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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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Manitoba Hydro Integrated Resource Plan outlines electrification-driven demand growth, clean electricity needs, wind generation, energy efficiency, hydropower strengths, and net-zero policy impacts, guiding investments to expand capacity and decarbonize Manitoba's grid.

Key Points

Manitoba Hydro IRP forecasting 2.5x demand, clean power needs, and capacity additions via wind and energy efficiency.

✅ Projects electricity demand could more than double within 20 years.

✅ Leverages 97% hydro supply; adds wind generation and efficiency.

✅ Positions for net-zero, electrification, and new capacity by the 2030s.

Electrical demand in Manitoba could more than double in the next 20 years, a trend echoed by BC Hydro's call for power in response to electrification, according to a new report from Manitoba Hydro.

On Tuesday, the Crown corporation released its first-ever Integrated Resource Plan (IRP), which not only predicts a significant increase in electrical demand, but also that new sources of energy, and a potential need for new power generation, could be needed in the next decade.

“Right now, what [our customers] are telling us, with the climate change objectives, with federal policy, provincial policies, is they see using electricity much more in the future than they do today,” said president and CEO of Manitoba Hydro Jay Grewal.

“And our current, where we’re at now, our customers have told us through all this consultation and engagement over the last two years, they’re going to want and need more than 2.5 times the electricity than we have in the province today.”

The IRP indicates that the move towards low or no-carbon energy sources will accelerate the need for clean electricity, which will require significant investments, including new turbine investments to expand capacity. Some of the clean energy measures Hydro is looking at for the future include wind generation and energy efficiency.

The report also found that Manitoba is in a good position as it prepares for the future due to its hydroelectric system, which delivers around 97 per cent of the yearly electricity. However, the province’s existing supply is limited, and vulnerable to Western Canada drought impacts on hydropower, so other electrical energy sources will be needed.

“Something Manitobans may not realize is, we are in such a privileged province, because 97 per cent of the electricity produced in Manitoba today is clean energy and net zero,” Grewal said.

Manitoba also supplies power to neighbouring utilities, with a SaskPower purchase agreement to buy more electricity under an expanded deal.

The IRP is the result of a two-year development process that involved multiple rounds of engagement with customers and other interested parties. The IRP is not a development plan, but it arrives as Hydro warns it can't service new energy-intensive customers under current capacity, and it outlines how Manitoba Hydro will monitor, prepare and respond to the changes in the energy landscape.

“We spoke with over 15,000 of our customers, whether they’re residential, commercial, industrial, industry associations, regulators, government – across the board, we talked with our customers,” said Grewal.

“And what we did was through this work, we understood what our customers are anticipating using electricity for going forward.

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Hybrid Electric Ships leverage marine batteries, LNG engines, and clean propulsion to cut emissions in shipping. From ferries to cargo vessels, electrification and sustainability meet IMO regulations, Corvus Energy systems, and dockside fast charging.

Key Points

Hybrid electric ships use batteries with diesel or LNG engines to cut fuel and emissions and meet stricter IMO rules.

✅ LNG or diesel gensets recharge marine battery packs.

✅ Cuts CO2, NOx, and particulate emissions in port and at sea.

✅ Complies with IMO standards; enables quiet, efficient operations.

The river is running strong and currents are swirling as the 150-metre-long Seaspan Reliant slides gently into place against its steel loading ramp on the shores of B.C.'s silty Fraser River.

The crew hustles to tie up the ship, and then begins offloading dozens of transport trucks that have been brought over from Vancouver Island.

While it looks like many vessels working the B.C. coast, below decks, the ship is very different. The Reliant is a hybrid, partly powered by electricity, and joins BC Ferries' hybrid ships in the region, the seagoing equivalent of a Toyota Prius.

Down below decks, Sean Puchalski walks past a whirring internal combustion motor that can run on either diesel or natural gas. He opens the door to a gleaming white room full of electrical cables and equipment racks along the walls.

"As with many modes of transportation, we're seeing electrification, from electric planes to ferries," said Puchalski, who works with Corvus Energy, a Richmond, B.C. company that builds large battery systems for the marine industry.

In this case, the batteries are recharged by large engines burning natural gas.

"It's definitely the way of the future," said Puchalski.

The 10-year-old company's battery system is now in use on 200 vessels around the world. Business has spiked recently, driven by the need to reduce emissions, and by landmark projects such as battery-electric high-speed ferries taking shape in the U.S.

"When you're building a new vessel, you want it to last for, say, 30 years. You don't want to adopt a technology that's on the margins in terms of obsolescence," said Puchalski. "You want to build it to be future-proof."

