Farmers want to grow power

By Kitchener-Waterloo Record


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Farmer Tim Barrie is ready to start growing electricity.

"I grow asparagus, I grow rhubarb," Barrie said. "Now it's solar power. It would be just another crop for me."

Township council held a meeting recently to hear public comment on a plan by Waterloo-based Arise Technologies to install a solar farm in an exhausted asparagus field along Kings Road at Highway 401.

It would be the first solar farm for Waterloo Region and one of the first in Canada.

Arise wants to rent 6.1 hectares (15.1 acres) from Barrie for 20 years and cover it with solar panels. Under a provincial solar incentive program, the power would be purchased for 42 cents a kilowatt hour, or seven times the usual rate.

In late 2006, when Arise first approached township officials with the solar farm idea, the concept was to produce up to 400 kilowatts of electricity a day at a cost of $4 million.

Today, Arise plans more solar panels to generate up to three megawatts of electricity.

That's enough to power 1,500 homes. The project will now cost $24 million.

The first phase, planned for installation in fall 2008, would generate one megawatt of power, said Jan van der Woerd, sales manager at Arise.

It's one of three solar farm projects Arise is moving ahead with this summer. Another is near Toronto, the third near Kingston.

All are going through the local approval process: happenstance will determine which ends up as the first Arise solar farm in operation.

The Ontario Power Authority has contracts signed to buy 420 megawatts of electricity from 45 solar farms. None, however, are yet in operation.

The Barrie project will use off-the-shelf solar panels and technology, van der Woerd said.

It will be built in phases to test the best way to design a solar farm for this part of the world. Some panels will track the sun, while others will be fixed and point south.

"We know it works, but before you build a 20-megawatt farm, do one megawatt," van der Woerd said. "How do you do that in Canada, in Ontario?"

Arise will use the Barrie project as a sales tool.

People already drop in and look at the solar cells Barrie put on his barn in 2006.

It's also a learning process for North Dumfries Township, which doesn't have regulations for solar farms. Neither does Waterloo Region, which sets general land use rules for cities and townships. But planning policies in Ontario, a leader in North America at promoting solar energy, now allow them on agricultural lands.

The township is looking at a site-specific amendment to its official plan, said township planner Steve Jefferson. If approved, the Barrie application will set general guidelines when other solar projects are proposed.

When customers first heard Barrie was going solar, they worried he was going to rip out all his crops. He's not. One field is affected and asparagus is already planted in the next field.

Barrie has moved asparagus out of the proposed solar field beside his house. The crop can only grow in one spot for 25 years before disease moves in. The land must sit fallow for 20 years before asparagus is replanted - exactly the length of the power sale contract.

Early on, Barrie's regular customers had a hard time understanding his solar mindset.

"At first, they were completely baffled as to why a farmer would be getting into energy," he said.

After he shows them the $32,000 solar installation on the roof - which will pay for itself in 12 years - and they see the digital meter inside, showing the power generated, they get it.

"Gas at $1.29 a litre cost is on everyone's mind," he said. "People know what a hybrid (car) is now. I think we've had a cultural shift in how we think about energy... the average person really understands."

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OPINION | Bridging the electricity gap between Alberta and B.C. makes perfect climate sense

BC-Alberta Transmission Intertie enables clean hydro to balance wind and solar, expanding transmission capacity so Site C hydro can dispatch power, cut emissions, lower costs, and accelerate electrification across provincial grids under federal climate policy.

 

Key Points

A cross-provincial grid link using BC hydro to firm Alberta wind and solar, cutting emissions and costs.

✅ Balances variable renewables with dispatchable hydro from Site C.

✅ Enables power trade: peak exports, low-cost wind imports.

✅ Lowers decarbonization costs and supports electrification goals.

 

By Mark Jaccard

Lost in the news and noise of the federal government's newly announced $170-per-tonne carbon tax was a single, critical sentence in Canada's updated climate plan, one that signals a strategy that could serve as the cornerstone for a future free of greenhouse gas emissions.

"The government will work with provinces and territories to connect parts of Canada that have abundant clean hydroelectricity with parts that are currently more dependent on fossil fuels for electricity generation — including by advancing strategic intertie projects."

