DoE is pessimistic about LED lighting

Sulphur Hexafluoride (SF6) Emissions drive rising greenhouse gas impacts in electrical switchgear, power grids, and renewables, with extreme global warming potential, long atmospheric lifetime, and leakage risks challenging climate targets and grid decarbonization.

Key Points

SF6 emissions are leaks from electrical switchgear and grids, a high-GWP gas with ~1,000-year lifetime.

✅ 23,500x CO2 global warming potential (GWP)

✅ Leaks from switchgear, breakers, gas-insulated substations

✅ Clean air and vacuum alternatives emerging for MV/HV

Sulphur hexafluoride, or SF6, is widely used in the electrical industry to prevent short circuits and accidents.

But leaks of the little-known gas in the UK and the rest of the EU in 2017 were the equivalent of putting an extra 1.3 million cars on the road.

Levels are rising as an unintended consequence of the green energy boom and the broader global energy transition worldwide.

Cheap and non-flammable, SF6 is a colourless, odourless, synthetic gas. It makes a hugely effective insulating material for medium and high-voltage electrical installations.

It is widely used across the industry, from large power stations to wind turbines to electrical sub-stations in towns and cities.

It prevents electrical accidents and fires.

However, the significant downside to using the gas is that it has the highest global warming potential of any known substance. It is 23,500 times more warming than carbon dioxide (CO2).

Just one kilogram of SF6 warms the Earth to the same extent as 24 people flying London to New York return.

It also persists in the atmosphere for a long time, warming the Earth for at least 1,000 years.

So why are we using more of this powerful warming gas?

The way we make electricity around the world is changing rapidly, with New Zealand's push to electrify in its energy system.

Where once large coal-fired power stations brought energy to millions, the drive to combat climate change and to move away from coal means they are now being replaced by mixed sources of power including wind, solar and gas.

This has resulted in many more connections to the electricity grid, and with EU electricity use could double by 2050, a rise in the number of electrical switches and circuit breakers that are needed to prevent serious accidents.

Collectively, these safety devices are called switchgear. The vast majority use SF6 gas to quench arcs and stop short circuits.

"As renewable projects are getting bigger and bigger, we have had to use it within wind turbines specifically," said Costa Pirgousis, an engineer with Scottish Power Renewables on its new East Anglia wind farm, which doesn't use SF6 in turbines.

"As we are putting in more and more turbines, we need more and more switchgear and, as a result, more SF6 is being introduced into big turbines off shore.

"It's been proven for years and we know how it works, and as a result it is very reliable and very low maintenance for us offshore."

How do we know that SF6 is increasing?

Across the entire UK network of power lines and substations, there are around one million kilograms of SF6 installed.

A study from the University of Cardiff found that across all transmission and distribution networks, the amount used was increasing by 30-40 tonnes per year.

This rise was also reflected across Europe with total emissions from the 28 member states in 2017 equivalent to 6.73 million tonnes of CO2. That's the same as the emissions from 1.3 million extra cars on the road for a year.

Researchers at the University of Bristol who monitor concentrations of warming gases in the atmosphere say they have seen significant rises in the last 20 years.

"We make measurements of SF6 in the background atmosphere," said Dr Matt Rigby, reader in atmospheric chemistry at Bristol.

"What we've seen is that the levels have increased substantially, and we've seen almost a doubling of the atmospheric concentration in the last two decades."

How does SF6 get into the atmosphere?

The most important means by which SF6 gets into the atmosphere is from leaks in the electricity industry.

Electrical company Eaton, which manufactures switchgear without SF6, says its research indicates that for the full life-cycle of the product, leaks could be as high as 15% - much higher than many other estimates.

Louis Schaeffer, electrical business manager at Eaton, said: "The newer gear has very low leak rates but the key question is do you have newer gear?

"We looked at all equipment and looked at the average of all those leak rates, and we didn't see people taking into account the filling of the gas. Plus, we looked at how you recycle it and return it and also included the catastrophic leaks."

