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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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U.S. Electricity Trade by State, 2013-2017 highlights EIA grid patterns, interstate imports and exports, cross-border flows with Canada and Mexico, net exporters and importers, and market regions like ISOs and RTOs shaping consumption and generation.

Key Points

Brief EIA overview of interstate and cross-border power flows, ranking top net importers and exporters.

✅ Pennsylvania was the largest net exporter, averaging 59 million MWh.

✅ California was the largest net importer, averaging 77 million MWh.

✅ Top cross-border: NY, CA, VT, MN, MI imports; WA, TX, CA, NY, MT exports.

According to the U.S. Energy Information Administration (EIA) State Electricity Profiles, from 2013 to 2017, Pennsylvania was the largest net exporter of electricity, while California was the largest net importer.

Pennsylvania exported an annual average of 59 million megawatt-hours (MWh), while California imported an average of 77 million MWh annually.

Based on the share of total consumption in each state, the District of Columbia, Maryland, Massachusetts, Idaho and Delaware were the five largest power-importing states between 2013 and 2017, highlighting how some clean states import 'dirty' electricity as consumption outpaces local generation. Wyoming, West Virginia, North Dakota, Montana and New Hampshire were the five largest power-exporting states. Wyoming and West Virginia were net power exporting states between 2013 and 2017.

New York, California, Vermont, Minnesota and Michigan imported the most electricity from Canada or Mexico on average from 2013 to 2017, reflecting the U.S. look to Canada for green power during that period. Similarly, Washington, Texas, California, New York, and Montana exported the most electricity to Canada or Mexico, on average, during the same period.

Electricity routinely flows among the Lower 48 states and, to a lesser extent, between the United States and Canada and Mexico. From 2013 to 2017, Pennsylvania was the largest net exporter of electricity, sending an annual average of 59 million megawatthours (MWh) outside the state. California was the largest net importer, receiving an average of 77 million MWh annually.

Based on the share of total consumption within each state, the District of Columbia, Maryland, Massachusetts, Idaho, and Delaware were the five largest power-importing states between 2013 and 2017. Wyoming, West Virginia, North Dakota, Montana, and New Hampshire were the five largest power-exporting states. States with major population centers and relatively less generating capacity within their state boundaries tend to have higher ratios of net electricity imports to total electricity consumption, as utilities devote more to electricity delivery than to power production in many markets.

Wyoming and West Virginia were net power exporting states (they exported more power to other states than they consumed) between 2013 and 2017. Customers residing in these two states are not necessarily at an economic disadvantage or advantage compared with customers in neighboring states when considering their electricity bills and fees and market dynamics. However, large amounts of power trading may affect a state’s revenue derived from power generation.

Some states also import and export electricity outside the United States to Canada or Mexico, even as Canada's electricity exports face trade tensions today. New York, California, Vermont, Minnesota, and Michigan are the five states that imported the most electricity from Canada or Mexico on average from 2013 through 2017. Similarly, Washington, Texas (where electricity production and consumption lead the nation), California, New York, and Montana are the five states that exported the most electricity to Canada or Mexico, on average, for the same period.

Many states within the continental United States fall within integrated market regions, referred to as independent system operators or regional transmission organizations. These integrated market regions allow electricity to flow freely between states or parts of states within their boundaries.

EIA’s State Electricity Profiles provide details about the supply and disposition of electricity for each state, including net trade with other states and international imports and exports, and help you understand where your electricity comes from more clearly.

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U.S. Power Grid Supply Shortages strain reliability as heat waves, hurricanes, and drought drive peak demand; transformer scarcity, gas constraints, and renewable delays raise outage risks across ERCOT and MISO, prompting FERC warnings.

Key Points

They are equipment and fuel constraints that, amid extreme weather and peak demand, elevate outage risks.

✅ Transformer shortages delay storm recovery and repairs.

✅ Record gas burn, low hydro tighten generation capacity.

✅ ERCOT and MISO warn of rolling outages in heat waves.

U.S. power companies are facing supply crunches amid the U.S. energy crisis that may hamper their ability to keep the lights on as the nation heads into the heat of summer and the peak hurricane season.

Extreme weather events such as storms, wildfires and drought are becoming more common in the United States. Consumer power use is expected to hit all-time highs this summer, reflecting unprecedented electricity demand across the Eastern U.S., which could strain electric grids at a time when federal agencies are warning the weather could pose reliability issues.

Utilities are warning of supply constraints for equipment, which could hamper efforts to restore power during outages. They are also having a tougher time rebuilding natural gas stockpiles for next winter, after the Texas power system failure highlighted cold-weather vulnerabilities, as power generators burn record amounts of gas following the shutdown of dozens of coal plants in recent years and extreme drought cuts hydropower supplies in many Western states.

