Clean coal misleading, says Greenpeace

Bitcoin Energy Debate examines electricity usage, mining costs, environmental impact, and blockchain efficiency, weighing renewable power, carbon footprint, scalability, and transaction throughput to clarify stakeholder claims from Tesla, Square, academics, and policymakers.

Key Points

Debate on Bitcoin mining's power use, environmental impact, efficiency, and scalability versus alternative blockchains.

✅ Compares energy intensity with transaction throughput and system outputs.

✅ Weighs renewables, stranded power, and carbon footprint in mining.

✅ Assesses PoS blockchains, stablecoins, and scalability tradeoffs.

There is a great debate underway about the electricity required to process Bitcoin transactions. The debate is significant, the stakes are high, the views are diverse, and there are smart people on both sides. Bitcoin generates a lot of emotion, thereby producing too much heat and not enough light. In this post, I explain the importance of identifying the key issues in the debate, and of understanding the nature and extent of disagreement about how much electrical energy Bitcoin consumes.

Consider the background against which the debate is taking place. Because of its unstable price, Bitcoin cannot serve as a global mainstream medium of exchange. The instability is apparent. On January 1, 2021, Bitcoin’s dollar price was just over $29,000. Its price rose above $63,000 in mid-April, and then fell below $35,000, where it has traded recently. Now the financial media is asking whether we are about to experience another “cyber winter” as the prices of cryptocurrencies continue their dramatic declines.

Central banks warns of bubble on bitcoins as it skyrockets
As bitcoins skyrocket to more than $12 000 for one BTC, many central banks as ECB or US Federal ... [+] NURPHOTO VIA GETTY IMAGES
Bitcoin is a high sentiment beta asset, and unless that changes, Bitcoin cannot serve as a global mainstream medium of exchange. Being a high sentiment beta asset means that Bitcoin’s market price is driven much more by investor psychology than by underlying fundamentals.

As a general matter, high sentiment beta assets are difficult to value and difficult to arbitrage. Bitcoin qualifies in this regard. As a general matter, there is great disagreement among investors about the fair values of high sentiment beta assets. Bitcoin qualifies in this regard.

One major disagreement about Bitcoin involves the very high demand for electrical power associated with Bitcoin transaction processing, an issue that came to light several years ago. In recent months, the issue has surfaced again, in a drama featuring disagreement between two prominent industry leaders, Elon Musk (from Tesla and SpaceX) and Jack Dorsey (from Square).

On one side of the argument, Musk contends that Bitcoin’s great need for electrical power is detrimental to the environment, especially amid disruptions in U.S. coal and nuclear power that increase supply strain.  On the other side, Dorsey argues that Bitcoin’s electricity profile is a benefit to the environment, in part because it provides a reliable customer base for clean electric power. This might make sense, in the absence of other motives for generating clean power; however, it seems to me that there has been a surge in investment in alternative technologies for producing electricity that has nothing to do with cryptocurrency. So I am not sure that the argument is especially strong, but will leave it there. In any event, this is a demand side argument.

A supply side argument favoring Bitcoin is that the processing of Bitcoin transactions, known as “Bitcoin mining,” already uses clean electrical power, power which has already been produced, as in hydroelectric plants at night, but not otherwise consumed in an era of flat electricity demand across mature markets.

Both Musk and Dorsey are serious Bitcoin investors. Earlier this year, Tesla purchased $1.5 billion of Bitcoin, agreed to accept Bitcoin as payment for automobile sales, and then reversed itself. This reversal appears to have pricked an expanding Bitcoin bubble. Square is a digital transaction processing firm, and Bitcoin is part of its long-term strategy.

Consider two big questions at the heart of the digital revolution in finance. First, to what degree will blockchain replace conventional transaction technologies? Second, to what degree will competing blockchain based digital assets, which are more efficient than Bitcoin, overcome Bitcoin’s first mover advantage as the first cryptocurrency?

