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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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Scotland Wind Energy October saw renewables supply the equivalent of 98 percent of electricity demand, as onshore wind outpaced National Grid needs, cutting emissions and powering households, per WWF Scotland and WeatherEnergy.

Key Points

A monthly update showing Scottish onshore wind met the equivalent of 98% of electricity demand in October.

✅ 98% of monthly electricity demand equivalent met by wind

✅ 16 days exceeded total national demand, per data

✅ WWF Scotland and WeatherEnergy cited; lower emissions

New figures publicized by WWF Scotland have revealed that wind energy generated the equivalent of 98% of the country’s electricity demand in October, or enough electricity to power millions of Scottish homes across the country.

Scotland has regularly been highlighted as a global wind energy leader, and over the last few years has repeatedly reported record-breaking months for wind generation. Now, it’s all very well and good to say that Scottish wind delivered 98% of the country’s electricity demand, but the specifics are a little different — hence why WWF Scotland always refers to it as wind providing “the equivalent of 98%” of Scotland’s electricity demand. That’s why it’s worth looking at the statistics provided by WWF Scotland, sourced from WeatherEnergy, part of the European EnergizAIR project:

• National Grid demand for the month – 1,850,512 MWh
• What % of this could have been provided by wind power across Scotland – 98%
• Best day – 23rd October 2018, generation was 105,900.94 MWh, powering 8.72m homes, 356% of households. Demand that day was 45,274.5MWh – wind generation was 234% of that.
• Worst day – 18th October 2018 when generation was 18,377.71MWh powering 1,512,568 homes, 62% of households. Demand that day was 73,628.5MWh – wind generation was 25%
• How many days generation was over 100% of households – 27
• How many days generation was over 100% of demand – 16

“What a month October proved to be, with wind powering on average 98 per cent of Scotland’s entire electricity demand for the month, at a time when wind became the UK’s main power source and exceeding our total demand for a staggering 16 out of 31 days,” said Dr Sam Gardner, acting director at WWF Scotland.

“These figures clearly show wind is working, it’s helping reduce our emissions and is the lowest cost form of new power generation. It’s also popular, with a recent survey also showing more and more people support turbines in rural areas. That’s why it’s essential that the UK Government unlocks market access for onshore wind at a time when we need to be scaling up electrification of heat and transport.”

Alex Wilcox Brooke, Weather Energy Project Manager at Severn Wye Energy Agency, added: “Octobers figures are a prime example of how reliable & consistent wind production can be, with production on 16 days outstripping national demand.”

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PG&E Wildfire Lawsuit alleges utility negligence, inadequate infrastructure maintenance, and faulty transmission lines, as victims seek compensation. Regulators investigate the blaze, echoing class actions after Victoria's Black Saturday mega-fires and utility oversight failures.

Key Points

PG&E Wildfire Lawsuit alleges utility negligence and power line faults, seeking victim compensation amid investigations.

✅ Alleged failure to maintain transmission infrastructure

✅ Spark reports and regulator filings before blaze erupted

✅ Class action parallels with Australia's Black Saturday

Victims of California's most destructive wildfire have filed a lawsuit accusing Pacific Gas & Electric Co. of causing the massive blaze, a move that follows the utility's 2018 Camp Fire guilty plea in a separate case.

The suit filed on Tuesday in state court in California accuses the utility of failing to maintain its infrastructure and properly inspect and manage its power transmission lines, amid prior reports that power lines may have sparked fires in California.

The utility's president said earlier the company doesn't know what caused the fire, but is cooperating with the investigation by state agencies, and other utilities such as Southern California Edison have faced wildfire lawsuits in California.

PG&E told state regulators last week that it experienced a problem with a transmission line in the area of the fire just before the blaze erupted.

A landowner near where the blaze began said PG&E notified her the day before the wildfire that crews needed to come onto her property because some wires were sparking, and the company later promoted its wildfire assistance program for victims seeking aid.

A massive class action after Australia's last mega-fire, Victoria's Black Saturday in 2009, saw $688.5 million paid in compensation to thousands of claimants affected by the Kilmore-Kinglake and Murrindindi-Marysville fires, partly by electricity company SP Ausnet, and partly by government agencies, while in California PG&E's bankruptcy plan won support from wildfire victims addressing compensation claims.

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SDG&E Mitsubishi Power Energy Storage adds a 10 MW/60 MWh BESS in Pala, boosting grid reliability, renewable integration, and flexibility with EMS and SCADA controls, LFP safety chemistry, NERC CIP compliance, UL 9540 standards.

Key Points

A 10 MW/60 MWh BESS for SDG&E in Pala that enhances grid reliability, renewables usage, and operational flexibility.

