Montana bills to alter renewable energy standards

Minnesota Electric Cooperatives are driving grid innovation with smart meters, time-of-use pricing, demand response, and energy storage, including iron-air batteries, to manage peak loads, integrate wind and solar, and cut costs for rural members.

Key Points

Member-owned utilities piloting load management, meters, and storage to integrate wind and solar, cutting peak demand.

✅ Time-of-use pricing pilots lower bills and shift peak load.

✅ Iron-air battery tests add multi-day, low-cost energy storage.

✅ Smart meters enable demand response across rural co-ops.

Minnesota electric cooperatives have quietly emerged as laboratories for clean grid innovation, outpacing investor-owned utilities on smart meter installations, time-based pricing pilots, and experimental battery storage solutions.

“Co-ops have innovation in their DNA,” said David Ranallo, a spokesperson for Great River Energy, a generation and distribution cooperative that supplies power to 28 member utilities — making it one of the state’s largest co-op players.

Minnesota farmers helped pioneer the electric co-op model more than a century ago, similar to modern community-generated green electricity initiatives, pooling resources to build power lines, transformers and other equipment to deliver power to rural parts of the state. Today, 44 member-owned electric co-ops serve about 1.7 million rural and suburban customers and supply almost a quarter of the state’s electricity.

Co-op utilities have by many measures lagged on clean energy. Many still rely on electricity from coal-fired power plants. They’ve used political clout with rural lawmakers to oppose new pollution regulations and climate legislation, and some have tried to levy steep fees on customers who install solar panels.

Where they are emerging as innovators is with new models and technology for managing electric grid loads — from load-shifting water heaters to a giant experimental battery made of iron. The programs are saving customers money by delaying the need for expensive new infrastructure, and also showing ways to unlock more value from cheap but variable wind and solar power.

Unlike investor-owned utilities, “we have no incentive to invest in new generation,” said Darrick Moe, executive director of the Minnesota Rural Electric Association. Curbing peak energy demand has a direct financial benefit for members.

Minnesota electric cooperatives have launched dozens of programs, such as the South Metro solar project, in recent years aimed at reducing energy use and peak loads, in particular. They include:

Cost calculations are the primary driver for electric cooperatives’ recent experimentation, and a lighter regulatory structure and evolving electricity market reforms have allowed them to act more quickly than for-profit utilities.

“Co-ops and [municipal utilities] can act a lot more nimbly compared to investor-owned utilities … which have to go through years of proceedings and discussions about cost-recovery,” said Gabe Chan, a University of Minnesota associate professor who has researched electric co-ops extensively. Often, approval from a local board is all that’s required to launch a venture.

Great River Energy’s programs, which are rebranded and sold through member co-ops, yielded more than 101 million kilowatt-hours of savings last year — enough to power 9,500 homes for a year.

Beyond lowering costs for participants and customers at large, the energy-saving and behavior-changing programs sometimes end up being cited as case studies by larger utilities considering similar offerings. Advocates supporting a proposal by the city of Minneapolis and CenterPoint Energy to allow residents to pay for energy efficiency improvements on their utility bills through distributed energy rebates used several examples from cooperatives.

Despite the pace of innovation on load management, electric cooperatives have been relatively slow to transition from coal-fired power. More than half of Great River Energy’s electricity came from coal last year, and Dairyland Power, another major power wholesaler for Minnesota co-ops, generated 70% of its energy from coal. Meanwhile, Xcel Energy, the state’s largest investor-owned utility, has already reduced coal to about 20% of its energy mix.

The transition to cleaner power for some co-ops has been slowed by long-term contracts with power suppliers that have locked them into dirty power. Others have also been stalled by management or boards that have been resistant to change. John Farrell, director of the Institute for Local Self-Reliance’s Energy Democracy program, said generalizing co-ops is difficult. 

“We’ve seen some co-ops that have got 75-year contracts for coal, that are invested in coal mines and using their newsletter to deny climate change,” he said. “Then you see a lot of them doing really amazing things like creating energy storage systems … and load balancing [programs], because they are unique and locally managed and can have that freedom to experiment without having to go through a regulatory process.”