Why do we think this one sentence is so important? And what has it got to do with the controversial Site C project Site C electricity debate under construction in British Columbia?

The answer lies in the huge amount of electricity we'll need to generate in Canada to achieve our climate goals for 2030 and 2050. Even while we aggressively pursue energy efficiency, our electric cars, buses and perhaps trucks in Canada's net-zero race will need a huge amount of new electricity, as will our buildings and industries. 

Luckily, Canada is blessed with an electricity system that is the envy of the world — already over 80 per cent zero emission, the bulk being from flexible hydro-electricity, with a backbone of nuclear power largely in Ontario, a national electricity success and rapidly growing shares of cheap wind and solar. 

Provincial differences
Yet the story differs significantly from one province to another. While B.C.'s electricity is nearly emissions free, the opposite is true of its neighbour, Alberta, where more than 80 per cent still comes from fossil fuels. This, despite an impressive shift away from coal power in recent years.

Now imagine if B.C. and Alberta were one province.

This might sound like the start of a bad joke, or a horror movie to some, but it's the crux of new research by a trio of energy economists who put a fine point on the value of such co-operation.

The study, by Brett Dolter, Kent Fellows and Nic Rivers, takes a detailed look at the economic case for completing Site C, BC Hydro's controversial large hydro project under construction, and makes three key conclusions.

First, they argue Site C should likely not have been started in the first place. Only a narrow set of assumptions can now justify its total cost. But what's done is done, and absent a time machine, the decision to complete the dam rests on go-forward costs.

On that note, their second conclusion is no more optimistic. Considering the cost to complete the project, even accounting for avoiding termination costs should it be cancelled, they find the economics of completing Site C over-budget status to be weak. If the New York Times had a Site C needle in the style of the newspaper's election visual, it would be "leaning cancel" at this point.

In Alberta, more than 80 per cent of the electricity still comes from fossil fuels, despite an impressive shift away from coal power in recent years. (CBC)
But it is their third conclusion that stands out as worthy of attention. They argue there is a case for completing Site C if the following conditions are met:

B.C. and Alberta reduce their electricity sector emissions by more than 75 per cent (this really means Alberta, given B.C.'s already clean position); and

B.C. and Alberta expand their ability to move electricity between their respective provinces by building new transmission lines.

Let's deal with each of these in turn.

On Condition 1, we give an emphatic: YES! Reducing electricity emissions is an absolute must to meet climate pledges if Canada is to come even close to achieving its net-zero goals. As noted above, a clean electricity grid will be the cornerstone of a decarbonized economy as we generate a great deal more power to electrify everything from industrial processes to heating to transportation and more. 

Condition 2 is more challenging. Talk of increasing transmission connections across Canada, including Hydro-Québec's U.S. strategy has been ongoing for over 50 years, with little success to speak of. But this time might well be different. And the implications for a completed Site C, should the government go that route, are profound.

Wind and solar costs rapidly declining
Somewhat ironically, the case for Site C is made stronger by the rapidly declining costs of two of its apparent renewable competitors: wind and solar.

The cost of wind and solar generation has fallen by 70 per cent and 90 per cent, respectively, a dramatic decline in the past 10 years. No longer can these variable sources of power be derided as high cost; they are unequivocally the cheapest sources of raw energy in electricity systems today.

However, electricity system operators must deal with their "non-dispatchability," a seemingly complicated term that simply means they produce electricity only when the sun shines and the wind blows, which is not necessarily when electricity customers want their electricity delivered (dispatched) to them. And because of this characteristic, the value of dispatchable electricity sources, like a completed Site C, will grow as a complement to wind and solar. 

Thus, as Alberta's generation of cheap wind and solar grows, so too does the value of connecting it with the firm, dispatchable resources available in B.C.

Rather than displacing wind and solar, large hydro facilities with the ability to increase or decrease output on short notice can actually enable more investment in these renewable sources. Expanding the transmission connection, with Site C on one side of that line, becomes even more valuable.

Many in B.C. might read this and rightly ask themselves, why should we foot the bill for this costly project to help out Albertans? The answer is that it won't be charity — B.C. will get paid handsomely for the power it delivers in peak periods and will be able to import wind power at low prices from Alberta in other times. B.C. will benefit greatly from these gains of trade.

