Cruise ships to “plug in” at port

ERCOT Ancillary Services Clawback and VOLL Pricing summarize PUCT and IMM actions on load shed, real-time pricing adders, clawbacks, and settlement corrections after the 2021 winter storm in the Texas power grid market.

Key Points

Policies addressing clawbacks for unprovided AS and correcting VOLL-based price adders after load shed ended in ERCOT.

✅ PUCT ordered clawbacks for ancillary services not delivered.

✅ IMM urged price correction after firm load shed ceased.

✅ ERCOT's VOLL adder raised costs by $16B during 32 hours.

Potomac Economics, the Independent Market Monitor (IMM) for the Electric Reliability Council of Texas (ERCOT), filed a report with the Public Utility Commission of Texas (PUCT) that certain payments were made by ERCOT for Ancillary Services (AS) that were not provided, even as ERCOT later issued a winter reliability RFP to procure capacity during subsequent seasons.

According to the IMM (emphasis added):

There were a number of instances during the operating days outlined above in which AS was not provided in real time because of forced outages or derations. For market participants that are not able to meet their AS responsibility, typically the ERCOT operator marks the short amount in the software. This causes the AS responsibility to be effectively removed and the day-ahead AS payment to be clawed back in settlement. However, the ERCOT operators did not complete this task during the winter event, echoing issues like the Ontario IESO phantom demand that cost customers millions, and therefore the "failure to provide" settlements were not invoked in real time.

Removing the operator intervention step and automating the "failure to provide" settlement was contemplated in NPRR947: Clarification to Ancillary Service Supply Responsibility Definition and Improvements to Determining and Charging for Ancillary Service Failed Quantities; however, the NPRR was withdrawn in August 2020 amid ongoing market reform discussions because of the system cost, some complexities related to AS trades, and the implementation of real-time co-optimization.

Invoking the "failure to provide" settlement for all AS that market participants failed to provide during the operating days outlined above will produce market outcomes and settlements consistent with underlying market principles. In this case, the principle is that market participants should not be paid for services that they do not provide, even as a separate ruling found power plants exempt from providing electricity in emergencies under Texas law, underscoring the distinction between obligations and settlements. Whether ERCOT marked the short amount in real-time or not should not affect the settlement of these ancillary services.

On March 3, 2021, the PUCT ordered (a related press release is here) that:

ERCOT shall claw back all payments for ancillary service that were made to an entity that did not provide its required ancillary service during real time on ERCOT operating days starting February 14, 2021 and ending on February 19,2021.

On March 4, 2021, the IMM filed another report and recommended that:

the [PUCT] direct ERCOT to correct the real-time prices from 0:00 February 18,2021, to 09:00 February 19, 2021, to remove the inappropriate pricing intervention that occurred during that time period.

The IMM approvingly noted the PUCT's February 15, 2021 order, which mandated that real-time energy prices reflect firm load shed by setting prices at the value of lost load (VOLL).1

According to the IMM (emphasis added):

This is essential in an energy-only market, like ERCOT's, where the Texas power grid faces recurring crisis risks, because it provides efficient economic signals to increase the electric generation needed to restore the load and service it reliably over the long term.

Conversely, it is equally important that prices not reflect VOLL when the system is not in shortage and load is being served, and experiences in capacity markets show auction payouts can fall sharply under different conditions. The Commission recognized this principle in its Order, expressly stating it is only ERCOT's out-of-market shedding firm load that is required to be reflected in prices. Unfortunately, ERCOT exceeded the mandate of the Commission by continuing to set process at VOLL long after it ceased the firm load shed.

ERCOT recalled the last of the firm load shed instructions at 23:55 on February 17, 2021. Therefore, in order to comply with the Commission Order, the pricing intervention that raised prices to VOLL should have ended immediately at that time. However, ERCOT continued to hold prices at VOLL by inflating the Real-Time On-Line Reliability Deployment Price Adder for an additional 32 hours through the morning of February 19. This decision resulted in $16 billion in additional costs to ERCOT's market, prompting legislative bailout proposals in Austin, of which roughly $1.5 billion was uplifted to load-serving entities to provide make-whole payments to generators for energy that was not needed or produced.

However, at its March 5, 2021, open meeting (related discussion begins around minute 20), although the PUCT acknowledged the "good points" raised by the IMM, the PUCT was not willing to retrospectively adjust its real-time pricing for this period out of concerns that some related transactions (ICE futures and others) may have already settled and for unintended consequences of such retroactive adjustments.  

