Burning coal underground has potential

UK Offshore Wind Expansion will make wind the main power source, driving renewable energy, offshore projects, smart grids, battery storage, and interconnectors to cut carbon emissions, boost exports, and attract global investment.

Key Points

A UK strategy to scale offshore wind, integrate smart grids and storage, cut emissions and drive investment and exports

✅ 30% energy target by 2030, backed by CfD support

✅ 250m industry investment and smart grid build-out

✅ Battery storage and interconnectors balance intermittency

Plans are afoot to make wind the UKs main power source for the first time in history amid ambitious targets to generate 30 percent of its total energy supply by 2030, up from 8 percent at present.

A recently inked deal will see the offshore wind industry invest 250 million into technology and infrastructure over the next 11 years, with the government committing up to 557 million in support, under a renewable energy auction that boosts wind and tidal projects, as part of its bid to lower carbon emissions to 80 percent of 1990 levels by 2050.

Offshore wind investment is crucial for meeting decarbonisation targets while increasing energy production, says Dominic Szanto, Director, Energy and Infrastructure at JLL. The governments approach over the last seven years has been to promise support to the industry, provided that cost reduction targets were met. This certainty has led to the development of larger, more efficient wind turbines which means the cost of offshore wind energy is a third of what it was in 2012.

Boosting the wind industry

Offshore wind power has been gathering pace in the UK and has grown despite COVID-19 disruptions in recent years. Earlier this year, the Hornsea One wind farm, the worlds largest offshore generator which is located off the Yorkshire coast, started producing electricity. When fully operational in 2020, the project will supply energy to over a million homes, and a further two phases are planned over the coming decade.

Over 10 gigawatts of offshore wind either already has government support or is eligible to apply for it in the near future, following a 10 GW contract award that underscores momentum, representing over 30 billion of likely investment opportunities.

Capital is coming from European utility firms and increasingly from Asian strategic investors looking to learn from the UKs experience. The attractive government support mechanism means banks are keen to lend into the sector, says Szanto.

New investment in the UKs offshore wind sector will also help to counter the growing influence of China. The UK is currently the worlds largest offshore wind market, but by 2021 it will be outstripped by China.

Through its new deal, the government hopes to increase wind power exports fivefold to 2.6 billion per year by 2030, with the UKs manufacturing and engineering skills driving projects in growth markets in Europe and Asia and in developing countries supported by the World Bank support through financing and advisory programs.

Over the next two decades, theres a massive opportunity for the UK to maintain its industry leading position by designing, constructing, operating and financing offshore wind projects, says Szanto. Building on projects such as the Hywind project in Scotland, it could become a major export to countries like the USA and Japan, where U.S. lessons from the U.K. are informing policy and coastal waters are much deeper.

Wind-powered smart grids

As wind power becomes a major contributor to the UKs energy supply, which will be increasingly made up of renewable sources in coming decades, there are key infrastructure challenges to overcome.

A real challenge is that the UKs power generation is becoming far more decentralised, with smaller power stations such as onshore wind farms and solar parks and more prosumers residential houses with rooftop solar coupled with a significant rise in intermittent generation, says Szanto. The grid was never designed to manage energy use like that.

One potential part of the solution is to use offshore wind farms in other sites in European waters.

By developing connections between wind projects from neighbouring countries, it will create super-grids that will help mitigate intermittency issues, says Szanto.

More advanced energy storage batteries will also be key for when less energy is generated on still days. There is a growing need for batteries that can store large amounts of energy and smart technology to discharge that energy. Were going through a revolution where new technology companies are working to enable a much smarter grid.

Future smart grids, based on developing technology such as blockchain, might enable the direct trading of energy between generators and consumers, with algorithms that can manage many localised sources and, critically, ensure a smooth power supply.

Investors seeking a higher-yield market are increasingly turning to battery technology, Szanto says. In a future smart grid, for example, batteries could store electricity bought cheaply at low-usage times then sold at peak usage prices or be used to provide backup energy services to other companies.

Majors investing in the transition

Its not just new energy technology companies driving change; established oil and gas companies are accelerating spending on renewable energy. Shell has committed to $1-2 billion per year on clean energy technologies out of a $25-30 billion budget, while Equinor plans to spend 15-20 percent of its budget on renewables by 2030.

