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FERC DER Aggregation advances debates over distributed energy resources as Congress presses action on Order 841, grid resilience, and wholesale market access, including rooftop solar, storage, and virtual power plant participation across PJM and ISO-NE.

Key Points

FERC DER Aggregation enables grouped distributed resources to join wholesale markets, providing capacity and flexibility.

? Opens wholesale market access for aggregated DER portfolios

? Aligns with Order 841, storage, and grid resilience goals

? Raises jurisdictional questions between FERC and state regulators

The Monday letter from Congressional Democrats illustrates growing frustration in Washington over the lack of FERC action on multiple power sector issues, including the aging U.S. grid and related challenges.

Last May, after the FERC technical conference, 16 Democratic Senators wrote to then-Chairman Kevin McIntyre urging him to develop guidance for grid operators on aggregated DERs.

In July, McIntyre responded, saying that FERC was "diligently reviewing the record," but the commission has taken no action since.

Since then, "DER adoption and renewable energy aggregation have continued to grow," House and Senate lawmakers wrote in their identical Monday letters, "driven not only by state and federal policies, but consumer interest in choosing cost-competitive technologies such as rooftop solar, smart thermostats and customer-sited energy generation and storage, reflecting key utility trends in the sector."

The lawmakers wrote they were "encouraged" by FERC Chairman Neil Chatterjee's comments in June 2018, writing that he "specifically cited the role DERs will play in our continued grid transition."

In that speech at the S&P Global Platts 2018 Transmission Planning and Development Conference, Chatterjee noted "growing interest" in non-transmission alternatives, including "DERs and storage."

"How the Commission treats filings associated with those first-of-kind projects could prove an important factor in investors’ assessments of whether similar non-traditional projects are bankable or not — and more broadly signal whether FERC is open to innovation in the transmission sector,” he said.

In addition to the DER order and rehearing decision on Order 841, FERC has multiple other power sector initiatives that have not seen official action in months, even as major changes to electricity pricing are debated by stakeholders.

The highest profile is its open proceeding on grid resilience, set up last January after FERC rejected a coal and nuclear bailout proposal from the Department of Energy. In October, the CEO of the PJM Interconnection, the nation’s largest wholesale power market, urged FERC to issue a final order in the docket, calling for "leadership" from the commission.

Chatterjee, however, has not indicated when FERC could decide on the case. In December, Commissioner Rich Glick told a Washington audience he is "not entirely sure where the chairman wants to go with that proceeding yet."

Outside of resilience, FERC also has open reviews of both its pipeline certificate policy and implementation of the Public Utilities Regulatory Policy Act, a key law supporting renewable energy. McIntrye set those reviews in motion during his tenure as chairman, but after his death in January the timing of both remains unclear.

In recent months, Chatterjee has also delayed FERC votes on major export facilities for liquefied natural gas and a political spending case involving PJM after impasses between Republicans and Democrats on FERC.

Two members from each party currently sit on the commission. That allows Democrats to deadlock commission votes on natural gas facilities and other issues — a partisan divide on display this week when they clashed with the chairman over offshore wind.

As the commission considers final guidance on DERs, the boundaries of federal jurisdiction are likely to be a key issue. At the technical conference, states from the Midcontinent ISO argued FERC should allow them to choose whether to let aggregated DERs participate in retail and wholesale markets. Other states argued the value proposition of distributed resources may rely on that sort of dual participation.

Despite the lack of action from FERC, some grid operators are moving forward with aggregated distributed resources in New England market reform efforts and elsewhere, demonstrating momentum. Last week, a residential solar-plus-storage aggregation cleared the ISO-NE capacity auction for the first time, committing to provide 20 MW of capacity beginning in 2022.

On the Senate side, Sens. Sheldon Whitehouse, R.I., and Ed Markey, Mass., led the letter to FERC. In the House, Reps. Peter Welch, Vt., and Mike Levin, Calif., led the signatories.

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Yukon Electricity Demand Record underscores peak load growth as winter cold snaps drive heating, lighting, and EV charging, blending hydro, LNG, and diesel with renewable energy and planned grid-scale battery storage in Whitehorse.

Key Points

It is the territory's new peak electricity load, reflecting winter demand, electric heating, EVs, and mixed generation.

