Green energy group leaves out consumers

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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Hydro One investment risk reflects Ontario government influence, board shakeup, Avista acquisition uncertainty, regulatory hearings, dividend growth prospects, and utility M&A moves in Peterborough, with stock volatility since the 2015 IPO.

Key Points

Hydro One investment risk stems from political control, governance turnover, regulatory outcomes, and uncertain M&A.

✅ Ontario retains near-50% stake, affecting autonomy and policy risk

✅ Board overhaul and CEO exit create governance uncertainty

✅ Avista deal, OEB hearings, local utility M&A drive outcomes

Hydro One may be only half-owned by the province on Ontario but that’s enough to cause uncertainty about the company’s future, thus making for an investment risk, says Douglas Kee of Leon Frazer & Associates.

Since its IPO in November of 2015, Hydro One has seen its share of ups and downs, including a Q2 profit decline earlier this year, mostly downs at this point. Currently trading at $19.87, the stock has lost 11 per cent of its value in 2018 and 12 per cent over the last 12 months, despite a one-time gain boosting Q2 profit that followed a court ruling.

This year has been a turbulent one, to say the least, as newly elected Ontario premier Doug Ford made good this summer on his campaign promise re Hydro One by forcing the resignation of the company’s 14-person board of directors along with the retirement of its chief executive, an event that saw Hydro One shares fall amid the turmoil. An interim CEO has been found and a new 10-person board and chairman put in place, but Kee says it’s unclear what impact the shakeup will ultimately have, other than delaying a promising-looking deal to purchase US utility Avista Corp, with the companies moving to ask the U.S. regulator to reconsider the order.

Douglas Kee’s take on Hydro One stock

“We looked at Hydro One a couple of times two years ago and just decided that with the Ontario government’s still owning a big chunk of the company … there are other public companies where you get the same kind of yield, the same kind of dividend growth, so we just avoided it,” says Kee, managing director and chief investment officer with Leon Frazer & Associates, to BNN Bloomberg.

“The old board versus the new board, I’m not sure that there’s much of an improvement. It was politics more than anything,” he says. “The unfortunate part is that the acquisition they were making in the United States is kind of on hold for now. The regulatory procedures have gone ahead but they are worried, and I guess the new board has to make a decision whether to go ahead with it or not.”

“Their transmissions side is coming up for regulatory hearings next year, which could be difficult in Ontario,” says Kee. “The offset to that is that there are a lot of municipal distributions systems in Ontario that may be sold — they bought one in Peterborough recently, which was a good deal for them. There may be more of that coming too.”

Last month, Hydro One reached an agreement with the City of Peterborough to buy its Peterborough Distribution utility which serves about 37,000 customers for $105 million. Another deal to purchase Orillia Power Distribution Corp for $41 million has been cancelled after an appeal to the Ontario Energy Board was denied in late August. Hydro One’s sought-after Avista Corp acquisition is reported to be worth $7 billion.

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UK Marine Energy and Climate Resilience can counter sea level rise and storm surge with tidal power, subsea turbines, heat pumps, and flood barriers, delivering renewable electricity, stability, and coastal protection for the United Kingdom.

Key Points

Integrated use of tidal power, barriers, and heat pumps to curb sea level rise, manage storms, and green the UK grid.

✅ Tidal bridges and subsea turbines enhance baseload renewables

✅ Integrated barriers cut storm surge and river flood risk

✅ Heat pumps and marine heat networks decarbonize coastal cities

IN concentrating on electrically driven cars, the UK’s new ten-point energy plans, and recent UK net zero policies, ignores the elephant in the room.

It fails to address the forecast six-metre sea level rise from global warming rapidly melting the Greenland ice sheet.

Rising sea levels and storm surge, combined with increasingly heavy rainfall swelling our rivers, threaten not only hundreds of coastal communities but also much unprotected strategic infrastructure, including electricity systems that need greater resilience.

New nuclear power stations proposed in this United Kingdom plan would produce radioactive waste requiring thousands of years to safely decay.

This is hardly the solution for the Green Energy future, or the broader global energy transition, that our overlooked marine energy resource could provide.

Sea defences and barrier design, built and integrated with subsea turbines and heat pumps, can deliver marine-driven heat and power to offset the costs, not only of new Thames Barriers, but also future Severn, Forth and other barrages, while reducing reliance on high-GWP gases such as SF6 in switchgear across the grid.