Dirty ships

For years, the shipping industry has been criticized for being slow to clean up its act. Most ships use heavy fuel oil, a cheap, viscous form of petroleum that produces immense exhaust. According to the European Commission, shipping currently pumps out about 940 million tonnes of CO2 each year, nearly three per cent of the global total.

That share is expected to climb even higher as other sectors reduce emissions.

When it comes to electric ships, Scandinavia is leading the world. Several of the region's car and passenger ferries are completely battery powered — recharged at the dock by relatively clean hydro power, and projects such as Kootenay Lake's electric-ready ferry show similar progress in Canada.

Tougher regulations and retailer pressure

The push for cleaner alternatives is being partly driven by worldwide regulations, with international shipping regulators bringing in tougher emission standards after a decade of talk and study, while financing initiatives are helping B.C. electric ferries scale up.

At the same time, pressure is building from customers, such as Mountain Equipment Co-op, which closely tracks its environmental footprint. Kevin Lee, who heads MEC's supply chain, said large companies are realizing they are accountable for their contributions to climate change, from the factory to the retail floor.

"You're hearing more companies build it into their DNA in terms of how they do business, and that's cool to see," said Lee. "It's not just MEC anymore trying to do this, there's a lot more partners out there."

In the global race to cut emissions, all kinds of options are on the table for ships, including giant kites being tested to harvest wind power at sea, and ports piloting hydrogen-powered cranes to cut dockside emissions.

Modern versions of sailing ships are also being examined to haul cargo with minimal fuel consumption.

But in practical terms, hybrids and, in the future, pure electrics are likely to play a larger role in keeping the propellers turning along Canada's coast, with neighboring fleets like Washington State Ferries' upgrade underscoring the shift.

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Ontario Nuclear Expansion aims to meet rising electricity demand and decarbonization goals, complementing renewables with energy storage, hydroelectric, and SMRs, while reducing natural gas reliance and safeguarding grid reliability across the province.

Key Points

A plan to add large nuclear capacity to meet demand, support renewables, cut gas reliance, and maintain grid reliability

✅ Adds firm, low-carbon baseload to complement renewables

✅ Reduces reliance on natural gas during peak and outages

✅ Requires public and Indigenous engagement on siting

Ontario is exploring the possibility of building new, large-scale nuclear plants in order to meet increasing demand for electricity and phase out natural gas generation.

A report late last year by the Independent Electricity System Operator found that the province could fully eliminate natural gas from the electricity system by 2050, starting with a moratorium in 2027, but it will require about $400 billion in capital spending and more generation including new, large-scale nuclear plants.

Decarbonizing the grid, in addition to new nuclear, will require more conservation efforts, more renewable energy sources and more wind and solar power sources and more energy storage, the report concluded.

The IESO said work should start now to assess the reliability of new and relatively untested technologies and fuels to replace natural gas, and to set up large, new generation sources such as nuclear plants and hydroelectric facilities.

The province has not committed to a natural gas moratorium or phase-out, or to building new nuclear facilities other than its small modular reactor plans, but it is now consulting on the prospect.

A document recently posted to the government’s environmental registry asks for input on how best to engage the public and Indigenous communities on the planning and location of new generation and storage facilities.

Building new nuclear plants is “one pathway” toward a fully electrified system, Energy Minister Todd Smith said in an interview.

“It’s a possibility, for sure, and that’s why we’re looking for the feedback from Ontarians,” he said. “We’re considering all of the next steps.”

Environmental groups such as Environmental Defence oppose new nuclear builds, as well as the continued reliance on natural gas.

“The IESO’s report is peddling the continued use of natural gas under the guise of a decarbonization plan, and it takes as a given the ramping up of gas generation and continues to rely on gas generated electricity until 2050, which is embarrassingly late,” said Lana Goldberg, Environmental Defence’s Ontario climate program manager.

“Building new nuclear is absurd when we have safe and much cheaper alternatives such as wind and solar power.”

The IESO has said the flexibility natural gas provides, alongside new gas plants, is needed to keep the system stable while new and relatively untested technologies are explored and new infrastructure gets built, but also as an electricity supply crunch looms.

Ontario is facing a shortfall of electricity with the Pickering nuclear station set to be retired, others being refurbished, and increasing demands including from electric vehicles, new electric vehicle and battery manufacturing, electric arc furnaces for steelmaking, and growth in the greenhouse and mining industries.

The government consultation also asks whether “additional investment” should be made in clean energy in the short term in order to decrease reliance on natural gas, “even if this will increase costs to the electricity system and ratepayers.”

But Smith indicated the government isn’t keen on higher costs.

“We’re not going to sacrifice reliability and affordability,” he said. “We have to have a reliable and affordable system, otherwise we won’t have people moving to electrification.”

