What's at stake if Davis-Besse and other nuclear plants close early?


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FirstEnergy Nuclear Plant Closures threaten Ohio and Pennsylvania jobs, tax revenue, and grid stability, as Nuclear Matters and Brattle Group warn of higher carbon emissions and market pressures from PJM and cheap natural gas.

 

Key Points

Planned shutdowns of Davis-Besse, Perry, and Beaver Valley, with regional economic and carbon impacts.

✅ Over 3,000 direct jobs and local tax revenue at risk

✅ Emissions may rise until renewables scale, possibly into 2034

✅ Debate over subsidies, market design, and PJM capacity rules

 

A national nuclear lobby wants to remind people what's at stake for Ohio and Pennsylvania if FirstEnergy Solutions follows through with plans to shut down three nuclear plants over the next three years, including its Davis-Besse nuclear plant east of Toledo.

A report issued Monday by Nuclear Matters largely echoes concerns raised by FES, a subsidiary of FirstEnergy Corp., and other supporters of nuclear power about economic and environmental hardships and brownout risks that will likely result from the planned closures.

Along with Davis-Besse, Perry nuclear plant east of Cleveland and the twin-reactor Beaver Valley nuclear complex west of Pittsburgh are slated to close.

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"If these plants close, the livelihoods of thousands of Ohio and Pennsylvania residents will disappear. The over 3,000 highly skilled individuals directly employed by these sites will leave to seek employment at other facilities still operating around the country," Lonnie Stephenson, International Brotherhood of Electrical Workers president, said in a statement distributed by Nuclear Matters. Mr. Stephenson also serves on the Nuclear Matters advocacy council.

This new report and others like it are part of an extensive campaign by nuclear energy advocates to court state and federal legislators one more time for tens of millions of dollars of financial support or at least legislation that better suits the nuclear industry. Critics allege such pleas amount to a request for massive government bailouts, arguing that deregulated electricity markets should not subsidize nuclear.

The latest report was prepared for Nuclear Matters by the Brattle Group, a firm that specializes in analyzing economic, finance, and regulatory issues for corporations, law firms, and governments.

"These announced retirements create a real urgency to learn what would happen if these plants are lost," Dean Murphy, the Brattle report's lead author, said.

More than 3,000 jobs would be lost, as would millions of dollars in tax revenue. It also could take as long as 2034 for the region's climate-altering carbon emissions to be brought back down to existing levels, based on current growth projections for solar- and wind-powered projects, and initiatives such as ending coal by 2032 by some utilities, Mr. Murphy said.

His group's report only takes into account nuclear plant operations, though. Many of those who oppose nuclear power have long pointed out that mining uranium for nuclear plant fuel generates substantial emissions, as does the process of producing steel cladding for fuel bundles and the enrichment-production of that fuel. Still, nuclear has ranked among the better performers in reports that have taken such a broader look at overall emissions.

FES has accused the regional grid operator, PJM Interconnection, of creating market conditions that favor natural gas and, thus, make it almost impossible for nuclear to compete throughout its 13-state region, a debate intensified by proposed electricity pricing changes at the federal level.

PJM has strongly denied those accusations, and has said it anticipates no shortfalls in energy distribution if those nuclear plants close prematurely, even as a recent FERC decision on grid policy drew industry criticism.

FES, citing massive losses, has filed for Chapter 11 bankruptcy. The target dates for closures of the FES properties are May 31, 2020 for Davis-Besse; May 31, 2021 for Perry and Beaver Valley Unit 1, and Oct. 31, 2021 for Beaver Valley Unit 2.

In addition to the three FES sites, the report includes information about the Three Mile Island Unit 1 plant near Harrisburg, Pa., which Chicago-based Exelon Generation Corp. has previously announced will be shut down in 2019. That plant and others are experiencing similar difficulties the FES plants face by competing in a market radically changed by record-low natural gas prices.

 

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BC Hydro says province sleeping in, showering less in pandemic

BC Hydro pandemic electricity trends reveal weekend-like energy consumption patterns: later morning demand, earlier evenings, more cooking, streaming on smart TVs, and work-from-home routines, with tips to conserve using laptops and small appliances.

 

Key Points

Weekend-like shifts in power demand from work-from-home routines: later mornings, earlier evenings, and more streaming.

