Why California's Climate Policies Are Causing Electricity Blackouts


california blackouts

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California Rolling Blackouts expose grid reliability risks amid a heatwave, as CAISO curtails power while solar output fades at sunset, wind stalls, and scarce natural gas and nuclear capacity plus PG&E issues strain imports.

 

Key Points

Grid outages during heatwaves from low reserves, fading solar, weak wind, and limited firm capacity.

✅ Heatwave demand rose as solar output dropped at sunset

✅ Limited imports and gas, nuclear shortfalls cut reserves

✅ Policy, pricing, and maintenance gaps increased outage risk

 

Millions of Californians were denied electrical power and thus air conditioning during a heatwave, raising the risk of heatstroke and death, particularly among the elderly and sick. 

The blackouts come at a time when people, particularly the elderly, are forced to remain indoors due to Covid-19, and as later heat waves would test the grid again statewide.

At first, the state’s electrical grid operator last night asked customers to voluntarily reduce electricity use. But after lapses in power supply pushed reserves to dangerous levels it declared a “Stage 3 emergency” cutting off power to people across the state at 6:30 pm.

The immediate reason for the black-outs was the failure of a 500-megawatt power plant and an out-of-service 750-megawatt unit not being available. “There is nothing nefarious going on here,” said a spokeswoman for California Independent System Operator (CAISO). “We are just trying to run the grid.”

But the underlying reasons that California is experiencing rolling black-outs for the second time in less than a year stem from the state’s climate policies, which California policymakers have justified as necessary to prevent deaths from heatwaves, and which it is increasingly exporting to Western states as a model.

In October, Pacific Gas and Electric cut off power to homes across California to avoid starting forest fires after reports that its power lines may have started fires in recent seasons. The utility and California’s leaders had over the previous decade diverted billions meant for grid maintenance to renewables. 

And yesterday, California had to impose rolling blackouts because it had failed to maintain sufficient reliable power from natural gas and nuclear plants, or pay in advance for enough guaranteed electricity imports from other states.

It may be that California’s utilities and their regulator, the California Public Utilities Commission, which is also controlled by Gov. Newsom, didn’t want to spend the extra money to guarantee the additional electricity out of fears of raising California’s electricity prices even more than they had already raised them.

California saw its electricity prices rise six times more than the rest of the United States from 2011 to 2019, helping explain why electricity prices are soaring across the state, due to its huge expansion of renewables. Republicans in the U.S. Congress point to that massive increase to challenge justifications by Democrats to spend $2 trillion on renewables in the name of climate change.

Even though the cost of solar panels declined dramatically between 2011 and 2019, their unreliable and weather-dependent nature meant that they imposed large new costs in the form of storage and transmission to keep electricity as reliable. California’s solar panels and farms were all turning off as the blackouts began, with no help available from the states to the East already in nightfall.

Electricity from solar goes away at the very moment when the demand for electricity rises. “The peak demand was steady in late hours,” said the spokesperson for CAISO, which is controlled by Gov. Gavin Newsom, “and we had thousands of megawatts of solar reducing their output as the sunset.”

The two blackouts in less than a year are strong evidence that the tens of billions that Californians have spent on renewables come with high human, economic, and environmental costs.

Last December, a report by done for PG&E concluded that the utility’s customers could see blackouts double over the next 15 years and quadruple over the next 30.

California’s anti-nuclear policies also contributed to the blackouts. In 2013, Gov. Jerry Brown forced a nuclear power plant, San Onofre, in southern California to close.

Had San Onofre still been operating, there almost certainly would not have been blackouts on Friday as the reserve margin would have been significantly larger. The capacity of San Onofre was double that of the lost generation capacity that triggered the blackout.

California's current and former large nuclear plants are located on the coast, which allows for their electricity to travel shorter distances, and through less-constrained transmission lines than the state’s industrial solar farms, to get to the coastal cities where electricity is in highest demand.

There has been very little electricity from wind during the summer heatwave in California and the broader western U.S., further driving up demand. In fact, the same weather pattern, a stable high-pressure bubble, is the cause of heatwaves, since it brought very low wind for days on end along with very high temperatures.

Things won’t be any better, and may be worse, in the winter, with a looming shortage as it produces far less solar electricity than the summer. Solar plus storage, an expensive attempt to fix problems like what led to this blackout, cannot help through long winters of low output.