The former Liberal government faced widespread anger over high hydro bills _ highlighted often by the Progressive Conservatives, then in Opposition — driven up in part by long-term contracts at above-market rates with clean power producers secured to spur a green energy transition.

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Germany Hydrogen-Ready Power Plants Tender accelerates the energy transition by enabling clean energy generation, decarbonization, and green hydrogen integration through retrofit and new-build capacity, resilient infrastructure, flexible storage, and grid reliability provisions.

Key Points

Germany tender to build or convert plants for hydrogen, advancing decarbonization, energy security, and clean power.

✅ Hydrogen-ready retrofits and new-build generation capacity

✅ Supports decarbonization, grid reliability, and flexible storage

✅ Future-proof design for green hydrogen supply integration

Germany, a global leader in energy transition and environmental sustainability, has recently launched an ambitious call for tenders aimed at developing hydrogen-ready power plants. This initiative is a significant step in the country's strategy to transform its energy infrastructure and support the broader goal of a greener economy. The move underscores Germany’s commitment to reducing greenhouse gas emissions and advancing clean energy technologies.

The Need for Hydrogen-Ready Power Plants

Hydrogen, often hailed as a key player in the future of clean energy, offers a promising solution for decarbonizing various sectors, including power generation. Unlike fossil fuels, hydrogen produces zero carbon emissions when used in fuel cells or burned. This makes it an ideal candidate for replacing conventional energy sources that contribute to climate change.

Germany’s push for hydrogen-ready power plants reflects the country’s recognition of hydrogen’s potential in achieving its climate goals. Traditional power plants, which typically rely on coal, natural gas, or oil, emit substantial amounts of CO2. Transitioning these plants to utilize hydrogen can significantly reduce their carbon footprint and align with Germany's climate targets.

The Details of the Tender

The recent tender call is part of Germany's broader strategy to incorporate hydrogen into its energy mix, amid a nuclear option debate in climate policy. The tender seeks proposals for power plants that can either be converted to use hydrogen or be built with hydrogen capability from the outset. This approach allows for flexibility and innovation in how hydrogen technology is integrated into existing and new energy infrastructures.

One of the critical aspects of this initiative is the focus on “hydrogen readiness.” This means that power plants must be designed or retrofitted to operate with hydrogen either exclusively or in combination with other fuels. The goal is to ensure that these facilities can adapt to the growing availability of hydrogen and seamlessly transition from conventional fuels without significant additional modifications.

By setting such requirements, Germany aims to stimulate the development of technologies that can handle hydrogen’s unique properties and ensure that the infrastructure is future-proofed. This includes addressing challenges related to hydrogen storage, transportation, and combustion, and exploring concepts like storing electricity in natural gas pipes for system flexibility.

Strategic Implications for Germany

Germany’s call for hydrogen-ready power plants has several strategic implications. First and foremost, it aligns with the country’s broader energy strategy, which emphasizes the need for a transition from fossil fuels to cleaner alternatives, building on its decision to phase out coal and nuclear domestically. As part of its commitment to the Paris Agreement and its own climate action plans, Germany has set ambitious targets for reducing greenhouse gas emissions and increasing the share of renewable energy in its energy mix.

Hydrogen plays a crucial role in this strategy, particularly for sectors where direct electrification is challenging. For instance, heavy industry and certain industrial processes, such as green steel production, require high-temperature heat that is difficult to achieve with electricity alone. Hydrogen can fill this gap, providing a cleaner alternative to natural gas and coal.

Moreover, this initiative helps Germany bolster its leadership in green technology and innovation. By investing in hydrogen infrastructure, Germany positions itself as a pioneer in the global energy transition, potentially influencing international standards and practices. The development of hydrogen-ready power plants also opens up new economic opportunities, including job creation in engineering, construction, and technology sectors.

Challenges and Opportunities

While the push for hydrogen-ready power plants presents significant opportunities, it also comes with challenges. Hydrogen production, especially green hydrogen produced from renewable sources, remains relatively expensive compared to conventional fuels. Scaling up production and reducing costs are critical for making hydrogen a viable alternative for widespread use.

Furthermore, integrating hydrogen into existing power infrastructure, alongside electricity grid expansion, requires careful planning and investment. Issues such as retrofitting existing plants, ensuring safe handling of hydrogen, and developing efficient storage and transportation systems must be addressed.

Despite these challenges, the long-term benefits of hydrogen integration are substantial, and a net-zero roadmap indicates electricity costs could fall by a third. Hydrogen can enhance energy security, reduce reliance on imported fossil fuels, and support global climate goals. For Germany, this initiative is a step towards realizing its vision of a sustainable, low-carbon energy system.