✅ Later morning electricity demand; earlier evening peaks

✅ More cooking and baking; increased streaming after dinner

✅ Conservation tips: laptops, small appliances, smart TVs

 

The latest report on electricity usage in British Columbia reveals the COVID-19 pandemic has created an atmosphere where every day feels like a Saturday, a pattern also reflected in BC electricity demand during peak seasons.

BC Hydro says overall power usage hasn't changed much, but similar Ontario electricity demand shifts suggest regional differences, while Manitoba demand fell more noticeably, and a survey of 500 people shows daily routines have shifted dramatically since mid-March when pandemic-related closures began.

The hydro report says, with nearly 40 per cent of B.C. residents working from home, trends in residential electricity use confirm almost half are sleeping in and eating breakfast later, while about a quarter say they are showering less.

Those patterns more closely resemble what hydro says is typical weekend power consumption, and could influence time-of-use rates as electricity demand occurs later in the morning and earlier in the evening.

The report also finds many people are cooking and baking more than before the pandemic, preparing the evening meal earlier, streaming or viewing more television after dinner even as Ottawa's electricity consumption dipped earlier in the pandemic, and 80 per cent are going to bed later.

Although electricity use is normal for this time of year, hydro says homebound residents can conserve by using laptops instead of desktops, small appliances such as Instant Pots instead of ovens, and streaming movies or TV shows on a smart televisions instead of game consoles, even as Hydro One peak rates continue to shape consumption patterns elsewhere.

 

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Magnitude 5 quake strikes near Iran nuclear plant

Iran Bushehr Earthquake rattles southern province near the Bushehr nuclear power plant, USGS reports M5.1 at 38 km depth; seismic activity along major fault lines raises safety, damage, and monitoring concerns.

 

Key Points

A magnitude 5.1 quake near Bushehr nuclear plant at 38 km depth, with no damage reported, per USGS.

✅ USGS lists magnitude 5.1 at 38 km depth

✅ Near Bushehr nuclear power plant; built for stronger quakes

✅ Iran lies on major fault lines; quake risk is frequent

 

A magnitude 5 earthquake struck southern Iran early Friday near the Islamic Republic's only nuclear power plant. There were no immediate reports of damage or injuries as Iran continues combined-cycle conversions across its power sector.

The quake hit Iran's Bushehr province at 5:23 a.m., according to the U.S. Geological Survey. It put the magnitude at 5.1 and the depth of the earthquake at 38 kilometres (24 miles), in a province tied to efforts to transmit electricity to Europe in coming years.

Iranian state media did not immediately report on the quake. However, the Bushehr nuclear power plant was designed to withstand much stronger earthquakes, a notable consideration as Iraq plans nuclear power plants to address shortages.

A magnitude 5 earthquake can cause considerable damage, including power disruptions that have seen blackouts spark protests in some Iranian cities.

Iran sits on major fault lines and is prone to near-daily earthquakes, yet it remains a key player in regional power, with Iran-Iraq energy cooperation ongoing. In 2003, a 6.6-magnitude quake flattened the historic city of Bam, killing 26,000 people, and today Iran supplies 40% of Iraq's electricity through cross-border power deals. Bam is near the Bushehr nuclear plant, which wasn’t damaged at that time, while more recently Iran finalized deals to rehabilitate Iraq's power grid to improve resilience.

 

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27,000 Plus More Clean Energy Jobs Lost in May

U.S. Clean Energy Job Losses highlight COVID-19 impacts on renewable energy, solar, wind, and energy efficiency, with PPP fatigue, unemployment, and calls for Congressional stimulus, per Department of Labor data analyzed by E2.

 

Key Points

Pandemic-driven layoffs across renewable, solar, wind, and efficiency sectors, risking recovery without federal aid.

✅ Over 620,500 clean energy jobs lost in three months

✅ Energy efficiency, solar, and wind hit hardest nationwide

✅ Industry urges Congress for stimulus, tax credit relief

 

As Congress this week begins debating economic stimulus support for the energy industry, a new analysis of unemployment data shows the biggest part of America's energy economy - clean energy - lost another 27,000 jobs in May, bringing the total number of clean energy workers who have lost their jobs in the past three months to more than 620,500.

