Ocean Waves Can Be Effectively Harnessed Through New Wave-Pump Technology

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Minnesota-based energy technology company Independent Natural Resources Inc. (INRI) announced it is conducting a three-month demonstration of its SEADOG technology in the Gulf of Mexico, off of Galveston, Texas, under supervision and documentation from the Texas A&M University at Galveston Marine Engineering Technology Department.

The versatile SEADOG Pump system can provide abundant fresh water when combined with desalination and produce clean renewable energy when combined with a variety of turbine-driven systems.

INRI, formed in January of 2002 by CEO Mark A. Thomas, developed and acquired the SEADOG Pump technology from its inventor, Kenneth W. Welch, Jr., and co-inventors Curtis and Harold Rothi.

SEADOG captures ocean-wave energy from swells or waves to pump large volumes of seawater to shore-based storage or sea-based platform systems while consuming no fuel. February 2007 ocean trial testing off the coast of Freeport/Surfside Beach, Texas, validated the results of several years of concepts and planning, showing the company's SEADOG Pump wave-pump technology as a viable means of harvesting renewable power from ocean waves.

"As a wave energy collector, its simplicity, apparent efficiency and effectiveness is commendable and can be placed among the best available wave energy collectors to date," said Frank Warnakulasuriya, Ph.D., assistant head of the department, Marine Engineering Technology, Texas A&M University at Galveston.

The size, configuration and pumping capacity of SEADOG varies depending on the wave regime, height and frequency. During testing off of the coast of Surfside Beach/Freeport, Texas, a single SEADOG Pump has experienced modest waves from 6 inches to 8 feet and has consistently pumped a range of 2,000 to 50,000 gallons of seawater per day.

"Our initial sea trial in the Gulf of Mexico exceeded our expectations, and we're excited to partner with Texas A&M University to supervise and document SEADOG Pump performance and utilize their contribution toward final design and material specification," said Mark A. Thomas, CEO, INRI. "Going forward, we're seeking actual ocean environments where we can place a demonstration wave-farm test field involving 9 to 200 SEADOG Pump wave pumps. If the wave pump continues to perform as well as our sea trials have shown, we believe it has the potential to be a breakthrough for global energy production." Wave farms may range from 50 to 80,000 pumps and exist in sea states from 6 inches to 80 foot seas.

Most wave-energy technologies involve off-shore electrical generation requiring the transmission of power to shore-based electricity grids. These technologies involve costly, complex equipment that is sensitive to corrosive seawater and has the intermittency issues similar to wind and solar. SEADOG uses a different approach with a simple pump design with few moving parts and no electronics.

To generate electricity, the SEADOG Pump ocean-wave pump captures energy from ocean swells or waves to pump seawater to a land-based holding area, where the water can be returned to the ocean through turbines, thereby producing inexpensive, renewable electricity.

Preliminary estimates based on SEADOG sea trial results suggest that a 1-square-mile field of SEADOG Pumps could generate anywhere from 50 megawatts to more than 1,500 megawatts of electricity on average, depending on the wave regime, enough power to run 67,000 to more than 2,000,000 homes.

The device pumps water to shore-based storage or sea-based platform systems, and it can store salt water or desalinated fresh water in the form of potential energy to generate power on demand, even if the current wave regime during a particular period is too low to generate power.

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How waves could power a clean energy future

Wave Energy Converters can deliver marine power to the grid, with DOE-backed PacWave enabling offshore testing, robust designs, and renewable electricity from oscillating waves to decarbonize coastal communities and replace diesel in remote regions.

 

Key Points

Wave energy converters are devices that transform waves' oscillatory motion into electricity for the grid or loads.

✅ DOE's PacWave enables full-scale, grid-connected offshore testing.

✅ Multiple designs convert oscillating motion into torque and power.

✅ Ideal for islands, microgrids, and replacing diesel generation.

 

Waves off the coast of the U.S. could generate 2.64 trillion kilowatt hours of electricity per year — that’s about 64% of last year’s total utility-scale electricity generation in the U.S. We won’t need that much, but one day experts do hope that wave energy will comprise about 10-20% of our electricity mix, alongside other marine energy technologies under development today.

“Wave power is really the last missing piece to help us to transition to 100% renewables, ” said Marcus Lehmann, co-founder and CEO of CalWave Power Technologies, one of a number of promising startups focused on building wave energy converters.

But while scientists have long understood the power of waves, it’s proven difficult to build machines that can harness that energy, due to the violent movement and corrosive nature of the ocean, combined with the complex motion of waves themselves, even as a recent wave and tidal market analysis highlights steady advances.

″Winds and currents, they go in one direction. It’s very easy to spin a turbine or a windmill when you’ve got linear movement. The waves really aren’t linear. They’re oscillating. And so we have to be able to turn this oscillatory energy into some sort of catchable form,” said Burke Hales, professor of cceanography at Oregon State University and chief scientist at PacWave, a Department of Energy-funded wave energy test site off the Oregon Coast. Currently under construction, PacWave is set to become the nation’s first full-scale, grid-connected test facility for these technologies, a milestone that parallels U.K. wind power lessons on scaling new industries, when it comes online in the next few years.

“PacWave really represents for us an opportunity to address one of the most critical barriers to enabling wave energy, and that’s getting devices into the open ocean,” said Jennifer Garson, Director of the Water Power Technologies Office at the U.S. Department of Energy.

At the beginning of the year, the DOE announced $25 million in funding for eight wave energy projects to test their technology at PacWave, as offshore wind forecasts underscore the growing investor interest in ocean-based energy. We spoke with a number of these companies, which all have different approaches to turning the oscillatory motion of the waves into electrical power.

