Crunch time for alternative-energy startups

By Globe and Mail


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Canada's nascent clean-tech sector has joined the growing list of battered industries looking for emergency government support.

With debt and equity financing increasingly tough to find, and oil prices hitting four-year lows, many companies that offer alternative energy and efficient technologies are facing a life-and-death struggle, says Vicky Sharpe, chief executive officer of Sustainable Development Technology Canada (SDTC).

"The clean-tech sector, like all the others, is facing issues over the availability of new capital," Ms. Sharpe said.

While North American venture funds are still offering early-stage and second-round investing, startup companies that need to raise capital from debt and equity markets for commercial-scale projects are running into road blocks.

"There is huge momentum in the groups of companies that SDTC has supported and (government) needs to make sure that there's investment to take these companies through to market," she said. "It would be a shame to leave them hanging there — which means some of them may not survive the wait until the price of energy goes back up."

The federal government is facing a growing clamour for support from industries mauled by the economic and financial downturn, including the auto sector, aerospace and forestry companies.

SDTC is set to announce its 13th round of financing for clean-tech startups, most of whom have energy-saving and renewable-energy technology. The fund also supports companies that have clean-air and clean-water technologies.

To date, it has allocated $342-million for 144 clean-tech projects, leveraging another $800-million in investment from the private sector or provincial funds.

But the financing only supports pre-commercial development, and Ms. Sharpe is urging the government to provide additional funding and a revamped mandate to allow SDTC to assist companies that face commercial-stage expansions but are having trouble accessing capital.

The agency already has such an expanded mandate for ethanol and other biofuels.

The Harper government allocated $500-million to the agency to support the commercial development of next-generation biofuels — ethanol and biodiesel made from agricultural, forestry and other waste streams. SDTC is now reviewing several applications for support from that fund.

Despite the pressures on it from sagging oil and gas prices, and the capital market meltdown, Ms. Sharpe insisted critics are misguided when they proclaim the death of the clean-tech sector.

Governments around the world, including the American and Canadian administrations, are embracing greenhouse gas emission targets and energy security mandates that will ensure a market for technologies that offer energy efficiency, as well as renewables like solar and wind.

And while some critics suggest the clean-tech sector is too dependent on subsidies to be viable, its supporters contend those subsidies merely reflect governments' efforts to create markets for technologies that reduce pollution and greenhouse gas emissions, in the absence of carbon taxes or other more punitive abatement measures.

Ms. Sharpe acknowledged, however, some companies — notably in the solar sector - may have been overvalued, even relative to market conditions that existed before the most recent tailspin.

She said companies that are sensitive to oil prices — especially ethanol producers and those that provide fuel-saving technologies — are being squeezed now, but should eventually see prices recover. And the higher prices will restore the economic appeal of alternative fuels and technologies aimed at improving energy efficiency.

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Feds "changing goalposts" with 2035 net-zero electricity grid target: Sask. premier

Canada Clean Electricity Regulations outline a 2035 net-zero grid target, driving decarbonization via wind, solar, hydro, SMRs, carbon capture, and efficiency, balancing reliability, affordability, and federal-provincial collaboration while phasing out coal and limiting fossil-fuel generation.

 

Key Points

Federal rules to cap CO2 from power plants and deliver a reliable, affordable net-zero grid by 2035.

✅ Applies to fossil-fired units; standards effective by Jan 1, 2035.

✅ Promotes wind, solar, hydro, SMRs, carbon capture, and efficiency.

✅ Balances reliability, affordability, and emissions cuts; ongoing consultation.

 

Saskatchewan’s premier said the federal government is “changing goalposts” with its proposed target for a net-zero electricity grid.

“We were looking at a net-zero plan in Saskatchewan and across Canada by the year 2050. That’s now been bumped to 2035. Well there are provinces that quite frankly aren’t going to achieve those types of targets by 2035,” Premier Scott Moe said Wednesday.

Ottawa proposed the Clean Electricity Regulations – formerly the Clean Electricity Standard – as part of its target for Canada to transition to net-zero emissions by 2050.

The regulations would help the country progress towards an updated proposed goal of a net-zero electricity grid by 2035.