At the Pentland Firth, existing marine turbine power could be enhanced by turbines deployed from new tidal bridges to provide much of UK’s electricity needs, as nations chart an electricity future that replaces fossil fuels, from its estimated 60 gigawatt capability.

Energy from Bluemull Sound could likewise be harvested and exported or used to enhance development around UK’s new space station at Unst.

The 2021 Climate Change Summit gives Glasgow the platform to secure Scotland’s place in a true green, marine energy future and help build an electric planet for the long term.

We must not waste this opportunity.

THERE is no vaccine for climate change.

It is, of course, wonderful news that such progress is being made in the development of Covid-19 vaccines but there is a risk that, no matter how serious the Covid crisis is, it is distracting attention, political will and resources from the climate crisis, a much longer term and more devastating catastrophe.

They are intertwined. As climate and ecological systems change, vectors and pathogens migrate and disease spreads.

What lessons can be learned from one to apply to the other?

Prevention is better than cure. We need to urgently address the climate crisis, charting a path to net zero electricity by the middle of the century, to help prevent future pandemics.

We are only as safe as the most vulnerable. Covid immunisation will protect the most vulnerable; to protect against the effects of climate change we need to look far more deeply. Global challenges require systemic change.

Neither Covid or climate change respect national borders and, for both, we need to value and trust science and the scientific experts and separate them from political posturing.

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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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Spain Wind Turbine Factory Shutdowns disrupt manufacturing as Vestas, Siemens Gamesa, and Nordex halt Spanish plants amid COVID-19 lockdowns, straining supply chains and renewables projects across Europe, with partial operations and maintenance continuing.

Key Points

COVID-19 lockdowns pause Spanish wind factories by Vestas, Siemens Gamesa, and Nordex, disrupting supply chains.

✅ Vestas, Siemens Gamesa, Nordex halt Spanish manufacturing

✅ Service and maintenance continue under safety protocols

✅ Supply chain and project timelines face delays in Europe

Europe’s largest wind turbine makers on Wednesday said they had shut down more factories in Spain, a major hub for the continent’s renewables sector, in response to an almost total lockdown in the country to contain the coronavirus outbreak as the Covid-19 crisis disrupts the sector.

Denmark’s Vestas, the world No.1, has suspended production at its two Spanish plants, a spokesman told Reuters, adding that its service and maintenance business was still working. Vestas has also paused manufacturing and construction in India, which is under a nationwide lockdown too, he said, and similar disruptions could stall U.S. utility solar projects this year.

Top rival Siemens Gamesa, known for its offshore wind turbine lineup, suspended production at six Spanish factories on Monday, bringing total closures there to eight, a spokeswoman said.

Four components factories are still partially up and running, at Reinosa on the north coast, Cuenca near Madrid, Mungia and Siguiero, she added.

Germany’s Nordex, the No.8 globally which is 36% owned by Spain’s Acciona, has now shuttered all of its production in Spain, even as new projects like Enel’s 90MW build move ahead, including two nacelle casing factories in Barasoain and Vall d’Uixo, as well as a rotor blade site in Lumbier.

“Production is no longer active,” a spokeswoman said in response to a Reuters query.

The new closures take the number of idled wind power factories on the continent to 19, all in Spain and Italy, the European countries worst hit by the pandemic, with investments at risk across the sector.

Spain is second only to Italy in terms of numbers of coronavirus-related fatalities and restrictions have become even stricter in the country’s third week of lockdown at a time when renewables surpassed fossil fuels for the first time in Europe.

“Some factories have temporarily paused activity as a precautionary step to strengthen sanitary measures within the sites and guarantee full compliance with government recommendations,” industry association WindEurope said, noting that wind power grows in some markets despite the pandemic.

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Community Solar for Low-Income Homes expands energy equity by delivering renewable energy access, predictable bill savings, and tax credit benefits to renters and energy-insecure households, accelerating distributed generation and storage adoption nationwide.

Key Points

A program model enabling renters and LMI households to subscribe to off-site solar and save on utility bills.

✅ Earn bill credits from shared solar generation.

✅ Expands access for renters and LMI subscribers.

✅ Often paired with storage and IRA tax credit adders.

On a square-foot basis, the issue of inequality is made worse by higher costs for energy usage in the nation. Efforts like community solar programs such as Maryland community solar are underway to boost low-income participation in the cost benefits of renewable energy.

