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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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Site C Dam Injunction signals Ottawa's neutrality while B.C. reviews a hydroelectric dam project on the Peace River, amid First Nations treaty rights claims, federal approval defenses, and scrutiny of environmental assessment and Crown consultation.

Key Points

A legal request to pause Site C while courts weigh First Nations treaty rights, environmental review, and approvals.

✅ Ottawa neutral on injunction; still defends federal approvals

✅ First Nations cite treaty rights over Peace River territory

✅ B.C. jurisdiction, environmental assessment and Crown consultation at issue

The federal government is not going to argue against halting construction of the controversial Site C hydroelectric dam in British Columbia while a B.C. court decides if the project violates constitutionally protected treaty rights.

Work on Site C suspended prior to First Nations lawsuit

However a spokeswoman for Environment Minister Catherine McKenna said Monday the government will continue to defend the federal approval given for the project in December 2014, even though that approval was given using an environmental review process McKenna herself has said is fundamentally flawed.

The Site C project is an 1,100-megawatt dam and generating station on the Peace River in northern B.C. that will flood parts of the traditional territory of the West Moberly and Prophet River First Nations.

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In January, they filed a civil court case against the provincial government, B.C. Hydro and the federal government asking a judge to decide if their rights were being violated by the dam. A few weeks later, West Moberly asked the court for an injunction to halt construction pending the outcome of the rights case, similar to other contested transmission projects like the Maine electricity corridor debate in New England.

On May 11, lawyers for Attorney General Jody Wilson-Raybould filed a notice that Canada would remain neutral on the question of the injunction, meaning Canada won't argue against the idea of postponing construction for months, if not years, while the rights case winds through the court.

Wilson-Raybould has been silent on Site C since being named Canada's minister of justice in 2015, but in 2012, when she was the B.C. regional chief for the Assembly of First Nations, she said the project was "running roughshod" over treaty rights. The Justice Department on Monday directed questions to Environment and Climate Change Canada.

Defence of environmental assessment

McKenna's spokeswoman, Caroline Theriault, said the injunction request is just a procedural step regarding construction and that it is B.C. jurisdiction not federal.

However, she said Canada will defend the environmental assessment and Crown consultation processes and the federally issued permits required for construction.

B.C. auditor general set to scrutinize Site C dam project

McKenna has legislation before the House of Commons to overhaul the process for environmental assessment of major projects like hydro dams and pipelines, arguing the former government's procedures had skewed too far towards proponents. The overhaul includes requiring traditional Indigenous knowledge be taken into account, a consideration also central to the Columbia River Treaty talks underway on both sides of the border.

However, Theriault said the commitment to overhaul the process also included a promise not to revisit projects that had already been approved, such as Site C.

"The federal environmental assessment process for the Site C project has already been upheld in other court actions," said Theriault.

'It feels kind of odd'

West Moberly Chief Roland Wilson said he was both excited and yet concerned by Canada's decision last week not to oppose the injunction.

"It feels kind of odd and makes me wonder what they're up to," Wilson said.

However he said all he has ever wanted was for the project to be stopped until the question of rights can be answered. Wilson said two previous dams on the Peace River already flooded 80 per cent of the functional land within West Moberly's territory and that Site C will flood half of what's left. That land is used for fishing and hunting and there is also concern the dam will allow mercury to leak into Moberly Lake, he said.

Retiree undaunted by steep odds against his petition to stop Site C dam

Construction began in 2015 and more than $2.4 billion has already been spent on a project that will at the earliest, not be completed until 2024 and will cost an estimated $10 billion total, with cost overrun risks underscored by the Muskrat Falls ratepayer agreement in Atlantic Canada.

The province continues to argue against the injunction and will also fight the rights case, even as Alberta suspends power purchase talks with B.C. over energy disputes. Premier John Horgan campaigned on a promise to review the Site C approval. A B.C. Utilities Commission report in November found there are alternatives to building it and that it will go over budget. Nevertheless Horgan in December said he had to let construction continue because cancelling the project would be too costly both for the province and its electricity consumers, despite the B.C. rate freeze announced around the same period.

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U.S. coal-fired generation 2021 rose as higher natural gas prices, stable coal costs, and a recovering power sector shifted the generation mix; capacity factors rebounded despite low coal stocks and ongoing plant retirements.

Key Points

Coal output rose 22% on high gas prices and higher capacity factors; a 5% decline is expected in 2022.