The oil and gas majors have the global footprint to deliver offshore wind projects in every country, says Szanto. This could also create co-investment opportunities for other investors in the sector especially as nascent wind markets such as the U.S., where the U.S. offshore wind timeline is still developing, and Japan evolve.

European energy giants, for example, have bid to build New Yorks first offshore wind project.

As offshore wind becomes a globalised sector, with a trillion-dollar market outlook emerging, the major fuel companies will have increasingly large roles. They have the resources to undertake the years-long, cost-intensive developments of wind projects, driven by a need for new business models as the world looks beyond carbon-based fuels, says Szanto.

Oil and gas heavyweights are also making wind, solar and energy storage acquisitions BP acquired solar developer Lightsource and car-charging network Chargemaster, while Shell spent $400 million on solar and battery companies.

The public perception is that renewable energy is niche, but its now a mainstream form of energy generation., concludes Szanto.

Every nation in the world is aligned in wanting a decarbonised future. In terms of electricity, that means renewable energy and for offshore wind energy, the outlook is extremely positive.

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UK Energy Networks Coronavirus Contingency outlines ESO's lockdown electricity demand forecast, reduced industrial and commercial load, rising domestic use, Ofgem guidance needs, grid resilience, control rooms, mutual aid, and backup centers.

Key Points

A coordinated plan with ESO forecasts, safeguards, and mutual aid to keep power and gas services during a lockdown.

✅ ESO forecasts lower industrial use, higher domestic demand

✅ Control rooms protected; backup sites and cross-trained staff

✅ Mutual aid and Ofgem coordination bolster grid resilience

National Grid ESO is predicting a reduction in electricity demand, consistent with residential use trends observed during the pandemic, in the case of the coronavirus spread prompting a lockdown across the country.

Its analysis shows the reduction in commercial and industrial use would outweigh an upsurge in domestic demand, mirroring Ontario demand data seen as people stayed home, according to similar analyses.

The prediction was included in an update from the Energy Networks Association (ENA), in which it sought to reassure the public that contingency plans are in place, reflecting utility disaster planning across electric and gas networks, to ensure services are unaffected by the coronavirus spread.

The body, which represents the UK's electricity and gas network companies, said "robust measures" had been put in place to protect control rooms and contact centres, similar to staff lockdown protocols considered by other system operators, to maintain resilience. To provide additional resilience, engineers have been trained across multiple disciplines and backup centres exist should operations need to be moved if, for example, deep cleaning is required, the ENA said.

Networks also have industry-wide mutual aid arrangements, similar to grid response measures outlined in the U.S., for people and the equipment needed to keep gas and electricity flowing.

ENA chief executive, David Smith, said, echoing system reliability assurances from other markets: "The UK's electricity and gas network is one of the most reliable in the world and network operators are working with the authorities to ensure that their contingency plans are reviewed and delivered in accordance with the latest expert advice. We are following this advice closely and reassuring customers that energy networks are continuing to operate as normal for the public."

Utility Week spoke to a senior figure at one of the networks who reiterated the robust measures in place to keep the lights on, even as grid alerts elsewhere highlight the importance of contingency planning. However, they pleaded for more clarity from Ofgem and government on how its workers will be treated if the coronavirus spread becomes a pandemic in the UK.

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BPA Privatization would sell the Bonneville Power Administration's transmission lines, raising FERC-regulated grid rates for ratepayers, impacting hydropower and the California-Oregon Intertie under the Trump 2018 budget proposal in the Pacific Northwest region.

Key Points

Selling Bonneville's transmission grid to private owners, raising rates and returns, shifting costs to ratepayers.

✅ Trump 2018 budget targets BPA transmission assets for sale.

✅ Higher capital costs, taxes, and profit would raise transmission rates.

✅ California-Oregon Intertie and hydropower flows face price impacts.

President Trump's 2018 budget proposal is so chock-full of noxious elements — replacing food stamps with "food boxes," drastically cutting Medicaid and Medicare, for a start — that it's unsurprising that one of its most misguided pieces has slipped under the radar.

That's the proposal to privatize the government-owned Bonneville Power Administration, which owns about three-quarters of the high-voltage electric transmission lines in a region that includes California, Washington state and Oregon, serving more than 13.5 million customers. By one authoritative estimate, any such sale would drive up the cost of transmission by 26%-44%.