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California Electricity Reliability covers grid resilience amid heat waves, rolling blackouts, renewable energy integration, resource adequacy, battery storage, natural gas peakers, ISO oversight, and peak demand management to keep homes, businesses, and industry powered.

Key Points

Dependable California power delivery despite heat waves, peak demand, and challenges integrating renewables into grid.

✅ Rolling blackouts revealed gaps in resource adequacy.

✅ Early evening solar drop requires fast ramping and storage.

✅ Agencies pledge planning reforms and flexible backup supply.

One hallmark of an advanced society is a reliable supply of electrical energy for residential, commercial and industrial consumers. Uncertainty that California electricity will be there when we need it it undermines social cohesion and economic progress, as demonstrated by the travails of poor nations with erratic energy supplies.

California got a small dose of that syndrome in mid-August when a record heat wave struck the state and utilities were ordered to impose rolling blackouts to protect the grid from melting down under heavy air conditioning demands.

Gov. Gavin Newsom quickly demanded that the three overseers of electrical service to most of the state - the Public Utilities Commission, the Energy Commission and the California Independent Service Operator – explain what went wrong.

"These blackouts, which occurred without prior warning or enough time for preparation, are unacceptable and unbefitting of the nation's largest and most innovative state," Newsom wrote. "This cannot stand. California residents and businesses deserve better from their government."

Initially, there was some fingerpointing among the three entities. The blackouts had been ordered by the California Independent System Operator, which manages the grid and its president, Steve Berberich, said he had warned the Public Utilities Commission about the potential supply shortfall facing the state.

"We have indicated in filing after filing after filing that the resource adequacy program was broken and needed to be fixed," he said. "The situation we are in could have been avoided."

However, as political heat increased, the three agencies hung together and produced a joint report that admitted to lapses of supply planning and grid management and promised steps to avoid a repeat next summer.

"The existing resource planning processes are not designed to fully address an extreme heat storm like the one experienced in mid August," their report said. "In transitioning to a reliable, clean and affordable resource mix, resource planning targets have not kept pace to lead to sufficient resources that can be relied upon to meet demand in the early evening hours. This makes balancing demand and supply more challenging."

Although California's grid had experienced greater heat-related demands in previous years, most notably 2006, managers then could draw standby power from natural gas-fired plants and import juice from other Western states when necessary.

Since then, the state has shut down a number of gas-fired plants and become more reliant on renewable but less reliable sources such as windmills and solar panels.

August's air conditioning demand peaked just as output from solar panels was declining with the setting of the sun and grid managers couldn't tap enough electrons from other sources to close the gap.

While the shift to renewables didn't, unto itself, cause the blackouts, they proved the need for a bigger cushion of backup generation or power storage in batteries or some other technology. The Public Utilities Commission, as Beberich suggested, has been somewhat lax in ordering development of backup supply.

In the aftermath of the blackouts, the state Water Resources Control Board, no doubt with direction from Newsom's office, postponed planned shutdowns of more coastal plants, which would have reduced supply flexibility even more.

Shifting to 100% renewable electricity, the state's eventual goal, while maintaining reliability will not get any easier. The state's last nuclear plant, Diablo Canyon, is ticketed for closure and demand will increase as California eliminates gasoline- and diesel-powered vehicles in favor of "zero emission vehicles" as part of its climate policies push and phases out natural gas in homes and businesses.

Politicians such as Newsom and legislators in last week's blackout hearing may endorse a carbon-free future in theory, but they know that they'll pay the price as electricity prices climb if nothing happens when Californians flip the switch.

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U.S. Energy Transition Delays stem from grid bottlenecks, permitting red tape, solar tariff uncertainty, supply-chain shocks, and scarce affordable EVs, risking deeper fossil fuel lock-in despite climate targets for renewables, transmission expansion, and decarbonization.

Key Points

Delays driven by grid limits, permitting, and supply shocks that slow renewables, transmission, EVs, and decarbonization.

✅ Grid interconnection and transmission backlogs stall renewables

✅ Tariff probes and supply chains disrupt utility-scale solar

✅ Permitting, policy gaps, and EV costs sustain fossil fuel use

Big solar projects are facing major delays. Plans to adapt the grid to clean energy are confronting mountains of red tape. Affordable electric vehicles are in short supply.