Great River Energy, for its part, says it intends to reach 54% renewable generation by 2025, while some communities, like Frisco, Colorado, are targeting 100% clean electricity by specific dates. Its members recently voted to sell North Dakota’s largest coal plant, but the arrangement involves members continuing to buy power from the new owners for another decade.

The cooperative’s path to clean power could become clearer if its experimental iron-air battery project is successful. The project, the first of its kind in the country, is expected to be completed by 2023.

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California energy rebate freeze disrupts heat pump incentives, HVAC upgrades, and climate funding, as federal uncertainty stalls Inflation Reduction Act support, delaying home electrification, energy efficiency gains, and greenhouse gas emissions reductions statewide.

Key Points

A statewide pause on $290M incentives for heat pumps and HVAC upgrades due to federal climate funding uncertainty.

✅ $290M program paused amid federal funding freeze

✅ Heat pump, HVAC, electrification upgrades delayed

✅ Previously approved rebates honored; new apps halted

California’s push for a more energy-efficient future has hit a significant roadblock as the state pauses a $290 million rebate program aimed at helping homeowners replace inefficient heating and cooling systems with more energy-efficient alternatives. The California Energy Commission announced the suspension of the program, citing uncertainty stemming from President Donald Trump’s decision to freeze funding for various climate-related initiatives.

The Halted Program

The energy rebate program, which utilizes federal funding to encourage the use of energy-efficient appliances such as heat pumps, was a crucial part of California’s efforts to reduce energy consumption and greenhouse gas emissions. By providing financial incentives for homeowners to upgrade to more efficient heating and cooling systems, the program aimed to make green energy solutions more accessible and affordable to residents. The rebate program had been popular, with many homeowners eager to participate in the initiative to lower their energy costs and improve the sustainability of their homes.

However, due to the uncertainty surrounding federal funding, the California Energy Commission announced on Monday that it would no longer be accepting new applications for the program. The agency did clarify that it would continue to honor rebates for applications that had already been approved. The pause will remain in effect until the Trump administration provides more clarity regarding the program's future funding.

The Trump Administration’s Role

This move highlights a broader issue regarding access to federal funding for state-level energy programs. The Trump administration’s decision to freeze funding for climate-related initiatives has left many states in limbo, as previously approved federal money has not been distributed as expected. Despite federal court rulings directing the Trump administration to restore these funds, states like California are still struggling to navigate the uncertainty of climate-related financial support from the federal government.

California’s decision to pause the rebate program comes after similar actions by other states. Arizona paused a similar program just a week prior, and Rhode Island had already paused new applications earlier this year. These states are all recipients of funding from a larger $4.3 billion initiative under the Inflation Reduction Act, which is designed to help homeowners purchase energy-efficient appliances like heat pumps, water heaters, and electric cooktops.

Impact of the Freeze

The pause of California's rebate program has serious implications for both consumers and the state’s energy goals. For residents, the halt means delays in the ability to upgrade to more energy-efficient home systems, which could lead to higher energy costs in the short term, a concern amid soaring electricity prices across the state.

The $290 million program was a significant step in encouraging homeowners to invest in energy efficiency, and its suspension leaves a gap in the availability of resources for those who were hoping to make energy-saving upgrades. Many of these upgrades are not just beneficial to homeowners, but they also contribute to the state’s overall energy efficiency goals, helping to reduce reliance on non-renewable energy sources, even as California's dependence on fossil fuels persists, and decrease greenhouse gas emissions.

Federal and State Tensions

The freeze in funding is just one of many points of tension between the Trump administration and states like California, which have pursued aggressive environmental policies aimed at reducing emissions and combating climate change. California has often found itself at odds with the federal government on environmental issues, especially under the leadership of President Trump. The state’s ambitious environmental policies have sometimes clashed with the federal government's approach, including efforts to wind down its fossil fuel industry in line with climate goals.

In this case, the freeze on climate-related funding appears to be part of a broader strategy by the Trump administration to limit federal spending on environmental programs, and as regulators weigh whether the state may need more power plants, planning remains complex. While the freeze impacts states that are working to transition to clean energy, critics argue that such moves undermine efforts to tackle climate change and could slow down progress toward a greener future.