Turning to Alberta, why should Albertans support B.C. reaping these gains? The answer is two-fold.

First, Site C will actually enable more low-cost wind and solar to be built in Alberta due to hydro's ability to balance these non-dispatchable renewables. Jobs and economic opportunity will occur in Alberta from this renewable energy growth.

Second, while B.C. imports won't come cheap, they will be less costly than the decarbonization alternatives Alberta would need without B.C.'s flexible hydro, as the economists' study shows. This means lower overall costs to Alberta's power consumers.

A clear role for Ottawa
To be sure, there are challenges to increasing the connectedness of B.C. and Alberta's power systems, not least of which is BC Hydro being a regulated, government-owned monopoly while Alberta is a competitive market amongst private generators. Some significant accommodations in climate policy and grids will be needed to ensure both sides can compete and benefit from trade on an equal footing.

There is also the pesky matter of permitting and constructing thousands of kilometres of power lines. Getting linear energy infrastructure built in Canada has not exactly been our forte of late.

We are not naive to the significant challenges in such an approach, but it's not often that we see such a clear narrative for beneficial climate action that, when considered at the provincial level, is likely to be thwarted, but when considered more broadly can produce a big win.

It's the clearest example yet of a role for the federal government to bridge the gap, to facilitate the needed regulatory conversations, and, let's be frank, to bring money to the table to make the line happen. Neither provincial side is likely to do it on their own, nor, as history has shown, are they likely to do it together. 

For a government committed to reducing emissions, and with a justified emphasis on the electricity sector, the opportunity to expand the Alberta-B.C. transmission intertie, leveraging the flexibility of B.C.'s hydro with the abundance of wind and solar potential on the Prairies, offers a potential massive decarbonization win for Western Canada that is too good to ignore.


Mark Jaccard, a professor at Simon Fraser University, and Blake Shaffer, a professor at the University of Calgary

 

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Tesla (TSLA) Wants to Become an Electricity Retailer

Tesla Energy Ventures Texas enters the deregulated market as a retail electricity provider, leveraging ERCOT, battery storage, solar, and grid software to enable virtual power plants and customer energy trading with Powerwall and Megapack assets.

 

Key Points

Tesla Energy Ventures Texas is Tesla's retail power unit selling grid and battery energy and enabling solar exports.

✅ ERCOT retail provider; sells grid and battery-stored power

✅ Uses Powerwall/Megapack; supports virtual power plants

✅ Targets Tesla owners; enables solar export and trading

 

Last week, Tesla Energy Ventures, a new subsidiary of electric car maker Tesla Inc. (TSLA), filed an application to become a retail electricity provider in the state of Texas. According to reports, the company plans to sell electricity drawn from the grid to customers and from its battery storage products. Its grid transaction software may also enable customers for its solar panels to sell excess electricity back to the smart grid in Texas.1

For those who have been following Tesla's fortunes in the electric car industry, the Palo Alto, California-based company's filing may seem baffling. But the move dovetails with Tesla's overall ambitions for its renewable energy business, as utilities face federal scrutiny of climate goals and electricity rates.

Why Does Tesla Want to Become an Electricity Provider?
The simple answer to that question is that Tesla already manufactures devices that produce and store power. Examples of such devices are its electric cars, which come equipped with lithium ion batteries, and its suite of battery storage products for homes and enterprises. Selling power generated from these devices to consumers or to the grid is a logical next step.


Tesla's move will benefit its operations. The filing states that it plans to build a massive battery storage plant near its manufacturing facility in Austin. The plant will provide the company with a ready and cheap source of power to make its cars.

Tesla's filing should also be analyzed in the context of the Texas grid. The state's electricity market is fully deregulated, unlike regions debating grid privatization approaches, and generated about a quarter of its overall power from wind and solar in 2020.2 The Biden administration's aggressive push toward clean energy is only expected to increase that share.

After a February fiasco in the state grid resulted in a shutdown of renewable energy sources and skyrocketing natural gas prices, Texas committed to boosting the role of battery storage in its grid. The Electricity Reliability Council of Texas (ERCOT), the state's grid operator, has said it plans to install 3,008 MW of battery storage by the end of 2022, a steep increase from the 225 MW generated at the end of 2020.3 ERCOT's proposed increase in installation represents a massive market for Tesla's battery unit.

