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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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New Zealand Energy Transition will electrify transport and industry with renewables, grid-scale solar, wind farms, geothermal, batteries, demand response, pumped hydro, and transmission upgrades to manage dry-year risk and winter peak loads.

Key Points

A shift to renewables and smart demand to decarbonise transport and industry while ensuring reliable, affordable power.

✅ Electrifies transport and industrial heat with renewables

✅ Uses demand response, batteries, and pumped hydro for resilience

✅ Targets 99%+ renewable supply, managing dry-year and peak loads

As fossil fuels are phased out over the coming decades, the Climate Change Commission (CCC) suggests electricity will take up much of the slack, aligning with the vision of a sustainable electric planet powering our vehicle fleet and replacing coal and gas in industrial processes.

But can the electricity system really provide for this increased load where and when it is needed? The answer is “yes”, with some caveats.

Our research examines climate change impacts on the New Zealand energy system. It shows we’ll need to pay close attention to demand as well as supply. And we’ll have to factor in the impacts of climate change when we plan for growth in the energy sector.

Demand for electricity to grow
While electricity use has not increased in NZ in the past decade, many agencies project steeply rising demand in coming years. This is partly due to both increasing population and gross domestic product, but mostly due to the anticipated electrification of transport and industry, which could result in a doubling of demand by mid-century.

It’s hard to get a sense of the scale of the new generation required, but if wind was the sole technology employed to meet demand by 2050, between 10 and 60 new wind farms would be needed nationwide.

Of course, we won’t only build wind farms, as renewables are coming on strong and grid-scale solar, rooftop solar, new geothermal, some new small hydro plant and possibly tidal and wave power will all have a part to play.

Managing the demand
As well as providing more electricity supply, demand management and batteries will also be important. Our modelling shows peak demand (which usually occurs when everyone turns on their heaters and ovens at 6pm in winter) could be up to 40% higher by 2050 than it is now.

But meeting this daily period of high demand could see expensive plant sitting idle for much of the time (with the last 25% of generation capacity only used about 10% of the time).

This is particularly a problem in a renewable electricity system when the hydro lakes are dry, as hydro is one of the few renewable electricity sources that can be stored during the day (as water behind the dam) and used over the evening peak (by generating with that stored water).

Demand response will therefore be needed. For example, this might involve an industrial plant turning off when there is too much load on the electricity grid.

But by 2050, a significant number of households will also need smart appliances and meters that automatically use cheaper electricity at non-peak times. For example, washing machines and electric car chargers could run automatically at 2am, rather than 6pm when demand is high.

Our modelling shows a well set up demand response system could mitigate dry-year risk (when hydro lakes are low on water) in coming decades, where currently gas and coal generation is often used.

Instead of (or as well as) having demand response and battery systems to combat dry-year risk, a pumped storage system could be built. This is where water is pumped uphill when hydro lake inflows are plentiful, and used to generate electricity during dry periods.

The NZ Battery project is currently considering the potential for this in New Zealand, and debates such as whether we would use Site C's electricity offer relevant lessons.

Almost (but not quite) 100% renewable
Dry-year risk would be greatly reduced and there would be “greater greenhouse gas emissions savings” if the Interim Climate Change Committee’s (ICCC) 2019 recommendation to aim for 99% renewable electricity was adopted, rather than aiming for 100%.

A small amount of gas-peaking plant would therefore be retained. The ICCC said going from 99% to 100% renewable electricity by overbuilding would only avoid a very small amount of carbon emissions, at a very high cost.

Our modelling supports this view. The CCC’s draft advice on the issue also makes the point that, although 100% renewable electricity is the “desired end point”, timing is important to enable a smooth transition.

Despite these views, Energy Minister Megan Woods has said the government will be keeping the target of a 100% renewable electricity sector by 2030.

Impacts of climate change
In future, the electricity system will have to respond to changing climate patterns as well, becoming resilient to climate risks over time.

The National Institute of Water and Atmospheric Research predicts winds will increase in the South Island and decrease in the far north in coming decades.

Inflows to the biggest hydro lakes will get wetter (more rain in their headwaters), and their seasonality will change due to changes in the amount of snow in these catchments.

Our modelling shows the electricity system can adapt to those changing conditions. One good news story (unless you’re a skier) is that warmer temperatures will mean less snow storage at lower elevations, and therefore higher lake inflows in the big hydro catchments in winter, leading to a better match between times of high electricity demand and higher inflows.

The price is right
The modelling also shows the cost of generating electricity is not likely to increase, because the price of building new sources of renewable energy continues to fall globally.

Because the cost of building new renewables is now cheaper than non-renewables (such as coal-fired plants), investing in carbon-free electricity is increasingly compelling, and renewables are more likely to be built to meet new demand in the near term.