“They’re un-consulted, notional targets that are put forward by the federal government without working with industries, provinces or anyone that’s generating electricity,” Moe said.

The Government of Canada was seeking feedback from stakeholders on the plan’s regulatory framework document earlier this year, up until August 2022.

“The clean electricity standard is something that’s still being consulted on and we certainly heard the views of Saskatchewan – not just Saskatchewan, many other provinces – and I think that’s something that’s being reflected on,” Jonathan Wilkinson, Canada’s minister of natural resources, said during an event near Regina Wednesday.

“We also recognize that the federal government has a role to play in helping provinces to make the kinds of changes that would need to be made in order to actually achieve a clean grid,” Wilkinson added.

The information received during the consultation will help inform the development of the proposed regulations, which are expected to be released before the end of the year, according to the federal government.


NET-ZERO ELECTRICITY GRID
The federal government said its Clean Electricity Regulations (CER) is part of a suite of measures, as the country moves towards a broad “decarbonization” of the economy, with Alberta's clean electricity path illustrating provincial approaches as well.

Net-zero emissions would mean Canada’s economy would either emit no greenhouse gas emissions or offset its emissions.

The plan encourages energy efficiency, abatement and non-emitting generation technologies such as carbon capture and storage and electricity generation options such as solar, wind, geothermal, small modular nuclear reactors (SMRs) and hydro, among others.

The government suggests consumer costs could be lowered by using some of these energy efficiency techniques, alongside demand management and a shift to lower-cost wind and solar power, echoing initiatives like the SaskPower 10% rebate aimed at affordability.

The CER focuses on three principles, each tied to affordability debates like the SaskPower rate hike in Saskatchewan:

 Maximize greenhouse gas reductions to achieve the 2035 target
 Ensure a reliable electrical grid to support Canadians and the economy
 Maintain electrical affordability

“Achieving a net-zero electricity supply is key to reaching Canada’s climate targets in two ways,” the government said in its proposed regulations.

“First, it will reduce [greenhouse gas] emissions from the production of electricity. Second, using clean electricity instead of fossil fuels in vehicles, heating and industry will reduce emissions from those sectors too.

The regulations would regulate carbon dioxide emissions from electricity generating units that combust any amount of fossil fuel, have a capacity above a small megawatt threshold and sell electricity onto a regulated electricity system.

New rules would also be implemented for the development of new electricity generation units firing fossil fuels in or after 2025 and existing units. All units would be subject to emission standards by Jan. 1, 2035, at the latest.

The federal government launched consultations on the proposed regulations in March 2022.

Canada also has a 2030 emissions reduction plan that works towards meeting its Paris Agreement target to reduce emissions by 40-45 per cent from 2005 levels by 2030. This plan includes regulations to phase out coal-fired electricity by 2030.


COLLABORATION
The province recently introduced the Saskatchewan First Act, in an attempt to confirm its own jurisdiction and sovereignty when it comes to natural resources.

The act would amend Saskatchewan’s constitution to exert exclusive legislative jurisdiction under the Constitution of Canada.

The province is seeking jurisdiction over the exploration of non-renewable resources, the development, conservation and management of non-renewable natural and forestry resources, and the operation of sites and facilities for the generation and production of electrical energy.

While the federal government and Saskatchewan have come head-to-head publicly over several policy concerns in the past year, both sides remain open to collaborating on issues surrounding natural resources.

“We do have provincial jurisdiction in the development of these natural resources. We’d like to work collaboratively with the federal government on developing some of the most sustainable potash, uranium, agri-food products in the world,” Moe said.

Minister Wilkinson noted that while both the federal and provincial governments aim to respect each other’s jurisdiction, there is often some overlap, particularly in the case of environmental and economic policies, with Alberta's electricity sector changes underscoring those tensions as well.

“My view is we should endeavour to try to figure out ways that we can work together, and to ensure that we’re actually making progress for Saskatchewanians and for Canadians,” Wilkinson said.

“I think that Canadians expect us to try to figure out ways to work together, and where there are some disputes that can’t get resolved, ultimately the Supreme Court will decide on the issue of jurisdiction as they did in the case on the price on pollution.”

Moe said Saskatchewan is always open to working with the federal government, but not at the expense of its “provincial, constitutional autonomy.”