"Increasingly frequent cold snaps, heat waves, drought and major storms continue to challenge the ability of our nation’s electric infrastructure to deliver reliable affordable energy to consumers," Richard Glick, chairman of the U.S. Federal Energy Regulatory Commission (FERC), said earlier this month.

Federal agencies responsible for power reliability like FERC have warned that grids in the western half of the country could face reliability issues this summer as consumers crank up air conditioners to escape the heat, with nationwide blackout risks not limited to Texas. read more

Some utilities have already experienced problems due to the heat. Texas' grid operator, the Electric Reliability Council of Texas (ERCOT), was forced to urge customers to conserve energy as the Texas power grid faced another crisis after several plants shut unexpectedly during an early heat wave in mid-May. read more

In mid-June, Ohio-based American Electric Power Co (AEP.O) imposed rolling outages during a heat wave after a storm damaged transmission lines and knocked out power to over 200,000 homes and businesses.

The U.S. Midwest faces the most severe risk because demand is rising while nuclear and coal power supplies have declined. read more

The Midcontinent Independent System Operator (MISO), which operates the grid from Minnesota to Louisiana, warned that parts of its coverage area are at increased risk of temporary outages to preserve the integrity of the grid.

Supply-chain issues have already delayed the construction of renewable energy projects across the country, and the aging U.S. grid is threatening progress on renewables and EVs. Those renewable delays coupled with tight power in the Midwest prompted Wisconsin's WEC Energy Group Inc (WEC.N) and Indiana's NiSource Inc (NI.N) to delay planned coal plant shutdowns in recent months.

BRACING FOR SUPPLY SHORTAGES
Utility operators are conserving their inventory of parts and equipment as they plan to prevent summer power outages during severe storms. Over the last several months, that means operators have been getting creative.

"We’re doing a lot more splicing, putting cables together, instead of laying new cable because we're trying to maintain our new cable for inventory when we need it," Nick Akins, chief executive of AEP, said at the CERAWeek energy conference in March.

Transformers, which often sit on top of electrical poles and convert high-voltage energy to the power used in homes, are in short supply.

New Jersey-based Public Service Enterprise Group Inc (PSEG) (PEG.N) Chief Executive Ralph Izzo told Reuters the company has had to look at alternate supply options for low voltage transformers.

"You don’t want to deplete your inventory because you don't know when that storm is coming, but you know it's coming," Izzo said.

Some utilities are facing waiting times of more than a year for transformer parts, the National Rural Electric Cooperative Association and the American Public Power Association told U.S. Energy Secretary Jennifer Granholm in a May letter.

Summer is just starting, but U.S. weather so far this year has already been about 21% warmer than the 30-year norm, according to data provider Refinitiv.

"If we have successive days of 100-degree-heat, those pole top transformers, they start popping like Rice Krispies, and we would not have the supply stack to replace them," Izzo said.

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Toronto Grid Upgrade expands electricity capacity and reliability with new substations, upgraded transmission lines, and integrated renewable energy, supporting EV growth, sustainability goals, and resilient power for Toronto's growing residential and commercial sectors.

Key Points

A joint plan to boost grid capacity, add renewables, and improve reliability for Toronto's rising power demand.

✅ New substations and upgraded transmission lines increase capacity

✅ Integrates solar, wind, and storage for cleaner, reliable power

✅ Supports EV adoption, reduces outages, and future-proofs the grid

As Toronto's population and economy continue to expand, the surge in electricity demand in the city is also increasing rapidly. In response, the Ontario government, in partnership with the City of Toronto and various stakeholders, has launched an initiative to enhance the electricity infrastructure to meet future needs.

The Ontario Ministry of Energy and the City of Toronto are focusing on a multi-faceted approach that includes upgrades to existing power systems and the integration of renewable energy sources, as well as updated IoT cybersecurity standards for sector devices. This initiative is critical as Toronto looks towards a sustainable future, with projections indicating significant growth in both residential and commercial sectors.

Energy Minister Todd Smith highlighted the urgency of this project, stating, “With Toronto's growing population and dynamic economy, the need for reliable electricity cannot be overstated. We are committed to ensuring that our power systems are not only capable of meeting today's demands but are also future-proofed against the needs of tomorrow.”

The plan involves substantial investments in grid infrastructure to increase capacity and improve reliability. This includes the construction of new substations and the enhancement of old ones, along with the upgrading of transmission lines and exploration of macrogrids to strengthen reliability. These improvements are designed to reduce the frequency and severity of power outages while accommodating new developments and technologies such as electric vehicles, which are expected to place additional demands on the system.

Additionally, the Ontario government is exploring the potential for renewable energy sources, such as rooftop solar grids and wind, to be integrated into the city’s power grid. This shift towards green energy is part of a broader effort to reduce carbon emissions and promote environmental sustainability.

