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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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Western Canada Electric Grid could deliver interprovincial transmission, reliability, peak-load support, reserve sharing, and wind and solar integration, lowering costs versus new generation while respecting AESO markets and Crown utility structures.

Key Points

Interprovincial transmission to share reserves, boost reliability, integrate wind and solar, and cut peak capacity costs.

✅ Cuts reserve margins via diversity of peak loads

✅ Enables wind and solar balancing across provinces

✅ Saves ratepayers vs replacing retiring thermal plants

The 2017 Canadian Free Trade Agreement does not do much to encourage provinces to trade electric energy east and west. Would a western Canada electric grid help electricity consumers in the western provinces? Some Alberta officials feel that their electric utilities are investor owned and they perceive the Crown corporations of BC Hydro, SaskPower and Manitoba Hydro to be subsidized by their provincial governments, so an interprovincial electric energy trade would not be on a level playing field.

Because of the limited trade of electric energy between the western provinces, each utility maintains an excessive reserve of thermal and hydroelectric generation greater than their peak loads, to provide a reliable supply during peak load days as grids are increasingly exposed to harsh weather across Canada. This excess does not include variable wind and solar generation, which within a province can’t be guaranteed to be available when needed most.

This attitude must change. Transmission is cheaper than generation, and coordinated macrogrids can further improve reliability and cut costs. By constructing a substantial grid with low profile and aesthetically designed overhead transmission lines, the excess reserve of thermal and hydroelectric generation above the peak electric load can be reduced in each province over time. Detailed assessments will ensure each province retains its required reliability of electric supply.

As the provinces retire aging thermal and coal-fired generators, they only need to replace them to a much lower level, by just enough to meet their future electric loads and Canada's net-zero grid by 2050 goals. Some of the money not spent in replacing retired generation can be profitably invested in the transmission grid across the four western provinces.

But what about Alberta, which does not want to trade electric energy with the other western provinces? It can carry on as usual within the Alberta Electric System Operator’s (AESO) market and will save money by keeping the installed reserve of thermal and hydroelectric generation to a minimum. When Alberta experiences a peak electric load day and some generators are out of service due to unplanned maintenance, it can obtain the needed power from the interprovincial electric grid. None of the other three western provinces will peak at the same time, because of different weather and time zones, so they will have spare capacity to help Alberta over its peak. The peak load in a province only lasts for a few hours, so Alberta will get by with a little help from its friends if needed.

The grid will have no energy flowing on it for this purpose except to assist a province from time to time when it’s unable to meet its peak load. The grid may only carry load five per cent of the time in a year for this purpose. Under such circumstances, the empty grid can then be used for other profitable markets in electric energy. This includes more effective use of variable wind and solar energy, by enabling a province to better balance such intermittent power as well as allowing increased installation of it in every province. This is a challenge for AESO which the grid would substantially ease.

Natural Resources Canada promoted the “Regional Electricity Co-Operative and Strategic Infrastructure” initiative for completion this year and contracted through AESO, alongside an Atlantic grid study to explore regional improvements. This is a first step, but more is needed to achieve the full benefit of a western grid.

In 1970 a study was undertaken to electrically interconnect Britain with France, which was justified based on the ability to reduce reserve generation in both countries. Initially Britain rejected it, but France was partially supportive. In time, a substantial interconnection was built, and being a profitable venture, they are contemplating increasing the grid connections between them.

For the sake of the western consumers of electricity and to keep electricity rates from rising too quickly, as well as allowing productive expansion of wind and solar energy in places like British Columbia's clean energy shift efforts, an electric grid is essential across western Canada.

Dennis Woodford is president of Electranix Corporation in Winnipeg, which studies electric transmission problems, particularly involving renewable energy generators requiring firm connection to the grid.

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Cal ISO Flex Alert urges Southern California energy conservation as a Stage 2 emergency strains the power grid, with potential rolling blackouts during peak hours from 3 to 10 p.m., if demand exceeds supply.

Key Points

A statewide call to conserve power during high demand, issued by the grid operator to prevent rolling blackouts.