✅ New peak: 104.42 MW, surpassing 2020 record of 103.84 MW

✅ Winter peaks met with hydro, LNG, diesel, and renewables mix

✅ Customers urged to shift use off peak hours and use timers

A new record for electricity demand has been set in Yukon. The territory recorded a peak of 104.42 megawatts, according to a news release from Yukon Energy.

The new record is about a half a megawatt higher than the previous record of 103.84 megawatts recorded on Jan. 14, 2020.

While in general, over 90 per cent of the electricity generated in Yukon comes from renewable resources each year, with initiatives such as new wind turbines expanding capacity, during periods of high electricity use each winter, Yukon Energy has to use its hydro, liquefied natural gas and diesel resources to generate the electricity, the release says.

But when it comes to setting records, Andrew Hall, CEO of Yukon Energy, says it's not that unusual.

"Typically, during the winter, when the weather is cold, demand for electricity in the Yukon reaches its maximum. And that's because folks use more electricity for heating their homes, for cooking meals, there's more lighting demand, because the days are shorter," he said.

"It usually happens either in December or sometimes in January, when we get a cold snap."

He said generally over the years, electricity demand has grown.

"We get new home construction, construction of new apartment buildings. And typically, those new homes are all heated by electricity, maybe not all of them but the majority," Hall said.

Vuntut Gwitchin First Nation's solar farm now generating electricity
In taking action on climate, this Arctic community wants to be a beacon to the world

Efforts to curb climate change add to electricity demand
There are also other reasons, ones that are "in the name of climate change," Hall added.

That includes people trying to limit fossil fuel heating by swapping to electric heating. And, he said some Yukoners are switching to electric vehicles as incentives expand across the North.

"Over time, those two new demands, in the name of climate change, will also contribute to growing demand for electricity," he said.

While Yukon did reach this new all time high, Hall said the territory still hadn't hit the maximum capacity for the week, which was 118 megawatts, and discussions about a potential connection to the B.C. grid are part of long-term planning.

Yukon Energy's hydroelectric dam in Whitehorse. Yukon Energy's CEO, Andrew Hall, said demand of 104 megawatts wasn't unexpected, nor was it an emergency. The corporation has the ability to generate 118 megawatts. (Paul Tukker/CBC)
Tips to curve demand
"When we plan our system, we actually plan for a scenario, guided by the view that sustainability is key to the grid's future, where we actually lose our largest hydro generating facility," Hall said.

"We had plenty of generation available so it wasn't an emergency situation, and, even as other provinces face electricity shortages, it was more just an observation that hey, our peaks are growing."

He also said it was an opportunity to reach out to customers on ways to curve their demand for electricity around peak times, drawing on energy efficiency insights from other provinces, which is typically between 7 a.m. and 9 a.m., and between 5 p.m. and 7 p.m., Monday to Friday.

For example, he said, people should consider running major appliances, like dishwashers, during non-peak hours, such as in the afternoon rather than in the morning or evening.

During winter peaks, people can also use a block heater timer on vehicles and turn down the thermostat by one or two degrees.

'We plan for each winter'
Hall said Yukon Energy is working to increase its peak output, including working on a large grid scale battery to be installed in Whitehorse, similar to Ontario's energy storage push now underway. 

When it comes to any added load from people working from home due to COVID-19, Hall said they haven't noticed any identifiable increase there.

"Presumably, if someone's working from home, you know, their computer is at home, and they're not using the computer at the office," he said.

Yukon Energy one step closer to having largest battery storage site in the North
He said there shouldn't be any concern for maxing out the capacity of electricity demand as Yukon moves into the colder winter months, since those days are forecast for.

"This number of 104 megawatts wasn't unexpected," he said, adding how much electricity is needed depends on the weather too.

"We plan for each winter."

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Renewable Energy Security strengthens affordability and grid reliability through electrification, wind, and solar, reducing fossil fuel volatility exposed by the Ukraine crisis, aligning with IEA guidance and the Paris Agreement to deliver resilient, low-cost power.

Key Points

Renewable energy security is reliable, affordable power from electrification, wind and solar, cutting fossil fuel risk.

✅ Wind and solar now outcompete gas for new power capacity.

