Cooper Bussmann contributes to arc flash research project

California Blackouts expose grid reliability risks as PG&E deenergizes lines during high winds. Mandated solar and wind displace dispatchable natural gas, straining ISO load balancing, transmission maintenance, and battery storage planning amid escalating wildfire liability.

Key Points

California grid shutoffs stem from wildfire risk, renewables, and deferred transmission maintenance under mandates.

✅ PG&E deenergizes lines to reduce wildfire ignition during high winds.

✅ Mandated solar and wind displace dispatchable gas, raising balancing costs.

✅ Storage, reliability pricing, and grid upgrades are needed to stabilize supply.

California is again facing widespread blackouts this season. Politicians are scrambling to assign blame to Pacific Gas & Electric (PG&E) a heavily regulated utility that can only do what the politically appointed regulators say it can do. In recent years this has meant building a bunch of solar and wind projects, while decommissioning reliable sources of power and scrimping on power line maintenance and upgrades.

The blackouts are connected with the legal liability from old and improperly maintained power lines being blamed for sparking fires—in hopes that deenergizing the grid during high winds reduces the likelihood of fires. 

How did the land of Silicon Valley and Hollywood come to have developing world electricity?

California’s Democratic majority, from Gov. Gavin Newsom to the solidly progressive legislature, to the regulators they appoint, have demanded huge increases in renewable energy. Renewable electricity targets have been pushed up, and policymakers are weighing a revamp of electricity rates to clean the grid, with the state expected to reach a goal of 33% of its power from renewable sources, mostly solar and wind, by next year, and 60% of its electricity from renewables by 2030.

In 2018, 31% of the electricity Californians purchased at the retail level came from approved renewables. But when rooftop solar is added to the mix, about 34% of California’s electricity came from renewables in 2018. Solar photovoltaic (PV) systems installed “behind-the-meter” (BTM) displace utility-supplied generation, but still affect the grid at large, as electricity must be generated at the moment it is consumed. PV installations in California grew 20% from 2017 to 2018, benefiting from the state’s Self-Generation Incentive Program that offers hefty rebates through 2025, as well as a 30% federal tax credit.

Increasingly large amounts of periodic, renewable power comes at a price—the more there is, the more difficult it is to keep the power grid stable and energized. Since electricity must be consumed the instant it is generated, and because wind and solar produce what they will whenever they do, the rest of the grid’s power producers—mostly natural gas plants—have to make up any differences between supply and immediate demand. This load balancing is vital, because without it, the grid will crash and widespread blackouts will ensue.

California often produces a surplus of mandated solar and wind power, generated for 5 to 8 cents per kilowatt hour. This power displaces dispatchable power from natural gas, coal and nuclear plants, resulting in reliable power plants spending less time online and driving up electricity prices as the plants operate for fewer hours of the day. Subsidized and mandated solar power, along with a law passed in California in 2006 (SB 1638) that bans the renewal of coal-fired power contracts, has placed enormous economic pressure on the Western region’s coal power plants—among them, the nation’s largest, Navajo Generating Station. As these plants go off line, the Western power grid will become increasingly unstable. Eventually, the states that share their electric power in the Western Interconnect may have to act to either subsidize dispatchable power or place a value on reliability—something that was taken for granted in the growth of the America’s electrical system and its regulatory scheme.

California law regarding electricity explicitly states that “a violation of the Public Utilities Act is a crime” and that it is “…the intent of the Legislature to provide for the evolution of the ISO (California’s Independent System Operator—the entity that manages California’s grid) into a regional organization to promote the development of regional electricity transmission markets in the western states.” In other words, California expects to dictate how the Western grid operates.

One last note as to what drives much of California’s energy policy: politics. California State Senator Kevin de León (the author served with him in the State Assembly) drafted SB 350, the Clean Energy and Pollution Reduction Act. It became law in 2015. Sen. de León followed up with SB 100 in 2018, signed into law weeks before the 2018 election. SB 100 increased California’s renewable portfolio standard to 60% by 2030 and further requires all the state’s electricity to come from carbon-free sources by 2045, a capstone of the state’s climate policies that factor into the blackout debate.  