✅ Stage 2 emergency signals severe grid strain

✅ Peak Flex Alert hours: 3 to 10 p.m. statewide

✅ Set thermostats to 78 and avoid major appliances

Residents and businesses across Southern California were urged to conserve power Tuesday afternoon amid ongoing electricity inequities across the state as the manager of the state’s power grid warned rolling blackouts could be imminent for some power customers.

The California Independent System Operator (Cal ISO), which manages the state power grid, declared a Stage 2 emergency as of 2:30 p.m., indicating severe strain on the electrical system, similar to a recent grid alert in Alberta that relied on reserves.

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Rolling blackouts for some customers could occur in a Stage 3 emergency, distinct from the intentional shut-offs some utilities use to reduce wildfire risk.

Cal ISO issued a statewide Flex Alert in effect from 3 to 10 p.m. Tuesday and Wednesday, with conservation considered especially critical during those hours, a concern heightened by pandemic-era grid operations this year.

Officials told reporters rolling blackouts might be avoided Tuesday evening if residents repeat the level of conservation seen Monday.
“If we can get the same sort of response we got yesterday, we can minimize this, or perhaps avoid it altogether,” Cal-ISO President/CEO Steve Berberich said, noting that some operators have even planned staff lockdowns during COVID-19 to maintain reliability.

Cal-ISO controls roughly 80% of the state’s power grid through Southern California Edison, Pacific Gas and Electric Co., with the utility recently restoring power after shut-offs in affected communities, and San Diego Gas & Electric.

Residents are urged to set thermostats at 78 in the afternoon and evening hours and avoiding the use of air conditioning and major appliances during the Flex Alert hours, as utilities like PG&E prepare for winter storms to improve resilience.

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EU Winter Energy Mix 2022-2023 shows renewables, wind, solar, and hydro overtaking coal and gas, as demand fell amid high prices; Ember and IEA confirm lower emissions across Europe during the energy crisis.

Key Points

It describes Europe's winter power mix: reduced coal and gas, and record wind, solar, and hydro output.

✅ Coal generation fell 11% YoY; gas output declined even more.

✅ Renewables supplied 40%: wind, solar, and hydro outpaced fossil fuels.

✅ Ember and IEA confirm trends; mild winter tempered demand.

The EU burned less coal this winter during the energy crisis than in previous years, according to an analysis, quashing fears that consumption of the most polluting fossil fuel would soar as countries scrambled to find substitutes for lost supplies of Russian gas.

The study from energy think-tank Ember shows that between October 2022 and March 2023 coal generation fell 27 terawatt hours, or almost 11 per cent year on year, while gas generation fell 38 terawatt hours, as renewables crowded out gas and consumers cut electricity consumption in response to soaring prices.

Renewable energy supplies also rose, with combined wind and solar power and hydroelectric output outstripping fossil fuel generation for the first time, providing 40 per cent of all electricity supplies. The Financial Times checked Ember’s findings with the International Energy Agency, which said they broadly matched its own preliminary analysis of Europe’s electricity generation over the winter.

The study demonstrates that fears of a steep rebound in coal usage in Europe’s power mix were overstated, despite the continent’s worst energy crisis in 40 years following Russia’s full-scale invasion of Ukraine, even as stunted hydro and nuclear output in parts of Europe posed challenges.

While Russia slashed gas supplies to Europe and succeeded in boosting energy prices for consumers to record levels, the push by governments to rejuvenate old coal plants, including Germany's coal generation, to ensure the lights stayed on ultimately did not lead to increased consumption.

“With Europe successfully on the other side of this winter and major supply disruptions avoided, it is clear the threatened coal comeback did not materialise,” analysts at Ember said in the report.

“With fossil fuel generation down, EU power sector emissions during winter were the lowest they have ever been.”

Ember cautioned, however, that Europe had been assisted by a mild winter that helped cut electricity demand for heating and there was no guarantee of such weather next winter. Companies and households had also endured a lot of pain as a result of the higher prices that had led them to cut consumption, even though in some periods, such as the latest lockdown, power demand held firm in parts of Europe.

Total electricity consumption between October and March declined 94 terawatt hours, or 7 per cent, compared with the same period in winter 2021/22, continuing post-Covid transition dynamics across Europe.