✅ Natural gas delivered cost averaged $4.93/MMBtu, more than double 2020

✅ Coal capacity factor rose to ~51% from 40% in 2020

✅ 2022 coal generation forecast to fall about 5%

We expect 22% more U.S. coal-fired generation in 2021 than in 2020, according to our latest Short-Term Energy Outlook (STEO). The U.S. electric power sector has been generating more electricity from coal-fired power plants this year as a result of significantly higher natural gas prices and relatively stable coal prices, even as non-fossil sources reached 40% of total generation. This year, 2021, will yield the first year-over-year increase in coal generation in the United States since 2014, highlighted by a January power generation jump earlier in the year.

Coal and natural gas have been the two largest sources of electricity generation in the United States. In many areas of the country, these two fuels compete to supply electricity based on their relative costs and sensitivity to policies and gas prices as well. U.S. natural gas prices have been more volatile than coal prices, so the cost of natural gas often determines the relative share of generation provided by natural gas and coal.

Because natural gas-fired power plants convert fuel to electricity more efficiently than coal-fired plants, record natural gas generation has at times underscored that advantage, and natural gas-fired generation can have an economic advantage even if natural gas prices are slightly higher than coal prices. Between 2015 and 2020, the cost of natural gas delivered to electric generators remained relatively low and stable. This year, however, natural gas prices have been much higher than in recent years. The year-to-date delivered cost of natural gas to U.S. power plants has averaged $4.93 per million British thermal units (Btu), more than double last year’s price.

The overall decline in electricity demand in 2020 and record-low natural gas prices led coal plants to significantly reduce the percentage of time that they generated power. In 2020, the utilization rate (known as the capacity factor) of U.S. coal-fired generators averaged 40%. Before 2010, coal capacity factors routinely averaged 70% or more. This year’s higher natural gas prices have increased the average coal capacity factor to about 51%, which is almost the 2018 average, a year when wind and solar reached 10% nationally.

Although rising natural gas prices have resulted in more U.S. coal-fired generation than last year, this increase in coal generation will most likely not continue as solar and wind expand in the generation mix. The electric power sector has retired about 30% of its generating capacity at coal plants since 2010, and no new coal-fired capacity has come online in the United States since 2013. In addition, coal stocks at U.S. power plants are relatively low, and production at operating coal mines has not been increasing as rapidly as the recent increase in coal demand. For 2022, we forecast that U.S. coal-fired generation will decline about 5% in response to continuing retirements of generating capacity at coal power plants and slightly lower natural gas prices.

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Ontario Electricity Capacity Gap threatens reliability as IESO forecasts shortfalls from the Pickering shutdown and rapid electrification, requiring new low-emission nuclear generation to meet net-zero targets, maintain baseload, and stabilize the grid.

Key Points

Expected 2030 shortfalls from Pickering closure and electrification, requiring new low-emission nuclear to meet net-zero.

✅ IESO projects a 3.6-9.5 GW capacity gap by 2030

✅ Pickering shutdown removes baseload, stressing reliability

✅ New low-emission nuclear needed to meet net-zero targets

Ontario faces an electricity supply shortage and reliability risks in the next four to eight years and will not meet net-zero objectives without building new low-emission, nuclear generation starting as soon as possible, according to a report released yesterday by the Power Workers' Union (PWU). The capacity needed to fill the expected supply gap will be equivalent to doubling the province's planned nuclear fleet in eight years.

The planned closure of the Pickering nuclear power plant in 2025 and the increase in demand from electrification of the economy are the drivers behind a capacity gap in 2030 of at least 3.6 GW which could widen to as much as 9.5 GW, Electrification Pathways for Ontario to Reduce Emissions, finds. Ontario's Independent Electricity System Operator (IESO) has since 2013 been forecasting a significant gap in the province's electricity supply due the closure of Pickering, but has been underestimating the impact of electrification, the report says.

In addition, the electrification of buildings, transport and industry sectors that will be needed to achieve goals of net-zero emissions by 2050 that being set by the federal government and civil society will see the province's electricity demand increase by at least 130% over current planning forecasts, and potentially by over 190%. Leveraging electricity, natural gas and hydrogen synergies can reduce supply needs, but 55 GW of new electricity capacity, including new large-scale nuclear plants, will still be needed by 2050 - four times Ontario's current nuclear and hydro assets - the report finds.

These findings underscore the urgent need for a paradigm shift in Ontario's electricity planning and procurement process, the authors say, adding that immediate action is needed both to mitigate the system reliability risks and enable the significant societal benefits needed to pursue net-zero objectives. Planning for procurement to replace Pickering's capacity, or to pursue life extension options, must begin as soon as possible.