Sen. de León used his environmental credentials to burnish his run for the U.S. Senate against Sen. Dianne Feinstein, eventually capturing the endorsements of the California Democratic Party and billionaire environmentalist Tom Steyer, now running for president. Feinstein and de León advanced to the general in California’s jungle primary, where Feinstein won reelection 54.2% to 45.8%.

De León may have lost his race for the U.S. Senate, but his legacy will live on in increasingly unaffordable electricity and blackouts, not only in California, but in the rest of the Western United States—unless federal or state regulators begin to place a value on reliability. This could be done by requiring utility scale renewable power providers to guarantee dispatchable power, as policymakers try to avert a looming shortage of firm capacity, either through purchase agreements with thermal power plants or through the installation of giant and costly battery farms or other energy storage means.

Related News

• Electricity Forum News

• Energy Policy News

Heavy-Duty Truck Electrification is disrupting the aftermarket as diesel declines: fewer parts, regenerative braking, emissions rules, e-drives, gearboxes, and software engineering needs reshape service demand, while ICE fleets persist for years.

Key Points

Transition of heavy trucks to EV systems, reducing parts and emissions while reshaping aftermarket service and skills.

✅ 33% fewer parts; regenerative braking slashes brake wear

✅ Diesel share declines; EVs and natural gas slowly gain

✅ Aftermarket shifts to e-drives, gearboxes, software and service

Those who sell parts and repair trucks might feel uneasy when reports emerge about a coming generation of electric trucks.

There are reportedly about 33% fewer parts to consider when internal combustion engines and transmissions are replaced by electric motors. Features such as regenerative braking are expected to dramatically reduce brake wear. As for many of the fluids needed to keep components moving? They can remain in their tanks and drums.

Think of them as disruptors. But presenters during the annual Heavy Duty Aftermarket Dialogue are stressing that the changes are not coming overnight. Chris Patterson, a consultant and former Daimler Trucks North America CEO, noted that the Daimler electrification plan underscores the shift as he counts just 50 electrified heavy trucks in North America.

About 88% of today’s trucks run on diesel, with the remaining 12% mostly powered by gasoline, said John Blodgett, MacKay and Company’s vice-president of sales and marketing. Five years out, even amid talk of an EV inflection point, he expects 1% to be electric, 2% to be natural gas, 12% to be gasoline, and 84% on diesel.

But a decade from now, forecasts suggest a split of 76% diesel, 11% gasoline, 7% electric, and 5% natural gas, with a fraction of a percent relying on hydrogen-electric power. Existing internal combustion engines will still be in service, and need to be serviced, but aftermarket suppliers are now preparing for their roles in the mix, especially as Canada’s EV opportunity comes into focus for North American players.

“This is real, for sure,” said Delphi Technologies CEO Rick Dauch.

Aftermarket support is needed
“As programs are launched five to six years from now, what are the parts coming back?” he asked the crowd. “Braking and steering. The fuel injection business will go down, but not for 20-25 years.” The electric vehicles will also require a gear box and motor.

“You still have a business model,” he assured the crowd of aftermarket professionals.

Shifting emissions standards are largely responsible for the transformation that is occurring. In Europe, Volkswagen’s diesel emissions scandal and future emissions rules of Euro 7 will essentially sideline diesel-powered cars, even as electric buses have yet to take over transit systems. Delphi’s light-duty diesel business has dropped 70% in just five years, leading to plant closures in Spain, France and England.

“We’ve got a billion-dollar business in electrification, last year down $200 million because of the downturn in light-duty diesel controllers,” Dauch said. “We think we’re going to double our electrification business in five years.”

That has meant opening five new plants in Eastern European markets like Turkey, Romania and Poland alone.

Deciding when the market will emerge is no small task, however. One new plant in China offered manufacturing capacity in July 2019, but it has yet to make any electric vehicle parts, highlighting mainstream EV challenges tied to policy shifts, because the Chinese government changed the incentive plans for electric vehicles.

‘All in’ on electric vehicles
Dana has also gone “all in” on electrification, said chairman and CEO Jim Kamsickas, referring to Dana’s work on e-drives with Kenworth and Peterbilt. Its gasket business is focusing on the needs of battery cooling systems and enclosures.