 

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Oil crash only a foretaste of what awaits energy industry

Oil and Gas Profitability Decline reflects shale-driven oversupply, OPEC-Russia dynamics, LNG exports, renewables growth, and weak demand, signaling compressed margins for producers, stressed petrodollar budgets, and shifting energy markets post-Covid.

 

Key Points

A sustained squeeze on hydrocarbon margins from agile shale supply, weaker OPEC leverage, and expanding renewables.

✅ Shale responsiveness caps prices and erodes industry rents

✅ OPEC-Russia cuts face limited impact versus US supply

✅ Renewables and EVs slow long-term oil and gas demand

 

The oil-price crash of March 2020 will probably not last long. As in 2014, when the oil price dropped below $50 from $110 in a few weeks, this one will trigger a temporary collapse of the US shale industry. Unless the coronavirus outbreak causes Armageddon, cheap oil will also support policymakers’ efforts to help the global economy.

But there will be at least one important and lasting difference this time round — and it has major market and geopolitical implications.

The oil price crash is a foretaste of where the whole energy sector was going anyway — and that is down.

It may not look that way at first. Saudi Arabia will soon realise, as it did in 2015, that its lethal decision to pump more oil is not only killing US shale but its public finances as well. Riyadh will soon knock on Moscow’s door again. Once American shale supplies collapse, Russia will resume co-operation with Saudi Arabia.

With the world economy recovering from the Covid-19 crisis by then, and with electricity demand during COVID-19 shifting, moderate supply cuts by both countries will accelerate oil market recovery. In time, US shale producers will return too.

Yet this inevitable bounceback should not distract from two fundamental factors that were already remaking oil and gas markets. First, the shale revolution has fundamentally eroded industry profitability. Second, the renewables’ revolution will continue to depress growth in demand.

The combined result has put the profitability of the entire global hydrocarbon industry under pressure. That means fewer petrodollars to support oil-producing countries’ national budgets, including Canada's oil sector exposures. It also means less profitable oil companies, which traditionally make up a large segment of stock markets, an important component of so many western pension funds.

Start with the first factor to see why this is so. Historically, the geological advantages that made oil from countries such as Saudi Arabia so cheap to produce were unique. Because oil and gas were produced at costs far below the market price, the excess profits, or “rent”, enjoyed by the industry were very large.

Furthermore, collusion among low-cost producers has been a winning strategy. The loss of market share through output cuts was more than compensated by immediately higher prices. It was the raison d’être of Opec.

The US shale revolution changed all this, exposing the limits of U.S. energy dominance narratives. A large oil-producing region emerged with a remarkable ability to respond quickly to price changes and shrink its costs over time. Cutting back cheap Opec oil now only increases US supplies, with little effect on world prices.

That is why Russia refused to cut production this month. Even if its cuts did boost world prices — doubtful given the coronavirus outbreak’s huge shock to demand — that would slow the shrinkage of US shale that Moscow wants.

Shale has affected the natural gas industry even more. Exports of US liquefied natural gas now put an effective ceiling on global prices, and debates over a clean electricity push have intensified when gas prices spike.

On top of all this, there is also the renewables’ revolution, though a green revolution has not been guaranteed in the near term. Around the world, wind and solar have become ever-cheaper options to generate electricity. Storage costs have also dropped and network management improved. Even in the US, renewables are displacing coal and gas. Electrification of vehicle fleets will damp demand further, as U.S. electricity, gas, and EVs face evolving pressures.

Eliminating fossil fuel consumption completely would require sustained and costly government intervention, and reliability challenges such as coal and nuclear disruptions add to the complexity. That is far from certain. Meanwhile, though, market forces are depressing the sector’s usual profitability.

The end of oil and gas is not immediately around the corner. Still, the end of hydrocarbons as a lucrative industry is a distinct possibility. We are seeing that in dramatic form in the current oil price crash. But this collapse is merely a message from the future.

 

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Which of the cleaner states imports dirty electricity?

Hourly Electricity Emissions Tracking maps grid balancing areas, embodied emissions, and imports/exports, revealing carbon intensity shifts across PJM, ERCOT, and California ISO, and clarifying renewable energy versus coal impacts on health and climate.

