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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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ABO Wind Tunisia 10MW Solar Project will build a photovoltaic park in Gabes with a STEG PPA, fixed tariff, 2,500 m grid connection, producing 18 million kWh annually, targeted for 2020 commissioning with local partners.

Key Points

A 10MW photovoltaic park in Gabes with a 20-year STEG PPA and fixed tariff, slated for 2020 commissioning.

✅ 18 million kWh/year; 2,500 m grid tie, 20-year fixed tariff

✅ Electricity supplied to STEG under PPA; 2020 commissioning

✅ Located in Gabes; built with local partners, 10MW capacity

ABO Wind has received a permit and a tariff for a 10MW photovoltaic project in Tunisia, amid global activity such as Spain's 90MW wind project now underway, which it plans to build and commission in 2020.

The solar park, in the governorate of Gabes, is 400km south of the country’s capital Tunis and aligns with renewable funding initiatives seen across developing markets.

The developer said it plans to build the project next year in close cooperation with local partners, as regional markets from North Africa to the Gulf expand, with Saudi Arabia boosting wind capacity as well.

ABO Wind department head Nicolas Konig said: “The solar park will produce more than 18 million kilowatt hours of electricity per year and will feed it into the grid at a distance of 2500 metres.”

The developer will conclude an electricity supply contract with the state-owned energy supplier (Societe tunisienne de l’electricite et du gaz (STEG), which will provide a fixed remuneration over 20 years, a model echoed by Germany's wind-solar tender for the electricity fed into the grid.

Earlier this year, ABO Wind had already secured a tariff for a wind farm with a capacity of 30MW in a tender, 35km south-east of Tunis, underscoring Tunisia's wind investments under its long-term plan.

The company is working on half a dozen Tunisian wind and solar projects, as institutions like the World Bank support wind growth in developing countries.

“We are making good progress on our way to assemble a portfolio of several ready-to-build wind and solar projects attractive to investors, as Saudi clean energy targets continue to expand globally,” said ABO Wind general manager responsible for international business development Patrik Fischer.

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H2 Gateway Hydrogen Network accelerates clean energy in B.C., building electrolysis plants and hydrogen fueling stations for zero-emission vehicles, heavy-duty trucks, and long-haul transit, supporting decarbonization, green hydrogen supply, and infrastructure investment.

Key Points

A $900M B.C. initiative by HTEC to build electrolysis plants and 20 hydrogen fueling stations for zero-emission transport.

✅ $900M project with HTEC, CIB, and B.C. government

✅ 3 electrolysis plants plus byproduct liquefaction in North Vancouver

✅ Up to 20 stations; 14 for heavy-duty vehicles in B.C. and Alberta

British Columbia is taking a significant step towards a cleaner future with a brand new $900 million project. This initiative, spearheaded by hydrogen company HTEC and supported by the CIB in B.C. and the B.C. government, aims to establish a comprehensive hydrogen network across the province. This network will encompass both hydrogen production plants and fueling stations, marking a major leap in developing hydrogen infrastructure in B.C.

The project, dubbed "H2 Gateway," boasts several key components. At its core lies the construction of three brand new electrolysis hydrogen production plants. These facilities will be strategically located in Burnaby, Nanaimo, and Prince George, ensuring a wide distribution of hydrogen fuel. An additional facility in North Vancouver will focus on liquefying byproduct hydrogen, maximizing resource efficiency.

The most visible aspect of H2 Gateway will undoubtedly be the network of hydrogen fueling stations. The project envisions up to 20 stations spread across British Columbia and Alberta, complementing the province's Electric Highway build-out, with 18 being situated within B.C. itself. This extensive network will significantly enhance the accessibility of hydrogen fuel, making it a more viable option for motorists. Notably, 14 of these stations will be designed to handle heavy-duty vehicles, catering to the transportation sector's clean energy needs.