The $5.2-billon price cited by the Trump administration, moreover, is nearly 20% below the actual value of the Bonneville grid — meaning that a private buyer would pocket an immediate windfall of $1.2 billion, at the expense of federal taxpayers and Bonneville customers.

Trump's plan for Portland, Ore.-based Bonneville is part of a larger proposal to sell off other government-owned electricity bodies, including the Colorado-based Western Area Power Administration and the Oklahoma-based Southwestern Power Administration. But Bonneville is by far the largest of the three, accounting for nearly 90% of the total $5.8 billion the budget anticipates collecting from the sales. The proposal is also part of the administration's

Both plans are said to be politically dead-on-arrival in Washington. But they offer a window into the thinking in the Trump White House.

"The word 'muddle' comes to mind," says Robert McCullough, a respected Portland energy consultant, referring to the justification for the privatization sale included in the Trump budget.

The White House suggests that selling the Bonneville grid would result in lower costs. But that narrative, McCullough wrote in a blistering assessment of the proposal, "displays a severe lack of understanding about the process of setting transmission rates."

McCullough's assessment is an update of a similar analysis he performed when the privatization scheme was first raised by the Trump administration last year. In that analysis issued in June, McCullough said the proposal "raises the question of why these valuable assets would be sold at a discount — and who would get the benefit of the discounted price."

The implications of a sale could be dire for Californians. Bonneville is the majority owner of the California-Oregon Intertie, an electrical transmission system that carries power, including Columbia River-generated hydropower and other clean-energy generation in British Columbia that supports the regional exchange, south to California in the summer and excess California generation to the Pacific Northwest in the winter.

But the idea has drawn fire throughout the region. When it was first broached last year, the Public Power Council, an association of utilities in the Northwest, assailed it as an apparent "transfer of value from the people of the Northwest to the U.S. Treasury," drawing parallels to Manitoba Hydro governance issues elsewhere.

The region's political leaders had especially harsh words for the idea this time around. "Oregonians raised hell last year when Trump tried to raise power bills for Pacific Northwesterners by selling off Bonneville Power, and yet his administration is back at it again," Sen. Ron Wyden (D-Ore.) said after the idea reappeared. "Our investment shouldn't be put up for sale to free up money for runaway military spending or tax cuts for billionaires." Sen. Maria Cantwell (D-Wash.) promised in a statement to work to "stop this bad idea in its tracks."

The notion of privatizing Bonneville predates the Trump administration; it was raised by Bill Clinton and again by George W. Bush, who thought the public would gain if the administration could sell its power at market rates. Both initiatives failed.

The same free-enterprise ideology underlies the Trump proposal. Privatizing the transmission lines "encourages a more efficient allocation of economic resources and mitigates unnecessary risk to taxpayers," the budget asserts. "Ownership of transmission assets is best carried out by the private sector where there are appropriate market and regulatory incentives."

But that's based on a misunderstanding of how transmission rates are set, McCullough says. Transmission is essentially a monopoly enterprise, with rates overseen by the Federal Energy Regulatory Commission based on the grid's costs, and with federal scrutiny of public utilities such as the TVA underscoring that oversight. There's very little in the way of market "incentives" involved in transmission, since no one has come forward to build a competing grid.

Those include the owners' cost of capital — which would be much higher for a private owner than a government agency, McCullough observes, as Hydro One investor uncertainty demonstrates in practice. A private owner, unlike the government-owned Bonneville, also would owe federal income taxes, which would be passed on to consumers.

Then there's the profit motive. Bonneville "currently sells and delivers its power at cost," McCullough wrote last year. "Under a private regime, an investor-owned utility would likely charge a higher rate of return, a pattern seen when UK network profits drew regulatory rebukes."

None of these considerations appears to have been factored into the White House budget proposal. "Either there's an unsophisticated person at the Office of Management and Budget thinking up these numbers himself," McCullough told me, "or there would seem to be ongoing negotiations with an unidentified third party." No such buyer has emerged in the past, however.

What's left is a blind faith in the magic of the market, compounded by ignorance about how the transmission market operates. Put it together, and there's reason to wonder if Trump is even serious about this plan.

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Berlin Electric Utility APPA Safety Award recognizes Gold Designation performance in public power, highlighting OSHA-aligned incident rates, robust safety culture, worker safety training, and operational reliability that keeps the community's electric service resilient.