 

Key Points

An hourly method tracing generation, flows, and embodied emissions to quantify carbon intensity across US balancing areas.

✅ Hourly traces of imports/exports and generation mix

✅ Consumption-based carbon intensity by balancing area

✅ Policy insights for renewables, coal, health costs

 

In the United States, electricity generation accounts for nearly 30% of our carbon emissions. Some states have responded to that by setting aggressive renewable energy standards; others are hoping to see coal propped up even as its economics get worse. Complicating matters further is the fact that many regional grids are integrated, and as America goes electric the stakes grow, meaning power generated in one location may be exported and used in a different state entirely.

Tracking these electricity exports is critical for understanding how to lower our national carbon emissions. In addition, power from a dirty source like coal has health and environment impacts where it's produced, and the costs of these aren't always paid by the parties using the electricity. Unfortunately, getting reliable figures on how electricity is produced and where it's used is challenging, even for consumers trying to find where their electricity comes from in the first place, leaving some of the best estimates with a time resolution of only a month.

Now, three Stanford researchers—Jacques A. de Chalendar, John Taggart, and Sally M. Benson—have greatly improved on that standard, and they have managed to track power generation and use on an hourly basis. The researchers found that, of the 66 grid balancing areas within the United States, only three have carbon emissions equivalent to our national average, and they have found that imports and exports of electricity have both seasonal and daily changes. de Chalendar et al. discovered that the net results can be substantial, with imported electricity increasing California's emissions/power by 20%.

Hour by hour
To figure out the US energy trading landscape, the researchers obtained 2016 data for grid features called balancing areas. The continental US has 66 of these, providing much better spatial resolution on the data than the larger grid subdivisions. This doesn't cover everything—several balancing areas in Canada and Mexico are tied in to the US grid—and some of these balancing areas are much larger than others. The PJM grid, serving Pennsylvania, New Jersey, and Maryland, for example, is more than twice as large as Texas' ERCOT, in a state that produces and consumes the most electricity in the US.

Despite these limitations, it's possible to get hourly figures on how much electricity was generated, what was used to produce it, and whether it was used locally or exported to another balancing area. Information on the generating sources allowed the researchers to attach an emissions figure to each unit of electricity produced. Coal, for example, produces double the emissions of natural gas, which in turn produces more than an order of magnitude more carbon dioxide than the manufacturing of solar, wind, or hydro facilities. These figures were turned into what the authors call "embodied emissions" that can be traced to where they're eventually used.

Similar figures were also generated for sulfur dioxide and nitrogen oxides. Released by the burning of fossil fuels, these can both influence the global climate and produce local health problems.

Huge variation
The results were striking. "The consumption-based carbon intensity of electricity varies by almost an order of magnitude across the different regions in the US electricity system," the authors conclude. The low is the Bonneville Power grid region, which is largely supplied by hydropower; it has typical emissions below 100kg of carbon dioxide per megawatt-hour. The highest emissions come in the Ohio Valley Electric region, where emissions clear 900kg/MW-hr. Only three regional grids match the overall grid emissions intensity, although that includes the very large PJM (where capacity auction payouts recently fell), ERCOT, and Southern Co balancing areas.

Most of the low-emissions power that's exported comes from the Pacific Northwest's abundant hydropower, while the Rocky Mountains area exports electricity with the highest associated emissions. That leads to some striking asymmetries. Local generation in the hydro-rich Idaho Power Company has embodied emissions of only 71kg/MW-hr, while its imports, coming primarily from Rocky Mountain states, have a carbon content of 625kg/MW-hr.

The reliance on hydropower also makes the asymmetry seasonal. Local generation is highest in the spring as snow melts, but imports become a larger source outside this time of year. As solar and wind can also have pronounced seasonal shifts, similar changes will likely be seen as these become larger contributors to many of these regional grids. Similar things occur daily, as both demand and solar production (and, to a lesser extent, wind) have distinct daily profiles.