The Path Forward

For California, the next steps will depend heavily on the actions of the federal government. While the state can continue to push for climate funding in the courts, the lack of clarity around the release of federal funds creates uncertainty for state programs that rely on these resources. As California continues to navigate this funding freeze, it will need to explore alternative solutions to keep its energy efficiency programs on track, such as efforts to revamp electricity rates to clean the grid, even in the face of federal challenges.

In the meantime, California residents and homeowners who were hoping to take advantage of the rebate program may have to wait until further clarification from the federal government is provided, even as officials warn of a looming electricity shortage in coming years. Whether the program can be restored or expanded in the future remains to be seen, but for now, the pause serves as a reminder of the ongoing struggles that states face when dealing with shifting federal priorities.

As the issue unfolds, other states facing similar challenges may take cues from California’s actions, and with California exporting energy policies to Western states, broader conversations about how federal and state governments can collaborate to ensure that energy efficiency initiatives and climate goals are not sidelined due to political or budgetary differences.

California’s decision to pause its $290 million energy rebate program is a significant development in the ongoing struggle between state and federal governments over climate-related funding. The uncertainty created by the Trump administration’s freeze on energy efficiency programs has led to disruptions in state-level efforts to promote sustainability and reduce emissions. As the situation continues to evolve, both California and other states will need to consider how to move forward without relying on federal funding that may or may not be available in the future.

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Work From Home Energy Consumption is driving higher electricity bills as residential usage rises. Smart meter data, ISO-New-England trends, and COVID-19 telecommuting show stronger power demand and sensitivity to utility rates across regions.

Key Points

Higher household electricity use from telecommuting, shifting load to residences and raising utility bills.

✅ Smart meters show 5-22 percent residential usage increases.

✅ Commercial demand fell as home cooling and IT loads rose.

✅ Utility rates and AC use drive bill spikes during summer.

Don't be surprised if your electric bills are looking higher than usual, with a sizable increase in the amount of power that you have used.

Summer traditionally is a peak period for electricity usage because of folks' need to run fans and air-conditioners to cool their homes or run that pool pump. But the arrival of the coronavirus and people working from home is adding to amount of power people are using.

Under normal conditions, those who work in their employer's offices might not be cooling their homes as much during the middle of the day or using as much electricity for lights and running computers.

For many, that's changed.

Estimates on how much of an increase residential electric customers are seeing as result of working from home vary widely.

ISO-New England, the regional electric grid operator, has seen a 3 percent to 5 percent decrease in commercial and industrial power demand, even as the grid overseer issued pandemic warnings nationally. The expectation is that much of that decrease translates into a corresponding increase in residential electricity usage.

But other estimates put the increase in residential electricity usage much higher. A Washington state company that makes smart electric meters, Itron, estimates that American households are using 5 percent to 10 percent more electricity per month since March, when many people began working from home as part of an effort to prevent the spread of the coronavirus.

Another smart metering company, Cambridge, Mass.-based Sense, found that average home electricity usage increased 22 percent in April compared to the same period in 2019, a reflection of people using more electricity while they stayed home. Based on its analysis of data from 5,000 homes across 30 states, Sense officials said a typical customer's monthly electric bill increased by between $22 and $25, with a larger increase for consumers in states with higher electricity rates.

Connecticut-specfic data is harder to come by.

Officials with Orange-based United Illuminating declined to provide any customer usage data, though, like others in the power industry, they did acknowledge that residential customers are using more electricity. And the state's other large electric distribution utility, Eversource, was unable to provide any recent data on residential electric usage. The company did tell Connecticut utility regulators there was a 3 percent increase in residential power usage for the week of March 21 compared to the week before.

Over the same time period, Eversource officials saw a 3 percent decrease in power usage by commercial and industrial customers.

Separately, nuclear plant workers raised concerns about pandemic precautions at some facilities, reflecting operational strains.

Alan Behm of Cheshire said he normally uses 597 kilowatt hours of electricity during an average month. But in April of this year, the amount of electricity he used rose by nearly 51 percent.