How damaging to the climate is this gas?

Concentrations in the atmosphere are very small right now, just a fraction of the amount of CO2 in the air.

However, the global installed base of SF6 is expected to grow by 75% by 2030, as data-driven electricity demand surges worldwide.

Another concern is that SF6 is a synthetic gas and isn't absorbed or destroyed naturally. It will all have to be replaced and destroyed to limit the impact on the climate.

Developed countries are expected to report every year to the UN on how much SF6 they use, but developing countries do not face any restrictions on use.

Right now, scientists are detecting concentrations in the atmosphere that are 10 times the amount declared by countries in their reports. Scientists say this is not all coming from countries like India, China and South Korea.

One study found that the methods used to calculate emissions in richer countries "severely under-reported" emissions over the past two decades.

Why hasn't this been banned?

SF6 comes under a group of human-produced substances known as F-gases. The European Commission tried to prohibit a number of these environmentally harmful substances, including gases in refrigeration and air conditioning, back in 2014.

But they faced strong opposition from industries across Europe.

"In the end, the electrical industry lobby was too strong and we had to give in to them," said Dutch Green MEP Bas Eickhout, who was responsible for the attempt to regulate F-gases.

"The electric sector was very strong in arguing that if you want an energy transition, and you have to shift more to electricity, you will need more electric devices. And then you also will need more SF6.

"They used the argument that otherwise the energy transition would be slowed down."

What do regulator and electrical companies say about the gas?

Everyone is trying to reduce their dependence on the gas, and US control efforts suggest targeted policies can drive declines, as it is universally recognised as harmful to the climate.

In the UK, energy regulator Ofgem says it is working with utilities to try to limit leaks of the gas.

"We are using a range of tools to make sure that companies limit their use of SF6, a potent greenhouse gas, where this is in the interest of energy consumers," an Ofgem spokesperson told BBC News.

"This includes funding innovation trials and rewarding companies to research and find alternatives, setting emissions targets, rewarding companies that beat those targets, and penalising those that miss them."

Are there alternatives - and are they very expensive?

The question of alternatives to SF6 has been contentious over recent years.

For high-voltage applications, experts say there are very few solutions that have been rigorously tested.

"There is no real alternative that is proven," said Prof Manu Haddad from the school of engineering at Cardiff University.

"There are some that are being proposed now but to prove their operation over a long period of time is a risk that many companies don't want to take."

Medium voltage operations there are several tried-and-tested materials. Some in the industry say that the conservative nature of the electrical industry is the key reason that few want to change to a less harmful alternative.

"I will tell you, everyone in this industry knows you can do this; there is not a technical reason not to do it," said Louis Schaffer from Eaton.

"It's not really economic; it's more a question that change takes effort and if you don't have to, you won't do it."

Some companies are feeling the winds of change

Sitting in the North Sea some 43km from the Suffolk coast, Scottish Power Renewables has installed one of world's biggest wind farms, in line with a sustainable electric planet vision, where the turbines will be free of SF6 gas.

East Anglia One will see 102 of these towering generators erected, with the capacity to produce up to 714MW (megawatts) of power by 2020, enough to supply half a million homes.

Previously, an installation like this would have used switchgear supplied with SF6, to prevent the electrical accidents that can lead to fires.

Each turbine would normally have contained around 5kg of SF6, which, if it leaked into the atmosphere, would add the equivalent of around 117 tonnes of carbon dioxide. This is roughly the same as the annual emissions from 25 cars.

"In this case we are using a combination of clean air and vacuum technology within the turbine. It allows us to still have a very efficient, reliable, high-voltage network but to also be environmentally friendly," said Costa Pirgousis from Scottish Power Renewables.

"Once there are viable alternatives on the market, there is no reason not to use them. In this case, we've got a viable alternative and that's why we are using it."

But even for companies that are trying to limit the use of SF6, there are still limitations. At the heart of East Anglia One sits a giant offshore substation to which all 102 turbines will connect. It still uses significant quantities of the highly warming gas.

What happens next ?