✅ Diversifies supply and reduces fossil price volatility.

✅ Requires grid flexibility, storage, and demand response.

Oil, gas, and coal have been the central pillar of the global energy system throughout the 20th century. And for decades, these fossil fuels have been closely associated with energy security.  

The perception of energy security, however, is rapidly changing. Renewables form an increasing share of energy sectors worldwide as countries look to deliver on the Paris Agreement and mitigate the effects of climate change, with IEA clean energy investment now significantly outpacing fossil fuels. Moreover, Russia’s invasion of Ukraine has demonstrated how relying on fossil fuels for power, heating, and transport has left many countries vulnerable or energy insecure.  

The International Energy Agency (IEA) defines energy security as “the uninterrupted availability of energy sources at an affordable price” (IEA, 2019a). This definition hardly describes today’s global energy situation, with the cancellation of natural gas deliveries and skyrocketing prices for oil and gas products, and with supply chain challenges in clean energy that also require attention. These circumstances have cascading effects on electricity prices in countries like the United Kingdom that rely heavily on natural gas to produce electricity. In Europe, energy insecurity has been even further amplified since the Russian corporation Gazprom recently cut off gas supplies to several countries.  

As a result, energy security has gained new urgency in Canada and worldwide, creating opportunities in the global electricity market for Canada. Recent events provide a stark reminder of the volatility and potential vulnerability of global fossil fuel markets and supply chains. Even in Canada, as one of the largest producers of oil and gas in the world, the price of fuels depends on global and regional market forces rather than government policy or market design. Thus, the average monthly price for gasoline in Canada hit a record high of CAD 2.07 per litre in May 2022 (Figure 1), and natural gas prices surged to a record CAD 7.54 per MMBtu in May 2022 (Figure 2).  

Energy price increases of this magnitude are more than enough to strain Canadian household budgets. But on top of that, oil and gas prices have accelerated inflation more broadly as it has become more expensive to produce, transport, and store goods, including food and other basic commodities (Global News, 2022).  

Renewable Energy Is More Affordable 

In contrast to oil and gas, renewable energy can reliably deliver affordable energy, as shown by falling wholesale electricity prices in markets with growing clean power. This is a unique and positive aspect of today’s energy crisis compared to historical crises: options for electrification and renewable-based electricity systems are both available and cost-effective.  

For new power capacity, wind and solar are now cheaper than any other source, and wind power is making gains as a competitive source in Canada. According to Equinor (2022), wind and solar were already cheaper than gas-based power in 2020. This means that renewable energy was already the cheaper option for new power before the recent natural gas price spikes. As illustrated in Figure 3, the cost of new renewable energy has dropped so dramatically that, for many countries, it is cheaper to install new solar or wind infrastructure than to keep operating existing fossil fuel-based power plants (International Renewable Energy Agency, 2021). This means that replacing fossil-based electricity generation with renewables would save money and reduce emissions. Wind and solar prices are expected to continue their downward trends as more countries increase deployment and learn how to best integrate these sources into the grid. 

Renewable Energy Is Reliable 

To deliver on the uninterrupted availability side of the energy security equation, renewable power must remain reliable even as more variable energy sources, like wind and solar, are added to the system, and regional leaders such as the Prairie provinces will help anchor this transition. For Canada and other countries to achieve high energy security through electrification, grid system operations must be able to support this, and pathways to zero-emissions electricity by 2035 are feasible.  

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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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Brazil Energy Emergency Loan Package aims to bolster utilities via BNDES as coronavirus curbs electricity demand. Aneel and the Mines and Energy Ministry weigh measures while Eletrobras privatization and auctions face delays.

Key Points

An emergency plan supporting Brazilian utilities via BNDES and banks during coronavirus demand slumps and payment risks.

✅ Modeled on 2014-2015 sector loans via BNDES and private banks

✅ Addresses cash flow from lower demand and bill nonpayment

✅ Auctions and Eletrobras privatization delayed amid outbreak

Brazil’s government is considering an emergency loan package for energy distributors struggling with lower energy use and facing lost revenues because of the coronavirus outbreak, echoing strains seen elsewhere such as Germany's utility troubles during the energy crisis, an industry group told Reuters.