“For a lot of people this winter was really hard with electricity prices that were extraordinarily high and we shouldn’t lose sight of that,” said Ember analyst Harriet Fox.

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Quebec Hydropower Export Retaliation examines using electricity exports to counter U.S. tariffs amid Canada-U.S. trade tensions, weighing clean energy supply, grid reliability, energy security, legal risks, and long-term market impacts.

Key Points

Using Quebec electricity exports as leverage against U.S. tariffs, and its economic, legal, and diplomatic consequences.

✅ Revenue loss for Quebec and higher costs for U.S. consumers

✅ Risk of legal disputes under trade and energy agreements

✅ Long-term erosion of market share and grid cooperation

As trade tensions between Canada and the United States continue to escalate, with electricity exports at risk according to recent reporting, discussions have intensified around potential Canadian responses to the imposition of U.S. tariffs. One of the proposals gaining attention is the idea of reducing or even halting the export of energy from Quebec to the U.S. This measure has been suggested by some as a potential countermeasure to retaliate against the tariffs. However, experts and industry leaders are urging caution, emphasizing that the consequences of such a decision could have significant economic and diplomatic repercussions for both Canada and the United States.

Quebec plays a critical role in energy trade, particularly in supplying hydroelectric power to the United States, especially to the northeastern states, including New York where tariffs may spike energy prices according to analysts, strengthening the case for stable cross-border flows. This energy trade is deeply embedded in the economic fabric of both regions. For Quebec, the export of hydroelectric power represents a crucial source of revenue, while for the U.S., it provides access to a steady and reliable supply of clean, renewable energy. This mutually beneficial relationship has been a cornerstone of trade between the two countries, promoting economic stability and environmental sustainability.

In the wake of recent U.S. tariffs on Canadian goods, some policymakers have considered using energy exports as leverage, echoing threats to cut U.S. electricity exports in earlier disputes, to retaliate against what is viewed as an unfair trade practice. The idea is to reduce or stop the flow of electricity to the U.S. as a way to strike back at the tariffs and potentially force a change in U.S. policy. On the surface, this approach may appear to offer a viable means of exerting pressure. However, experts warn that such a move would be fraught with significant risks, both economically and diplomatically.

First and foremost, Quebec's economy is heavily reliant on revenue from hydroelectric exports to the U.S. Any reduction in these energy sales could have serious consequences for the province's economic stability, potentially resulting in job losses and a decrease in investment. The hydroelectric power sector is a major contributor to Quebec's GDP, and recent events, including a tariff threat delaying a green energy bill in Quebec, illustrate how trade tensions can ripple through the policy landscape, while disrupting this source of income could harm the provincial economy.

Additionally, experts caution that reducing energy exports could have long-term ramifications on the energy relationship between Quebec and the northeastern U.S. These two regions have developed a strong and interconnected energy network over the years, and abruptly cutting off the flow of electricity could damage this vital partnership. Legal challenges could arise under existing trade agreements, and even as tariff threats boost support for Canadian energy projects among some stakeholders, the situation would grow more complex. Such a move could also undermine trust between the two parties, making future negotiations on energy and other trade issues more difficult.

Another potential consequence of halting energy exports is that U.S. states may seek alternative sources of energy, diminishing Quebec's market share in the long run. As the U.S. has a growing demand for clean energy, especially as it looks to transition away from fossil fuels, and looks to Canada for green power in several regions, cutting off Quebec’s electricity could prompt U.S. states to invest in other forms of energy, including renewables or even nuclear power. This could have a lasting effect on Quebec's position in the U.S. energy market, making it harder for the province to regain its footing.

Moreover, reducing or ceasing energy exports could further exacerbate trade tensions, leading to even greater economic instability. The U.S. could retaliate by imposing additional tariffs on Canadian goods or taking other measures that would negatively impact Canada's economy. This could create a cycle of escalating trade barriers that would hurt both countries and undermine the broader North American trade relationship.