With many offices closed, the expense of heating, cooking and lighting is being shifted from employer to employee, and some utilities such as Manitoba Hydro have pursued unpaid days off to trim costs during the pandemic. And one remote work expert believes some companies are recognizing the burden those added costs are placing on workers -- and are trying to do something about it.

Technology giant Google announced in late May that it was giving employees who work from home $1,000 allowances to cover equipment costs and other expenses associated with establishing a home office.

Moe Vela, chief transparency officer for the New York City-based computer software company TransparentBusiness, said the move by Google executives is a savvy one.

"Google is very smart to have figured this out," Vela said. "This is what employees want, especially millenials. People are so much happier to be working remotely, getting those two to three hours back per day that some people spend getting to and from work is so much more important than a stipend."

Vela predicted that even after a vaccine is found for the corona virus, one of the key worklife changes is likely to be a broader acceptance of telework and working from home.

Beyond the immediate shifts, more young Canadians would work in electricity if awareness improved, pointing to future talent pipelines.

"I think that's where we're headed," he said. "I think it will make an employer more attractive as they try to attract talent from around the world."

Vela said employers save an average of $11,000 per year for each employee they have working from home.

"It would be a brilliant move if a company were to share some of that amount with employees," he said. "I wouldn't do it if it's going to cause a company to not be there (in business) though."

The idea of a company sharing whatever savings it achieves by having employees work from home wasn't well received by many Connecticut residents who responded to questions posed via social media by Hearst Connecticut Media. More than 100 people responded and an overwhelming number of people spoke out against the idea.

"You are saving on gas and other travel related expenses, so the small increase in your electric bill shouldn't really be a concern," said Kathleen Bennett Charest of Wallingford.

Jim Krupp, also of Wallingford, said, "to suggest that the employers compensate the employees makes as much sense as suggesting that the employees should take a pay cut due to their reduced expenses for travel, day care, and eating lunch at work."

"Employers must still maintain their offices and incur all of the fixed expenses involved, including basic utilities, taxes and insurance," Krupp said. "The cost savings (for employers) that are realized are also offset by increased costs of creating and maintaining IT networks that allow employees to access their work sites from home and the costs of monitoring and managing the work force."

Kiki Nichols Nugent of Cheshire said she was against the idea of an employee trying to get their employer to pay for the increased electricity costs associated with working from home.

"I would not nickle and dime," Nugent said. "If companies are saving on electricity now, maybe employers will give better raises next year."

New Haven resident Chris Smith said he is "just happy to have a job where I am able to telecommute."

"When teleworking becomes more the norm, either now or in the future, we may see increased wages for teleworkers either for the lower cost to the employer or for the increase in productivity it brings," Smith said.

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Ukraine Nuclear Plant Ownership Proposal outlines U.S. management of Ukrainian reactors amid the Russia-Ukraine war, citing nuclear safety, energy security, and IAEA oversight; Kyiv rejects ownership transfer, especially regarding Zaporizhzhia under Russian control.

Key Points

U.S. control of Ukraine's nuclear plants for safety; Kyiv rejects transfer, citing sovereignty risks at Zaporizhzhia.

✅ U.S. proposal to manage Ukraine's reactors amid war

✅ Kyiv refuses ownership transfer; open to investment

✅ Zaporizhzhia under Russian control raises safety risks

In the midst of the ongoing conflict between Russia and Ukraine, U.S. President Donald Trump has proposed a controversial idea: Ukraine should give its nuclear power plants to the United States for safekeeping and management. This suggestion came during a phone call with Ukrainian President Volodymyr Zelenskyy, wherein Trump expressed the belief that American ownership of these nuclear plants could offer them the best protection amid the ongoing war. But Kyiv, while open to foreign support, has firmly rejected the idea of transferring ownership, especially as the Zaporizhzhia nuclear plant remains under Russian occupation.

Ukraine’s nuclear energy infrastructure has always been a vital component of its power generation. Before the war, the country’s four nuclear plants supplied nearly half of its electricity. As Russia's military forces target Ukraine's energy infrastructure, including power plants and coal mines, international watchdogs like the IAEA have warned of nuclear risks as these nuclear facilities have become crucial to maintaining the nation’s energy stability. The Zaporizhzhia plant, in particular, has attracted international concern due to its size and the ongoing threat of a potential nuclear disaster.