"Policymakers around the world realise climate change can't be tackled without nuclear. Ontario's nuclear fleet has delivered emissions reductions for over 50 years," PWU President Jeff Parnell said. "In fact, without building new nuclear units, Ontario will miss its emission reduction targets and carbon emissions from electricity generation will rise dramatically, as explored in why Ontario's power could get dirtier today."

"This report clearly shows that Ontario cannot sustain the low-carbon status of its hydro and nuclear-based electricity system, decarbonise its economy and meet its carbon reduction targets without new nuclear or continued operation at Pickering in the near term. Most disturbing is the fact that we are already well behind and needed to start planning for this capacity yesterday," he said.

The six operating Candu reactors at Ontario Power Generation's Pickering plant have been kept in operation to provide baseload electricity during the refurbishment of units at the Darlington and Bruce plants. Currently, the company plans to shut down Pickering units 1 and 4 in 2024 and units 5 to 8 in 2025, even as Ontario moves to refurbish Pickering B to extend life.

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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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Canada's First Commercial Electric Flight accelerates sustainable aviation, showcasing electric aircraft, pilot training, battery propulsion, and noise reduction, aligning with net-zero goals and e-aviation innovation across commercial, regional, and training operations.

Key Points

Canada's electric flight advances sustainable aviation, proving e-aircraft viability and pilot training readiness.

✅ Battery-electric propulsion cuts emissions and noise

✅ New curricula prepare pilots for electric systems and procedures

✅ Supports net-zero goals through green aviation infrastructure

Canada, renowned for its vast landscapes and pioneering spirit, has achieved a significant milestone in aviation history with its first commercial electric flight. This groundbreaking achievement marks a pivotal moment in the transition towards sustainable aviation and an aviation revolution for the sector, highlighting Canada's commitment to reducing carbon emissions and embracing innovative technologies.

The inaugural commercial electric flight in Canada not only showcases the capabilities of electric aircraft, with examples like Harbour Air's prototype flight demonstrating feasibility, but also underscores the importance of pilot training in advancing e-aviation. As the aviation industry explores cleaner and greener alternatives to traditional fossil fuel-powered aircraft, pilot training plays a crucial role in preparing aviation professionals for the future of sustainable flight.

Electric aircraft, powered by batteries instead of conventional jet fuel, offer numerous environmental benefits, including lower greenhouse gas emissions and reduced noise pollution, though Canada's 2019 electricity mix still included some fossil generation that can affect lifecycle impacts. These advantages align with Canada's ambitious climate goals and commitment to achieving net-zero emissions by 2050. By investing in e-aviation, Canada aims to lead by example in the global effort to decarbonize the aviation sector and mitigate the impacts of climate change.

The success of Canada's first commercial electric flight is a testament to collaborative efforts between industry stakeholders, government support, and technological innovation. Electric aircraft manufacturers have made significant strides in developing reliable and efficient electric propulsion systems, with research investment helping advance prototypes and certification, paving the way for broader adoption of e-aviation across commercial and private sectors.

Pilot training programs tailored for electric aircraft are crucial in ensuring the safe and effective operation of these advanced technologies, as operators target first electric passenger flights across regional routes. Canadian aviation schools and training institutions are at the forefront of integrating e-aviation into their curriculum, equipping future pilots with the skills and knowledge needed to navigate electric aircraft systems and procedures.

Moreover, the introduction of commercial electric flights in Canada opens new opportunities for aviation enthusiasts, environmental advocates, and stakeholders interested in sustainable transportation solutions. The shift towards e-aviation represents a paradigm shift in how air travel is perceived and executed, emphasizing efficiency, environmental stewardship, and technological innovation.

Looking ahead, Canada's role in advancing e-aviation extends beyond pilot training to include research and development, infrastructure investment, and policy support. Collaborative initiatives with industry partners and international counterparts, including Canada-U.S. collaboration on electrification, will be essential in accelerating the adoption of electric aircraft and establishing a robust framework for sustainable aviation practices.

In conclusion, Canada's first commercial electric flight marks a significant milestone in the journey towards sustainable aviation. By pioneering e-aviation through pilot training and technological innovation, Canada sets a precedent for global leadership in reducing carbon emissions and shaping the future of air transportation. As electric aircraft become more prevalent in the skies, Canada's commitment to sustainability and ambitious EV goals at the national level will continue to drive progress towards a cleaner, greener future for aviation worldwide.

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