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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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Cape Town Renewable Energy Plan targets 450+ MW via solar, wind, and battery storage, cutting Eskom reliance, lowering greenhouse gas emissions, stabilizing electricity prices, and boosting grid resilience through municipal procurement, PPAs, and city-owned plants.

Key Points

A municipal plan to procure over 450 MW, cut Eskom reliance, stabilize prices, and reduce Cape Town emissions.

✅ Up to 150 MW from private plants within the city

✅ 300 MW to be purchased from outside Cape Town later

✅ City financing 100-200 MW of its own generation

Cape Town is seeking to secure more than 450 megawatts of power from renewable sources to cut reliance on state power utility Eskom Holdings SOC Ltd., where wind procurement cuts were considered during lockdown, and reduce greenhouse gas emissions.

South Africa’s second-biggest city is looking at a range of options, including geothermal exploration in comparable markets, and expects the bulk of the electricity to be generated from solar plants, Kadri Nassiep, the city’s executive director of energy and climate change, said in an interview.

On July 14 the city of 4.6 million people released a request for information to seek funding to build its own plants. This month or next it will seek proposals for the provision of as much as 150 megawatts from privately owned plants, largely solar additions, to be built and operated within the city, he said. As much as 300 megawatts may also be purchased at a later stage from plants outside of Cape Town, according to Nassiep.

The city could secure finance to build 100 to 200 megawatts of its own generation capacity, Nassiep said. “We realized that it is important for the city to be more in control around the pricing of the power,” he added.

Power Outages

Cape Town’s foray into the securing of power from sources other than Eskom comes after more than a decade of intermittent electricity outages, while elsewhere in Africa coal projects face scrutiny from lenders, because the utility can’t meet national demand. The government last year said municipalities could find alternative suppliers.

Earlier this month Ethekwini, the municipal area that includes the city of Durban, issued a request for information for the provision of 400 megawatts of power, similar to BC Hydro’s call for power driven by EV uptake.

The City of Johannesburg will in September seek information and proposals for the construction of a 150-megawatt solar plant, reflecting moves like Ontario’s new wind and solar procurements to tackle supply gaps, 50 megawatts of rooftop solar panels and the refurbishment of an idle gas-fired plant that could generate 20 megawatts, it said in June. It will also seek information for the installation of 100 megawatts of battery storage.

Cape Town, which uses a peak of 1,800 megawatts of electricity in winter, hopes to start generating some of its own power next year, aligning with SaskPower’s 2030 renewables plan seen in Canada, according to a statement that accompanied its request for financing proposals.
 

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Energy Transition Grid Reforms address transmission capacity, interconnection, congestion management, and flexibility markets, enabling renewable integration and grid stability while optimizing network charges and access in Australia, Ireland, and Great Britain.

Key Points

Measures to expand transmission, boost flexibility, and manage congestion for reliable, low-carbon electricity systems.

✅ Transmission upgrades and interconnectors ease congestion

✅ Flexible markets, DER, and storage bolster grid stability

✅ Evolving network charges and access incentivize siting

Electricity networks globally are experiencing significant increases in the volume of renewable capacity as countries seek to decarbonise their power sectors, even as clean energy's 'dirty secret' highlights integration trade-offs, without impacting the security of supply. The scale of this change is creating new challenges for power networks and those responsible for keeping the lights on.

The latest insight paper from Cornwall Insight – Market design amidst global energy transition – looks into this issue. It examines the outlook for transmission networks, and how legacy design and policies are supporting decarbonisation, aligning with IRENA findings on renewables and shaping the system. The paper focuses on three key markets; Australia, Ireland and Great Britain (GB).

Australia's main priority is to enhance transmission capacity and network efficiency; as concerns over excess solar risking blackouts grow in distribution networks, without this, the transmission system will be a barrier to growth for decentralised flexibility and renewables. In contrast, GB and Ireland benefit from interconnection with other national markets. This provides them with additional levers that can be pulled to manage system security and supply. However, they are still trying to hone and optimise network flexibility in light of steepening decarbonisation objectives.