While New Zealand’s electricity system can enable the rapid decarbonisation of (at least) our transport and industrial heat sectors, international efforts like cleaning up Canada's electricity underline the need for certainty so the electricity industry can start building to meet demand everywhere.

Bipartisan cooperation at government level will be important to encourage significant investment in generation and transmission projects with long lead times and life expectancies, as analyses of climate policy and grid implications underscore in comparable markets.

Infrastructure and markets are needed to support demand response uptake, as well as certainty around the Tiwai exit in 2024 and whether pumped storage is likely to be built.

Our electricity system can support the rapid decarbonisation needed if New Zealand is to do its fair share globally to tackle climate change.

But sound planning, firm decisions and a supportive and relatively stable regulatory framework are all required before shovels can hit the ground.

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Ukraine Electricity Exports resume to the European grid, starting with Moldova and expanding to Poland, Slovakia, and Romania, signaling energy security, grid resilience, added megawatts, and recovery after Russian strikes with support and renewables.

Key Points

Ukraine Electricity Exports are resumed sales of surplus power to EU neighbors, reflecting grid recovery and resilience.

✅ Initial deliveries to Moldova; Poland, Slovakia, Romania to follow.

✅ Extra capacity from repairs, warmer demand, and renewables.

✅ Exports may vary amid ongoing Russian strikes risk.

Ukraine began resuming electricity exports to European countries on Tuesday, its energy minister said, a dramatic turnaround from six months ago when fierce Russian bombardment of power stations plunged much of the country into darkness in a bid to demoralize the population.

The announcement by Energy Minister Herman Halushchenko that Ukraine was not only meeting domestic consumption demands but also ready to restart exports to its neighbors was a clear message that Moscow’s attempt to weaken Ukraine by targeting its infrastructure did not work.

Ukraine’s domestic energy demand is “100%” supplied, he told The Associated Press in an interview, and it has reserves to export due to the “titanic work” of its engineers and international partners.

Russia ramped up infrastructure attacks in September, when waves of missiles and exploding drones destroyed about half of Ukraine’s energy system. Power cuts were common across the country as temperatures dropped below freezing and tens of millions struggled to keep warm.

Moscow said the strikes were aimed at weakening Ukraine’s ability to defend itself, and has also moved to reactivate the Zaporizhzhia plant through new power lines, while Western officials said the blackouts that caused civilians to suffer amounted to war crimes. Ukrainians said the timing was designed to destroy their morale as the war marked its first anniversary.

Ukraine had to stop exporting electricity in October to meet domestic needs.

Engineers worked around the clock, often risking their lives to come into work at power plants and keep the electricity flowing. Kyiv’s allies also provided help. In December, U.S. Secretary of State Antony Blinken announced $53 million in bilateral aid to help the country acquire electricity grid equipment, and USAID mobile gas turbine plant support, on top of $55 million for energy sector support.

Much more work remains to be done, Halushchenko said. Ukraine needs funding to repair damaged generation and transmission lines, and revenue from electricity exports would be one way to do that.

The first country to receive Ukraine’s energy exports will be Moldova, he said.

Besides the heroic work by engineers and Western aid, warmer temperatures are enabling the resumption of exports by making domestic demand lower, even as Germany’s coal generation shapes regional power flows.

Renewables like solar and wind power also come into play as temperatures rise, taking some pressure off nuclear and coal-fired power plants.

But it’s unclear if Ukraine can keep up exports amid the constant threat of Russian bombardment, with any potential agreement on power plant attacks still uncertain.

“Unfortunately now a lot of things depend on the war,” Halushchenko said. “I would say we feel quite confident now until the next winter.”

Exports to Poland, Slovakia and Romania are also on schedule to resume, he said.

“Today we are starting with Moldova, and we are talking about Poland, we are talking about Slovakia and Romania,” Halushchenko added, noting that how much will depend on their needs.

“For Poland, we have only one line that allows us to export 200 megawatts, but I think this month we will finish another line which will increase this to an additional 400 MW, so these figures could change,” he said.

Export revenue will depend on fluctuating electricity prices in Europe, where stunted hydro and nuclear output may affect recovery. In 2022, while Ukraine was still able to export energy, Ukrainian companies averaged 40 million to 70 million euros a month depending on prices, Halushchenko said.
 

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UK Future System Operator to replace National Grid as ESO, enabling smart grid reform, impartial system planning, vehicle-to-grid, long duration storage, and data-driven oversight to meet net zero and cut consumer energy costs.

Key Points

The UK Future System Operator is an independent ESO and planner, steering net zero with impartial data and smart grid coordination.

✅ Replaces National Grid ESO with independent system operator

✅ Enables smart grid, vehicle-to-grid, and long-duration storage

✅ Supports net zero, lower bills, and impartial system planning

The government plans to strip National Grid of its role keeping Great Britain’s lights on as part of a proposed “revolution’” in the electricity network driven by smart digital grid technologies.

