s what the minister has asked the AESO to do,” he said.

Generators say they believe some tinkering is needed to the energy-only market to ensure new generation is built when it’s required.

“The No. 1 change that the government has to … think about is in pricing,” added Farrell.

“If you don’t have enough of a price signal in an energy-only market to attract new capital, you won’t get new capital — and you’ll run up against the wall.”

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US Grid Pandemic Response coordinates control rooms, grid operators, and critical infrastructure, leveraging hydroelectric plants, backup control centers, mutual assistance networks, and deep cleaning protocols to maintain reliability amid reduced demand and COVID-19 risks.

Key Points

US Grid Pandemic Response encompasses measures by utilities and operators to safeguard power reliability during COVID-19

✅ Control rooms staffed on-site; operators split across backup centers

✅ Health screenings, deep cleaning, and isolation protocols mitigate contagion

✅ Reduced demand and mutual assistance improve grid resilience

Control rooms are the brains of NYPA’s power plants, which are mostly hydroelectric and supply about a quarter of all the electricity in New York state. They’re also a bit like human petri dishes. The control rooms are small, covered with frequently touched switches and surfaces, and occupied for hours on end by a half-dozen employees. Since social distancing and telecommuting isn’t an option in this context, NYPA has instituted regular health screenings and deep cleanings to keep the coronavirus out.

The problem is that each power plant relies on only a handful of control room operators. Since they have a specialized skill set, they can’t be easily replaced if they get sick. “They are very, very critical,” says Gil Quiniones, NYPA president and CEO. If the pandemic worsens, Quiniones says that NYPA may require control room operators to live on-site at power plants to reduce the chance of the virus making it in from the outside world. It sounds drastic, but Quiniones says NYPA has done it before during emergencies—once during the massive 2003 blackout, and again during Hurricane Sandy.

Meanwhile, PJM is one of North America’s nine regional grid operators and manages the transmission lines that move electricity from power plants to millions of customers in 13 states on the Eastern seaboard, including Washington, DC. PJM has had a pandemic response plan on the books for 15 years, but Mike Bryson, senior vice president of operations, says that this is the first time it’s gone into full effect. As of last week, about 80 percent of PJM’s 750 full-time employees have been working from home. But PJM also requires a skeleton crew of essential workers to be on-site at all times in its control centers. As part of its emergency planning, PJM built a backup control center years ago, and now it is splitting control center operators between the two to limit contact.

Past experience with large-scale disasters has helped the energy sector keep the lights on and ventilators running during the pandemic. Energy is one of 16 sectors that the US government has designated as “critical infrastructure,” which also includes the communications industry, transportation sector, and food and water systems. Each is seen as vital to the country and therefore has a duty to maintain operations during national emergencies.

“We need to be treated as first responders,” says Scott Aaronson, the vice president of security and preparedness at the Edison Electric Institute, a trade group representing private utilities. “Everybody's goal right now is to keep the public healthy, and to keep society functioning as best we can. A lack of electricity will certainly create a challenge for those goals.”

America’s electricity grid is a patchwork of regional grid operators connecting private and state-owned utilities. This means simply figuring out who’s in charge and coordinating among the various organizations is one of the biggest challenges to keeping the electricity flowing during a national emergency, according to Aaronson.

Generally, a lot of this responsibility falls on formal energy organizations like the nonprofit North American Electric Reliability Corporation and the Federal Energy Regulatory Commission. But during the coronavirus outbreak, an obscure organization run by the CEOs of electric utilities called the Electricity Subsector Coordinating Council has also served as a primary liaison between the federal government and the thousands of utility companies around the US. Aaronson says the organization has been meeting twice a week for the past three weeks to ensure that utilities are implementing best practices in their response to the coronavirus, as well as to inform the government of material needs to keep the energy sector running smoothly.

This tight-knit coordination will be especially important if the pandemic gets worse, as many forecasts suggest it will. Most utilities belong to at least one mutual assistance group, an informal network of electricity suppliers that help each other out during a catastrophe. These mutual assistance networks are usually called upon following major storms that threaten prolonged outages. But they could, in principle, be used to help during the coronavirus pandemic too. For example, if a utility finds itself without enough operators to manage a power plant, it could conceivably borrow trained operators from another company to make sure the power plant stays online.

So far, utilities and grid operators have managed to make it work on their own. There have been a handful of coronavirus cases reported at power plants, but they haven’t yet affected these plants’ ability to deliver energy. The challenges of running a power plant with a skeleton crew is partially offset by the reduced power demand as businesses shut down and more people work from home, says Robert Hebner, the director of the Center for Electromechanics at the University of Texas. “The reduced demand for power gives utilities a little breathing room,” says Hebner.

A recent study by the University of Chicago’s Energy Policy Institute found that electricity demand in Italy has plunged by 18 percent following the severe increase in coronavirus cases in the country. Energy demand in China also plummeted as a result of the pandemic. Bryson, at PJM, says the grid operator has seen about a 6 percent decrease in electricity demand in recent weeks, but expects an even greater drop if the pandemic gets worse.

Generally speaking, problems delivering electricity in the US occur when the grid is overloaded or physically damaged, such as during California wildfires or a hurricane.

An open question among coronavirus researchers is whether there will be a second wave of the pandemic later this year. During the Spanish flu pandemic in the early 20th century, the second wave turned out to be deadlier than the first. If the coronavirus remerges later this year, it could be a serious threat to reliable electricity in the US, says John MacWilliams, a former associate deputy secretary of the Department of Energy and a senior fellow at Columbia University’s Center on Global Energy Policy.

“If this crisis extends into the fall, we're going to hit hurricane season along the coasts,” MacWilliams says. “Utilities are doing a very good job right now, but if we get unlucky and have an active hurricane season, they're going to get very stressed because the number of workers that are available to repair damage and restore power will become more limited.”

This was a sentiment echoed by Bryson at PJM. “Any one disaster is manageable, but when you start layering them on top of each other, it gets much more challenging,” he adds. The US electricity grid struggles to handle major storms as it is, and these challenges will be heightened if too many workers are home sick. In this sense, the energy sector’s ability to deliver the electricity needed to keep manufacturing medical supplies or keep ventilators running depends to a large extent on our ability to flatten the curve today. The coronavirus is bad enough without having to worry about the lights going out.

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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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