Trump’s Proposal and Ukraine’s Response

Trump’s proposal of U.S. ownership came as a response to the ongoing threats posed by Russia’s occupation of the Zaporizhzhia plant. Trump argued that the U.S., with its expertise in running nuclear power plants, could safeguard these facilities from further damage and potential nuclear accidents. However, Zelenskyy quickly clarified that the discussion was only focused on the Zaporizhzhia plant, which is currently under Russian control. The Ukrainian president emphasized that Kyiv would not entertain the idea of permanently transferring ownership of its nuclear plants, even though they would welcome investment in their restoration and modernization, particularly after the war.

The Zaporizhzhia nuclear plant has been a focal point of geopolitical tensions since Russia's occupation in 2022. Despite being in "cold shutdown" to prevent further risk of explosions, the facility remains a major concern due to its potential to cause a nuclear disaster. Ukrainian officials, along with international observers, have raised alarm about the safety risks posed by the plant, including mines at Zaporizhzhia reported by UN watchdogs, which is situated in a war zone and under the control of Russian forces who are reportedly neglecting proper safety protocols.

The Fear of a Nuclear Provocation

Ukrainians have expressed concerns that Trump’s proposal could embolden Russia to escalate tensions further, even as a potential agreement on power-plant attacks has been discussed by some parties. Some fear that any attempt to reclaim the plant by Ukraine could trigger a Russian provocation, including a deliberate attack on the plant, which would have catastrophic consequences for both Ukraine and the broader region. The analogy is drawn with the destruction of the Nova Kakhovka dam, which Ukraine accuses Russia of sabotaging, an act that severely disrupted water supplies to the Zaporizhzhia plant. Ukrainian military officials, including Ihor Romanenko, a former deputy head of Ukraine’s armed forces, warned that Trump’s suggestion might be an exploitation of Ukraine’s vulnerable position in the ongoing war.

Despite these fears, there are some voices within Ukraine, including former employees of the Zaporizhzhia plant, who believe that a deliberate attack by Russian forces is unlikely. They argue that the Russian military needs the plant in functioning condition for future negotiations, with Russia building new power lines to reactivate the site as part of that calculus, and any damage could reduce its value in such exchanges. However, the possibility of Russian negligence or mismanagement remains a significant risk.

The Strategic Role of Ukraine's Nuclear Plants

Ukraine's nuclear plants were a cornerstone of the country’s energy sector long before the conflict began. In recent years, as Ukraine lost access to coal resources in the Donbas region due to Russian occupation, nuclear power became even more vital, alongside a growing focus on wind power to improve resilience. The country’s reliance on these plants grew as Russia launched a sustained campaign to destroy Ukraine’s energy infrastructure, including attacks on nuclear power stations.

The Zaporizhzhia plant, in particular, holds strategic importance not only due to its size but also because of its location in southeastern Ukraine, an area that has been at the heart of the conflict. Despite being in Russian hands, the plant’s reactors have been safely shut down, reducing the immediate risk of a nuclear explosion. However, the plant’s future remains uncertain, as Russia’s long-term control over it could disrupt Ukraine’s energy security for years to come.

Wider Concerns About Aging Nuclear Infrastructure

Beyond the geopolitical tensions, there are broader concerns about the aging infrastructure of Ukraine's nuclear power plants. International watchdogs, including the environmentalist group Bankwatch, have criticized these facilities as “zombie reactors” due to their outdated designs and safety risks. Experts have called for Ukraine to decommission some of these reactors, fearing that they are increasingly unsafe, especially in the context of a war.

However, Ukrainian officials, including Petro Kotin, head of Energoatom (Ukraine's state-owned nuclear energy company), argue that these reactors are still functional and critical to Ukraine's energy needs. The ongoing conflict, however, complicates efforts to modernize and secure these facilities, which are increasingly vulnerable to both physical damage and potential nuclear hazards.

The Global Implications

Trump's suggestion to take control of Ukraine's nuclear power plants has raised significant concerns on the international stage. Some fear that such a move could set a dangerous precedent for nuclear security and sovereignty. Others see it as an opportunistic proposal that exploits Ukraine's wartime vulnerability.