But he also puts the demand for new electric vehicle systems in perspective. “The mechanical piece is still going to be there.”

The demand for the new components and systems, however, has both companies challenged to find enough capable software engineers. Delphi has 1,600 of them now, and it needs more.

“Just being a motor supplier, just being an inverter supplier, just being a gearbox supplier itself, yes you’ll get value out of that. But in the longhaul you’re going to need to have engineers,” Kamsickas said of the work to develop systems.

Dauch noted that Delphi will leave the capital-intensive work of producing batteries to other companies in markets like China and Korea. “We’re going to make the systems that are in between – inverters, chargers, battery management systems,” he said.

Difficult change
But people working for European companies that have been built around diesel components are facing difficult days. Dauch refers to one German village with a population of 1,200, about 800 of whom build diesel engine parts. That business is working furiously to shift to producing gasoline parts.

Electrification will face hurdles of its own, of course. Major cities around the world are looking to ban diesel-powered vehicles by 2050, but they still lack the infrastructure needed to charge all the cars and truck fleet charging at scale, he added.

Kamsickas welcomes the disruptive forces.

“This is great,” he said. “It’s making us all think a little differently. It’s just that business models have had to pivot – for you, for us, for everybody.”

They need to be balanced against other business demands, including evolving cross-border EV collaboration dynamics, too.

Said Kamsickas: “Working through the disruption of electrification, it’s how do you financially manage that? Oh, by the way, the last time I checked there are [company] shareholders and stakeholders you need to take care of.”

“It’s going to be tough,” Dauch agreed, referring to the changes for suppliers. “The next three to four years are really going to be game changes. “There’ll be some survivors and some losers, that’s for sure.”

Related News

• Electricity Forum News

• EV Infrastructure News

EV Grid Capacity Management shows how smart charging, load balancing, and off-peak pricing align with utility demand response, DC fast charging networks, and renewable integration to keep national electricity infrastructure reliable as EV adoption scales

Key Points

EV Grid Capacity Management schedules charging and balances load to keep EV demand within utility capacity.

✅ Off-peak pricing and time-of-use tariffs shift charging demand.

✅ Smart chargers enable demand response and local load balancing.

✅ Gradual EV adoption allows utilities to plan upgrades efficiently.

One of the most frequent concerns you will see from electric vehicle haters is that the electricity grid can’t possibly cope with all cars becoming EVs, or that EVs will crash the grid entirely. However, they haven’t done the math properly. The grids in most developed nations will be just fine, so long as the demand is properly management. Here’s how.

The biggest mistake the social media keyboard warriors make is the very strange assumption that all cars could be charging at once. In the UK, there are currently 32,697,408 cars according to the UK Department of Transport. The UK national grid had a capacity of 75.8GW in 2020. If all the cars in the UK were EVs and charging at the same time at 7kW (the typical home charger rate), they would need 229GW – three times the UK grid capacity. If they were all charging at 50kW (a common public DC charger rate), they would need 1.6TW – 21.5 times the UK grid capacity. That sounds unworkable, and this is usually the kind of thinking behind those who claim the UK grid can't cope with EVs.

What they don’t seem to realize is that the chances of every single car charging all at once are infinitesimally low. Their arguments seem to assume that nobody ever drives their car, and just charges it all the time. If you look at averages, the absurdity of this position becomes particularly clear. The distance each UK car travels per year has been slowly dropping, and was 7,400 miles on average in 2019, again according to the UK Department of Transport. An EV will do somewhere between 2.5 and 4.5 miles per kWh on average, so let’s go in the middle and say 3.5 miles. In other words, each car will consume an average of 2,114kWh per year. Multiply that by the number of cars, and you get 69.1TWh. But the UK national grid produced 323TWh of power in 2019, so that is only 21.4% of the energy it produced for the year. Before you argue that’s still a problem, the UK grid produced 402TWh in 2005, which is more than the 2019 figure plus charging all the EVs in the UK put together. The capacity is there, and energy storage can help manage EV-driven peaks as well.