Tesla already has considerable experience in this arena. It has built battery storage plants in California and Australia and is building a massive battery storage unit in Houston, according to a June Bloomberg report.4 The unit is expected to service wholesale power producers. Besides this, the company plans to "drum up" business among existing customers for its batteries through an app and a website that will allow them to buy and sell power among themselves, a model also being explored by Octopus Energy in international talks.

Tesla Energy Ventures: A Future Profit Center?
Tesla's foray into becoming a retail electricity provider could boost the top line for its energy services business, even as issues like power theft in India highlight retail market challenges. In its last reported quarter, the company stated that its energy generation and storage business brought in $810 million in revenues.

Analysts have forecast a positive future for its battery storage business. Alex Potter from research firm Piper Sandler wrote last year that battery storage could bring in more than $200 billion per year in revenue and grow up to a third of the company's overall business.5

Immediately after the news was released, Morningstar analyst Travis Miller wrote that Tesla does not represent an immediate threat to other major players in Texas's retail market, where providers face strict notice obligations illustrated when NT Power was penalized for delayed disconnection notices, such as NRG Energy, Inc. (NRG) and Vistra Corp. (VST). According to him, the company will initially target its own customers to "complement" its offerings in electric cars, battery, charging, and solar panels.6

Further down the line, however, Tesla's brand name and resources may work to its advantage. "Tesla's brand name recognition gives it an advantage in a hypercompetitive market," Miller wrote, adding that the car company's entry confirmed the firm's view that consumer technology or telecom companies will try to enter retail energy markets, where policy shifts like Ontario rate reductions can shape customer expectations.

 

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Tariff Threats Boost Support for Canadian Energy Projects

Canadian Energy Infrastructure Tariffs are reshaping pipelines, deregulation, and energy independence, as U.S. trade tensions accelerate approvals for Alberta oil sands, Trans Mountain expansion, and CAPP proposals amid regulatory reform and market diversification.

 

Key Points

U.S. tariff threats drive approvals, infrastructure, and diversification to strengthen Canada energy security.

✅ Tariff risk boosts support for pipelines and export routes

✅ Faster project approvals and deregulation gain political backing

✅ Diversifying markets reduces reliance on U.S. buyers

 

In recent months, the Canadian energy sector has experienced a shift in public and political attitudes toward infrastructure projects, particularly those related to oil and gas production. This shift has been largely influenced by the threat of tariffs from the United States, as well as growing concerns about energy independence and U.S.-Canada trade tensions more broadly.

Scott Burrows, the CEO of Pembina Pipeline Corp., noted in a conference call that the potential for U.S. tariffs on Canadian energy imports has spurred a renewed sense of urgency and receptiveness toward energy infrastructure projects in Canada. With U.S. President Donald Trump’s proposed tariffs Trump tariff threat on Canadian imports, particularly a 10% tariff on energy products, there is increasing recognition within Canada that these projects are essential for the country’s long-term economic and energy security.

While the direct impact of the tariffs is not immediate, industry leaders are optimistic about the long-term benefits of deregulation and faster project approvals, even as some see Biden as better for Canada’s energy sector overall. Burrows highlighted that while it will take time for the full effects to materialize, there are significant "tailwinds" in favor of faster energy infrastructure development. This includes the possibility of more streamlined regulatory processes and a shift toward more efficient project timelines, which could significantly benefit the Canadian energy sector.

This changing landscape is particularly important for Alberta’s oil production, which is one of the largest contributors to Canada’s energy output. The Canadian Association of Petroleum Producers (CAPP) has responded to the growing tariff threat by releasing an “energy platform,” outlining recommendations for Ottawa to help mitigate the risks posed by the evolving trade situation. The platform includes calls for improved infrastructure, such as pipelines and transportation systems, and priorities like clean grids and batteries, to ensure that Canadian energy can reach global markets more effectively.