The economic and environmental benefits of H2 Gateway are undeniable. The project is expected to generate nearly 300 jobs, aligning with recent grid job creation efforts, providing a much-needed boost to the B.C. economy. More importantly, the widespread adoption of hydrogen fuel promises significant reductions in greenhouse gas emissions. Hydrogen-powered vehicles produce zero tailpipe emissions, making them a crucial tool in combating climate change.

British Columbia's investment in hydrogen infrastructure aligns with a global trend. As countries strive to achieve ambitious climate goals, hydrogen is increasingly viewed as a promising clean energy source. Hydrogen fuel cells offer several advantages over traditional electric vehicles, and while B.C. leads the country in going electric, they boast longer driving ranges and shorter refueling times, making them particularly attractive for long-distance travel and heavy-duty applications.

While H2 Gateway represents a significant step forward, challenges remain. The production of clean hydrogen, often achieved through electrolysis using renewable energy sources, faces power supply challenges and requires substantial initial investment. Additionally, the number of hydrogen-powered vehicles on the road is still relatively low.

However, projects like H2 Gateway are crucial in overcoming these hurdles. By creating a robust hydrogen infrastructure, B.C. is sending a strong signal to the industry and, alongside BC Hydro's EV charging expansion across southern B.C., is building a comprehensive clean transportation network. This investment will not only benefit the environment but also incentivize the development and adoption of hydrogen-powered vehicles. As the technology matures and production costs decrease, hydrogen fuel has the potential to revolutionize transportation and play a key role in a sustainable future.

The road ahead for hydrogen may not be entirely smooth, but British Columbia's commitment to H2 Gateway demonstrates a clear vision. By investing in clean energy infrastructure, the province is not only positioning itself as a leader in the fight against climate change, with Canada and B.C. investing in green energy solutions to accelerate progress, but also paving the way for a more sustainable transportation landscape.

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SECCRA Waga Energy RNG Partnership captures landfill methane with WAGABOX, upgrades biogas to pipeline-quality RNG, enables grid injection, and lowers greenhouse gas emissions, delivering sustainable energy to Chester County homes and businesses.

Key Points

A joint project converting landfill methane to RNG with WAGABOX, cutting emissions and supplying local heat.

✅ WAGABOX captures and purifies landfill gas to RNG

✅ Grid injection supplies energy for 4,000+ homes

✅ Cuts methane and greenhouse gas emissions significantly

In a significant environmental initiative, the Southeastern Chester County Refuse Authority (SECCRA) has partnered with French energy company Waga Energy to convert methane emissions from its landfill into renewable natural gas (RNG). This collaboration aims to reduce greenhouse gas emissions and provide sustainable energy to the local community, echoing energy efficiency projects in Quebec seen elsewhere.

Understanding the Issue

Landfills are a substantial source of methane emissions, accounting for over 14% of human-induced methane emissions, according to the U.S. Environmental Protection Agency. Methane is a potent greenhouse gas, and issues like SF6 in power equipment further boost warming, trapping more heat in the atmosphere than carbon dioxide, making its reduction crucial in the fight against climate change.

The SECCRA-Waga Energy Partnership

SECCRA, serving approximately 105,000 residents in Chester County, processes between 450 to 500 tons of waste daily. To mitigate methane emissions from its landfill, SECCRA has partnered with Waga Energy to install a WAGABOX unit—a technology designed to capture and convert landfill methane into RNG, while related efforts like electrified LNG in B.C. illustrate sector-wide decarbonization.

How the WAGABOX Technology Works

The WAGABOX system utilizes a proprietary process to extract methane from landfill gas, purify it, and inject it into the natural gas grid. This process not only reduces harmful emissions, as emerging carbon dioxide electricity generation concepts also aim to do, but also produces a renewable energy source that can be used to heat homes and power businesses.