Let’s do the same calculation for the USA, where an EV boom is about to begin and planning matters. In 2020, there were 286.9 million cars registered in America. In 2020, while the US grid had 1,117.5TW of utility electricity capacity and 27.7GW of solar, according to the US Energy Information Administration. If all the cars were EVs charging at 7kW, they would need 2,008.3TW – nearly twice the grid capacity. If they charged at 50kW, they would need 14,345TW – 12.8 times the capacity.

However, in 2020, the US grid generated 4,007TWh of electricity. Americans drive further on average than Brits – 13,500 miles per year, according to the US Department of Transport’s Federal Highway Administration. That means an American car, if it were an EV, would need 3,857kWh per year, assuming the average efficiency figures above. If all US cars were EVs, they would need a total of 1,106.6TWh, which is 27.6% of what the American grid produced in 2020. US electricity consumption hasn’t shrunk in the same way since 2005 as it has in the UK, but it is clearly not unfeasible for all American cars to be EVs. The US grid could cope too, even as state power grids face challenges during the transition.

After all, the transition to electric isn’t going to happen overnight. The sales of EVs are growing fast, with for example more plug-ins sold in the UK in 2021 so far than the whole of the previous decade (2010-19) put together. Battery-electric vehicles are closing in on 10% of the market in the UK, and they were already 77.5% of new cars sold in Norway in September 2021. But that is new cars, leaving the vast majority of cars on the road fossil fuel powered. A gradual introduction is essential, too, because an overnight switchover would require a massive ramp up in charge point installation, particularly devices for people who don’t have the luxury of home charging. This will require considerable investment, but could be served by lots of chargers on street lamps, which allegedly only cost £1,000 ($1,300) each to install, usually with no need for extra wiring.

This would be a perfectly viable way to provide charging for most people. For example, as I write this article, my own EV is attached to a lamppost down the street from my house. It is receiving 5.5kW costing 24p (32 cents) per kWh through SimpleSocket, a service run by Ubitricity (now owned by Shell) and installed by my local London council, Barnet. I plugged in at 11am and by 7.30pm, my car (which was on about 28% when I started) will have around 275 miles of range – enough for a couple more weeks. It will have cost me around £12 ($16) – way less than a tank of fossil fuel. It was a super-easy process involving the scanning of a QR code and entering of a credit card, very similar to many parking systems nowadays. If most lampposts had one of these charging plugs, not having off-street parking would be no problem at all for owning an EV.

With most EVs having a range of at least 200 miles these days, and the average mileage per day being 20 miles in the UK (the 7,400-mile annual figure divided by 365 days) or 37 miles in the USA, EVs won’t need charging more than once a week or even every week or two. On average, therefore, the grids in most developed nations will be fine. The important consideration is to balance the load, because if too many EVs are charging at once, there could be a problem, and some regions like California are looking to EVs for grid stability as part of the solution. This will be a matter of incentivizing charging during off-peak times such as at night, or making peak charging more expensive. It might also be necessary to have the option to reduce charging power rates locally, while providing the ability to prioritize where necessary – such as emergency services workers. But the problem is one of logistics, not impossibility.

There will be grids around the world that are not in such a good place for an EV revolution, at least not yet, and some critics argue that policies like Canada's 2035 EV mandate are unrealistic. But to argue that widespread EV adoption will be an insurmountable catastrophe for electricity supply in developed nations is just plain wrong. So long as the supply is managed correctly to make use of spare capacity when it’s available as much as possible, the grids will cope just fine.

Related News

• Electricity Forum News

• EV Infrastructure News

Courtyard by Marriott Lancaster Solar Array delivers 100% renewable electricity via photovoltaic panels at Greenfield Corporate Center, Pennsylvania, a High Hotels and Marriott sustainability initiative reducing grid demand and selling excess power for efficient operations.

Key Points

A $1.5M PV installation powering the 133-room hotel with 100% renewable electricity in Greenfield Center, Lancaster.