California’s electricity prices will continue to rise if it continues to add more renewables to its grid, and goes forward with plans to shut down its last nuclear plant, Diablo Canyon, in 2025.

Had California spent an estimated $100 billion on nuclear instead of on wind and solar, it would have had enough energy to replace all fossil fuels in its in-state electricity mix.

To manage the increasingly unreliable grid, California will either need to keep its nuclear plant operating, build more natural gas plants, underscoring its reliance on fossil fuels for reliability, or pay ever more money annually to reserve emergency electricity supplies from its neighbors.

After the blackouts last October, Gov. Newsom attacked PG&E Corp. for “greed and mismanagement” and named a top aide, Ana Matosantos, to be his “energy czar.” 

“This is not the new normal, and this does not take 10 years to solve,” Newsom said. “The entire system needs to be reimagined.”

 

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Germany is first major economy to phase out coal and nuclear

Germany Coal Phase-Out 2038 advances the energy transition, curbing lignite emissions while scaling renewable energy, carbon pricing, and hydrogen storage amid a nuclear phase-out and regional just-transition funding for miners and communities.

 

Key Points

Germany's plan to end coal by 2038, fund regional transition, and scale renewable energy while exiting nuclear.

✅ Closes last coal plant by 2038; reviews may accelerate.

✅ 40b euros aid for lignite regions and workforce.

✅ Emphasizes renewables, hydrogen, carbon pricing reforms.

 

German lawmakers have finalized the country's long-awaited phase-out of coal as an energy source, backing a plan that environmental groups say isn't ambitious enough and free marketeers criticize as a waste of taxpayers' money.

Bills approved by both houses of parliament Friday envision shutting down the last coal-fired power plant by 2038 and spending some 40 billion euros ($45 billion) to help affected regions cope with the transition, which has been complicated by grid expansion woes in recent years.

The plan is part of Germany's `energy transition' - an effort to wean Europe's biggest economy off planet-warming fossil fuels and generate all of the country's considerable energy needs from renewable sources. Achieving that goal is made harder than in comparable countries such as France and Britain because of Germany's existing commitment to also phase out nuclear power entirely by the end of 2022.

"The days of coal are numbered in Germany," Environment Minister Svenja Schulze said. "Germany is the first industrialized country that leaves behind both nuclear energy and coal."

Greenpeace and other environmental groups have staged vocal protests against the plan, including by dropping a banner down the front of the Reichstag building Friday. They argue that the government's road map won't reduce Germany's greenhouse gas emissions fast enough to meet the targets set out in the Paris climate accord.

"Germany, the country that burns the greatest amount of lignite coal worldwide, will burden the next generation with 18 more years of carbon dioxide," Greenpeace Germany's executive director Martin Kaiser told The Associated Press.

Kaiser, who was part of a government-appointed expert commission, accused Chancellor Angela Merkel of making a "historic mistake," saying an end date for coal of 2030 would have sent a strong signal for European and global climate policy. Merkel has said she wants Europe to be the first continent to end its greenhouse gas emissions, by 2050, even as some in Berlin debate a possible nuclear U-turn to reach that goal faster.

Germany closed its last black coal mine in 2018, but it continues to import the fuel and extract its own reserves of lignite, a brownish coal that is abundant in the west and east of the country, and generates about a third of its electricity from coal in recent years. Officials warn that the loss of mining jobs could hurt those economically fragile regions, though efforts are already under way to turn the vast lignite mines into nature reserves and lakeside resorts.

Schulze, the environment minister, said there would be regular government reviews to examine whether the end date for coal can be brought forward, even as Berlin temporarily extended nuclear operations during the energy crisis. She noted that by the end of 2022, eight of the country's most polluting coal-fired plants will have already been closed.

Environmentalists have also criticized the large sums being offered to coal companies to shut down their plants, a complaint shared by libertarians such as Germany's opposition Free Democratic Party.

Katja Suding, a leading FDP lawmaker, said the government should have opted to expand existing emissions trading systems that put a price on carbon, thereby encouraging operators to shut down unprofitable coal plants.

Katja Suding, a leading FDP lawmaker, said the government should have opted to expand existing emissions trading systems, rather than banking on a nuclear option, that put a price on carbon, thereby encouraging operators to shut down unprofitable coal plants.