✅ Emerald EMS/SCADA meets NERC CIP, IEC/ISA 62443, NIST 800-53

✅ LFP chemistry with UL 9540 and UL 9540A safety compliance

✅ Adds capacity, energy, and ancillary services to CA grid

San Diego Gas & Electric Company (SDG&E), a regulated public utility that provides energy service to 3.7 million people, has awarded Mitsubishi Power an order for a 10 megawatt (MW) / 60 megawatt-hour (MWh) energy storage solution for its Pala-Gomez Creek Energy Storage Project in Pala, California. The battery energy storage system (BESS) will add capacity to help meet high energy demand, support grid reliability and operational flexibility, underscoring the broader benefits of energy storage now recognized by utilities, maximize use of renewable energy, and help prevent outages during peak demand.

The BESS project is Mitsubishi Power’s eighth in California, bringing total capacity to 280 MW / 1,140 MWh of storage to help meet California’s clean energy goals with reliable power to complement renewables, alongside emerging solutions like a California green hydrogen microgrid for added resilience.

Mitsubishi Power’s Emerald storage solution for SDG&E includes full turnkey design, engineering, procurement, and construction, as well as a 10-year long-term service agreement, aligning with CEC long-duration storage funding initiatives underway. It is scheduled to be online in early 2023.

The project will repower an existing energy storage site. It will employ Mitsubishi Power’s Emerald Integrated Plant Controller, which is an Energy Management System (EMS) and Supervisory Control and Data Acquisition (SCADA) system with real-time BESS operation and a monitoring/supervisory control platform. Mitsubishi Power leverages its decades of technology monitoring and diagnostics to turn data into actionable insights to maximize reliability, a priority as regions like Ontario increasingly rely on battery storage to meet rising demand. The Mitsubishi Power Emerald Integrated Plant Controller complies with North American Electric Reliability Corporation critical infrastructure protection (NERC CIP) standards and meets the highest security certification in the energy storage industry (IEC/ISA 62443, NIST 800-53) for maximum protection from cybersecurity risks and vulnerabilities.

For added physical safety, Mitsubishi Power’s solution employs lithium iron phosphate (LFP) battery chemistry, aligning with BESS adoption in New York where safety and performance are critical. Compared with other chemistries, LFP provides longer life and superior thermal stability and chemical stability, while meeting UL 9540 and UL 9540A safety standards.

Fernando Valero, Director, Advanced Clean Technology, SDG&E, said, “SDG&E is committed to achieving net-zero greenhouse gas emissions by 2045. We are increasing our portfolio of energy storage assets, including virtual power plant models, to reach this goal. These assets enhance grid reliability and operational flexibility while maximizing our use of abundant renewable energy sources in California.”

Tom Cornell, Senior Vice President, Energy Storage Solutions, Mitsubishi Power Americas, said, “As more and more renewables come online during the energy transition, BESS solutions are essential to support a reliable and stable grid. We look forward to providing SDG&E with our BESS solution to add capacity, energy, and ancillary services to California’s grid. Mitsubishi Power’s Emerald storage solutions are enabling a smarter and more resilient energy future for our customers in California and around the globe, with projects like an energy storage demonstration in India underscoring this momentum.”

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Nova Scotia Cap-and-Trade Program joins Western Climate Initiative to leverage emissions trading IT systems, track allowances, and manage compliance, while setting in-province caps, carbon pricing signals, and third-party verified reporting for industrial and fuel suppliers.

Key Points

A provincial emissions trading system using WCI services to cap GHGs, track allowances, and enforce verified compliance.

✅ Uses WCI IT system to manage allowances and registry

✅ Initial trading limited to in-province participants

✅ Third-party verification and annual reporting deadlines

Nova Scotia is yet to set targets for its new cap and trade regime to reduce greenhouse gases, but the province announced Monday that it has joined the Western Climate Initiative Inc. -- a non-profit corporation formed to provide administrative and technical services to states and provinces with emissions trading programs.

Environment Minister Iain Rankin said joining the initiative would allow the province to use its IT system to manage and track its new cap and trade program.

Rankin said the province can join without trading greenhouse gas emission allowances with other jurisdictions -- California, Quebec, and Ontario are currently linked through the program, with Hydro-Québec's U.S. sales highlighting cross-border dynamics. Nova Scotia currently has no plans to trade outside the province as it works on emissions caps Rankin said will be ready sometime in June.

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Nova Scotia is yet to set targets for its new cap and trade regime to reduce greenhouse gases, but the province announced Monday that it has joined the Western Climate Initiative Inc. -- a non-profit corporation formed to provide administrative and technical services to states and provinces with emissions trading programs.

Environment Minister Iain Rankin said joining the initiative would allow the province to use its IT system to manage and track its new cap and trade program.

Rankin said the province can join without trading greenhouse gas emission allowances with other jurisdictions -- California, Quebec, and Ontario are currently linked through the program. Nova Scotia currently has no plans to trade outside the province as it works on emissions caps Rankin said will be ready sometime in June.

"By keeping our system internal it ensures that our greenhouse gas reductions are happening within our province," said Rankin. "But we do have that opportunity (to join) and if there are new entrants or we need more access to credits then that may shift our strategy."

The use of the system will cost Nova Scotia about US$314,000 for 2018-19, with an annual cost in subsequent years of about US$228,000 or more, if the province requests modifications.