✅ 2,700 PV panels generate 1,239,000 kWh annually

✅ First Marriott in the US with 100% solar electricity

✅ $504,900 CFA grant; excess power sold to the utility

High Hotels Ltd., a hotel developer and operator, recently announced it is installing a $1.5 million solar array that will generate 100% of the electrical power required to operate one of its existing hotels in Greenfield Corporate Center. The completed installation will make the 133-room Courtyard by Marriott-Lancaster the first Marriott-branded hotel in the United States with 100% of its electricity needs generated from solar power. It is also believed to be the first solar array in the country installed for the sole purpose of generating 100% of the electricity needs of a hotel, mirroring how other firms are commissioning their first solar power plant to meet sustainability goals.

“This is an exciting approach to addressing our energy needs that aligns very well with High’s commitment to environmental stewardship,”

“We’ve been advancing many environmentally responsible practices across our hotel portfolio, including converting the interior and exterior lighting at the Lancaster Courtyard to LED, which will lower electricity demand by 15%,” said Russ Urban, president of High Hotels. “Installing solar is another important step in this progression, and we will look to apply lessons from this as we expand our portfolio of premium select-service hotels.”

The Lancaster-based hotel developer, owner and operator is working in partnership with Marriott International Inc. to realize this vision, in step with major brands announcing new clean energy projects across their portfolios.

The installation of more than 2,700 ballasted photovoltaic panels will fill an area more than two football fields in size. After evaluating several on-site and near-site alternatives, High Hotels decided to install the solar array on the roof of a nearby building in Greenfield Corporate Center. Using the existing roof saves more than three acres of open land and has additional aesthetic benefits, aligning with recommendations for solar farms under consideration by local planners. The solar array will produce 1,239,000 kWh of power for the hotel, which consumes 1,177,000 kWh. Any excess power will be sold to the utility, though affordable solar batteries are making on-site storage increasingly feasible.

High Hotels received a grant of $504,900 from the Commonwealth Financing Authority (CFA) through the Solar Energy Program to complete the project. An independent agency of the Department of Community and Economic Development (DCED), the CFA is responsible for evaluating projects and awarding funds for a variety of economic development programs, including the Solar Energy Program and statewide initiatives like solar-power subscriptions that broaden access. The project will receive a solar renewable energy credit which will be conveyed to the CFA to provide the agency with more funds to offer grants in the future.

“This is a cutting-edge project that is exactly the kind we are looking for to promote the generation and use of solar energy,” said DCED Secretary Dennis Davin. “I am very pleased that the first Marriott in the US to receive 100% of its electric needs through renewable solar energy is located right here in Central Pennsylvania.” Secretary Davin also serves as chairman of the CFA’s board.

Panels for the solar array will be Q Cells manufactured by Hanwha Cells Co., Ltd., headquartered in Seoul, South Korea. Ephrata, Pa.-based Meadow Valley Electric Inc. will install the array in the second and third quarters of 2018 with commissioning targeted for September 2018.

Related News

• Electricity Forum News

• Renewable Energy News

Waste-to-Graphene uses flash joule heating to convert carbon-rich trash into turbostratic graphene for composites, asphalt, concrete, and flexible electronics, delivering scalable, low-cost, high-quality material from food scraps, plastics, and tires with minimal processing.

Key Points

A flash heating method converting waste carbon into turbostratic graphene for scalable, low-cost industrial uses.

✅ Converts food scraps, plastics, and tires into graphene

✅ Produces turbostratic flakes that disperse well in composites

✅ Scalable, low-cost process via flash joule heating

Science doesn’t usually take after fairy tales. But Rumpelstiltskin, the magical imp who spun straw into gold, would be impressed with the latest chemical wizardry. Researchers at Rice University report today in Nature that they can zap virtually any source of solid carbon, from food scraps to old car tires, and turn it into graphene—sheets of carbon atoms prized for applications ranging from high-strength plastic to flexible electronics, and debates over 5G electricity use continue to evolve. Current techniques yield tiny quantities of picture-perfect graphene or up to tons of less prized graphene chunks; the new method already produces grams per day of near-pristine graphene in the lab, and researchers are now scaling it up to kilograms per day.

“This work is pioneering from a scientific and practical standpoint” as it promises to make graphene cheap enough to use to strengthen asphalt or paint, says Ray Baughman, a chemist at the University of Texas, Dallas. “I wish I had thought of it.” The researchers have already founded a new startup company, Universal Matter, to commercialize their waste-to-graphene process, while others are digitizing the electrical system to modernize infrastructure.