"You just have to make it so expensive that it's not profitable anymore to turn coal into electricity," she said.

This week, utility companies in Spain shut down seven of the country's 15 coal-fired power plants, saying they couldn't be operated at profit without government subsidies.

But the head of Germany's main miners' union, Michael Vassiliadis, welcomed the decision, calling it a "historic milestone." He urged the government to focus next on an expansion of renewable energy generation and the use of hydrogen as a clean alternative for storing and transporting energy in the future, amid arguments that nuclear won't fix the gas crunch in the near term.

 

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Power Demand Seen Holding Firm In Europe’s Latest Lockdown

European Power Demand During Second Lockdowns remains resilient as winter heating offsets commercial losses; electricity consumption tracks seasonal norms, with weather sensitivity, industrial activity, natural gas shielding, and coal decline shaping dynamics under COVID-19 restrictions.

 

Key Points

It is expected to remain near seasonal norms, driven by heating, industry activity, and weather sensitive consumption.

✅ Winter heating offsets retail and hospitality closures

✅ Demand sensitivity rises with colder weather in France

✅ Gas generation shielded; coal likely to curtail first

 

European power demand is likely to hold up in the second round of national lockdown restrictions, with fluctuations most likely driven by changes in the weather.

Traders and analysts expect normal consumption this time around as home heating during the chilly season replaces commercial demand.

Last week electricity consumption in France, Germany and the U.K. was close to business-as-usual levels for the time of year, according to BloombergNEF data. By contrast, power demand had dropped 16% in the first seven days of the springtime lockdown, as reflected by the U.K.’s 10% daily decline reported then.

How power demand performs has significance outside the sector. It’s often seen as a proxy for economic growth and during lockdowns earlier this year, electricity use slumped along with GDP, and stunted hydro and nuclear output could further hobble recovery. For Western Europe, annual demand is expected to be 5% lower than the previous year, a bigger decline than after the global financial crisis in 2008, according to S&P Global Platts.

The Covid-19 limits are lighter than those from earlier in the year “with an explicit drive to preserve economic activity, particularly at the more energy-intensive industrial end of the spectrum,” said Glenn Rickson, head of European power analysis at S&P Global Platts.

Higher levels of working from home will offset some of the losses from shop and hospitality closures, “but also increase the temperature sensitivity of overall gas and power demand, as heat-driven demand records have shown in recent summers,” he said.

The latest wave of national lockdowns began in France, Germany, Spain, Italy and Britain, with Spain having seen April demand plummet earlier in the year, as coronavirus cases surged and officials struggled to keep the spread of the virus under control.

Much of the manufacturing industry remains working for now despite additional restrictions to contain the coronavirus. With the peak of the second wave yet to be reached, “it seems almost inevitable that the fourth quarter will prove economically challenging,” analysts at Alfa Energy said.

There will initially be significantly less of an impact on demand compared with this spring when global daily demand dipped about 15% and electricity consumption in Europe was down 30%, Johan Sigvardsson, power price analyst at Swedish utility Bixia AB said.

The prevalence of electric heating systems in France means that power demand is particularly sensitive to cold weather. A cold spell would significantly boost demand and drive record electricity prices in tight markets.

Similar to the last round of shutdowns, it’s use of coal that will probably be hit first if power demand sags, as transition-focused responses gather pace, leaving natural gas mostly shielded from fluctuations in the market.

“We expect that another drop in power demand would again impact coal-fired generation and shield gas power to some extent,” said Carlos Torres Diaz, an analyst at Rystad Energy.

 

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Freezing Rain Causes Widespread Power Outages in Quebec

Quebec Ice Storm 2025 disrupted power across Laurentians and Lanaudiere as freezing rain downed lines; Hydro-QuE9bec crews accelerated grid restoration, emergency response, and infrastructure resilience amid ongoing outages and severe weather alerts.

 

Key Points

Quebec Ice Storm 2025 brought freezing rain, outages, and grid damage, hitting Laurentians and Lanaudiere hardest.