The Energy Information Administration (EIA) shows that households that are considered energy insecure, or those that have the inability to adequately meet basic household energy costs, are paying more for electricity than their wealthier counterparts. 

On average in the United States in 2020, households were billed about $1.04 per square foot for all energy sources. For homes that did not report energy insecurity, that average was $0.98 per square foot, while homes with energy insecurity issues paid an average of $1.24 per square foot for energy. This means that U.S. residents that need the most support on their energy bills are stuck with costs 27% higher than their neighbors on square-foot-basis.

EIA said energy-insecure households have reduced or forgone basic necessities to pay energy bills, kept their houses at unsafe temperatures because of energy cost concerns, or been unable to repair heating or cooling equipment because of cost.

In 2020, households with income less than $10,000 a year were billed an average of $1.31 per square foot for energy, while households making $100,000 or more were billed an average of $0.96 per square foot, said EIA. Renters paid considerably more ($1.28 per square foot) than owners ($0.98 per square foot). There were also considerable differences between regions, with New England solar growth sparking grid upgrade debates, ethnic groups and races, and insulation levels, as seen below.

The energy transition toward renewables like solar has offered price stability, amid record solar and storage growth nationwide, but thus far energy-insecure communities have relatively been left behind. A recent Berkeley Lab report, Residential Solar-Adopter Income and Demographic Trends, indicates that even though the rate of solar adoption among low-income residents is increasing (from 5% in 2010 to 11% in 2021), that segment of energy consumers remains under-represented among solar adopters, relative to its share of the population.

Community solar efforts

As such, the United States is targeting communities most impacted by energy costs that have not benefitted from the transition, highlighting “Energy Communities” that are eligible for an additional 10% tax credit through funds made possible by the Inflation Reduction Act.

Additionally, a push for community solar development is taking place nationwide to extend access to affordable solar energy to renters and other residents that aren’t able to leverage finances to invest in predictable, low-cost residential solar systems. The Biden Administration set a goal this year to sign up 5 million community solar households, achieving $1 billion in bill savings by 2025. The community solar model only represents about 8% of the total distributed solar capacity in the nation. This target would entail a jump from 3 GW installed capacity to 20 GW by the target year. The Department of Energy estimates community solar subscribers save an average of 20% on their bills.

California this year passed AB 2316, the Community Renewable Energy Act takes aim at four acute problems in the state’s power market: reliability amid rising outage risks, rates, climate and equity. The law creates a community renewable energy program, including community solar-plus-storage, supported by cheaper batteries, to overcome access barriers for nearly half of Californians who rent or have low incomes. Community solar typically involves customers subscribing to an off-site solar facility, receiving a utility bill credit for the power it generates.

“Community renewable energy is a proven powerful tool to help close California’s clean energy gap, bringing much needed relief to millions struggling with high housing costs and utility debt,” said Alexis Sutterman, energy equity program manager at the California Environmental Justice Alliance.

The program has energy equity baked into its structure, working to make sure Californians of all income levels participate in the benefits of the energy transition. Not only does it open solar access to renters, the law ensures that at least 51% of subscribers are low-income customers, which is expected to make projects eligible for a 10% tax credit adder under the IRA.

“The money’s on the table now,” said Jeff Cramer, president and chief executive of the Coalition for Community Solar Access. “While there are groups pushing for solar access for all, and states with strong legislation, there are other pockets of interest in surprising places in the United States. For example, Louisiana has no policy for community solar or support for low-income residents going solar but the city of New Orleans has its own utility commission with a community solar program. In Nebraska, forward-looking co-operatives have created community solar projects.

Community solar markets are active in 22 states, with more expected to come online in the future as states pursue 100% clean energy targets across the country. However, the market is expected to require strong community outreach efforts to foster trust and gain subscribers.

“There is a distrust of community solar initially in LMI communities as many have been burned before by retail energy false promises,” said Eric LaMora, executive director, community solar, Nautilus Solar on a panel at the Solar Energy Industries Association Finance, Tax, and Buyers seminar. “People are suspicious but there really are no hooks with community solar.”

LMI residents are leery to provide tax records or much documents at all in order to sign up for community solar, LaMora said. “We were surprised to see less of a default rate with LMI residents. We attribute this to the fact that they see significant savings on their electric bill, making it easier to pay each month,” he said.

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