To gain some insight about possible answers to these questions, and the nature of the issues related to the disagreement between Dorsey and Musk, I emailed a series of academics and/or authors who have expertise in blockchain technology.

David Yermack, a financial economist at New York University, has written and lectured extensively on blockchains. In 2019, Yermack wrote the following: “While Bitcoin and successor cryptocurrencies have grown remarkably, data indicates that many of their users have not tried to participate in the mainstream financial system. Instead they have deliberately avoided it in order to transact in black markets for drugs and other contraband … or evade capital controls in countries such as China.” In this regard, cyber-criminals demanding ransom for locking up their targets information systems often require payment in Bitcoin. Recent examples of cyber-criminal activity are not difficult to find, such as incidents involving Kaseya and Colonial Pipeline.

David Yermack continues: “However, the potential benefits of blockchain for improving data security and solving moral hazard problems throughout the financial system have become widely apparent as cryptocurrencies have grown.” In his recent correspondence with me, he argues that the electrical power issue associated with Bitcoin “mining,” is relatively minor because Bitcoin miners are incentivized to seek out cheap electric power, and patterns shifted as COVID-19 changed U.S. electricity consumption across sectors.

Thomas Philippon, also a financial economist at NYU, has done important work characterizing the impact of technology on the resource requirements of the financial sector. He has argued that historically, the financial sector has comprised about 6-to-7% of the economy on average, with variability over time. Unit costs, as a percentage of assets, have consistently been about 2%, even with technological advances. In respect to Bitcoin, he writes in his correspondence with me that Bitcoin is too energy inefficient to generate net positive social benefits, and that energy crisis pressures on U.S. electricity and fuels complicate the picture, but acknowledges that over time positive benefits might be possible.

Emin Gün Sirer is a computer scientist at Cornell University, whose venture AVA Labs has been developing alternative blockchain technology for the financial sector. In his correspondence with me, he writes that he rejects the argument that Bitcoin will spur investment in renewable energy relative to other stimuli. He also questions the social value of maintaining a fairly centralized ledger largely created by miners that had been in China and are now migrating to other locations such as El Salvador.

Bob Seeman is an engineer, lawyer, and businessman, who has written a book entitled Bitcoin: The Mother of All Scams. In his correspondence with me, he writes that his professional experience with Bitcoin led him to conclude that Bitcoin is nothing more than unlicensed gambling, a point he makes in his book.

David Gautschi is an academic at Fordham University with expertise in global energy. I asked him about studies that compare Bitcoin’s use of energy with that of the U.S. financial sector. In correspondence with me, he cautioned that the issues are complex, and noted that online technology generally consumes a lot of power, with electricity demand during COVID-19 highlighting shifting load profiles.

My question to David Gautschi was prompted by a study undertaken by the cryptocurrency firm Galaxy Digital. This study found that the financial sector together with the gold industry consumes twice as much electrical power as Bitcoin transaction processing. The claim by Galaxy is that Bitcoin’s electrical power needs are “at least two times lower than the total energy consumed by the banking system as well as the gold industry on an annual basis.”

Galaxy’s analysis is detailed and bottom up based. In order to assess the plausibility of its claims, I did a rough top down analysis whose results were roughly consistent with the claims in the Galaxy study. For sake of disclosure, I placed the heuristic calculations I ran in a footnote.1 If we accept the Galaxy numbers, there remains the question of understanding the outputs produced by the electrical consumption associated with both Bitcoin mining and U.S. banks’ production of financial services. I did not see that the Galaxy study addresses the output issue, and it is important.