✅ Peak: 62,000 Hydro-QuE9bec customers without electricity

✅ Most outages in Laurentians and Lanaudiere regions

✅ Crews repairing lines; restoration updates ongoing

 

A significant weather event struck Quebec in late March 2025, as a powerful ice storm caused widespread power outages across the province. The storm led to extensive power outages, affecting tens of thousands of residents, particularly in the Lanaudière and Laurentians regions. ​

Impact on Power Infrastructure

The freezing rain accumulated on power lines and vegetation, leading to numerous power outages across the network. Hydro-Québec reported that at its peak, over 62,000 customers were without electricity, with the majority of outages concentrated in the Laurentians and Lanaudière regions. By the afternoon, the number decreased to approximately 30,000, and further to just under 18,500 by late afternoon. 

Comparison with Previous Storms

While the March 2025 ice storm caused significant disruptions, it was less severe compared to the catastrophic ice storm of April 2023, which left 1.1 million Hydro-Québec customers without power. Nonetheless, the 2025 storm's impact was considerable, leading to the closure of municipal facilities and posing challenges for local economies, a pattern echoed when Toronto outages persisted for hundreds after a spring storm.

Ongoing Challenges

As of April 1, 2025, some areas continued to experience power outages, and incidents such as a manhole fire left thousands without service in separate cases. Hydro-Québec and municipal authorities worked diligently to restore services and address the aftermath of the storm, while Hydro One crews restored power to more than 277,000 customers after damaging storms in Ontario. Residents were advised to stay updated through official channels for restoration timelines and safety information.

Future Preparedness

The recurrence of such severe weather events highlights the importance of robust infrastructure and emergency preparedness, as seen in BC Hydro's storm response to an 'atypical' event that demanded extensive coordination. Both utility companies and residents must remain vigilant, especially during seasons prone to unpredictable weather patterns, with local utilities like Sudbury Hydro crews working to reconnect service after regional storms.

 

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COVID-19: Daily electricity demand dips 15% globally, says report

COVID-19 Impact on Electricity Demand, per IEA data, shows 15% global load drop from lockdowns, with residential use up, industrial and service sectors down; fossil fuel generation fell as renewables and photovoltaics gained share.

 

Key Points

An overview of how lockdowns cut global power demand, boosted residential use, and increased the renewable share.

✅ IEA review shows at least 15% dip in daily global electricity load

✅ Lockdowns cut commercial and industrial demand; homes used more

✅ Fossil fuels fell as renewables and PV generation gained share

 

The daily demand for electricity dipped at least 15 per cent across the globe, according to Global Energy Review 2020: The impacts of the COVID-19 crisis on global energy demand and CO2 emissions, a report published by the International Energy Agency (IEA) in April 2020, even as global power demand surged above pre-pandemic levels.

The report collated data from 30 countries, including India and China, that showed partial and full lockdown measures adopted by them were responsible for this decrease.

Full lockdowns in countries — including France, Italy, India, Spain, the United Kingdom where daily demand fell about 10% and the midwest region of the United States (US) — reduced this demand for electricity.

 

Reduction in electricity demand after lockdown measures (weather corrected)


 

Source: Global Energy Review 2020: The impacts of the COVID-19 crisis on global energy demand and CO2 emissions, IEA


Drivers of the fall

There was, however, a spike in residential demand for electricity as a result of people staying and working from home. This increase in residential demand, though, was not enough to compensate for reduced demand from industrial and commercial operations.

The extent of reduction depended not only on the duration and stringency of the lockdown, but also on the nature of the economy of the countries — predominantly service- or industry-based — the IEA report said.

A higher decline in electricity demand was noted in countries where the service sector — including retail, hospitality, education, tourism — was dominant, compared to countries that had industrial economies.

The US, for example — where industry forms only 20 per cent of the economy — saw larger reductions in electricity demand, compared to China, where power demand dropped as the industry accounts for more than 60 per cent of the economy.

Italy — the worst-affected country from COVID-19 — saw a decline greater than 25 per cent when compared to figures from last year, even as power demand held firm in parts of Europe during later lockdowns.

The report said the shutting down of the hospitality and tourism sectors in the country — major components of the Italian economy — were said to have had a higher impact, than any other factor, for this fall.

 

Reduced fossil fuel dependency

Almost all of the reduction in demand was reportedly because of the shutting down of fossil fuel-based power generation, according to the report. Instead, the share of electricity supply from renewables in the entire portfolio of energy sources, increased during the pandemic, reflecting low-carbon electricity lessons observed during COVID-19.

This was due to a natural increase in wind and photovoltaic power generation compared to 2019 along with a drop in overall electricity demand that forced electricity producers from non-renewable sources to decrease their supplies, before surging electricity demand began to strain power systems worldwide.