The EU will review the use of SF6 next year and will examine whether alternatives are available. However, even the most optimistic experts don't think that any ban is likely to be put in place before 2025.

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US-Canada Electricity Tariff Dispute intensifies as proposed tariffs spur Canadian threats to restrict hydroelectric exports, risking cross-border energy supply, grid reliability, higher electricity prices, and clean energy goals in the Northeast and Midwest.

Key Points

Trade clash over tariffs and hydroelectric exports that threatens power supply, prices, and grid reliability.

✅ Potential export curbs on Canadian hydro to US markets

✅ Risks: higher prices, strained grids, reduced clean energy

✅ Diplomacy urged to avoid retaliatory trade measures

In early February 2025, escalating trade tensions between the United States and Canada have raised concerns about the future of electricity exports from Canada to the U.S. The potential imposition of tariffs by the U.S. has prompted Canadian officials to consider retaliatory measures, including restricting electricity exports and pursuing high-level talks such as Ford's Washington meeting with federal counterparts.

Background of the Trade Dispute

In late November 2024, President-elect Donald Trump announced plans to impose a 25% tariff on all Canadian products, citing issues related to illegal immigration and drug trafficking. This proposal has been met with strong opposition from Canadian leaders, who view such tariffs as unjustified and detrimental to both economies, even as tariff threats boost support for Canadian energy projects among some stakeholders.

Canada's Response and Potential Retaliatory Measures

In response to the proposed tariffs, Canadian officials have discussed various countermeasures. Ontario Premier Doug Ford has threatened to cut electricity supplies to 1.5 million Americans and ban imports of U.S.-made beer and liquor. Other provinces, such as Quebec and Alberta, are also considering similar actions, though experts advise against cutting Quebec's energy exports due to reliability concerns.

Impact on U.S. Energy Supply

Canada is a significant supplier of electricity to the United States, particularly in regions like the Northeast and Midwest. A reduction or cessation of these exports could lead to energy shortages and increased electricity prices in affected U.S. states, with New York especially vulnerable according to regional assessments. For instance, Ontario exports substantial amounts of electricity to neighboring U.S. states, and any disruption could strain local energy grids.

Economic Implications

The imposition of tariffs and subsequent retaliatory measures could have far-reaching economic consequences. In Canada, industries such as agriculture, manufacturing, and energy could face significant challenges due to reduced access to the U.S. market, even as many Canadians support energy and mineral tariffs as leverage. Conversely, U.S. consumers might experience higher prices for goods and services that rely on Canadian imports, including energy products.

Environmental Considerations

Beyond economic factors, the trade dispute could impact environmental initiatives. Canada's hydroelectric power exports are a clean energy source that helps reduce carbon emissions in the U.S., where policymakers look to Canada for green power to meet targets. A reduction in these exports could lead to increased reliance on fossil fuels, potentially hindering environmental goals.

The escalating trade tensions between the United States and Canada, particularly concerning electricity exports, underscore the complex interdependence of the two nations. While the situation remains fluid, it highlights the need for diplomatic engagement to resolve disputes and maintain the stability of cross-border energy trade.

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DOE Office of Fossil Energy safeguards energy security via the Strategic Petroleum Reserve, domestic critical minerals from coal byproducts, and carbon capture to curb CO2, strengthening resiliency amid shocks and supporting U.S. manufacturing and defense.

Key Points

A DOE program advancing energy security through SPR stewardship, critical minerals R&D, and carbon capture.

✅ Manages the Strategic Petroleum Reserve for emergency crude supply

✅ Develops domestic critical minerals from coal and mining byproducts

✅ Deploys carbon capture, utilization, and storage to cut CO2

The global economy has just experienced a period of unique transformation because of COVID-19. The fact that remains constant in this new economic landscape is that our society relies on energy; it’s an integral part of our day-to-day lives, even as U.S. energy use has evolved over time. According to the U.S. Energy Information Administration, approximately 80 percent of energy consumption in the United States comes from fossil fuels, so having access to a secure and reliable supply of those energy resources is more important than ever for national energy security considerations today. Below are three examples that highlight how our work at the U.S. Department of Energy’s Office of Fossil Energy (FE) helps ensure the Nation’s energy security and resiliency.