While May saw an improvement in new unemployment claims over March and April, the findings represent the sector's third straight month of significant job losses across solar, wind, energy efficiency, clean vehicles and other industries. With coronavirus cases once again rising in many states and companies beginning to run out of the Payroll Protection Program (PPP) funding that has helped small businesses keep workers employed, and as households confront pandemic power shut-offs that heighten energy insecurity, the report increases concerns the sector will be unable to resume its economy-leading jobs growth in the short- or long-term without a significant policy response.

Given the size and scope of the clean energy industry, such a sustained loss would cast a pall on the nation's overall economic recovery, as shifting electricity demand during COVID-19 complicates forecasts, according to the analysis of the Department of Labor's May unemployment data from E2 (Environmental Entrepreneurs), E4TheFuture and the American Council on Renewable Energy (ACORE).

Prior to COVID-19, clean energy - including energy efficiency, solar and wind generation, clean vehicles and related sectors - was among the U.S. economy's biggest and fastest-growing employment sectors, growing 10.4% since 2015 to nearly 3.4 million jobs at the end of 2019. That made clean energy by far the biggest employer of workers in all energy occupations, employing nearly three times as many people as the fossil fuel industry. For comparison, coal mining employs about 47,000 workers, even as clean energy projects in coal communities aim to revitalize local economies.

The latest monthly analysis for the groups by BW Research Partnership runs contrary to recent Bureau of Labor Statistics (BLS) reports, which indicated that a more robust economic rebound was underway, even as high fuel prices haven't spurred a green shift in adoption, while also acknowledging misclassifications and serious reporting difficulties in its own data.

Bob Keefe, Executive Director at E2, said:

"May's almost 30,000 clean energy jobs loss is sadly an improvement in the rate of jobs shed but make no mistake: There remains huge uncertainty and volatility ahead. It will be very tough for clean energy to make up these continuing job losses without support from Congress. Lawmakers must act now. If they do, we can get hundreds of thousands of these workers back on the job today and build a better, cleaner, more equitable economy for tomorrow. And who doesn't want that?"

Pat Stanton, Policy Director at E4TheFuture, said:

"Most of the time, energy efficiency workers need to go inside homes, businesses and other buildings to get the job done. Since they couldn't do that during COVID lockdowns, they couldn't work. Now states are opening up. But utilities, contractors and building owners need to protect employees and occupants from possible exposure to the virus and need more clarity about potential liabilities."

Gregory Wetstone, President and CEO of ACORE, said:

"In May, we saw thousands of additional renewable energy workers join the ranks of the unemployed, further underscoring the damage COVID-19 is inflicting on our workforce. Since the pandemic began, nearly 100,000 renewable energy workers have lost their jobs. We need help from Congress to get American clean energy workers back to work. With commonsense measures like temporary refundability and a delay in the phasedown of renewable energy tax credits, Congress can help restore these good-paying jobs so the renewable sector can continue to provide the affordable, pollution-free power American consumers and businesses want and deserve."

Phil Jordan, Vice President and Principal at BW Research Partnership, said:

"We understand the challenges and limitations of data collection for BLS in the middle of a global pandemic. But any suggestion that a strong employment rebound is underway in the United States simply is not reflected in the clean energy sector right now. And with PPP expiring, that only increases uncertainty in the months ahead."

The report comes as both the Senate Committee on Energy and Natural Resources and the House Energy and Commerce Committee are considering clean energy stimulus to restart the U.S. economy, and amid assessments of mixed results from the climate law shaping expectations, and as lawmakers in both the House and Senate are increasing calls for supporting clean energy workers and businesses, including this bicameral letter signed by 57 members of Congress and another signed today by 180 House members.

Industries Hit Hardest

According to the analysis, energy efficiency lost more jobs than any other clean energy sector for the third consecutive month in May, shedding about 18,900 jobs. These workers include electricians, HVAC technicians who work with high-efficiency systems, and manufacturing employees who make Energy Star appliances, LED lighting systems and efficient building materials.

Renewable energy, including solar and wind, lost nearly 4,300 jobs in May.

Clean grid and storage and clean vehicles manufacturing -- including grid modernization, energy storage, car charging and electric and plug-in hybrid vehicle manufacturing -- lost a combined 3,200 jobs in May, as energy crisis impacts electricity, gas, and EVs in several ways.

The clean fuels sector lost more than 650 jobs in May.