The Power System Operation Corporation of India also reported that electricity production from coal — India’s primary source of electricity — fell by 32.2 per cent to 1.91 billion units (kilowatt-hours) per day, in line with India's electricity demand decline reported during the pandemic, compared to the 2019 levels.

 

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How Canada can capitalize on U.S. auto sector's abrupt pivot to electric vehicles

Canadian EV Manufacturing is accelerating with GM, Ford, and Project Arrow, integrating cross-border supply chains, battery production, rare-earths like lithium and cobalt, autonomous tech, and home charging to drive clean mobility and decarbonization.

 

Key Points

Canadian EV manufacturing spans electric and autonomous vehicles, domestic batteries, and integrated US-Canada trade.

✅ GM and Ford retool plants for EVs and autonomous production

✅ Project Arrow showcases Canadian zero-emission supply capabilities

✅ Lithium, cobalt, and battery hubs target cross-border resilience

 

The storied North American automotive industry, the ultimate showcase of Canada’s high-tensile trade ties with the United States and emerging Canada-U.S. collaboration on EVs momentum, is about to navigate a dramatic hairpin turn.

But as the Big Three veer into the all-electric, autonomous era, some Canadians want to seize the moment and take the wheel.

“There’s a long shadow between the promise and the execution, but all the pieces are there,” says Flavio Volpe, president of the Automotive Parts Manufacturers’ Association.

“We went from a marriage on the rocks to one that both partners are committed to. It could be the best second chapter ever.”

Volpe is referring specifically to GM, which announced late last month an ambitious plan to convert its entire portfolio of vehicles to an all-electric platform by 2035.

But that decision is just part of a cascading transformation across the industry, marking an EV inflection point with existential ramifications for one of the most tightly integrated cross-border manufacturing and supply-chain relationships in the world.

China is already working hard to become the “source of a new way” to power vehicles, President Joe Biden warned last week.

“We just have to step up.”

Canada has both the resources and expertise to do the same, says Volpe, whose ambitious Project Arrow concept — a homegrown zero-emissions vehicle named for the 1950s-era Avro interceptor jet — is designed to showcase exactly that, as recent EV assembly deals in Canada underscore.

“We’re going to prove to the market, we’re going to prove to the (manufacturers) around the planet, that everything that goes into your zero-emission vehicle can be made or sourced here in Canada,” he says.

“If somebody wants to bring what we did over the line and make 100,000 of them a year, I’ll hand it to them.”

GM earned the ire of Canadian auto workers in 2018 by announcing the closure of its assembly plant in Oshawa, Ont. It later resurrected the facility with a $170-million investment to retool it for autonomous vehicles.

“It was, ‘You closed Oshawa, how dare you?’ And I was one of the ‘How dare you’ people,” Volpe says.

“Well, now that they’ve reopened Oshawa, you sit there and you open your eyes to the commitment that General Motors made.”

Ford, too, has entered the fray, promising $1.8 billion to retool its sprawling landmark facility in Oakville, Ont., to build EVs.

It’s a leap of faith of sorts, considering what market experts say is ongoing consumer doubt about EVs and EV supply shortages that drive wait times.

“Range anxiety” — the persistent fear of a depleted battery at the side of the road — remains a major concern, even though it’s less of a problem than most people think.

Consulting firm Deloitte Canada, which has been tracking automotive consumer trends for more than a decade, found three-quarters of future EV buyers it surveyed planned to charge their vehicles at home overnight.

“The difference between what is a perceived issue in a consumer’s mind and what is an actual issue is actually quite negligible,” Ryan Robinson, Deloitte’s automotive research leader, says in an interview.

“It’s still an issue, full stop, and that’s something that the industry is going to have to contend with.”

So, too, is price, especially with the end of the COVID-19 pandemic still a long way off. Deloitte’s latest survey, released last month, found 45 per cent of future buyers in Canada hope to spend less than $35,000 — a tall order when most base electric-vehicle models hover between $40,000 and $45,000.

“You put all of that together and there’s still, despite the electric-car revolution hype, some major challenges that a lot of stakeholders that touch the automotive industry face,” Robinson says.

“It’s not just government, it’s not just automakers, but there are a variety of stakeholders that have a role to play in making sure that Canadians are ready to make the transition over to electric mobility.”