Marcos Madureira, president of Brazilian energy distributors association Abradee, said the package being negotiated by companies and the government could involve loans from state development bank BNDES or a pool of banks, but that the value of the loans and other details was not yet settled.

Also, Brazil’s Mines and Energy Ministry is indefinitely postponing projects to auction off energy transmission and generation assets planned for this year because of the coronavirus, even as the need for electricity during COVID-19 remained critical, it said in the Official Gazette.

The coronavirus outbreak will also delay the privatization of state-owned utility Eletrobras, its chief executive officer said on Monday.

The potential loan package under discussion would resemble a similar measure in 2014 and 2015 that offered about 22 billion reais ($4.2 billion) in loans to the sector as Brazil was entering its deepest recession on record, and drawing comparisons to a proposed Texas market bailout after a winter storm, Madureira said.

Public and private banks including BNDES, Caixa Economica Federal, Itau Unibanco and Banco Bradesco participated in those loans.

Three sources involved in the discussions said on condition of anonymity that the Mines and Energy Ministry and energy regulator Aneel were considering the matter.

Aneel declined to comment. The Mines and Energy Ministry and BNDES did not immediately respond to requests for comment.

Energy distributors worry that reduced electricity demand during COVID-19 could result in deep revenue losses.

The coronavirus has led to widespread lockdowns of non-essential businesses in Brazil, while citizens are being told to stay home. That is causing lost income for many hourly and informal workers in Brazil, who could be unable to pay their electricity bills, raising risks of pandemic power shut-offs for vulnerable households.

The government sees a loan package as a way to stave off a potential chain of defaults in the sector, a move discussed alongside measures such as a Brazil tax strategy on energy prices, one of the sources said.

On a conference call with investors about the company’s latest earnings, Eletrobras CEO Wilson Ferreira Jr. said privatization would be delayed, without giving any more details on the projected time scale.

The largest investors in Brazil’s energy distribution sector include Italy’s Enel, Spain’s Iberdrola via its subsidiary Neoenergia and China’s State Grid via CPFL Energia, with Chinese interest also evidenced by CTG's bid for EDP, as well as local players Energisa e Equatorial Energia. 

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Thailand Covid-19 Electricity Bill Relief offers energy subsidies, tariff cuts, and free power for small meters, helping work-from-home users as authorities waive charges and discount kWh rates via EGAT, MEA, PEA for three months.

Key Points

Program waiving or cutting household electricity bills for 22 million homes in March-May, easing work-from-home costs.

? Free power for meters <= 5 amps; up to 10M homes

? Up to 800 kWh: pay February rate; above, 50% discount

? >3,000 kWh: 30% discount; program valid March-May

The Thailand cabinet has formally approved energy authorities' decision to either waive or cut electricity charges, similar to B.C. electricity relief measures, for 22 million households where people are working at home because of the coronavirus disease.

Energy Minister Sontirat Sontijirawong said after the cabinet meeting on Tuesday that the ministers acknowledged the step taken by from the Energy Regulatory Commission, the Electricity Generating Authority of Thailand, the Metropolitan Electricity Authority and the Provincial Electricity Authority and noted parallels with Ontario's COVID-19 hydro plan rolled out to support ratepayers.

The measure would be valid for three months, from March to May, and cover 22 million households. It would cost the state 23.68 billion baht in lost revenue, he said, a pattern also seen with Ontario rate reductions affecting provincial revenues.

"The measure reduces the electricity charges burden on households. It is the cost of living of the people who are working from home to support the government's control of Covid-19," Mr Sontirat said.

The business sector also wants similar assistance, echoing sentiments from Ontario manufacturers during recent price reduction efforts. He said their requests were being considered.

Free electricity is extended to households with a power meter of no more than 5 amps. Up to 10 million households are expected to benefit, although issues like electricity payment challenges in India highlight different market contexts.

For households with a power meter over 5 amps, if their consumption does not exceed 800 units (kilowat hours), they will pay as much as they did in their February bill. The amount over 800 units will be subject to a 50 per cent discount, while elsewhere B.C. commercial consumption has fallen sharply.

Large houses that consume more than 3,000 units will get a 30 per cent discount, at a time when BC Hydro demand is down 10%.

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