The FTSE 100 company has played a role in managing the energy system of England, Scotland and Wales, including efforts such as a subsea power link that brings renewable power from Scotland to England (Northern Ireland has its own network). It is the electricity system operator, balancing supply and demand to ensure the electricity supply. But it will lose its place at the heart of the industry after government officials put forward plans to replace it with an independent “future system operator”.

The new system controller would help steer the country towards its climate targets, at the lowest cost to energy bill payers, by providing impartial data and advice after an overhaul of the rules governing the energy system to make it “fit for the future”.

The plans are part of a string of new proposals to help connect millions of electric cars, smart appliances and other green technologies to the energy system, and to fast-track grid connections nationwide, which government officials believe could help to save £10bn a year by 2050, and create up to 10,000 jobs for electricians, data scientists and engineers.

The new regulations aim to make it easier for electric cars to export electricity from their batteries back on to the power grid or to homes when needed. They could also help large-scale and long-duration batteries play a role in storing renewable energy, supported by infrastructure such as a 2GW substation helping integrate supply, so that it is available when solar and wind power generation levels are low.

Anne-Marie Trevelyan, the energy and climate change minister, said the rules would allow households to “take control of their energy use and save money” while helping to make sure there is clean electricity available “when and where it’s needed”.

She added: “We need to ensure our energy system can cope with the demands of the future. Smart technologies will help us to tackle climate change while making sure that the lights stay on and bills stay low.”

The energy regulator, Ofgem, raised concerns earlier this year that National Grid would face a “conflict of interest” in providing advice on the future electricity system because it also owns energy networks that stand to benefit financially from future investment plans. It called for a new independent operator to take its place.

Jonathan Brearley, Ofgem’s chief executive, said the UK requires a “revolution” in how and when it uses electricity, including demand shifts during self-isolation to help meet its climate targets and added that the government’s plans for a new digital energy system were “essential” to meeting this goal “while keeping energy bills affordable for everyone”.

A National Grid spokesperson said the company would “work closely” with the government and Ofgem on the role of a future system operator, as well as “the most appropriate ownership model and any future related sale”.

The division has earned National Grid, which has addressed cybersecurity fears in supplier choices, an average of £199m a year over the last five years, or 1.3% of the group’s total revenues, which are split between the UK – where it operates high-voltage transmission lines in England and Wales, and the country’s gas system – and its growing energy supply business in the US, aligned with investment in a smarter electricity infrastructure in the US to modernize grids.

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UK Coal-Free Electricity Record highlights rapid growth in renewables as National Grid phases out coal; wind, solar, and offshore projects surge, green tariffs expand, and energy comparison helps consumers switch to cheaper, cleaner deals.

Key Points

Britain's longest coal-free run, enabled by renewables, lower demand, and grid shifts for cheaper, greener tariffs.

✅ Record set after two months without coal-fired generation

✅ Renewables outpace fossil fuels; wind and solar dominate

✅ Green tariffs expand; prices at three-year lows

On Wednesday 10 June, Britain hit a significant landmark: the UK went for two full months without burning coal to generate power – that's the longest period since the 1880s, following earlier milestones such as a full week without coal power in the recent past.

According to the National Grid, Britain has now run its electricity network without burning coal since midnight on the 9 April. This coal-free period has beaten the country’s previous record of 18 days, six hours and 10 minutes, which was set in June 2019, even though low-carbon generation stalled in 2019 according to analyses.

With such a shift in Britain’s drive for renewables and lower electricity demand following the coronavirus lockdown, as Britain recorded its cleanest electricity during lockdown to date, now may be the perfect time to do an online energy comparison and switch to a cheaper, greener deal.

Only a decade ago, around 40 per cent of Britain’s electricity came from coal generation, but since then the country has gradually shifted towards renewable energy, with the coal share at record lows in the system today. When Britain was forced into lockdown in response to the coronavirus pandemic, electricity demand dropped sharply, and the National Grid took the four remaining coal-fired plants off the network.

Over the past 10 years, Britain has invested heavily in renewable energy. Back in 2010, only 3 per cent of the country's electricity came from wind and solar, and many people remained sceptical. However, now, the UK has the biggest offshore wind industry in the world. Plus, last year, construction of the world’s single largest wind farm was completed off the coast of Yorkshire.

At the same time, Drax – Britain’s biggest power plant – has started to switch from burning coal to burning compressed wooden pellets instead, reflecting the UK's progress as it keeps breaking its coal-free energy record again across the grid. By this time next year, the plant hopes to have phased out coal entirely.