"If we were to do something like that internally we would have to build a full database and hire more people, so this was an obvious choice for us," said Rankin.

Nova Scotia has already met the national reduction target of 30 per cent below 2005 levels and says it's on track to have 40 per cent of electricity generation from renewables by 2020, underscoring how cleaning up Canada's electricity supports climate pledges.

Stephen Thomas, energy campaign coordinator for the Ecology Action Centre, called the province's move an "important small step," stressing the importance of using the same administrative rules as the other jurisdictions involved.

But Thomas said Nova Scotia should go further and trade emissions with California, Quebec, and Ontario, and also put a price on carbon by auctioning credits as they do.

Thomas said Nova Scotia's system stands to be volatile because of the smaller number of participants -- about 20 including Nova Scotia Power, Northern Pulp, Lafarge, and large oil and gasoline companies such as ExxonMobil, Imperial and Irving.

"It's very likely to favour Nova Scotia Power as the largest single emitter with the most credits to sell here, and that would change if we had a linked system, at a time when Canada will need more electricity to hit net-zero according to the IEA," Thomas said.

He said it's important to have a linked system and a regional approach in Atlantic Canada, which has more emissions per person and more emissions per GDP than places like Ontario, Quebec and California, and where policies like Newfoundland's rate reduction plan can influence electricity strategy.

"Reducing emissions, because we are so emissions-intensive here, is a little bit cheaper," said Thomas. "So it's possible that Ontario, Quebec and California could pay Nova Scotia to reduce its emissions."

Under its program, Nova Scotia requires industrial facilities generating 50,000 tonnes or more of greenhouse gas emissions per year to report emissions.

Regulations also cover petroleum product suppliers that import or produce 200 litres of fuel or more per year for consumption and natural gas distributors whose products produce at least 10,000 tonnes of greenhouse gas emissions a year.

Companies were to have reported to the Environment Department by May 1 but Rankin said the deadline has been pushed back to June 1, a deadline that was to be followed in subsequent years in any event. Reports must be verified by a third party by Sept. 1 every year.

The Liberal government passed enabling legislation for cap and trade last fall.

As for the upcoming emissions caps, Rankin isn't tipping the province's hand yet, even as B.C.'s 2050 targets face a shortfall in some forecasts.

"Those caps will recognize the investments that have already been made and therefore will be the most cost-effective program that we can put together to meet the federal requirement," he said.

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UK Coal-Free Grid Streak highlights record hours without coal, as renewable energy, wind and solar boost electricity generation, cutting CO2 emissions, reducing fossil fuel reliance, and accelerating grid decarbonization amid volatile gas markets.

Key Points

It is the UKs longest coal-free power run, driven by renewables, signaling decarbonization and reduced gas reliance.

✅ Record-breaking hours of electricity with zero coal generation

✅ Enabled by wind, solar, and growing offshore wind capacity

✅ Highlights need to cut gas use and expand renewable investment

Today is the fourth the UK has entered with not a watt of electricity generated by coal.

It’s the longest such streak since the 1880s and comes only days after the last modern era coal-free power record of 55 hours was set.

That represents good news for those of us who have children and would rather like there to be a planet for them to live on when we’re gone.

Coal generated power is dirty power, and not just through the carbon that gets pumped into the atmosphere when it burns.

The fact that the UK is increasingly able to call upon cleaner alternatives for its requirements, to the extent that records are being regularly broken and coal's share has fallen to record lows, is a welcome development.

The trouble is one of those alternatives is gas, and while it is better than coal it still throws off CO2, among other pollutants. The UK’s use of it, for electricity generation and most of its heating, comes with the added disadvantage of leaving it in hock to volatile international markets and producers that aren’t always friendly.

It was only last month, with the country in the middle of a cold snap, that the Grid was issuing a deficit warning (its first in eight years).

As I wrote at the time, we need to burn less of the stuff as low-carbon progress stalled in 2019 shows, too.

As such, Greenpeace’s call for more investment in renewable energy technology and generation, including solar, onshore wind and offshore wind, which is making an increasing contribution as wind beat coal in 2016 demonstrated, was well made.

Those who complain about onshore wind farms, particularly when they are built in windy places that are pretty, seem willfully blind to the pollution caused by gas.

The need to be listened to less. So do those, like British Gas owner Centrica, that bellyache about green taxes.

It bears repeating that fossil fuels are subsidised still more. It’s just that the subsidies are typically hidden.

A report issued last year by a coalition of environmental organisations found the UK provided $972m (£695m) of annual financing for fossil fuels on average between 2013 and 2015, compared with $172m for renewable energy.

But while they come up with wildly varying amounts as a result of wildly varying approaches, the OECD, the IMF and the International Energy Agency have all quantified substantial subsidies for fossils fuels. Their annual estimates have ranged from $160bn to $5.3tn (yes you read that rate and the number was the IMF’s) globally.

So by all means celebrate coal free days, and a full week without coal power as milestones. But we need more of them more quickly and we need more renewable energy to pick up the slack. As such, the philosophy and approach of government needs to change.

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