While the future of Ukraine's nuclear plants remains uncertain, one thing is clear: these facilities are now at the center of a geopolitical struggle that could have far-reaching consequences for the energy security of Europe and the world. The safety of these plants and their role in Ukraine's energy future will remain a critical issue as the war continues and as Ukraine navigates its relations with both the U.S. and Russia, with the grid even having resumed electricity exports at times.

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Manitoba Hydro Court Ruling affirms the Public Utilities Board exceeded its jurisdiction by ordering a First Nations rate class, overturning an electricity rates appeal tied to geography, poverty, and regulatory authority in Manitoba.

Key Points

A decision holding the PUB lacked authority to create a First Nations rate class, restoring uniform electricity pricing.

✅ Court says PUB exceeded jurisdiction creating on-reserve rate

✅ Equalized electricity pricing reaffirmed across Manitoba

✅ Geography, not poverty, found decisive in unlawful rate class

Manitoba Hydro was wrongly forced to create a new rate class for electricity customers living on First Nations, the Manitoba Court of Appeal has ruled. 

The court decided the Public Utilities Board "exceeded its jurisdiction" by mandating Indigenous customers on First Nations could have a different electricity rate from other Manitobans. 

The board made the order in 2018, which exempted those customers from the general rate increase that year of 3.6 per cent.

"The directive constituted the creation and implementation of general social policy, an area outside of the PUB's jurisdiction and encroaching into areas that are better suited to the federal and provincial government," says the decision, which was released Tuesday.

Hydro's appeal of the PUB's decision went to court earlier this year.

At the time, the Crown corporation acknowledged many Indigenous people on First Nations live in poverty, but it argued the Public Utilities Board was overstepping its authority in trying to address the issue by creating a new rate class.

It also argued it was against provincial law to charge different rates in different areas of the province.

The PUB, however, insisted that legislation gives it the right to decide which factors are relevant when considering electricity prices, such as social issues. 

Special Manitoba Hydro rate class needed to offset challenges of living on First Nations, appeal court hears
Manitoba Hydro can appeal order to create special First Nation rate
The board had heard evidence that some customers were making "unacceptable" sacrifices to keep the lights on each month.

Decision 'heavy-handed': AMC
The Assembly of Manitoba Chiefs, an intervener in the appeal, had backed the utility board's position. It said on-reserve customers are disproportionately vulnerable to rate hikes over time.

Grand Chief Arlen Dumas said Wednesday he was surprised by the court's ruling. 

He argued Indigenous people are unduly excluded in the setting of electricity rates in Manitoba.

"I will be speaking with my federal and provincial counterparts on how we deal with this issue, because I think it's the wrong [decision]. It's heavy-handed and we need to address it."

The appeal court judges said there is past precedent for setting equal electricity rates, regardless of where customers live. Legislation to that effect was made in the early 2000s and a few years ago, the PUB recognized that geographical limitations should not be imposed on a class of customers.

Since the board's new order didn't extend the same savings to First Nations members who don't live on reserve but face similar financial circumstances, it is clear the deciding factor was geography, rather than poverty or treaty status, the judges said.

Manitoba Hydro temporarily cutting 200 jobs, many of them front-line workers
"In my view, the PUB erred in law when it created an on-reserve class based solely on a geographic region of the province in which customers are located," the decision read.

While Manitoba Hydro objected to the PUB's order in 2018, it still devoted money to create the new customer class.

Spokesperson Bruce Owen said the utility is still studying the impact of the court's decision, but it appreciates the ruling.  

"We all recognize that many people on First Nations have challenges, but our argument was solely on whether or not the PUB had the authority to create a special rate class based on where people live."

Owen added that Hydro recognizes electricity rates can be a hardship on individuals facing poverty. He said those considerations are part of the discussions the corporation has with the utilities board.

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ERCOT Ancillary Services Clawback and VOLL Pricing summarize PUCT and IMM actions on load shed, real-time pricing adders, clawbacks, and settlement corrections after the 2021 winter storm in the Texas power grid market.

Key Points

Policies addressing clawbacks for unprovided AS and correcting VOLL-based price adders after load shed ended in ERCOT.