Key Points

A national honor for Berlin's Gold Designation recognizing safety performance, worker protection, and reliable service.

✅ Gold Designation in 15,000-29,999 worker hours APPA category

✅ OSHA-based incident rate and robust safety culture

✅ Training, PPE, and reliability focus in public power operations

The Town of Berlin Electric Utility Department has been recognized for its outstanding safety practices with the prestigious Safety Award of Excellence from the American Public Power Association (APPA), a distinction also reflected in Medicine Hat Electric Utility for health and safety excellence, highlighting industry-wide commitment to worker protection.

Recognition for Excellence

In an era when workplace safety is a critical concern, with organizations highlighting leadership in worker safety across the sector, the Town of Berlin Electric Utility Department’s achievement stands out. The department earned the Gold Designation award in the category for utilities with 15,000 to 29,999 worker hours of annual worker exposure. This category is part of the APPA’s annual Safety Awards, which are designed to recognize the safety performance of public power utilities across the United States.

Out of more than 200 utilities that participated in the 2024 Safety Awards, Berlin's Electric Utility Department distinguished itself with an exemplary safety record. The utility’s ranking was based on its low incidence of work-related injuries and illnesses, alongside its robust safety programs and strong safety culture.

What the Award Represents

The Safety Award of Excellence is given to utilities that demonstrate effective safety protocols and practices over the course of the year. The APPA evaluates utilities based on their incident rate, which is calculated using the number of work-related reportable injuries or illnesses relative to worker hours. This measurement adheres to guidelines established by the Occupational Safety and Health Administration (OSHA), ensuring a standardized approach to assessing safety.

For the Town of Berlin Electric Utility Department, achieving the Gold Designation award signifies a year of outstanding safety performance. The award reflects the department’s dedication to preventing accidents and creating a work environment where safety is prioritized at every level.

Why Safety Matters

For utilities like the one in Berlin, safety is not just about preventing injuries—it's about fostering a culture of care and responsibility. Electric utility workers face unique and significant risks, ranging from the dangers of working with high-voltage systems, including hazards near downed power lines that require extreme caution, to the physical demands of the job. A utility’s ability to minimize these risks and keep its workforce safe is a direct reflection of its safety practices, training, and overall management.

The commitment to safety extends beyond just the immediate work environment. Utilities that place a high value on safety typically invest in ongoing training, safety gear, and processes, and even contingency measures like staff living on site during outbreaks, that ensure all employees are well-prepared to handle the challenges of their roles. The Town of Berlin Electric Utility Department has taken these steps seriously, providing its workers with the resources they need to stay safe while maintaining the power supply for the local community.

The Importance of Worker Safety in Public Power

The American Public Power Association’s Safety Award program highlights the best practices in public utilities, which, as the U.S. grid overseer's pandemic warning reminded the sector, play a crucial role in providing essential services to communities across the country. Public power utilities, like Berlin’s, are governed by local or municipal entities rather than for-profit corporations, which often allows them to have a closer relationship with their communities. As a result, these utilities often go above and beyond when it comes to worker safety, understanding that the well-being of employees directly impacts the quality of service provided to residents.

For the Town of Berlin, this award not only highlights the utility's commitment to its employees but also reinforces the importance of the work that public utilities do in keeping communities safe and powered. Berlin's recognition underscores the significance of maintaining a safe work environment, especially when the safety of first responders and utility workers, as seen when nuclear plant workers raised concerns over virus precautions, directly impacts the public’s access to reliable services.

What’s Next for Berlin’s Electric Utility Department

Receiving the Safety Award of Excellence is a remarkable achievement, but for the Town of Berlin Electric Utility Department, it’s not the end of their safety journey—it’s just one more step in their ongoing commitment to improvement. The department’s leadership, including the safety team, has emphasized the importance of continually evaluating and enhancing safety protocols to stay ahead of potential risks. This includes adopting new safety technologies, refining training programs, and ensuring that all employees are involved in the process of safety.

As the Town of Berlin looks forward to the future, its focus on worker safety will remain a top priority. Maintaining this level of safety is not only crucial for the health and well-being of employees but also for ensuring the continued success of the community’s utility services.