The United States is struggling to squeeze opportunity out of an energy crisis that should have been a catalyst for cleaner, domestically produced power. After decades of putting the climate on the back burner, the country is finding itself unprepared to seize the moment and at risk of emerging from the crisis even more reliant on fossil fuels.

10 steps you can take to lower your carbon footprint
The problem is not entirely unique to the United States. Across the globe, climate leaders are warning that energy shortages including coal and nuclear disruptions prompted by Russia’s unprovoked invasion of Ukraine and high gas prices driven by inflation threaten to make the energy transition an afterthought — potentially thwarting efforts to keep global temperature rise under 1.5 degrees Celsius.

“The energy crisis exacerbated by the war in Ukraine has seen a perilous doubling down on fossil fuels by the major economies,” U.N. Secretary General António Guterres said at a conference in Vienna on Tuesday, according to prepared remarks. He warned governments and investors that a failure to immediately and more aggressively embrace clean energy could be disastrous for the planet.

U.S. climate envoy John F. Kerry suggested that nations are falling prey to a flawed logic that fossil fuels will help them weather this period of instability, undermining U.S. national security and climate goals, which has seen gas prices climb to a record-high national average of $5 per gallon. “You have this new revisionism suggesting that we have to be pumping oil like crazy, and we have to be moving into long-term [fossil fuel] infrastructure building,” he said at the Time100 Summit in New York this month. “We have to push back.”

Climate envoy John F. Kerry attends the Summit of the Americas in Los Angeles on June 8. Kerry has criticized the tendency to turn toward fossil fuels in times of uncertainty. (Apu Gomes/AFP/Getty Images)
In the United States — the world’s second-largest emitter of greenhouse gases after China — the hurdles go beyond the supply-chain crisis and sanctions linked to the war in Ukraine. The country’s lofty goals for all carbon pollution to be gone from the electricity sector by 2035 and for half the cars sold to be electric by 2030 are jeopardized by years of neglect of the electrical grid, regulatory hurdles that have set projects back years, and failures by Congress and policymakers to plan ahead.
The challenges are further compounded by plans to build costly new infrastructure for drilling and exporting natural gas that will make it even harder to transition away from the fossil fuel.

“We are running into structural challenges preventing consumers and businesses from going cleaner, even at this time of high oil and gas prices,” said Paul Bledsoe, a climate adviser in the Clinton administration who now works on strategy at the Progressive Policy Institute, a center-left think tank. “It is a little alarming that even now, Congress is barely talking about clean energy.”

Consumers are eager for more wind and solar. Companies looking to go carbon-neutral are facing growing waitlists for access to green energy, and a Pew Research Center poll in late January found that two-thirds of Americans want the United States to prioritize alternative energy over fossil fuel production.

But lawmakers have balked for more than a decade at making most of the fundamental economic and policy changes such as a clean electricity standard that experts widely agree are crucial to an orderly and accelerated energy transition. The United States does not have a tax on carbon, nor a national cap-and-trade program that would reorient markets toward lowering emissions. The unraveling in Congress of President Biden’s $1.75 trillion Build Back Better plan has added to the head winds that green-energy developers face, even as climate law results remain mixed.

Vice President Harris tours electric school buses at Meridian High School in Falls Church, Va., on May 20. (Mandel Ngan/AFP/Getty Images)
“There is literally nothing pushing this forward in the U.S. beyond the tax code and some state laws,” said Heather Zichal, a former White House climate adviser who is now the chief executive of the American Clean Power Association.

The effects of the U.S. government’s halting approach are being felt by solar-panel installers, who saw the number of projects in the most recent quarter fall to the lowest level since the pandemic began. There was 24 percent less solar installed in the first quarter of 2022 than in the same quarter of 2021.

The holdup largely stems from a Commerce Department investigation into alleged tariff-dodging by Chinese manufacturers. Faced with the potential for steep retroactive penalties, hundreds of industrial-scale solar projects were frozen in early April. Weak federal policies to encourage investment in solar manufacturing left American companies ill-equipped to fill the void.

“We shut down multiple projects and had to lay off dozens of people,” said George Hershman, chief executive of SOLV Energy, which specializes in large solar installations. SOLV, like dozens of other solar companies, is now scrambling to reassemble those projects after the administration announced a pause of the tariffs.