Environmental and Community Benefits

By converting methane into RNG, the project significantly lowers greenhouse gas emissions, supported by DOE funding for carbon capture initiatives, contributing to climate change mitigation. Additionally, the RNG produced is expected to supply energy to heat over 4,000 homes, providing a sustainable energy source for the local community.

Broader Implications

This initiative aligns with international clean energy cooperation to reduce methane emissions from landfills. Similar projects have been implemented worldwide, demonstrating the effectiveness of converting landfill methane into renewable energy. For instance, Waga Energy has successfully deployed WAGABOX units at various landfills, showcasing the scalability and impact of this technology.

The collaboration between SECCRA and Waga Energy represents a proactive step toward environmental sustainability and energy innovation. By transforming landfill methane into renewable natural gas, the project not only addresses a significant source of greenhouse gas emissions as new EPA power plant rules on carbon capture advance parallel strategies, but also provides a clean energy alternative for the Chester County community.

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North American Grid Reliability faces extreme weather, climate change, demand spikes, and renewable variability; utilities, AESO, and NERC stress resilience, dispatchable capacity, interconnections, and grid alerts to prevent blackouts during heatwaves and cold snaps.

Key Points

North American grid reliability is the ability to meet demand during extreme weather while maintaining stability.

✅ Extreme heat and cold drive record demand and resource strain.

✅ Balance dispatchable and intermittent generation for resilience.

✅ Expand interconnections, capacity, and demand response to avert outages.

The recent alerts in Alberta's electricity grid during extreme cold have highlighted a broader North American issue, where power systems are more susceptible to being overwhelmed by extreme weather impacts on reliability.

Electricity Canada's chief executive emphasized that no part of the grid is safe from the escalating intensity and frequency of weather extremes linked to climate change across the sector.

“In recent years, during these extreme weather events, we’ve observed record highs in electricity demand,” he stated.

“It’s a nationwide phenomenon. For instance, last summer in Ontario and last winter in Quebec, we experienced unprecedented demand levels. This pattern of extremes is becoming more pronounced across the country.”

The U.S. has also experienced strain on its electricity grids due to extreme weather, with more blackouts than peers documented in studies. Texas faced power outages in 2021 due to winter storms, and California has had to issue several emergency grid alerts during heat waves.

In Canada, Albertans received a government emergency alert two weeks ago, urging an immediate reduction in electricity use to prevent potential rotating blackouts as temperatures neared -40°C. No blackouts occurred, with a notable decrease in electricity use following the alert, according to the Alberta Electric System Operator (AESO).

AESO's data indicates an increase in grid alerts in Alberta for both heatwaves and cold spells, reflecting dangerous vulnerabilities noted nationwide. The period between 2017 and 2020 saw only four alerts, in contrast to 17 since 2021.

Alberta's electricity grid reliability has sparked political debate, including proposals for a western Canadian grid to improve reliability, particularly with the transition from coal-fired plants to increased reliance on intermittent wind and solar power. Despite this debate, the AESO noted that the crisis eased when wind and solar generation resumed, despite challenges with two idled gas plants.

Bradley pointed out that Alberta's grid issues are not isolated. Every Canadian region is experiencing growing electricity demand, partly due to the surge in electric vehicles and clean energy technologies. No province has a complete solution yet.

“Ontario has had to request reduced consumption during heatwaves,” he noted. “Similar concerns about energy mix are present in British Columbia or Manitoba, especially now with drought affecting their hydro-dependent systems.”

The North American Electric Reliability Corporation (NERC) released a report in November warning of elevated risks across North America this winter for insufficient energy supplies, particularly under extreme conditions like prolonged cold snaps.

While the U.S. is generally more susceptible to winter grid disruptions, and summer blackout warnings remain a concern, the report also highlights risks in parts of Canada. Saskatchewan faces a “high” risk due to increased demand, power plant retirements, and maintenance, whereas Quebec and the Maritimes are at “elevated risk.”