States and Localities Hit Across Country

California continues to be the hardest hit state in terms of total job losses, losing 4,313 jobs in May and more than 109,700 since the COVID-19 crisis began. Florida was the second hardest hit state in May, losing an additional 2,563 clean energy jobs, while Georgia, Texas, Washington, and Michigan all suffered more than 1,000 job losses across the sector. An additional 12 states saw at least 500 clean energy unemployment filings, and reports like Pennsylvania's clean energy jobs analysis provide added context, according to the latest analysis.

For a full breakdown of clean energy job losses in each state, along with a list of the hardest hit counties and metro areas, see the full analysis here.

 

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Can California Manage its Solar Boom?

California Duck Curve highlights midday solar oversupply and steep evening peak demand, stressing grid stability. Solutions include battery storage, demand response, diverse renewables like wind, geothermal, nuclear, and regional integration to reduce curtailment.

 

Key Points

A mismatch between midday solar surplus and evening demand spikes, straining the grid without storage and flexibility.

✅ Midday solar oversupply forces curtailment and wasted clean energy.

✅ Evening ramps require fast, fossil peaker plants to stabilize load.

✅ Batteries, demand response, regional trading flatten the curve.

 

California's remarkable success in adopting solar power, including a near-100% renewable milestone, has created a unique challenge: managing the infamous "duck curve." This distinctive curve illustrates a growing mismatch between solar electricity generation and the state's energy demands, creating potential problems for grid stability and ultimately threatening to slow California's progress in the fight against climate change.


The Shape of the Problem

The duck curve arises from a combination of high solar energy production during midday hours and surging energy demand in the late afternoon and evening when solar power declines. During peak solar hours, the grid often has an overabundance of electricity, and curtailments are increasing as a result, while as the sun sets, demand surges when people return home and businesses ramp up operations. California's energy grid operators must scramble to make up this difference, often relying on fast-acting but less environmentally friendly power sources.


The Consequences of the Duck Curve

The increasing severity of the duck curve has several potential consequences for California:

  • Grid Strain: The rapid ramp-up of power sources to meet evening demand puts significant strain on the electrical grid. This can lead to higher operational costs and potentially increase the risk of blackouts during peak demand times.
  • Curtailed Energy: To avoid overloading the grid, operators may sometimes have to curtail excess solar energy during midday, as rising curtailment reports indicate, essentially wasting clean electricity that could have been used to displace fossil fuel generation.
  • Obstacle to More Solar: The duck curve can make it harder to add new solar capacity, as seen in Alberta's solar expansion challenges, for fear of further destabilizing the grid and increasing the need for fossil fuel-based peaking plants.


Addressing the Challenge

California is actively seeking solutions to mitigate the duck curve, aligning with national decarbonization pathways that emphasize practicality. Potential strategies include:

  • Energy Storage: Deploying large-scale battery storage can help soak up excess solar electricity during the day and release it later when demand peaks, smoothing out the duck curve.
  • Demand Flexibility: Encouraging consumers to shift their energy use to off-peak hours through incentives and smart grid technologies can help reduce late-afternoon surges in demand.
  • Diverse Power Sources: While solar is crucial, a balanced mix of energy sources, including geothermal, wind, and nuclear, can improve grid stability and reduce reliance on rapid-response fossil fuel plants.
  • Regional Cooperation: Integrating California's grid with neighboring states can aid in balancing energy supply and demand across a wider geographical area.


The Ongoing Solar Debate

The duck curve has become a central point of debate about the future of California's energy landscape. While acknowledging the challenge, solar advocates argue for continued expansion, backed by measures like a bill to require solar on new buildings, emphasizing the urgent need to transition away from fossil fuels. Grid operators and some utility companies call for a more cautious approach, emphasizing grid reliability and potential costs if the problem isn't effectively managed.


Balancing California's Needs and its Green Ambitions

Finding the right path forward is essential; it will determine whether California can continue to lead the way in solar energy adoption while ensuring a reliable and affordable electricity supply. Successfully navigating the duck curve will require innovation, collaboration, and a strong commitment to building a sustainable energy system, as wildfire smoke impacts on solar continue to challenge generation predictability.

 

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Why Atomic Energy Is Heating Up Again

Nuclear Power Revival drives decarbonization, climate change mitigation, and energy security with SMRs, Generation IV designs, baseload reliability, and policy support, complementing renewables to meet net-zero targets and growing global electricity demand.