Meanwhile, adding clean electricity to the aging power grid has become an increasingly complicated undertaking, given the failure to plan for adequate transmission lines and long delays connecting viable wind and solar projects to the electricity network.

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Renewable Energy Security strengthens affordability and grid reliability through electrification, wind, and solar, reducing fossil fuel volatility exposed by the Ukraine crisis, aligning with IEA guidance and the Paris Agreement to deliver resilient, low-cost power.

Key Points

Renewable energy security is reliable, affordable power from electrification, wind and solar, cutting fossil fuel risk.

✅ Wind and solar now outcompete gas for new power capacity.

✅ Diversifies supply and reduces fossil price volatility.

✅ Requires grid flexibility, storage, and demand response.

Oil, gas, and coal have been the central pillar of the global energy system throughout the 20th century. And for decades, these fossil fuels have been closely associated with energy security.  

The perception of energy security, however, is rapidly changing. Renewables form an increasing share of energy sectors worldwide as countries look to deliver on the Paris Agreement and mitigate the effects of climate change, with IEA clean energy investment now significantly outpacing fossil fuels. Moreover, Russia’s invasion of Ukraine has demonstrated how relying on fossil fuels for power, heating, and transport has left many countries vulnerable or energy insecure.  

The International Energy Agency (IEA) defines energy security as “the uninterrupted availability of energy sources at an affordable price” (IEA, 2019a). This definition hardly describes today’s global energy situation, with the cancellation of natural gas deliveries and skyrocketing prices for oil and gas products, and with supply chain challenges in clean energy that also require attention. These circumstances have cascading effects on electricity prices in countries like the United Kingdom that rely heavily on natural gas to produce electricity. In Europe, energy insecurity has been even further amplified since the Russian corporation Gazprom recently cut off gas supplies to several countries.  

As a result, energy security has gained new urgency in Canada and worldwide, creating opportunities in the global electricity market for Canada. Recent events provide a stark reminder of the volatility and potential vulnerability of global fossil fuel markets and supply chains. Even in Canada, as one of the largest producers of oil and gas in the world, the price of fuels depends on global and regional market forces rather than government policy or market design. Thus, the average monthly price for gasoline in Canada hit a record high of CAD 2.07 per litre in May 2022 (Figure 1), and natural gas prices surged to a record CAD 7.54 per MMBtu in May 2022 (Figure 2).  

Energy price increases of this magnitude are more than enough to strain Canadian household budgets. But on top of that, oil and gas prices have accelerated inflation more broadly as it has become more expensive to produce, transport, and store goods, including food and other basic commodities (Global News, 2022).  

Renewable Energy Is More Affordable 

In contrast to oil and gas, renewable energy can reliably deliver affordable energy, as shown by falling wholesale electricity prices in markets with growing clean power. This is a unique and positive aspect of today’s energy crisis compared to historical crises: options for electrification and renewable-based electricity systems are both available and cost-effective.  

For new power capacity, wind and solar are now cheaper than any other source, and wind power is making gains as a competitive source in Canada. According to Equinor (2022), wind and solar were already cheaper than gas-based power in 2020. This means that renewable energy was already the cheaper option for new power before the recent natural gas price spikes. As illustrated in Figure 3, the cost of new renewable energy has dropped so dramatically that, for many countries, it is cheaper to install new solar or wind infrastructure than to keep operating existing fossil fuel-based power plants (International Renewable Energy Agency, 2021). This means that replacing fossil-based electricity generation with renewables would save money and reduce emissions. Wind and solar prices are expected to continue their downward trends as more countries increase deployment and learn how to best integrate these sources into the grid. 

Renewable Energy Is Reliable 

To deliver on the uninterrupted availability side of the energy security equation, renewable power must remain reliable even as more variable energy sources, like wind and solar, are added to the system, and regional leaders such as the Prairie provinces will help anchor this transition. For Canada and other countries to achieve high energy security through electrification, grid system operations must be able to support this, and pathways to zero-emissions electricity by 2035 are feasible.  

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SunCrate Solar Microgrid delivers resilient, plug-and-play renewable power to Puerto Rico schools, combining Canadian Solar PV, Tesla Powerwall battery storage, and Black & Veatch engineering to ensure off-grid continuity during outages and disasters.

Key Points

A compact PV-and-battery system for resilient, diesel-free power and microgrid backup at schools and clinics.