Consider some quick statistics which relate to the issue of outputs. The total market for global financial services was about $20 trillion in 2020. The number of Bitcoin transactions processed per day was about 330,000 in December 2020, and about 400,000 in January 2021. The corresponding number for Bitcoin’s digital rival Ethereum during this time was about 1.1 million transactions per day. In contrast, the global number of credit card transactions per day in 2018 was about 1 billion.2

Bitcoin Value Falls
LONDON, ENGLAND - NOVEMBER 20: A visual representation of the cryptocurrencies Bitcoin and Ethereum ... [+] GETTY IMAGES
These numbers tell us that Bitcoin transactions comprise a small share, on the order of 0.04%, of global transactions, but use something like a third of the electricity needed for these transactions. That said, the associated costs of processing Bitcoin transactions relate to tying blocks of transactions together in a blockchain, not to the number of transactions. Nevertheless, even if the financial sector does indeed consume twice as much electrical power as Bitcoin, the disparity between Bitcoin and traditional financial technology is striking, and the experience of Texas grid reliability underscores system constraints when it comes to output relative to input.  This, I suggest, weakens the argument that Bitcoin’s electricity demand profile is inconsequential because Bitcoin mining uses slack electricity.

A big question is how much electrical power Bitcoin mining would require, if Bitcoin were to capture a major share of the transactions involved in world commerce. Certainly much more than it does today; but how much more?

Given that Bitcoin is a high sentiment beta asset, there will be a lot of disagreement about the answers to these two questions. Eventually we might get answers.

At the same time, a high sentiment beta asset is ill suited to being a medium of exchange and a store of value. This is why stablecoins have emerged, such as Diem, Tether, USD Coin, and Dai. Increased use of these stable alternatives might prevent Bitcoin from ever achieving a major share of the transactions involved in world commerce.

We shall see what the future brings. Certainly El Salvador’s recent decision to make Bitcoin its legal tender, and to become a leader in Bitcoin mining, is something to watch carefully. Just keep in mind that there is significant downside to experiencing foreign exchange rate volatility. This is why global financial institutions such as the World Bank and IMF do not support El Salvador’s decision; and as I keep saying, Bitcoin is a very high sentiment beta asset.

In the past I suggested that Bitcoin bubble would burst when Bitcoin investors conclude that its associated processing is too energy inefficient. Of course, many Bitcoin investors are passionate devotees, who are vulnerable to the psychological bias known as motivated reasoning. Motivated reasoning-based sentiment, featuring denial,3 can keep a bubble from bursting, or generate a series of bubbles, a pattern we can see from Bitcoin’s history.

I find the argument that Bitcoin is necessary to provide the right incentives for the development of clean alternatives for generating electricity to be interesting, but less than compelling. Are there no other incentives, such as evolving utility trends, or more efficient blockchain technologies? Bitcoin does have a first mover advantage relative to other cryptocurrencies. I just think we need to be concerned about getting locked into an technologically inferior solution because of switching costs.

There is an argument to made that decisions, such as how to use electric power, are made in markets with self-interested agents properly evaluating the tradeoffs. That said, think about why most of the world adopted the Windows operating system in the 1980s over the superior Mac operating system offered by Apple. Yes, we left it to markets to determine the outcome. People did make choices; and it took years for Windows to catch up with the Mac’s operating system.

My experience as a behavioral economist has taught me that the world is far from perfect, to expect to be surprised, and to expect people to make mistakes. We shall see what happens with Bitcoin going forward.

As things stand now, Bitcoin is well suited as an asset for fulfilling some people’s urge to engage in high stakes gambling. Indeed, many people have a strong need to engage in gambling. Last year, per capita expenditure on lottery tickets in Massachusetts was the highest in the U.S. at over $930.

High sentiment beta assets offer lottery-like payoffs. While Bitcoin certainly does a good job of that, it cannot simultaneously serve as an effective medium of exchange and reliable store of value, even setting aside the issue at the heart of the electricity debate.

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Germany Energy Price Hikes are driving electricity tariffs, gas prices, and heating costs higher as wholesale markets surge after the Ukraine invasion; households face inflationary pressure despite relief measures and a renewables levy cut.

Key Points

Germany Energy Price Hikes reflect surging power and gas tariffs from wholesale spikes, prompting relief measures.

✅ Electricity tariffs to rise 19.5% in Apr-Jun

✅ Gas tariffs up 42.3%; heating and fuel costs soar

✅ Renewables levy ends July; saves €6.6 billion yearly

Record prices for electricity and gas in Germany will continue to rise in the coming months, the dpa agency, citing estimates from the consumer portal Verivox.