The tariff threat has also sparked a wider conversation about the need for Canada to strengthen its energy infrastructure and reduce its dependency on the U.S. for energy exports. With the potential for escalating trade tensions, there is a growing push for Canadian energy resources to be processed and utilized more domestically, though cutting Quebec’s energy exports during a tariff war. This has led to increased political support for projects like the Trans Mountain pipeline expansion, which aims to connect Alberta’s oil sands to new markets in Asia via the west coast.

However, the energy sector’s push for deregulation and quicker approvals has raised concerns among environmental groups and Indigenous communities. Critics argue that fast-tracking energy projects could lead to inadequate environmental assessments and greater risks to local ecosystems. These concerns underscore the tension between economic development and environmental protection in the energy sector.

Despite these concerns, there is a clear consensus that Canada’s energy industry needs to evolve to meet the challenges posed by shifting trade dynamics, even as polls show support for energy and mineral tariffs in the current dispute. The proposed U.S. tariffs have made it increasingly clear that the country’s energy infrastructure needs significant investment and modernization to ensure that Canada can maintain its status as a reliable and competitive energy supplier on the global stage.

As the deadline for the tariff decision approaches, and as Ford threatens to cut U.S. electricity exports, Canada’s energy sector is bracing for the potential fallout, while also preparing to capitalize on any opportunities that may arise from the changing trade environment. The next few months will be critical in determining how Canadian policymakers, businesses, and environmental groups navigate the complex intersection of energy, trade, and regulatory reform.

While the threat of U.S. tariffs may be unsettling, it is also serving as a catalyst for much-needed changes in Canada’s energy policy. The push for faster approvals and deregulation may help address some of the immediate concerns facing the sector, but it will be crucial for the government to balance economic interests with environmental and social considerations as the country moves forward in its energy transition.

 

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Cost of US nuclear generation at ten-year low

US Nuclear Generating Costs 2017 show USD33.50/MWh for nuclear energy, the lowest since 2008, as capital expenditures, fuel costs, and operating costs declined after license renewals and uprates, supporting a reliable, low-carbon grid.

 

Key Points

The 2017 US nuclear average was USD33.50/MWh, lowest since 2008, driven by reduced capital, fuel, and operating costs.

✅ Average cost USD33.50/MWh, lowest since 2008

✅ Capital, fuel, O&M costs fell sharply since 2012 peak

✅ License renewals, uprates, market reforms shape competitiveness

 

Average total generating costs for nuclear energy in 2017 in the USA were at their lowest since 2008, according to a study released by the Nuclear Energy Institute (NEI), amid a continuing nuclear decline debate in other regions.

The report, Nuclear Costs in Context, found that in 2017 the average total generating cost - which includes capital, fuel and operating costs - for nuclear energy was USD33.50 per megawatt-hour (MWh), even as interest in next-generation nuclear designs grows among stakeholders. This is 3.3% lower than in 2016 and more than 19% below 2012's peak. The reduction in costs since 2012 is due to a 40.8% reduction in capital expenditures, a 17.2% reduction in fuel costs and an 8.7% reduction in operating costs, the organisation said.

The year-on-year decline in capital costs over the past five years reflects the completion by most plants of efforts to prepare for operation beyond their initial 40-year licence. A few major items - a series of vessel head replacements; steam generator replacements and other upgrades as companies prepared for continued operation, and power uprates to increase output from existing plants - caused capital investment to increase to a peak in 2012. "As a result of these investments, 86 of the [USA's] 99 operating reactors in 2017 have received 20-year licence renewals and 92 of the operating reactors have been approved for uprates that have added over 7900 megawatts of electricity capacity. Capital spending on uprates and items necessary for operation beyond 40 years has moderated as most plants are completing these efforts," it says.

Since 2013, seven US nuclear reactors have shut down permanently, with the Three Mile Island debate highlighting wider policy questions, and another 12 have announced their permanent shutdown. The early closure for economic reasons of reliable nuclear plants with high capacity factors and relatively low generating costs will have long-term economic consequences, the report warns: replacement generating capacity, when needed, will produce more costly electricity, fewer jobs that will pay less, and, for net-zero emissions objectives, more pollution, it says.