✅ PUCT ordered clawbacks for ancillary services not delivered.

✅ IMM urged price correction after firm load shed ceased.

✅ ERCOT's VOLL adder raised costs by $16B during 32 hours.

Potomac Economics, the Independent Market Monitor (IMM) for the Electric Reliability Council of Texas (ERCOT), filed a report with the Public Utility Commission of Texas (PUCT) that certain payments were made by ERCOT for Ancillary Services (AS) that were not provided, even as ERCOT later issued a winter reliability RFP to procure capacity during subsequent seasons.

According to the IMM (emphasis added):

There were a number of instances during the operating days outlined above in which AS was not provided in real time because of forced outages or derations. For market participants that are not able to meet their AS responsibility, typically the ERCOT operator marks the short amount in the software. This causes the AS responsibility to be effectively removed and the day-ahead AS payment to be clawed back in settlement. However, the ERCOT operators did not complete this task during the winter event, echoing issues like the Ontario IESO phantom demand that cost customers millions, and therefore the "failure to provide" settlements were not invoked in real time.

Removing the operator intervention step and automating the "failure to provide" settlement was contemplated in NPRR947: Clarification to Ancillary Service Supply Responsibility Definition and Improvements to Determining and Charging for Ancillary Service Failed Quantities; however, the NPRR was withdrawn in August 2020 amid ongoing market reform discussions because of the system cost, some complexities related to AS trades, and the implementation of real-time co-optimization.

Invoking the "failure to provide" settlement for all AS that market participants failed to provide during the operating days outlined above will produce market outcomes and settlements consistent with underlying market principles. In this case, the principle is that market participants should not be paid for services that they do not provide, even as a separate ruling found power plants exempt from providing electricity in emergencies under Texas law, underscoring the distinction between obligations and settlements. Whether ERCOT marked the short amount in real-time or not should not affect the settlement of these ancillary services.

On March 3, 2021, the PUCT ordered (a related press release is here) that:

ERCOT shall claw back all payments for ancillary service that were made to an entity that did not provide its required ancillary service during real time on ERCOT operating days starting February 14, 2021 and ending on February 19,2021.

On March 4, 2021, the IMM filed another report and recommended that:

the [PUCT] direct ERCOT to correct the real-time prices from 0:00 February 18,2021, to 09:00 February 19, 2021, to remove the inappropriate pricing intervention that occurred during that time period.

The IMM approvingly noted the PUCT's February 15, 2021 order, which mandated that real-time energy prices reflect firm load shed by setting prices at the value of lost load (VOLL).1

According to the IMM (emphasis added):

This is essential in an energy-only market, like ERCOT's, where the Texas power grid faces recurring crisis risks, because it provides efficient economic signals to increase the electric generation needed to restore the load and service it reliably over the long term.

Conversely, it is equally important that prices not reflect VOLL when the system is not in shortage and load is being served, and experiences in capacity markets show auction payouts can fall sharply under different conditions. The Commission recognized this principle in its Order, expressly stating it is only ERCOT's out-of-market shedding firm load that is required to be reflected in prices. Unfortunately, ERCOT exceeded the mandate of the Commission by continuing to set process at VOLL long after it ceased the firm load shed.

ERCOT recalled the last of the firm load shed instructions at 23:55 on February 17, 2021. Therefore, in order to comply with the Commission Order, the pricing intervention that raised prices to VOLL should have ended immediately at that time. However, ERCOT continued to hold prices at VOLL by inflating the Real-Time On-Line Reliability Deployment Price Adder for an additional 32 hours through the morning of February 19. This decision resulted in $16 billion in additional costs to ERCOT's market, prompting legislative bailout proposals in Austin, of which roughly $1.5 billion was uplifted to load-serving entities to provide make-whole payments to generators for energy that was not needed or produced.

However, at its March 5, 2021, open meeting (related discussion begins around minute 20), although the PUCT acknowledged the "good points" raised by the IMM, the PUCT was not willing to retrospectively adjust its real-time pricing for this period out of concerns that some related transactions (ICE futures and others) may have already settled and for unintended consequences of such retroactive adjustments.  

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