According to him, electricity suppliers and local utilities, in whose area of ​​responsibility there are 13 million households, made an announcement of tariff increases in April, May and June by 19.5%. Gas tariffs increased by an average of 42.3%.

According to Verivox, electricity prices in Germany have approximately doubled over the year - a pattern seen as European electricity prices rose more than double the EU average - if previously a household with a consumption of 4,000 kWh paid 1,171 euros a year, now the amount has risen to 1,737 euros. Gas prices have risen even more, though European gas prices later returned to pre-Ukraine war levels: last year, a household with a consumption of 20,000 kWh paid 1,184 euros in annual terms, and now it is 2,787 euros. 

Energy costs for the average German household are 52 percent higher than a year ago, adding to EU inflation pressures, according to energy contract sales website Check24. In a press release, the company said the wholesale electricity price was at €122.93 per megawatt-hour in February 2022, compared to €49 this time last year, while in the United States US electricity prices climbed at the fastest pace in 41 years. In addition, electricity prices on the power exchange haven been rising rapidly since Russian troops invaded Ukraine, comparison portal Strom Report said. Costs for heating rose the most, triggered by the high gas price (105 euros per megawatt-hour on the wholesale market) and around 100 USD per barrel of oil – its highest price since 2014. Driving also became more expensive with costs for petrol up 25 percent and diesel 30 percent, Check24 said.

The German government has decided on relief measures for low-income households, including a 200 billion euro energy shield, in response to high consumer energy costs. In July, it will abolish the renewables levy on the power price, saving consumers around €6.6 billion annually. In a reform proposal released this week, the ministry for economy and climate also detailed how it will legally oblige power suppliers to reduce their power bills when the levy is abolished.

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Western Canada Hydropower Drought strains British Columbia and Manitoba as reservoirs hit historic lows, cutting hydroelectric output and prompting power imports, natural gas peaking, and grid resilience planning amid climate change risks this winter.

Key Points

Climate-driven reservoir lows cut hydro in B.C. and Manitoba, prompting imports and backup gas to maintain reliability.

✅ Reservoirs at multi-year lows cut hydro generation capacity

✅ BC Hydro and Manitoba Hydro import electricity for reliability

✅ Natural gas turbines used; climate change elevates drought risk

Severe drought conditions in Western Canada are compelling two hydroelectricity-dependent provinces, British Columbia and Manitoba, to import power from other regions. These provinces, known for their reliance on hydroelectric power, are facing reduced electricity production due to low water levels in reservoirs this autumn and winter as energy-intensive customers encounter temporary connection limits.

While there is no immediate threat of power outages in either province, experts indicate that climate change is leading to more frequent and severe droughts. This trend places increasing pressure on hydroelectric power producers in the future, spurring interest in upgrading existing dams as part of adaptation strategies.

In British Columbia, several regions are experiencing "extreme" drought conditions as classified by the federal government. BC Hydro spokesperson Kyle Donaldson referred to these conditions as "historic," and a first call for power highlights the strain, noting that the corporation's large reservoirs in the north and southeast are at their lowest levels in many years.

To mitigate this, BC Hydro has been conserving water by utilizing less affected reservoirs and importing additional power from Alberta and various western U.S. states. Donaldson confirmed that these measures would persist in the upcoming months.

Manitoba is also facing challenges with below-normal levels in reservoirs and rivers. Since October, Manitoba Hydro has occasionally relied on its natural gas turbines to supplement hydroelectric production as electrical demand could double over the next two decades, a measure usually reserved for peak winter demand.

Bruce Owen, a spokesperson for Manitoba Hydro, reassured that there is no imminent risk of a power shortage. The corporation can import electricity from other regions, similar to how it exports clean energy in high-water years.