Community Impact

This recognition also serves as an example for other utilities in the region and across the country. By prioritizing safety, the Town of Berlin Electric Utility Department sets a standard that other utilities can aspire to. In a time when worker safety is more important than ever, Berlin’s commitment to best practices provides a model for others to follow.

Ultimately, the safety of utility workers is a reflection of a community’s dedication to its workforce and its commitment to providing reliable, uninterrupted services. For the residents of Berlin, the recognition of their local electric utility department’s safety practices means that they can continue to rely on a safe, secure, and resilient power infrastructure, while staying mindful of home risks such as overheated power strips that can spark fires.

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Franco-German Nuclear Power Divide shapes EU energy policy, electricity market reform, and decarbonization strategies, as Paris backs reactors and state subsidies while Berlin prioritizes renewables, hydrogen, and energy security after Russian gas shocks.

Key Points

A policy rift over nuclear shaping EU market reform, subsidies, and the balance between reactors and renewables.

✅ Nuclear in EU targets vs. renewables-first strategy

✅ Market design disputes over long-term power prices

✅ Energy security after Russian gas; hydrogen definitions

Near the French village of Fessenheim, facing Germany across the Rhine, a nuclear power station stands dormant. The German protesters that once demanded the site’s closure have decamped, in a sign of Europe's nuclear decline, and the last watts were produced three years ago. 

But disagreements over how the plant from 1977 should be repurposed persist, speaking to a much deeper divide over nuclear power, which Eon chief's warning to Germany underscored, between the two countries on either side of the river’s banks.

German officials have disputed a proposal to turn it into a centre to treat metals exposed to low levels of radioactivity, Fessenheim’s mayor Claude Brender says. “They are not on board with anything that might in some way make the nuclear industry more acceptable,” he adds.

France and Germany’s split over nuclear power is a tale of diverging mindsets fashioned over decades, including since the Chernobyl disaster in USSR-era Ukraine. But it has now become a major faultline in a touchy relationship between Europe’s two biggest economies.

Their stand-off over how to treat nuclear in a series of EU reforms has consequences for how Europe plans to advance towards cleaner energy. It will also affect how the bloc secures power supplies as the region weans itself off Russian gas, even though nuclear would do little for the gas issue, and how it provides its industry with affordable energy to compete with the US and China. 

“There can be squabbles between partners. But we’re not in a retirement home today squabbling over trivial matters. Europe is in a serious situation,” says Eric-André Martin, a specialist in Franco-German relations at French think-tank IFRI. 

France, which produces two-thirds of its power from nuclear plants and has plans for more reactors, is fighting for the low-carbon technology to be factored into its targets for reducing emissions and for leeway to use state subsidies to fund the sector.

For Germany, which closed its last nuclear plants this year and, having turned its back on nuclear, has been particularly shaken by its former reliance on Russian gas, there’s concern that a nuclear drive will detract from renewable energy advances.

But there is also an economic subtext in a region still reeling from an energy crisis last year, reviving arguments for a needed nuclear option for climate in Germany, when prices spiked and laid bare how vulnerable households and manufacturers could become.

Berlin is wary that Paris would benefit more than its neighbours if it ends up being able to guarantee low power prices from its large nuclear output as a result of new EU rules on electricity markets, amid talk of a possible U-turn on the phaseout, people close to talks between the two countries say.

Ministers on both sides have acknowledged there is a problem. “The conflict is painful. It’s painful for the two governments as well as for our [EU] partners,” Sven Giegold, state secretary at the German economy and climate action ministry, where debates about whether a nuclear resurgence is possible persist, tells the Financial Times. 

Agnès Pannier-Runacher, France’s energy minister, says she wants to “get out of the realm of the emotional and move past the considerable misunderstandings that have accumulated in this discussion”.

In a joint appearance in Hamburg last week, German chancellor Olaf Scholz and French president Emmanuel Macron made encouraging noises over their ability to break the latest deadlock: a disagreement over the design of the EU’s electricity market. Ministers had been due to agree a plan in June but will now meet on October 17 to discuss the reform, aimed at stabilising long-term prices.

But the French and German impasse on nuclear has already slowed down debates on key EU policies such as rules on renewable energy and how hydrogen should be produced. Smaller member states are becoming impatient. The delay on the market design is “a big Franco-German show of incompetence again”, says an energy ministry official from another EU country who requested anonymity. 

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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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