Toronto Mayor John Tory emphasized the collaborative nature of this initiative, stating, “This is a prime example of how collaboration between different levels of government and the private sector can lead to innovative solutions that benefit everyone. By enhancing our electricity infrastructure, we are not only improving the quality of life for our residents but also supporting Toronto's competitive edge as a global city.”

The project also includes a public engagement component, where citizens are encouraged to provide input on the planning and implementation phases. This participatory approach ensures that the solutions developed are in alignment with the needs and expectations of Toronto's diverse communities.

Experts agree that the timing of these upgrades is critical. As urban populations grow, the strain on infrastructure, especially in a powerhouse like Toronto, can lead to significant challenges. Proactive measures, such as those being implemented by Ontario and Toronto, and mirrored by British Columbia's clean energy shift underway on the west coast, are essential in avoiding potential crises and ensuring economic stability.

The success of this initiative could serve as a model for other cities facing similar challenges, highlighting the importance of forward-thinking and cooperation in urban planning and energy management. As Toronto moves forward with these ambitious plans, the eyes of the world, particularly other urban centers, will be watching and learning how to similarly tackle the dual challenges of growth and sustainability, with recent examples like London's newest electricity tunnel demonstrating large-scale grid upgrades.

This strategic approach to managing Toronto's electricity needs reflects a comprehensive understanding of the complexities involved in urban energy systems and a commitment to ensuring a resilient and sustainable future that aligns with Canada's net-zero grid by 2050 goals at the national level for all residents.

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Advanced Traffic Light System for Geothermal Safety models fracture growth and friction with rock physics, geophones, and supercomputers to predict induced seismicity during hydraulic stimulation, enabling real-time risk control for ETH Zurich and SED.

Key Points

ATLS uses rock physics, geophones, and HPC to forecast induced seismicity in real time during geothermal stimulation.

✅ Real-time seismic risk forecasts during hydraulic stimulation

✅ Uses rock physics, friction, and fracture modeling on HPC

✅ Supports ETH Zurich and SED field tests in Iceland and Bedretto

The Swiss Earthquake Service and ETH Zurich want to make geothermal energy safer, so news piece from Switzerland earlier this month. This is to be made possible by new software, including machine learning, and the computing power of supercomputers. The first geothermal tests have already been carried out in Iceland, and more will follow in the Bedretto laboratory.

In areas with volcanic activity, the conditions for operating geothermal plants are ideal. In Iceland, the Hellisheidi power plant makes an important contribution to sustainable energy use, alongside innovations like electricity from snow in cold regions.

Deep geothermal energy still has potential. This is the basis of the 2050 energy strategy. While the inexhaustible source of energy in volcanically active areas along fault zones of the earth’s crust can be tapped with comparatively little effort and, where viable, HVDC transmission used to move power to demand centers, access on the continents is often much more difficult and risky. Because the geology of Switzerland creates conditions that are more difficult for sustainable energy production.

Improve the water permeability of the rock

On one hand, you have to drill four to five kilometers deep to reach the correspondingly heated layers of earth in Switzerland. It is only at this depth that temperatures between 160 and 180 degrees Celsius can be reached, which is necessary for an economically usable water cycle. On the other hand, the problem of low permeability arises with rock at these depths. “We need a permeability of at least 10 millidarcy, but you can typically only find a thousandth of this value at a depth of four to five kilometers,” says Thomas Driesner, professor at the Institute of Geochemistry and Petrology at ETH Zurich.

In order to improve the permeability, water is pumped into the subsurface using the so-called “fracture”. The water acts against friction, any fracture surfaces shift against each other and tensions are released. This hydraulic stimulation expands fractures in the rock so that the water can circulate in the hot crust. The fractures in the earth’s crust originate from tectonic tensions, caused in Switzerland by the Adriatic plate, which moves northwards and presses against the Eurasian plate.

In addition to geothermal energy, the “Advanced Traffic Light System” could also be used in underground construction or in construction projects for the storage of carbon dioxide.

Quake due to water injection

The disadvantage of such hydraulic stimulations are vibrations, which are often so weak or cannot be perceived without measuring instruments. But that was not the case with the geothermal projects in St. Gallen 2013 and Basel 2016. A total of around 11,000 cubic meters of water were pumped into the borehole in Basel, causing the pressure to rise. Using statistical surveys, the magnitudes 2.4 and 2.9 defined two limit values ??for the maximum permitted magnitude of the earthquakes generated. If these are reached, the water supply is stopped.

In Basel, however, there was a series of vibrations after a loud bang, with a time delay there were stronger earthquakes, which startled the residents. In both cities, earthquakes with a magnitude greater than 3 have been recorded. Since then it has been clear that reaching threshold values ??determines the stop of the water discharge, but this does not guarantee safety during the actual drilling process.