However, the cost implications are significant. Manitoba Hydro anticipates a financial loss for the current fiscal year, with more red ink tied to emerging generation needs, the second in a decade, with the previous one in 2021. That year, drought conditions led to a significant reduction in the company's power production capabilities, resulting in a $248-million loss.

The 2021 drought also affected hydropower production in the United States. The U.S. Department of Energy reported a 16% reduction in overall generation, with notable decreases at major facilities like Nevada's Hoover Dam, where production dropped by 25%.

Drought has long been a major concern for hydroelectricity producers, and they plan their operations with this risk in mind. Manitoba's record drought in 1940-41, for example, is a benchmark for Manitoba Hydro's operational planning to ensure sufficient electricity supply even in extreme low-water conditions.

Climate change, however, is increasing the frequency of such rare events, highlighting the need for more robust backup systems such as new turbine investments to enhance reliability. Blake Shaffer, an associate professor of economics at the University of Calgary specializing in electricity markets, emphasized the importance of hydroelectric systems incorporating the worsening drought forecasts due to climate change into their energy production planning.

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Hydro-Québec Carillon Refurbishment delivers a $750M hydropower modernization, replacing six turbines and upgrading civil works, water passageways, and grid equipment to extend run-of-river, renewable energy output for peak demand near Montréal.

Key Points

A $750M project replacing six units and upgrading civil, water and electrical systems to supply power for 50 years.

✅ Replaces six generating units with Andritz turbines.

✅ Upgrades civil works, water passageways, and electrical gear.

✅ Extends run-of-river output for 50 years; boosts peak supply.

Hydro-Québec will invest $750 million to refurbish its Carillon generating station with a major powerhouse upgrade that will mainly replace six generating units. The investment also covers the cost of civil engineering work, including making adjustments to water passageways, upgrading electrical equipment and replacing the station roof. Work will start in 2021, aligning with Hydro-Québec's capacity expansion plans for 2021, and continue until 2027.

Carillon generating station is a run-of-river power plant consisting of 14 generating units with a total installed capacity of 753 MW. Built in the early 1960s, it is a key part of Hydro-Québec's hydroelectric generating fleet, which includes the La Romaine complex as well. The station is close to the greater Montréal area and feeds power into the grid to support industrial demand growth during peak consumption periods.

The selected supplier, turbine manufacturer Andritz, has been asked to maximize the project's economic spinoffs in Québec, as Canada continues investing in new turbines across the country to modernize assets. Once the work is completed, the new generating units will be able to provide clean, renewable energy, supporting Hydro-Québec's strategy to reduce fossil fuel reliance for the next 50 years.

"Carillon generating station is a symbol of our hydroelectric development and plays a strategic role in our production fleet. However, most of the generating units' main components date back to the station's original construction from 1959 to 1962. Hydropower generating stations have long service lives - with this refurbishment, Carillon will be producing clean renewable energy for decades to come." said David Murray, Chief Innovation Officer and President, Hydro-Québec Production.

"In light of today's economic situation, this is an important announcement that clearly reaffirms Hydro-Québec's role in relaunching Québec's economy and strengthening interprovincial electricity partnerships that open new markets. Over 600,000 hours of work will be required for everything from the engineering work to component assembly, creating many new high-quality skilled jobs for Québec industries."

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PG&E 2024 Rate Hikes signal sharp increases to fund wildfire safety, infrastructure upgrades, and CPUC-backed reliability, with rates expected to stabilize in 2025, affecting rural residents, businesses, and high-risk zones across California.

Key Points

PG&E’s 2024 hikes fund wildfire safety and grid upgrades, with pricing expected to stabilize in 2025.

✅ Driven by wildfire safety, infrastructure, and reinsurance costs

✅ Largest impacts in rural, high-risk zones; business rates vary

✅ CPUC oversight aims to ensure necessary, justified investments

Pacific Gas and Electric (PG&E) is expected to implement a series of rate hikes that, amid analyses of why California electricity prices are soaring across the state, will significantly impact California residents. These increases, while substantial, are anticipated to be followed by a period of stabilization in 2025, offering a sense of relief to customers facing rising costs.