Unsurprisingly, renewable energy resources have been growing in all three markets, with Ireland regarded as a leader in grid integration, with this expected to continue for the foreseeable future. Many of these projects are often located in places where network infrastructure is not as well developed, creating pressure on system operation as a result.

In all three markets, unit charges are rising, driven by a reduced charging base as decentralised energy grows quickly. This combination of changes is leading to network congestion, a challenge mirrored by the US grid overhaul for renewables underway, as transmission network development struggles to keep up, and flexibility markets are being optimised and changed.

In summary, reforms are on-going in each jurisdiction to accommodate the rapid physical transformation of the generation mix. Each has its objectives and tensions which are reflective of wider global reform programmes being undertaken in most developed, liberalised and decarbonising energy markets.

Gareth Miller, CEO of Cornwall Insight, said: “Despite differences in market design and characteristics, all three markets are grappling with similar issues, that comes from committing to deep decarbonisation. This includes the most appropriate methods for charging for networks, managing access to them and dealing with issues such as network congestion and constraint.

“In all three countries, renewable projects are often placed in isolated locations, as seen in Scotland where more pylons are needed to keep the lights on, away from the traditional infrastructure that is closer to demand. However, as renewable growth is set to continue, the networks will need to transition from being demand-centric to more supply orientated.

“Both system operators and stakeholders will need to continually evaluate their market structures and designs to alleviate issues surrounding locational congestion and grid stability. Each market is at very different stages in the process in trying to improve any problems implementing solutions to allow for higher efficiencies in renewable energy integration.

“It is uncertain whether any of the proposed changes will fundamentally resolve the issues that come with increased renewables on the system. However, despite marked differences, they certainly could all learn from each other and elements of their network arrangements, as well as from US decarbonisation strategies research.”

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Hydro-Quebec back-billing arises from analogue meter errors and estimated consumption, leading to arrears for electricity usage; disputes over access, payment plans, and potential power diversion reviews can impact cottage owners near Gatineau.

Key Points

Hydro-Quebec back-billing recovers underbilled electricity from analogue meter errors or prolonged estimated use.

✅ Triggered by inaccurate analogue meters or missed readings

✅ Based on actual usage versus prior estimated consumption

✅ Payment plans may spread arrears; theft checks may adjust

A relaxing lakefront cottage has become a powerful source of stress for an Ottawa woman who Hydro-Quebec is charging $5,300 to cover what it says are years of undercharging for electricity usage.

The utility said an old analogue power meter is to blame for years of inaccurate electricity bills for the summer getaway near Gatineau, Que.

Separate from individual billing issues, Hydro-Quebec has also reported pandemic-related losses earlier this year.

Owner Jan Hodgins does not think she should be held responsible for the mistake, nor does she understand how her usage could have surged over the years.

“I’m very hydro conscious, because I was raised that way. When you left a room, you always turned the light out,” she told CTV Montreal on Wednesday, relating her shock after receiving some hefty bills from Hydro-Quebec on Sept. 22.

Hodgins said she mainly uses the cottage on weekends, does not heat the place when she is not there, and does not use a washer or dryer, to keep her energy footprint as small as possible. She’s owned the cottage for 14 years, during which she says her monthly bill has hovered around $40.

Hydro-Quebec said it has not had an accurate reading of her usage for several years, relying instead on consumption estimates to determine what she pays. The company recently reviewed her energy consumption back to 2014, and found their estimates were not accurate.

“In the past, she was consuming about 10 to 15 kilowatt hours per day. This summer she was more around 40 kilowatt hours per day,” Marc-Antoine Pouliot with Hydro-Quebec told CTV Ottawa.

Hodgins said that means her regular bill will now be more than twice the $200 her neighbours are paying for hydro each month, even with peak hydro rates in place.

Hydro-Quebec said it will correct the bill if its technicians discover that someone is illegally diverting power nearby.

Hodgins said it’s not her fault that technicians did not check her meter in person, and chose to rely on inaccurate estimates. Pouliot argues that reaching her cottage was too difficult.

“There was too much snow. There were conditions during the winter disconnection ban period, and the consequence was that people, our workers, were not able to reach the meter,” he said.