(1) Open crude oil reserves to respond to crises

FE has overall program responsibility for carrying out the mission of the Strategic Petroleum Reserve (SPR), the world’s largest supply of emergency crude oil. These federally-owned stocks are stored in massive underground salt caverns along the coastline of the Gulf of Mexico. The SPR is a powerful tool U.S. leaders use to respond to a wide range of crises, including energy crisis impacts on electricity and fuels, involving crude oil disruption or demand loss.  When the COVID-19 pandemic hit, the oil markets crashed and crude oil demand dropped drastically across the world. U.S. oil producers turned to the SPR to store their oil while broader energy dominance constraints were becoming evident in practice. This helped alleviate the pressure on producers to shut in oil production and proved to be a critical asset for American energy and national security.

(2) Use the Nation’s abundant coal reserves to produce valuable materials

Critical materials, including rare earth elements, are a group of chemical elements and materials with unique properties that support manufacturing of most modern technologies. They are essential components for critical defense and homeland security applications, green energy technologies, hybrid and electric vehicles, and high-value electronics. While these materials are not rare, they are hard to separate and expensive to extract. The United States relies heavily on imports from China. To reduce U.S. dependence on foreign sources, FE has a research and development program aimed at producing a domestic supply of critical materials from the Nation’s abundant coal resources and associated byproducts from legacy and current mining operations. Many of the technologies being developed can also be used to separate critical minerals from other mining materials and byproducts. Tapping into these resources has the potential to create new industries and revitalize coal communities and the workforce in coal-producing regions.

(3) Decrease carbon emissions for a cleaner energy future

FE is committed to balancing the Nation’s energy use with the need to protect the environment, and has a comprehensive portfolio of technological solutions that help keep carbon dioxide (CO2) emissions out of the atmosphere. For example, amid high natural gas prices that reinforce the case for clean electricity, the Department has been investing in carbon capture, utilization, and storage technologies for over a decade. These technologies capture CO2 emissions from various sources, including coal-fired power plants and manufacturing plants, before they enter the atmosphere. Several of these cutting-edge technologies have been deployed at major demonstration sites, supported by clean energy funding that aims to benefit millions. Three of these projects—Petra Nova, Archer Daniels Midland, and Air Products & Chemicals—have captured and injected over 10.8 million metric tons of CO2. The success of these projects is paving the way toward a cleaner and more sustainable American energy future.

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Ecofiscal Commission EV Policy Shift examines carbon pricing limits, endorsing signal boosters like subsidies, EV incentives, and coal bans, amid advisory changes and public pushback, to accelerate emissions cuts beyond market-based taxes and regulations.

Key Points

An updated stance recognizing carbon pricing limits and backing EV incentives, subsidies, and rules to reduce emissions.

✅ Carbon pricing plus subsidies, EV incentives

✅ Advisory shift; Jack Mintz departs

✅ Focus on emissions cuts, coal power bans

Something strange happened at the Ecofiscal Commission recently. Earlier this month, the carbon-tax advocacy group featured on its website as one of its advisers the renowned Canadian economist (and FP Comment columnist) Jack M. Mintz. The other day, suddenly and without fanfare, Mintz was gone from the website, and the commission’s advisory board.

Advisers come and advisers go, of course, but it turns out there was an impetus for Mintz’s departure. The Ecofiscal Commission in its latest report, dropped just before Canada Day, seemingly shifted from its position that carbon prices were so excellent at mimicking market forces that the tax could repeal and replace virtually the entire vast expensive gallimaufry of subsidies, caps, rules and regulations that are costing Canada a fortune in business and bureaucrats. As some Ecofiscal commissioners wrote just a few months ago, policies that “dictate specific technologies or methods for reducing emissions constrain private choice and increase costs” and were a bad idea.