Simulation during stimulation

The Swiss Seismological Service SED and the ETH Zurich are now pursuing a new approach that can be used to predict in real time, building on advances by electricity prediction specialists in Europe, during a hydraulic stimulation whether noticeable earthquakes are expected in the further course. This is to be made possible by the so-called “Advanced Traffic Light System” based on rock physics, a software developed by the SED, which carries out the analysis on a high-performance computer.

Geophones measure the ground vibrations around the borehole, which serve as indicators for the probability of noticeable earthquakes. The supercomputer then runs through millions of possible scenarios, similar to algorithms to prevent power blackouts during ransomware attacks, based on the number and type of fractures to be expected, the friction and tensions in the rock. Finally, you can filter out the scenario that best reflects the underground.

Further tests in the mountain

However, research is currently still lacking any real test facility for the system, because incorrect measurements must be eliminated and a certain data format adhered to before the calculations on the supercomputer. The first tests were carried out in Iceland last year, with more to follow in the Bedretto geothermal laboratory in late summer, where reliable backup power from fuel cell solutions can keep instrumentation running. An optimum can now be found between increasing the permeability of rock layers and an adequate water supply.

The new approach could make geothermal energy safer and ultimately help this energy source to become more accepted, while grid upgrades like superconducting cables improve efficiency. Research also sees areas of application wherever artificially caused earthquakes can occur, such as in underground mining or in the storage of carbon dioxide underground.

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California Wildfire Power Shut-Offs escalate as PG&E imposes blackouts amid high winds, Getty and Kincade fires, mass evacuations, Sonoma County threats, and a state of emergency, drawing regulatory scrutiny over grid safety and outage scope.

Key Points

Planned utility outages to curb wildfire risk during extreme winds, prompting evacuations and regulatory scrutiny.

✅ PG&E preemptive blackouts under regulator inquiry

✅ Getty and Kincade fires drive mass evacuations

✅ Sonoma County under threat amid high winds

Pacific Gas & Electric (PG&E) already faces an investigation by regulators after cutting supplies to 970,000 homes and businesses amid California blackouts that raised concerns.

It announced that another 650,000 properties would face precautionary shut-offs.

Wildfires fanned by the strong winds are raging in two parts of the state.

Thousands of residents near the wealthy Brentwood neighbourhood of Los Angeles have been told to evacuate because of a wildfire that began early on Monday.

Further north in Sonoma County, a larger fire has forced 180,000 people from their homes.

California's governor has declared a state-wide emergency.

What about the power cuts?

On Monday regulators announced a formal inquiry into whether energy utilities broke rules by pre-emptively cutting power to an estimated 2.5 million people, amid a blackouts policy debate that intensified, as wildfire risks soared.

They did not name any utilities but analysts said PG&E was responsible for the bulk of the "public safety power shut-offs", and later faced a Camp Fire guilty plea that underscored its liabilities.

The company filed for bankruptcy in January after facing hundreds of lawsuits from victims of wildfires in 2017 and 2018.

Of the 970,000 properties hit by the most recent cuts, under half had their services back by Monday, and some sought help through wildfire assistance programs, the Associated Press reported.

Despite criticism that the precautionary blackouts were too widespread and too disruptive, PG&E said more would come on Tuesday and Wednesday because further strong winds were expected.

The company said it had logged more than 20 preliminary reports of damage to its network from the most recent windstorm.

In a video posted to Twitter on Saturday, Governor Gavin Newsom said the power cuts were "infuriating everyone, and rightfully so".

Where are the fires now?

In Los Angeles, the Getty Fire has burned over 600 acres (242 ha) and about 10,000 buildings are in the mandatory evacuation zone.

At least eight homes have been destroyed and five others damaged.

"If you are in an evacuation zone, don't screw around," Mr Schwarzenegger tweeted. "Get out."

LA fire chief Ralph Terrazas said fire crews had been "overwhelmed" by the scale of the fires.

"They had to make some tough decisions on which houses they were able to protect," he said.

"Many times it depends on where the ember lands. I saw homes that were adjacent to homes that were totally destroyed, without any damage."

In northern California, schools remain closed in Sonoma County, where tens of thousands of homes and businesses are under threat.

Sonoma has been ravaged by the Kincade Fire, which started on Wednesday and has burned through 50,000 acres of land, fanned by the winds.

The Kincade Fire began seven minutes after a nearby power line was damaged, and power lines may have started fires according to reports, but PG&E has not yet confirmed if the power glitch started the blaze.

About 180,000 people have been ordered to evacuate, with roads around Santa Rosa north of San Francisco packed with cars as people tried to flee.

There are fears the flames could cross the 101 highway and enter areas that have not seen wildfires since the 1940s.

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