Hydro-Quebec said it is willing to stretch out the debt into monthly payments over a year, which Hodgins said amount to $440 per month on top of her regular bill.

Utilities also caution customers about scammers threatening shutoffs during billing disputes.

“I’m on a fixed income. I don’t have that kind of money. I’m completely distraught,” she said. “I don’t know what I’m going to do.”

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Carbon Price Support, the UK carbon tax on power, slashed coal generation, cut CO2 emissions, boosted gas and imports via interconnectors, and signaled effective electricity market decarbonization across Great Britain and the EU.

Key Points

A UK power-sector carbon tax that drove coal off the grid, cut emissions, and shifted generation toward gas and imports.

✅ Coal generation fell from 40% to 3% in six years

✅ Rate rose to £18/tCO2 in 2015, boosting the coal-to-gas switch

✅ Added ~£39 to 2018 bills; imports via interconnectors eased prices

A tax on carbon dioxide emissions in Great Britain, introduced in 2013, has led to the proportion of electricity generated from coal falling from 40% to 3% over six years, a trend mirrored by global coal decline in power generation, according to research led by UCL.

British electricity generated from coal fell from 13.1 TWh (terawatt hours) in 2013 to 0.97 TWh in September 2019, and was replaced by other less emission-heavy forms of generation such as gas, as producers move away from coal in many markets. The decline in coal generation accelerated substantially after the tax was increased in 2015.

In the report, 'The Value of International Electricity Trading', researchers from UCL and the University of Cambridge also showed that the tax—called Carbon Price Support—added on average £39 to British household electricity bills, within the broader context of UK net zero policies shaping the energy transition, collecting around £740m for the Treasury, in 2018.

Academics researched how the tax affected electricity flows to connected countries and interconnector (the large cables connecting the countries) revenue between 2015—when the tax was increased to £18 per tonne of carbon dioxide—and 2018. Following this increase, the share of coal-fired electricity generation fell from 28% in 2015 to 5% in 2018, reaching 3% by September 2019. Increased electricity imports from the continent, alongside the EU electricity demand outlook across member states, reduced the price impact in the UK, and meant that some of the cost was paid through a slight increase in continental electricity prices (mainly in France and the Netherlands).

Project lead Dr. Giorgio Castagneto Gissey (Bartlett Institute for Sustainable Resources, UCL) said: "Should EU countries also adopt a high carbon tax we would likely see huge carbon emission reductions throughout the Continent, as we've seen in Great Britain over the last few years."

Lead author, Professor David Newbery (University of Cambridge), said: "The Carbon Price Support provides a clear signal to our neighbours of its efficacy at reducing CO2 emissions."

The Carbon Price Support was introduced in England, Scotland and Wales at a rate of £4.94 per tonne of carbon dioxide-equivalent and is now capped at £18 until 2021.The tax is one part of the Total Carbon Price, which also includes the price of EU Emissions Trading System permits and reflects global CO2 emissions trends shaping policy design.

Report co-author Bowei Guo (University of Cambridge) said: "The Carbon Price Support has been instrumental in driving coal off the grid, but we show how it also creates distortions to cross-border trade, making a case for EU-wide adoption."

Professor Michael Grubb (Bartlett Institute for Sustainable Resources, UCL) said: "Great Britain's electricity transition is a monumental achievement of global interest, and has also demonstrated the power of an effective carbon price in lowering dependence on electricity generated from coal."

The overall report on electricity trading also covers the value of EU interconnectors to Great Britain, measures the efficiency of cross-border electricity trading and considers the value of post-Brexit decoupling from EU electricity markets, setting these findings against the global energy transition underway.

Published today, the report annex focusing on the Carbon Price Support was produced by UCL to focus on the impact of the tax on British energy bills, with comparisons to Canadian climate policy debates informing grid impacts.

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

Key Points

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

✅ Cuts reserve margins via diversity of peak loads

✅ Enables wind and solar balancing across provinces

✅ Saves ratepayers vs replacing retiring thermal plants

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

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

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

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

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

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

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

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

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

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

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