Conclusion

Germany’s call for hydrogen-ready power plants is a forward-thinking move that reflects its commitment to sustainability and innovation. By encouraging the development of infrastructure capable of using hydrogen, Germany is taking a significant step towards a cleaner energy future. While challenges remain, the strategic focus on hydrogen underscores Germany’s leadership in the global transition to a low-carbon economy. As the world grapples with the urgent need to address climate change, Germany’s approach serves as a model for integrating emerging technologies into national energy strategies.

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Houston Power Outage Heatwave intensifies a prolonged blackout, straining the grid and infrastructure resilience; emergency response, cooling centers, and power restoration efforts race to protect vulnerable residents amid extreme temperatures and climate risks.

Key Points

A multi-day blackout and heatwave straining Houston's grid, limiting cooling, and prompting emergency response.

✅ Fourth day without power amid dangerous heat

✅ Grid failures expose infrastructure vulnerabilities

✅ Cooling centers, aid groups support vulnerable residents

Houston is enduring significant frustration and hardship as a power outage stretches into its fourth day amid a sweltering heatwave. The extended blackout has exacerbated the challenges faced by residents in one of the nation’s largest and most dynamic cities, underscoring the critical need for reliable infrastructure and effective emergency response systems.

The power outage began early in the week, coinciding with a severe heatwave that has driven temperatures to dangerous levels. With the city experiencing some of the highest temperatures of the year, the lack of electricity has left residents without essential cooling, contributing to widespread discomfort and health risks. The heatwave has placed an added strain on Houston's already overburdened power grid, which has struggled to cope with the soaring demand for air conditioning and cooling.

The prolonged outage has led to escalating frustration among residents. Many households are grappling with sweltering indoor temperatures, leading to uncomfortable living conditions and concerns about the impact on vulnerable populations, including the elderly, young children, and individuals with pre-existing health conditions. The lack of power has also disrupted daily routines, as morning routine disruptions in London demonstrate, including access to refrigeration for food, which has led to spoilage and further complications.

Emergency services and utility companies have been working around the clock to restore power, but progress has been slow, echoing how Texas utilities struggled to restore power during Hurricane Harvey, as crews contended with access constraints. The complexity of the situation, combined with the high demand for repairs and the challenging weather conditions, has made it difficult to address the widespread outages efficiently. As the days pass, the situation has become increasingly dire, with residents growing more impatient and anxious about when they might see a resolution.

Local officials and utility providers have been actively communicating with the public, providing updates on the status of repairs and efforts to restore power. However, the communication has not always been timely or clear, leading to further frustration among those affected. The sense of uncertainty and lack of reliable information has compounded the difficulties faced by residents, who are left to manage the impacts of the outage with limited guidance.

The situation has also raised questions about the resilience of Houston’s power infrastructure. The outage has highlighted vulnerabilities in the city's energy grid, similar to how a recent windstorm caused significant outages elsewhere, which has faced previous challenges but has not experienced an extended failure of this magnitude in recent years. The inability of the grid to withstand the extreme heat and maintain service during a critical time underscores the need for infrastructure improvements and upgrades to better handle similar situations in the future.

In response to the crisis, community organizations and local businesses have stepped up to provide support to those in need, much like Toronto's cleanup after severe flooding mobilized volunteers and services, in order to aid affected residents. Cooling centers have been established to offer relief from the heat, providing a respite for individuals who are struggling to stay cool at home. Additionally, local food banks and charitable organizations are distributing essential supplies to those affected by food spoilage and other challenges caused by the power outage.

The power outage and heatwave have also sparked broader discussions about climate resilience and preparedness. Extreme weather events and prolonged heatwaves are becoming increasingly common due to climate change, as strong winds knocked out power across the Miami Valley recently, raising concerns about how cities and infrastructure systems can adapt to these new realities. The current situation in Houston serves as a stark reminder of the importance of investing in resilient infrastructure and developing comprehensive emergency response plans to mitigate the impacts of such events.

As the outage continues, there is a growing call for improved strategies to manage power grid failures, with examples like the North Seattle outage affecting 13,000 underscoring the need, and better support for residents during crises. Advocates are urging for a reevaluation of emergency response protocols, increased investment in infrastructure upgrades, and enhanced communication systems to ensure that the public receives timely and accurate information during emergencies.

In summary, Houston's power outage, now extending into its fourth day amid extreme heat, has caused significant frustration and hardship for residents. The prolonged disruption has underscored the need for more resilient energy infrastructure, as seen when power outages persisted for hundreds in Toronto, and effective emergency response measures. With temperatures soaring and the situation continuing to unfold, the city faces a critical challenge in restoring power, managing the impacts on its residents, and preparing for future emergencies. The crisis highlights broader issues related to infrastructure resilience and climate adaptation, emphasizing the need for comprehensive strategies to address and mitigate the effects of extreme weather events.

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