The Golden State
California's CISO provides another instructive case. Imports represent less than 30% of its total electric use in 2016, yet California electricity imports provided 40% of its embodied emissions. Some of these, however, come internally from California, provided by the Los Angeles Department of Water and Power. The state itself, however, has only had limited tracking of imported emissions, lumping many of its sources as "other," and has been exporting its energy policies to Western states in ways that shape regional markets.

Overall, the 2016 inventory provides a narrow picture of the US grid, as plenty of trends are rapidly changing our country's emissions profile, including the rise of renewables and the widespread adoption of efficiency measures and other utility trends in 2017 that continue to evolve. The method developed here can, however, allow for annual updates, providing us with a much better picture of trends. That could be quite valuable to track things like how the rapid rise in solar power is altering the daily production of clean power.

More significantly, it provides a basis for more informed policymaking. States that wish to promote low-emissions power can use the information here to either alter the source of their imports or to encourage the sites where they're produced to adopt more renewable power. And those states that are exporting electricity produced primarily through fossil fuels could ensure that the locations where the power is used pay a price that includes the health costs of its production.

 

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Can COVID-19 accelerate funding for access to electricity?

Africa Energy Access Funding faces disbursement bottlenecks as SDG 7 goals demand investment in decentralized solar, minigrids, and rural electrification; COVID-19 pressures donors, requiring faster approvals, standardized documentation, and stronger project preparation and due diligence.

 

Key Points

Financing to expand Africa's electrification, advancing SDG 7 via disbursement to decentralized solar and minigrids.

✅ Accelerates investment for SDG 7 and rural electrification

✅ Prioritizes decentralized solar, minigrids, and utilities

✅ Speeds approvals, standard docs, and project preparation

 

The time frame from final funding approval to disbursement can be the most painful part of any financing process, and the access-to-electricity sector is not spared.

Amid the global spread of the coronavirus over the last few weeks, there have been several funding pledges to promote access to electricity in Africa. In March, the African Development Bank and other partners committed $160 million for the Facility for Energy Inclusion to boost electricity connectivity in Africa through small-scale solar systems and minigrids. Similarly, the Export-Import Bank of the United States allocated $91.5 million for rural electrification in Senegal.

Rockefeller chief wants to redefine 'energy poverty'

Rajiv Shah, president of The Rockefeller Foundation, believes that SDG 7 on energy access lacks ambition. He hopes to drive an effort to redefine it.

Currently, funding is not being adequately deployed to help achieve universal access to energy. The International Energy Agency’s “Africa Energy Outlook 2019” report estimated that an almost fourfold increase in current annual access-to-electricity investments — approximately $120 billion a year over the next 20 years — is required to provide universal access to electricity for the 530 million people in Africa that still lack it.

While decentralized renewable energy across communities, particularly solar, has been instrumental in serving the hardest-to-reach populations, tracking done by Sustainable Energy for All — in the 20 countries with about 80% of those living without access to sustainable energy — suggests that decentralized solar received only 1.2% of the total electricity funding.

The spread of COVID-19 is contributing significantly to Africa’s electricity challenges across the region, creating a surge in the demand for energy from the very important health facilities, an exponential increase in daytime demand as a result of most people staying and working indoors, and a rise from some food processing companies that have scaled up their business operations to help safeguard food security, among others. Thankfully — and rightly so — access-to-electricity providers are increasingly being recognized as “essential service” providers amid the lockdowns across cities.

To start tackling Africa’s electricity challenges more effectively, “funding-ready” energy providers must be able to access and fulfill the required conditions to draw down on the already pledged funding. What qualifies as “funding readiness” is open to argument, but having a clear, commercially viable business and revenue model that is suitable for the target market is imperative.

Developing the skills required to navigate the due-diligence process and put together relevant project documents is critical and sometimes challenging for companies without prior experience. Typically, the final form of all project-related agreements is a prerequisite for the final funding approval.

In addition, having the right internal structures in place — for example, controls to prevent revenue leakage, an experienced management team, a credible board of directors, and meeting relevant regulatory requirements such as obtaining permits and licenses — are also important indicators of funding readiness.

1. Support for project preparation. Programs — such as the Private Financing Advisory Network and GET.invest’s COVID-19 window — that provide business coaching to energy project developers are key to helping surmount these hurdles and to increasing the chances of these projects securing funding or investment. Donor funding and technical-assistance facilities should target such programs.