PG&E, one of the largest utility providers in the state, announced that its 2024 rate hikes are part of efforts to address increasing operational costs, including those related to wildfire safety, infrastructure upgrades, and regulatory requirements. As California continues to face climate-related challenges like wildfires, utilities like PG&E are being forced to adjust their financial models to manage the evolving risks. Wildfire-related liabilities, which have plagued PG&E in recent years, play a significant role in these rate adjustments. In response to previous fire-related lawsuits, including a bankruptcy plan supported by wildfire victims that reshaped liabilities, and the increased cost of reinsurance, PG&E has made it clear that customers will bear part of the financial burden.

These rate hikes will have a multi-faceted impact. Residential users, particularly those in rural or high-risk wildfire zones, will see some of the largest increases. Business customers will also be affected, although the adjustments may vary depending on the size and energy consumption patterns of each business. PG&E has indicated that the increases are necessary to secure the utility’s financial stability while continuing to deliver reliable service to its customers.

Despite the steep increases in 2024, PG&E's executives have assured that the company's pricing structure will stabilize in 2025. The utility has taken steps to balance the financial needs of the business with the reality of consumer affordability. While some rate hikes are inevitable given California's regulatory landscape and climate concerns, PG&E's leadership believes the worst of the increases will be seen next year.

PG&E’s anticipated stabilization comes after a year of scrutiny from California regulators. The California Public Utilities Commission (CPUC) has been working closely with PG&E to scrutinize its rate request and ensure that hikes are justifiable and used for necessary investments in infrastructure and safety improvements. The CPUC’s oversight is especially crucial given the company’s history of safety violations and the public outrage over past wildfire incidents, including reports that its power lines may have sparked fires in California, which have been linked to PG&E’s equipment.

The hikes, though significant, reflect the broader pressures facing utilities in California, where extreme weather patterns are becoming more frequent and intense due to climate change. Wildfires, which have grown in severity and frequency in recent years, have forced PG&E to invest heavily in fire prevention and mitigation strategies, including compliance with a judge-ordered use of dividends for wildfire mitigation across its service area. This includes upgrading equipment, inspecting power lines, and implementing more rigorous protocols to prevent accidents that could spark devastating fires. These investments come at a steep cost, which PG&E is passing along to consumers through higher rates.

For homeowners and businesses, the potential for future rate stabilization offers a glimmer of hope. However, the 2024 increases are still expected to hit consumers hard, especially those already struggling with high living costs. The steep hikes have prompted public outcry, with calls for action as bills soar amplifying advocacy group arguments that utilities should absorb more of the costs related to climate change and fire prevention instead of relying on ratepayers.

Looking ahead to 2025, the expectation is that PG&E’s rates will stabilize, but the question remains whether they will return to pre-2024 levels or continue to rise at a slower rate. Experts note that California’s energy market remains volatile, and while the rates may stabilize in the short term, long-term cost management will depend on ongoing investments in renewable energy sources and continued efforts to make the grid more resilient to climate-related risks.

As PG&E navigates this challenging period, the company’s commitment to transparency and working with regulators will be crucial in rebuilding trust with its customers. While the immediate future may be financially painful for many, the hope is that the utility's focus on safety and infrastructure will lead to greater long-term stability and fewer dramatic rate increases in the years to come.

Ultimately, California residents will need to brace for another tough year in terms of utility costs but can find reassurance that PG&E’s rate increases will eventually stabilize. For those seeking relief, there are ongoing discussions about increasing energy efficiency, exploring renewable energy alternatives, and expanding assistance programs for lower-income households to help mitigate the financial strain of these price hikes.

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

Key Points

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

✅ PUCT ordered clawbacks for ancillary services not delivered.

✅ IMM urged price correction after firm load shed ceased.

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

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

According to the IMM (emphasis added):

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

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

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

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

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

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

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

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

According to the IMM (emphasis added):

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

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

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

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

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