NEI Vice President of Policy Development and Public Affairs John Kotek said the "hardworking men and women of the nuclear industry" had done an "amazing job" reducing costs through the institute's Delivering the Nuclear Promise campaign and other initiatives, in line with IAEA low-carbon lessons from the pandemic. "As we continue to face economic headwinds in markets which do not properly compensate nuclear plants, the industry has been doing its part to reduce costs to remain competitive," he said.

"Some things are in urgent need of change if we are to keep the nation's nuclear plants running and enjoy their contribution to a reliable, resilient and low-carbon grid. Namely, we need to put in place market reforms that fairly compensate nuclear similar to those already in place in New York, Illinois and other states," Kotek added.

Cost information in the study was collected by the Electric Utility Cost Group with prior years converted to 2017 dollars for accurate historical comparison.

 

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Philippines Reaffirms Clean Energy Commitment at APEC Summit

Philippines Clean Energy Commitment underscores APEC-aligned renewables, energy transition, and climate resilience, backed by policy incentives, streamlined regulation, technology transfer, and public-private investments to boost energy security, jobs, and sustainable growth.

 

Key Points

It is the nation's pledge to scale renewables and build climate resilience through APEC-aligned energy policy.

✅ Policy incentives, PPPs, and streamlined permits

✅ Grid upgrades, storage, and smart infrastructure

✅ Regional cooperation on tech transfer and capacity building

 

At the recent Indo-Pacific Economic Cooperation (APEC) Summit, the Philippines reiterated its dedication to advancing clean energy initiatives as part of its sustainable development agenda. This reaffirmation underscores the country's commitment to mitigating climate change impacts, promoting energy security, and fostering economic resilience through renewable energy solutions, with insights from an IRENA study on the power crisis informing policy direction.

Strategic Goals and Initiatives

During the summit, Philippine representatives highlighted strategic goals aimed at enhancing clean energy adoption and sustainability practices. These include expanding renewable energy infrastructure, accelerating energy transition efforts toward 100% renewables targets, and integrating climate resilience into national development plans.

Policy Framework and Regulatory Support

The Philippines has implemented a robust policy framework to support clean energy investments and initiatives. This includes incentives for renewable energy projects, streamlined regulatory processes, and partnerships with international stakeholders, such as ADFD-IRENA funding initiatives, to leverage expertise and resources in advancing sustainable energy solutions.

Role in Regional Cooperation

As an active participant in regional economic cooperation, the Philippines collaborates with APEC member economies to promote knowledge sharing, technology transfer, and capacity building in renewable energy development, as over 30% of global electricity is now generated from renewables, reinforcing the momentum. These partnerships facilitate collective efforts to address energy challenges and achieve mutual sustainability goals.

Economic and Environmental Benefits

Investing in clean energy not only reduces greenhouse gas emissions but also stimulates economic growth and creates job opportunities in the renewable energy sector. The Philippines recognizes the dual benefits of transitioning to cleaner energy sources, with projects like the Aboitiz geothermal financing award illustrating private-sector momentum, contributing to long-term economic stability and environmental stewardship.

Challenges and Opportunities

Despite progress, the Philippines faces challenges such as energy access disparities, infrastructure limitations, and financing constraints in scaling up clean energy projects, amid regional signals like India's solar slowdown and coal resurgence that underscore transition risks. Addressing these challenges requires innovative financing mechanisms, public-private partnerships, and community engagement to ensure inclusive and sustainable development.

Future Outlook

Moving forward, the Philippines aims to accelerate clean energy deployment through strategic investments, technology innovation, and policy coherence, aligning with the U.S. clean energy market trajectory toward majority share to capture emerging opportunities. Embracing renewable energy as a cornerstone of its economic strategy positions the country to attract investments, enhance energy security, and achieve resilience against global energy market fluctuations.

Conclusion

The Philippines' reaffirmation of its commitment to clean energy at the APEC Summit underscores its leadership in promoting sustainable development and addressing climate change challenges. By prioritizing renewable energy investments and fostering regional cooperation, the Philippines aims to build a resilient energy infrastructure that supports economic growth and environmental sustainability. As the country continues to navigate its energy transition journey, collaboration and innovation will be key in realizing a clean energy future that benefits present and future generations.

 

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ACORE tells FERC that DOE Proposal to Subsidize Coal, Nuclear Power Plants is unsupported by Record

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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