✅ Plug-and-play, modular PV, inverter, and battery architecture

✅ Tesla Powerwall storage; Canadian Solar 325 W panels

✅ Scales via daisy-chain for higher loads and microgrids

Eleven months since their three-building school was first plunged into darkness by Hurricane Maria, 140 students in Puerto Rico’s picturesque Yabucoa district have reliable power. Resilient electricity service was provided Saturday to the SU Manuel Ortiz school through an innovative scalable, plug-and-play solar system pioneered by SunCrate Energy with Black & Veatch support. Known as a “SunCrate,” the unit is an effective mitigation measure to back up the traditional power supply from the grid. The SunCrate can also provide sustainable power in the face of ongoing system outages and future natural disasters without requiring diesel fuel.

The humanitarian effort to return sustainable electricity to the K-8 school, found along the island’s hard-hit southeastern coast, drew donated equipment and expertise from a collection of North American companies. Additional support for the Yabucoa project came from Tesla, Canadian Solar and Lloyd Electric, reflecting broader efforts to build a solar-powered grid in Puerto Rico after Hurricane Maria.

“We are grateful for this initiative, which will equip this school with the technology needed to become a resilient campus and not dependent on the status of the power grid. This means that if we are hit with future harmful weather events, the school will be able to open more quickly and continue providing services to students,” Puerto Rico Secretary of Education Julia Keleher said.

The SunCrate harnesses a scalable rapid-response design developed by Black & Veatch and manufactured by SunCrate Energy. Electricity will be generated by an array of 325-W CS6U-Poly modules from Canadian Solar. California-based Tesla contributed advanced battery energy storage through various Powerwall units capable of storing excess solar power and delivering it outside peak generation periods, with related experience from a virtual power plant in Texas informing deployment.  Lloyd Electric Co. of Wichita Falls, Texas, partnered to support delivery and installation of the SunCrate.

“As families in the region begin to prepare for the school year, this community is still impacted by the longest U.S. power outage in history,” said Dolf Ivener, a Midwestern entrepreneur who owns King of Trails Construction and SunCrate Energy, which is donating the SunCrate. “SunCrate, with its rapid deployment and use of renewable energy, should give this school peace of mind and hopefully returns a touch of long-overdue normalcy to students and their parents. When it comes to consistent power, SunCrate is on duty.”

The SunCrate is a portable renewable energy system conceived by Ivener and designed and tested by Black & Veatch. Its modular design uses solar PV panels, inverters and batteries to store and provide electric power in support of critical services such as police, fire, schools, clinics and other community level facilities.

A SunCrate can generate 23 to 156 kWh per day, and store 10 kWh to 135 kWh depending on configuration. A SunCrate’s power generation and storage capacity can be easily scaled through daisy-chained configurations to accommodate larger buildings and loads. Leveraging resources from Tesla, Canadian Solar, Lloyd Electric and Lord Electric, the unit in Yabucoa will provide an estimated 52 kWh of storable power without requiring use of costlier diesel-powered generators and cutting greenhouse gas emissions. Its capabilities allow the school to strengthen its function as a designated Community Emergency Response Center in the event of future natural disasters.

“Canadian Solar has a long history of using solar power to support humanitarian efforts aiding victims of social injustice and natural disasters, including previous donations to Puerto Rico after Hurricane Maria,” said Dr. Shawn Qu, Chairman and Chief Executive Officer of Canadian Solar. “We are pleased to make the difference for these schoolchildren in Yabucoa who have been without reliable power for too long.”

The SunCrate will also substantially lower the school’s ongoing electricity costs by providing a reliable source of renewable energy on site, as falling costs of solar batteries improve project economics overall.

“Through our experience providing engineering services in Puerto Rico for nearly 50 years, including dozens of specialized projects for local government and industrial clients, we see great potential for SunCrate as a source of resilient power for the Commonwealth’s remote schools and communities at large, underscoring the importance of electricity resilience across critical infrastructure,” said Charles Moseley, a Program Director in Black & Veatch’s water business. “We hope that the deployment of the SunCrate in Yabucoa sets a precedent for facility and municipal level migro-grid efforts on the island and beyond.”

SunCrate also has broad potential applications in conflict/post-conflict environments and in rural electrification efforts in the developing world, serving as a resilient source of electricity within hours of its arrival on site and could enable peer-to-peer energy within communities. Of particular benefit, the system’s flexibility cuts fuel costs to a fraction of a generator’s typical consumption when they are used around the clock with maintenance requirements.

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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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