2. Project development funds. Equity for project development is crucial but difficult to attract. Special funds to meet this need are essential, such as the $760,000 for the development of small-scale renewable energy projects across sub-Saharan Africa recently approved by the African Development Bank-managed Sustainable Energy Fund for Africa.

3. Standardized investment documentation. Even when funding-ready energy project developers have secured investors, delays in fulfilling the typical preconditions to draw down funds have been a major concern. This is a good time for investors to strengthen their technical assistance by supporting the standardization of approval documents and funding agreements across the energy sector to fast-track the disbursement of funds.

4. Bundled investment approvals and more frequent approval sessions. While we implement mechanisms to hasten the drawdown of already pledged funding, there is no better time to accelerate decision-making for new access-to-electricity funding to ensure we are better prepared to weather the next storm. Donors and investors should review their processes to be more flexible and allow for more frequent meetings of investment committees and boards to approve transactions. Transaction reviews and approvals can also be conducted for bundled projects to reduce transaction costs.

5. Strengthened local capacity. African countries must also commit to strengthening the local manufacturing and technical capacity for access-to-electricity components through fiscal incentives such as extended tax holidays, value-added-tax exemptions, accelerated capital allowances, and increased investment allowances.

The ongoing pandemic and resulting impacts due to lack of electricity have further shown the need to increase the pace of implementation of access-to-electricity projects. We know that some of the required capital exists, and much more is needed to achieve Sustainable Development Goal 7 — about access to affordable and clean energy for all — by 2030.

It is time to accelerate our support for access-to-electricity companies and equip them to draw down on pledged funding, while calling on donors and investors to speed up their funding processes to ensure the electricity gets to those most in need.

 

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Failed PG&E power line blamed for Drum fire off Hwy 246 last June

PG&E Drum Fire Cause identified as a power line failure in Santa Barbara County, with arcing electricity igniting vegetation near Buellton on Drum Canyon Road; 696 acres burned as investigators and CPUC review PG&E safety.

 

Key Points

A failed PG&E power line sparked the 696-acre Drum Fire near Buellton; the utility is conducting its own probe.

✅ Power line failed between poles, arcing ignited vegetation.

✅ 696 acres burned; no structures damaged or injuries.

✅ PG&E filed CPUC incident report; ongoing investigation.

 

A downed Pacific Gas and Electric Co. power line was the cause of the Drum fire that broke out June 14 on Drum Canyon Road northwest of Buellton, a reminder that a transformer explosion can also spark multiple fires, the Santa Barbara County Fire Department announced Thursday.

The fire broke out about 12:50 p.m. north of Highway 246 and burned about 696 acres of wildland before firefighters brought it under control, although no structures were damaged or mass outages like the Los Angeles power outage occurred, according to an incident summary.

A team of investigators pinpointed the official cause as a power line that failed between two utility poles and fell to the ground, and as downed line safety tips emphasize, arcing electricity ignited the surrounding vegetation, said County Fire Department spokesman Capt. Daniel Bertucelli.

In response, a PG&E spokesman said the utility is conducting its own investigation and does not have access to whatever data investigators used, and, as the ATCO regulatory penalty illustrates, such matters can draw significant oversight, but he noted the company filed an electric incident report on the wire with the California Public Utilities Commission on June 14.

"We are grateful to the first responders who fought the 2020 Drum fire in Santa Barbara County and helped make sure that there were no injuries or fatalities, outcomes not always seen in copper theft incidents, and no reports of structures damaged or burned," PG&E spokesman Mark Mesesan said.

"While we are continuing to conduct our own investigation into the events that led to the Drum fire, and as the Site C watchdog inquiry shows, oversight bodies can seek more transparency, PG&E does not have access to the Santa Barbara County Fire Department's report."

He said PG&E remains focused on reducing wildfire risk across its service area while limiting the scope and duration of public safety power shutoffs, including strategies like line-burying decisions adopted by other utilities, and that the safety of customers and communities it serves are its most important responsibility.

 

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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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Whether you would prefer Live Online or In-Person instruction, our electrical training courses can be tailored to meet your company's specific requirements and delivered to your employees in one location or at various locations.