Mark Olson, NERC’s manager of reliability assessments, mentioned that Alberta wasn't initially considered at risk, illustrating the challenges in predicting electricity demand amid intensifying extreme weather.

Rob Thornton, president and CEO of the International District Energy Association, acknowledged public concerns about grid alerts but reassured that the risk of a catastrophic grid failure remains very low.

“The North American grid is exceptionally reliable. It’s a remarkably efficient system,” he said.

However, Thornton emphasized the importance of policies for a resilient and reliable electricity system through 2050 and beyond. This involves balancing dispatchable and intermittent electricity sources, investing in extra capacity, enhancing macrogrids and inter-jurisdictional connections, and more.

“These grid alerts raise awareness, if not anxiety, about our energy future,” Thornton concluded.

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Texas ERCOT Power Grid leads U.S. wind generation yet faces isolated interconnection, FERC exemption, and high industrial energy use, with distinct electricity and natural gas prices managed by a single balancing authority.

Key Points

The state-run interconnection that balances Texas electricity, isolated from FERC oversight and other U.S. grids.

✅ Largest U.S. wind power producer, high industrial demand

✅ Operates one balancing authority, independent interconnection

✅ Pays lower electricity, higher natural gas vs national average

For nearly two decades, the Lone Star State has generated more wind-sourced electricity than any other state in the U.S., according to the Energy Information Administration, or EIA.

In 2022, EIA reported Texas produced more electricity than any other state and generated twice as much as second-place Florida.

However, Texas also leads the country in another category. According to EIA, Texas is the largest energy-consuming state in the nation across all sectors with more than half of the state’s energy being used by the industrial sector.

As of May 2023, Texas residents paid 43% more for natural gas and around 10% less for electricity compared to the national average, according to EIA, and in competitive areas shopping for electricity is getting cheaper as well. Commercial and industrial sectors on average for the same month paid 25% less for electricity compared to the national average.

U.S. electric system compared to Texas
The U.S. electric system is essentially split into three regions called interconnections and are managed by a total of 74 entities called balancing authorities that ensure that power supply and demand are balanced throughout the region to prevent the possibility of blackouts, according to EIA.

The three regions (Interconnections):

Eastern Interconnection: Covers all U.S. states east of the Rocky Mountains, a portion of northern Texas, and consists of 36 balancing authorities.
Western Interconnection: Covers all U.S. states west of the Rockies and consists of 37 balancing authorities.
ERCOT: Covers the majority of Texas and consists of one balancing authority (itself).

During the 2021 winter storm, Texas electric cooperatives were credited with helping maintain service in many communities.

“ERCOT is unique in that the balancing authority, interconnection, and the regional transmission organization are all the same entity and physical system,” according to EIA, a structure often discussed in analyses of Texas power grid challenges today.

With this being the case, Texas is the only state in the U.S. that balances itself, the only state that is not subject to the jurisdiction of the Federal Energy Regulatory Commission, or FERC, and the only state that is not synchronously interconnected to the grid in the rest of the United States in the event of tight grid conditions, highlighting ongoing discussions about improving Texas grid reliability before peak seasons, according to EIA.

Every other state in the U.S. is connected to a web of multiple balancing authorities that contribute to ensuring power supply and demand are met.

California, for example, was the fourth largest electricity producer and the third largest electricity consumer in the nation in 2022, according to EIA, and California imports the most electricity from other states while Pennsylvania exports the most.

Although California produces significantly less electricity than Texas, it has the ability to connect with more than 10 neighboring balancing authorities within the Western Interconnection to interchange electricity, a dynamic that can see clean states importing dirty electricity under certain market conditions. ERCOT being independent only has electricity interchange with two balancing authorities, one of which is in Mexico.

Regardless of Texas’ unique power structure compared to the rest of the nation, the vast majority of the U.S. risked electricity supplies during this summer’s high heat, as outlined in severe heat blackout risks reports, according to EIA.

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