But, in this latest report, the commission is now musing about the benefits of carbon-tax “signal boosters”: that is, EV subsidies and rules to, for instance, get people to start buying electric vehicles (EVs), as well as bans on coal-fired power. “Even well designed carbon pricing can have limitations,” rationalized the commission. Mintz said he had “misgivings” about the change of tack. He decided it best if he focus his advisory energies elsewhere.

It’s hard to blame the commission for falling like everyone else for the electric-car mania that’s sweeping the nation and the world. Electric cars offer a sexiness that dreary old carbon taxes can never hope to match — especially in light of a new Angus Reid poll last week that showed the majority of Canadians now want governments to shelve any plans for carbon taxes.

So far, because nobody’s really driving these miracle machines, said mania has been limited to breathless news reports about how the electric-vehicle revolution is about to rock our world. EVs comprise just two-tenths of a per cent of all passenger vehicles in North America, despite the media’s endless hype and efforts of green-obsessed governments to cover much of the price tag, like Ontario’s $14,000 rebate for Tesla buyers. In Europe, where virtue-signalling urban environmentalism is the coolest, they’re not feeling the vehicular electricity much more: EVs account for barely one per cent of personal vehicles in France, the U.K. and Germany. When Hong Kong cancelled Tesla rebates in April, sales fell to zero.

Going by the ballyhoo, you’d think EVs were at an inflection point and an unstoppable juggernaut. But it’s one that has yet to even get started. In his 2011 State of the Union address, then president Barack Obama predicted one million electric cars on the road by 2015. Four years later, there wasn’t even a third that many. California offered so many different subsidies for electric vehicles that low-income families could get rebates of up to US$13,500, but it still isn’t even close to reaching its target of having zero-emission vehicles make up 15 per cent of California auto sales by 2025, being stuck at three per cent since 2014. Ontario’s Liberal government last year announced to much laughter its plan to ensure that every family would have at least one zero-emission vehicle (ZEV) by 2024, and Quebec made a plan to make ZEVs worth 15.5 per cent of sales by 2020, while Ottawa’s 2035 EV mandate attracts criticism too. Let’s see how that’s going: Currently, ZEVs make up 0.16 per cent of new vehicle sales in Ontario and 0.38 per cent in Quebec.

The latest sensational but bogus EV news out last week was France’s government announcing the “end of the sale of gasoline and diesel cars by 2040,” and Volvo apparently announcing that as of 2019, all its models would be “electric.” Both announcements made international headlines. Both are baloney. France provided no actual details about this plan (will it literally become a crime to sell a gasoline car? Will hybrids, run partly on gasoline, be allowed?), but more importantly, as automotive writer Ed Wiseman pointed out in The Guardian, a lot will happen in technology and automotive use over the next 23 years that France has no way to predict, with changes in self-driving cars, public car-sharing and fuel technologies. Imagine making rules for today’s internet back in 1994.

Volvo, meanwhile, looked to be recycling and repackaging years-old news to seize on today’s infatuation with electric vehicles to burnish its now Chinese-owned brand. Since 2010, Volvo’s plan has been to focus on engines that were partly electric, with electric turbochargers, but still based on gasoline. Volvo doesn’t actually have an all-electric model, but the gasoline-swigging engine of its popular XC90 SUV is, partly, electrical. When Volvo said all its models would in two years be “electric,” it meant this kind of engine, not that it was phasing out the internal-combustion gasoline engine. But that is what it wanted reporters to think, and judging by all the massive and inaccurate coverage, it worked.

The real story being missed is just how pathetic things look right now for electric cars. Gasoline prices in the U.S. turned historically cheap in 2015 and stayed cheap, icing demand for gasless cars. Tesla, whose founder’s self-promotion had made the niche carmaker magically more valuable than powerhouses like Ford and GM, haemorrhaged US$12 billion in market value last week after tepid sales figures brought some investors back to Earth, even as the company’s new Model 3 began rolling off the line.