While the concept of using energy exports as a retaliatory tool may seem appealing to some, the experts' advice is clear: the potential economic and diplomatic costs of such a strategy outweigh the short-term benefits. Quebec’s role as an energy supplier to the U.S. is crucial to its own economy, and maintaining a stable, reliable energy trade relationship is essential for both parties. Rather than escalating tensions further, it may be more prudent for Canada and the U.S. to seek diplomatic solutions that preserve trade relations and minimize harm to their economies.

While the idea of using Quebec’s energy exports as leverage in response to U.S. tariffs may appear attractive on the surface, and despite polls showing support for tariffs on energy and minerals among Canadians, it carries significant risks. Experts emphasize the importance of maintaining a stable energy export strategy to protect Quebec’s economy and preserve positive diplomatic relations with the U.S. Both countries have much to lose from further escalating trade tensions, and a more measured approach is likely to yield better outcomes in the long run.

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Global Energy Electrification drives IEA targets as smart grids, storage, EVs, and demand-side management scale. Paris Agreement-aligned policies and innovation accelerate decarbonization, enabling flexible, low-carbon power systems and net-zero pathways by 2060.

Key Points

A shift to electricity across sectors via smart grids, storage, EVs, and policy to cut CO2 and improve energy security.

✅ Smart grids, storage, DSM enable flexible, resilient power.

✅ Aligns with IEA pathways and Paris Agreement goals.

✅ Drives EV adoption, building efficiency, and net-zero by 2060.

The global energy system is changing, with European electricity market trends highlighting rapid shifts. More people are connecting to the grid as living standards improve around the world. Demand for consumer appliances and electronic devices is rising. New and innovative transportation technologies, such as electric vehicles and autonomous cars are also boosting power demand.

The International Energy Agency's latest report on energy technologies outlines how these and other trends as well as technological advances play out in the next four decades to reshape the global energy sector.

Energy Technology Perspectives 2017 (ETP) highlights that decisive policy actions and market signals will be needed to drive technological development and benefit from higher electrification around the world. Investments in stronger and smarter infrastructure, including transmission capacity, storage capacity and demand side management technologies such as demand response programs are necessary to build efficient, low-carbon, integrated, flexible and robust energy system. 

Still, current government policies are not sufficient to achieve long-term global climate goals, according to the IEA analysis, and warnings about falling global energy investment suggest potential supply risks as well. Only 3 out of 26 assessed technologies remain “on track” to meet climate objectives, according to the ETP’s Tracking Clean Energy Progress report. Where policies have provided clean signals, progress has been substantial. However, many technology areas suffer from inadequate policy support. 

"As costs decline, we will need a sustained focus on all energy technologies to reach long-term climate targets," said IEA Executive Director Dr Fatih Birol. "Some are progressing, but too few are on track, and this puts pressure on others. It is important to remember that speeding the rate of technological progress can help strengthen economies, boost energy security while also improving energy sustainability."

ETP 2017’s base case scenario, known as the Reference Technology Scenario (RTS), takes into account existing energy and climate commitments, including those made under the Paris Agreement. Another scenario, called 2DS, shows a pathway to limit the rise of global temperature to 2ºC, and finds the global power sector could reach net-zero CO2 emissions by 2060.

A second decarbonisation scenario explores how much available technologies and those in the innovation pipeline could be pushed to put the energy sector on a trajectory beyond 2DS. It shows how the energy sector could become carbon neutral by 2060 if known technology innovations were pushed to the limit. But to do so would require an unprecedented level of policy action and effort from all stakeholders.

Looking at specific sectors, ETP 2017 finds that buildings could play a major role in supporting the energy system transformation. High-efficiency lighting, cooling and appliances could save nearly three-quarters of today’s global electricity demand between now and 2030 if deployed quickly. Doing so would allow a greater electrification of the energy system that would not add burdens on the system. In the transportation system, electrification also emerges as a major low-carbon pathway, with clean grids and batteries becoming key areas to watch in deployment.

The report finds that regardless of the pathway chosen, policies to support energy technology innovation at all stages, from research to full deployment, alongside evolving utility trends that operators need to watch, will be critical to reap energy security, environmental and economic benefits of energy system transformations. It also suggests that the most important challenge for energy policy makers will be to move away from a siloed perspective towards one that enables systems integration.

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