With protectionism no longer a dirty word in the United States and Biden promising to prioritize American workers and suppliers, the Canadian government’s job remains the same as it ever was: making sure the U.S. understands Canada’s mission-critical role in its own economic priorities.

“We’re both going to be better off on both sides of the border, as we have been in the past, if we orient ourselves toward this global competition as one force,” says Gerald Butts, vice-chairman of the political-risk consultancy Eurasia Group and a former principal secretary to Prime Minister Justin Trudeau.

“It served us extraordinarily well in the past … and I have no reason to believe it won’t serve us well in the future.”

Last month, GM announced a billion-dollar plan to build its new all-electric BrightDrop EV600 van in Ingersoll, Ont., at Canada’s first large-scale EV manufacturing plant for delivery vehicles.

That investment, Volpe says, assumes Canada will take the steps necessary to help build a homegrown battery industry — with projects such as a new Niagara-region battery plant pointing the way — drawing on the country’s rare-earth resources like lithium and cobalt that are waiting to be extracted in northern Ontario, Quebec and elsewhere.

Given that the EV industry is still in his infancy, the free market alone won’t be enough to ensure those resources can be extracted and developed, he says.

“General Motors made a billion-dollar bet on Canada because it’s going to assume that the Canadian government — this one or the next one — is going to commit” to building that business.

Such an investment would pay dividends well beyond the auto sector, considering the federal Liberal government’s commitment to lowering greenhouse gas-emissions, including a 2035 EV mandate, and meeting targets set out in the Paris climate accord.

“If you make investments in renewable energy and utility storage using battery technology, you can build an industry at scale that the auto industry can borrow,” Volpe says.

Major manufacturing, retail and office facilities would be able to use that technology to help “shave the peak” off Canada’s GHG emissions and achieve those targets, all the while paving the way for a self-sufficient electric-vehicle industry.

“You’d be investing in the exact same technology you’d use in a car.”

There’s one problem, says Robinson: the lithium-ion batteries on roads right now might not be where the industry ultimately lands.

“We’re not done with with battery technology,” Robinson says. “What you don’t want to do is invest in a technology that is that is rapidly evolving, and could potentially become obsolete going forward.”

Fuel cells — energy-efficient, hydrogen-powered units that work like batteries, but without the need for constant recharging — continue to be part of the conversation, he adds.

“The amount of investment is huge, and you want to be sure that you’re making the right decision, so you don’t find yourself behind the curve just as all that capacity is coming online.”

 

 

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FERC needs to review capacity market performance, GAO recommends

FERC Capacity Markets face scrutiny as GAO flags inconsistent data on resource adequacy and costs, urging performance goals, risk assessment, and better metrics across PJM, ISO-NE, NYISO, and MISO amid cost-recovery proposals.

 

Key Points

FERC capacity markets aim for resource adequacy, but GAO finds weak data and urges goals and performance reviews.

✅ GAO cites inconsistent data on resource adequacy and costs

✅ Calls for performance goals, metrics, and risk assessment

✅ Applies to PJM, ISO-NE, NYISO; MISO market is voluntary

 

Capacity markets may or may not be functioning properly, but FERC can't adequately make that determination, according to the GAO report.

"Available information on the level of resource adequacy ... and related costs in regions with and without capacity markets is not comprehensive or consistent," the report found. "Moreover, consistent data on historical trends in resource adequacy and related costs are not available for regions without capacity markets."

The review concluded that FERC collects some useful information in regions with and without capacity markets, but GAO said it "identified problems with data quality, such as inconsistent data."

GAO included three recommendations, including calling for FERC to take steps to improve the quality of data collected, and regularly assess the overall performance of capacity markets by developing goals for those assessments.

"FERC should develop and document an approach to regularly identify, assess, and respond to risks that capacity markets face," the report also recommended. The commission "has not established performance goals for capacity markets, measured progress against those goals, or used performance information to make changes to capacity markets as needed."

The recommendation comes as the agency is grappling with a controversial proposal to assure cost-recovery for struggling coal and nuclear plants in the power markets. So far, the proposal would only apply to power markets with capacity markets, including PJM Interconnection, the New England ISO, the New York ISO and possibly MISO. However MISO only has a voluntary capacity market, making it unclear how the proposed rule would be applied there. 

 

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