So far this year, renewables have generated more power than all fossil fuels put together, the BBC reports, and the energy dashboard shows the current mix in real time. Renewables have been responsible for 37 per cent of electricity supplied to the network, with wind and solar surpassing nuclear for the first time, while fossil fuels have accounted for 35 per cent. During the same period, nuclear accounted for 18 per cent and imports made up the remaining 10 per cent.

What does this mean for consumers?

As the country’s electricity supply moves more towards renewables, customers have more choice than ever before. Most of the ‘Big Six’ energy companies now have tariffs that offer 100 per cent green electricity. On top of this, specialist green energy suppliers such as Bulb, Octopus and Green Energy UK make it easier than ever to find a green energy tariff.

The good news is that our energy comparison research suggests that green energy doesn’t have to cost you more than a traditional fixed-price energy contract would. In fact, some of the cheapest energy suppliers are actually green companies.

At present, energy bills are at three-year lows, which means that now is the perfect time to switch supplier. As prices remain low and renewables begin to dominate the marketplace, more switchers will be drawn to green energy deals than ever before.

However, if you’re interested in choosing a green energy supplier, make sure that you look at the company's fuel mix. This way, you’ll be able to see whether they are guaranteeing the usage of green energy, or whether they’re just offsetting your usage. All suppliers must report how their energy is generated to Ofgem, so you’ll easily be able to compare providers.

You may find that you pay more for a supplier that generates its own energy from renewables, or pay less if the supplier simply matches your usage by buying green energy. You can decide which option is right for you after comparing the prices.

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Duration Portfolio Energy Storage aligns layered peak demand with right-sized batteries, enabling peak shaving, gas peaker replacement, and solar-plus-storage synergy while improving grid flexibility, reliability, and T&D deferral through two- to four-hour battery durations.

Key Points

An approach that layers battery durations to match peaks, cut costs, replace peakers, and boost grid reliability.

✅ Layers 2- to 4-hour batteries by peak duration

✅ Enables solar-plus-storage and peak shaving

✅ Cuts T&D upgrades, emissions, and fuel costs

The debate over energy storage replacing gas-fired peakers has raged for years, but a new approach that shifts the terms of the argument could lead to an acceleration of storage deployments.

Rather than looking at peak demand as a single mountainous peak, some analysts now advocate a layered approach that allows energy storage to better match peak needs and complement ongoing efforts to improve solar and wind power across the grid.

"You don’t have to have batteries that run to infinity."

Some developers of solar-plus-storage projects, bolstered by cheap batteries, say they can already compete head-to-head with gas-fired peakers. "I can beat a gas peaker anywhere in the country today with a solar-plus-storage power plant," Tom Buttgenbach, president and CEO of developer 8minutenergy Renewables, recently told S&P Global.

Customers are very busy these days and rebate programs need to fit the speed of their life. Participation should be quick, easy, and accessible anywhere.

Others disagree. Storage is not disruptive for generation, but will be disruptive for transmission and distribution, Kris Zadlo, executive vice president and chief development officer at Invenergy, told the audience at a Bloomberg New Energy Finance conference last spring. Invenergy, like many renewable power developers, develops generation, energy storage and transmission projects.

But there is another path that avoids the pitfalls of positions on either end of the all-or-none approach. "Do the analysis of the need itself," Ray Hohenstein, market applications director at Fluence, told Utility Dive. If the need is only two hours in duration, it may be best served by a two-hour battery. "You don’t have to have batteries that run to infinity."

Storage vs. fossil fuel peakers

Energy storage has several benefits over traditional fossil fuel peaking plants, Hohenstein said. It is instantaneous, it has no emissions and requires no fuel, and has limited infrastructure needs. It can also help the grid absorb higher levels of renewable generation by soaking up excess output, such as solar power at noon, and many planned storage additions will be paired with solar in the next few years. But the one thing energy storage cannot do, he said, is provide limitless energy.

So, instead of looking at replacing an individual peaker, Hohenstein advocated a "duration portfolio" approach that uses energy storage to shave peak load.

If the need is for 150 MW of resources that will never need to run for more than two hours at a time, then a battery is "quite cheap," significantly less than a four or eight-hour battery, said Hohenstein. "If you fill up your peak by duration layer, it could be more cost effective."

NREL research driver

Fluence’s approach is informed by research by Paul Denholm and Robert Margolis at the National Renewable Energy Laboratory (NREL), released last spring.

The NREL researchers looked at the California market where they said 11 GW of fossil fuel capacity is expected to be retired by 2029 because of new once-through-cooling requirements that are taking effect. A lot of that capacity is peaking capacity and, according to NREL’s analysis, a large fraction could be replaced with four-hour energy storage, assuming continued storage cost reductions and growth in solar installations.

The key in NREL’s research was the level of solar power penetration. There is a "synergistic" relationship between solar penetration and storage deployment, the researchers wrote, and other studies suggest wind and solar could meet 80% of U.S. demand as these trends continue.

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