With atom-thin sheets of carbon atoms arranged like chicken wire, graphene is stronger than steel, conducts electricity and heat better than copper, and can serve as an impermeable barrier preventing metals from rusting, while advances such as superconducting cables aim to cut grid losses. But since its 2004 discovery, high-quality graphene—either single sheets or just a few stacked layers—has remained expensive to make and purify on an industrial scale. That’s not a problem for making diminutive devices such as high-speed transistors and efficient light-emitting diodes. But current techniques, which make graphene by depositing it from a vapor, are too costly for many high-volume applications. And higher throughput approaches, such as peeling graphene from chunks of the mineral graphite, produce flecks composed of up to 50 graphene layers that are not ideal for most applications.

Graphene comes in many forms. Single sheets, which are ideal for electronics and optics, can be grown using a method called chemical vapor deposition. But it produces only tiny amounts. For large volumes, companies commonly use a technique called liquid exfoliation. They start with chunks of graphite, which is just myriad stacked graphene layers. Then they use acids and solvents, as well as mechanical grinding, to shear off flakes. This approach typically produces tiny platelets each made up of 20 to 50 layers of graphene.

In 2014, James Tour, a chemist at Rice, and his colleagues found they could make a pure form of graphene—each piece just a few layers thick—by zapping a form of amorphous carbon called carbon black with a laser. Brief pulses heated the carbon to more than 3000 kelvins, snapping the bonds between carbon atoms; for comparison, researchers have also generated electricity from falling snow using triboelectric effects. As the cloud of carbon cooled, it coalesced into the most stable structure possible, graphene. But the approach still produced only tiny qualities and required a lot of energy.

Two years ago, Luong Xuan Duy, one of Tour’s graduate students, read that other researchers had created metal nanoparticles by zapping a material with electricity, creating the same brief blast of heat behind the success of the laser graphene approach. “I wondered if I could use that to heat a carbon source and produce graphene,” Duy says. So, he put a dash of carbon black in a clear glass vial and zapped it with 400 volts, similar in spirit to electrical weed zapping approaches in agriculture, for about 200 milliseconds. Initially he got junk. But after a bit of tweaking, he managed to create a bright yellowish white flash, indicating the temperature inside the vial was reaching about 3000 kelvins. Chemical tests revealed he had produced graphene.

It turned out to be a type of graphene that is ideal for bulk uses. As the carbon atoms condense to form graphene, they don’t have time to stack in a regular pattern, as they do in graphite. The result is a material known as turbostatic graphene, with graphene layers jumbled at all angles atop one another. “That’s a good thing,” Duy says. When added to water or other solvents, turbostatic graphene remains suspended instead of clumping up, allowing each fleck of the material to interact with whatever composite it’s added to.

“This will make it a very good material for applications,” says Monica Craciun, a materials physicist at the University of Exeter. In 2018, she and her colleagues reported that adding graphene to concrete more than doubled its compressive strength. Tour’s team saw much the same result. When they added just 0.05% by weight of their flash-produced graphene to concrete, the compressive strength rose 25%; graphene added to polydimethylsiloxane, a common plastic, boosted its strength by 250%.

As digital control spreads across energy networks, research to counter ransomware-driven blackouts is increasingly important for grid resilience.

Those results could reignite efforts to use graphene in a wide range of composites. Researchers in Italy reported recently that adding graphene to asphalt dramatically reduces its tendency to fracture and more than doubles its life span. Last year, Iterchimica, an Italian company, began to test a 250-meter stretch of road in Milan paved with graphene-spiked asphalt. Tests elsewhere have shown that adding graphene to paint dramatically improves corrosion resistance.

These applications would require high-quality graphene by the ton. Fortunately, the starting point for flash graphene could hardly be cheaper or more abundant: Virtually any organic matter, including coffee grounds, food scraps, old tires, and plastic bottles, can be vaporized to make the material. “We’re turning garbage into graphene,” Duy says.

Related News

• Electricity Forum News

• Grid Technologies News

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.

Related News

• Electricity Forum News

• Energy Policy News