 

Key Points

A global shift back to nuclear energy, leveraging SMRs and advanced reactors to cut emissions and enhance energy security.

✅ SMRs offer safer, modular, and cost-effective deployment.

✅ Provides baseload power to complement intermittent renewables.

✅ Policy support and investments accelerate advanced designs.

 

In recent years, nuclear power has experienced a remarkable revival in public interest, policy discussions, and energy investment. Once overshadowed by controversies surrounding safety, waste management, and high costs, nuclear energy is now being reexamined as a vital component of the global energy transition, despite recurring questions such as whether it is in decline from some commentators. Here's why nuclear power is "so hot" right now:

1. Climate Change Urgency

One of the most compelling reasons for the renewed interest in nuclear energy is the urgent need to address climate change. Unlike fossil fuels, nuclear power generates electricity with zero greenhouse gas emissions during operation. As countries rush to meet net-zero carbon targets, evidence that net-zero may require nuclear is gaining traction, and nuclear offers a reliable, large-scale alternative to complement renewable energy sources like wind and solar.

2. Energy Security and Independence

Geopolitical tensions and supply chain disruptions have exposed vulnerabilities in relying on imported fossil fuels, and Europe's shrinking nuclear capacity has sharpened concerns over resilience. Nuclear power provides a domestic, stable energy source that can operate independently of volatile global markets. For many nations, this has become a strategic priority, reducing dependence on politically sensitive energy imports.

3. Advances in Technology

Modern innovations in nuclear technology are transforming the industry. Small Modular Reactors (SMRs) are leading the way as part of next-gen nuclear innovation, offering safer, more affordable, and flexible options for nuclear deployment. Unlike traditional large-scale reactors, SMRs can be built faster, scaled to specific energy needs, and deployed in remote or smaller markets.

Additionally, advances in reactor designs, such as Generation IV reactors and fusion research, promise to address longstanding concerns like waste management and safety. For example, some new designs can recycle spent fuel or run on alternative fuels, significantly reducing radioactive waste.

4. Public Perception Is Shifting

Public opinion on nuclear power is also changing. While the industry faced backlash after high-profile incidents like Chernobyl and Fukushima, increasing awareness of climate change and energy security is prompting many to reconsider, including renewed debates such as Germany's potential nuclear return in policy circles. A younger, climate-conscious generation views nuclear energy not as a relic of the past, but as an essential tool for a sustainable future.

5. Renewables Alone Are Not Enough

While renewable energy sources like solar and wind have grown exponentially, their intermittent nature remains a challenge. Energy storage technologies, such as batteries, have not yet matured enough to fully bridge the gap. Nuclear power, with its ability to provide constant, "baseload" energy, as France's fleet demonstrates in practice, serves as an ideal complement to variable renewables in a decarbonized energy mix.

6. Government Support and Investment

Policymakers are taking action to bolster the nuclear sector. Many countries are including nuclear energy in their clean energy plans, offering subsidies, grants, and streamlined regulations to accelerate its deployment. For instance, the United States has allocated billions of dollars to support advanced nuclear projects, the UK's green industrial revolution outlines support for upcoming reactor waves, while Europe has classified nuclear power as "sustainable" under its green taxonomy.

7. Global Energy Demand Is Growing

As populations and economies grow, so does the demand for electricity. Developing nations, in particular, are seeking energy solutions that can support industrialization while limiting environmental impact. Nuclear energy is being embraced as a way to meet these dual objectives, especially in regions with limited access to consistent renewable energy resources.

Challenges Ahead

Despite its potential, nuclear energy is not without its challenges. High upfront costs, lengthy construction timelines, and public concerns over safety and waste remain significant hurdles. The industry will need to address these issues while continuing to innovate and build public trust.

Nuclear power's resurgence is driven by its unique ability to tackle some of the most pressing challenges of our time: climate change, energy security, and the growing demand for electricity. With advances in technology, changing perceptions, and robust policy support, nuclear energy is poised to play a critical role in the global transition to a sustainable and secure energy future.

In a world increasingly shaped by the need for clean and reliable power, nuclear energy has once again become a hot topic—and for good reason.

 

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More Polar Vortex 2021 Fallout (and Texas Two-Step): Monitor For ERCOT Identifies Improper Payments For Ancillary Services

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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