Not helping is that environmental claims about environmental cars are falling apart. In June, Tesla was rocked by a controversial Swedish study that found that making one of its car batteries released as much CO2 as eight years of gasoline-powered driving. And Bloomberg reported last week on a study by Chinese engineers that found that electric vehicles, because of battery manufacturing and charging by fossil-fuel-powered electricity sources, emit 50-per-cent more carbon than do internal-combustion engines. Still, the electric-vehicle hype not only continues unabated, it gets bigger and louder every day. If some car company figures out how to harness it, we’d finally have a real automotive revolution on our hands.

Kevin Libin, Financial Post

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Texas wholesale electricity price spike disrupts ERCOT markets as Griddy and other retail energy providers face surge pricing; customers confront spot market exposure, fixed-rate plan switching, demand response appeals, and deep-freeze grid constraints across Texas.

Key Points

An extreme ERCOT market surge sending real-time rates to caps, exposing Griddy users and driving provider-switch pleas.

✅ Wholesale index plans pass through $9,000/MWh scarcity pricing.

✅ Retailers urge switching; some halt enrollments amid volatility.

✅ Demand response incentives and conservation pleas reduce load.

Some retail power companies in Texas are making an unusual plea to their customers amid a winter storm that has sent electricity prices skyrocketing: Please, leave us.

Power supplier, Griddy, told all 29,000 of its customers that they should switch to another provider as spot electricity prices soared to as high as $9,000 a megawatt-hour. Griddy’s customers are fully exposed to the real-time swings in wholesale power markets, so those who don’t leave soon will face extraordinarily high electricity bills.

“We made the unprecedented decision to tell our customers — whom we worked really hard to get — that they are better off in the near term with another provider,” said Michael Fallquist, chief executive officer of Griddy. “We want what’s right by our consumers, so we are encouraging them to leave. We believe that transparency and that honesty will bring them back” once prices return to normal.

Texas is home to the most competitive electricity market in America. Homeowners and businesses shopping for electricity churn power providers there like credit cards. In the face of such cutthroat competition, retail power providers in the region have grown accustomed to offering new customers incredibly low rates, incentives and, at least in Griddy’s case, unusual plans that allow customers to pay wholesale power prices as opposed to fixed ones.

The ruthless nature of the business has power traders speculating over which firms might have been caught short this week in the most dramatic run-up in spot power prices they’ve ever seen, and even talk of a market bailout has surfaced.

Not all companies are asking customers to leave. Others are just pleading for them to cut back to reduce blackout risks during extreme weather.

Pulse Power, based in The Woodlands, Texas, is offering customers a chance to win a Tesla Model 3, or free electricity for up to a year if they reduce their power usage by 10% in the coming days. Austin-based Bulb is offering $2 per kilowatts-hour, up to $200, for any energy customers save.

Griddy, however, is in a different position. Its service is simple — and controversial. Members pay a $9.99 monthly fee and then pay the cost of spot power traded on Texas’s power grid based on the time of day they use it. Earlier this month, that meant customers were saving money — and at times even getting paid — to use electricity at night. But in recent days, the cost of their power has soared from about 5 to 6 cents a kilowatt-hour to $1 or more. That’s when Fallquist knew it was time to urge his customers to leave.

“I can tell you it was probably one of the hardest decisions we’ve ever made,” he said. “Nobody ever wants to see customers go.”

Griddy isn’t the only one out there actively encouraging its customers to leave. People were posting similar pleas on Twitter over the holiday weekend from other Texas utilities and retail power providers offering everything from $100 rebates to waived cancellation fees as incentives to switch.

Customers may not even be able to switch. Rizwan Nabi, president of energy consultancy Riz Energy in Houston, said several power providers in Texas have told him they aren’t accepting new customers due to this week’s volatile prices, while grid improvements are debated statewide.

Hector Torres, an energy trader in Texas, who is a Griddy customer himself, said he tried to switch services over the long weekend but couldn’t find a company willing to take him until Wednesday, when the weather is forecast to turn warmer.

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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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