Different approaches
Of the eight projects, Bay Area-based CalWave received the largest amount, $7.5 million. 

″The device we’re testing at PacWave will be a larger version of this,” said Lehmann. The x800, our megawatt-class system, produces enough power to power about 3,000 households.”

CalWave’s device operates completely below the surface of the water, and as waves rise and fall, surge forward and backward, and the water moves in a circular motion, the device moves too. Dampers inside the device slow down that motion and convert it into torque, which drives a generator to produce electricity, a principle mirrored in some wind energy kite systems as they harvest aerodynamic forces.

“And so the waves move the system up and down. And every time it moves down, we can generate power, and then the waves bring it back up. And so that oscillating motion, we can turn into electricity just like a wind turbine,” said Lehmann.

Another approach is being piloted by Seattle-based Oscilla Power, which was awarded $1.8 million from the DOE, and is getting ready to deploy its wave energy converter off the coast of Hawaii, at the U.S. Navy Wave Energy Test site.

Oscilla Power’s device is composed of two parts. One part floats on the surface and moves with the waves in all directions — up and down, side to side and rotationally. This float is connected to a large, ring-shaped structure which hangs below the surface, and is designed to stay relatively steady, much like how underwater kites leverage a stable reference to generate power. The difference in motion between the float and the ring generates force on the connecting lines, which is used to rotate a gearbox to drive a generator.

″The system that we’re deploying in Hawaii is what we call the Triton-C. This is a community-scale system,” said Balky Nair, CEO of Oscilla Power. “It’s about a third of the size of our flagship product. It’s designed to be 100 kilowatt rated, and it’s designed for islands and small communities.”

Nair is excited by wave energy’s potential to generate electricity in remote regions, which currently rely on expensive and polluting diesel imports to meet their energy needs when other renewables aren’t available, and similar tidal energy for remote communities efforts in Canada point to viable models. Before wave energy is adopted at-scale, many believe we’ll see wave energy replacing diesel generators in off-the-grid communities.

A third company, C-Power, based in Charlottesville, Virginia, was awarded more than $4 million to test its grid-scale wave energy converter at PacWave. But first, the company wants to commercialize its smaller scale system, the SeaRAY, which is designed for lower-power applications. 

″Think about sensors in the ocean, research, metocean data gathering, maybe it’s monitoring or inspection,” said C-Power CEO Reenst Lesemann on the initial applications of his device.

The SeaRAY consists of two floats and a central body, the nacelle, which contains the drivetrain. As waves pass by, the floats bob up and down, rotating about the nacelle and turning their own respective gearboxes which power the electric generators.

Eventually, C-Power plans to scale up its SeaRAY so that it’s capable of satellite communications and deep water deployments, before building a larger system, called the StingRAY, for terrestrial electricity generation.

Meanwhile, one Swedish company, Eco Wave Power, is taking another approach completely, eschewing offshore technologies in favor of simpler wave power devices that can be installed on breakwaters, piers, and jetties.

“All the expensive conversion machinery, instead of being inside the floaters like in the competing technologies, is on land just like a regular power station. So basically this enables a very low installation, operation, and maintenance cost,” explained CEO Inna Braverman.

 

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Climate change: Greenhouse gas concentrations again break records

Rising Greenhouse Gas Concentrations drive climate change, with CO2, methane, and nitrous oxide surging; WMO data show higher radiative forcing, elevated pre-industrial baselines, and persistent atmospheric concentrations despite Paris Agreement emissions pledges.

 

Key Points

Increasing atmospheric CO2, methane, and nitrous oxide levels that raise radiative forcing and drive warming.

✅ WMO data show CO2 at 407.8 ppm in 2018, above decade average

✅ Methane and nitrous oxide surged, elevating total radiative forcing

✅ Concentrations differ from emissions; sinks absorb about half

 

The World Meteorological Organization (WMO) says the increase in CO2 was just above the average rise recorded over the last decade.

Levels of other warming gases, such as methane and nitrous oxide, have also surged by above average amounts.

Since 1990 there's been an increase of 43% in the warming effect on the climate of long lived greenhouse gases.

The WMO report looks at concentrations of warming gases in the atmosphere rather than just emissions.

The difference between the two is that emissions refer to the amount of gases that go up into the atmosphere from the use of fossil fuels, such as burning coal for coal-fired electricity generation and from deforestation.

Concentrations are what's left in the air after a complex series of interactions between the atmosphere, the oceans, the forests and the land. About a quarter of all carbon emissions are absorbed by the seas, and a similar amount by land and trees, while technologies like carbon capture are being explored to remove CO2.

Using data from monitoring stations in the Arctic and all over the world, researchers say that in 2018 concentrations of CO2 reached 407.8 parts per million (ppm), up from 405.5ppm a year previously.

This increase was above the average for the last 10 years and is 147% of the "pre-industrial" level in 1750.

The WMO also records concentrations of other warming gases, including methane and nitrous oxide, and some countries have reported declines in certain potent gases, as noted in US greenhouse gas controls reports, though global levels remain elevated. About 40% of the methane emitted into the air comes from natural sources, such as wetlands, with 60% from human activities, including cattle farming, rice cultivation and landfill dumps.

Methane is now at 259% of the pre-industrial level and the increase seen over the past year was higher than both the previous annual rate and the average over the past 10 years.

Nitrous oxide is emitted from natural and human sources, including from the oceans and from fertiliser-use in farming. According to the WMO, it is now at 123% of the levels that existed in 1750.

Last year's increase in concentrations of the gas, which can also harm the ozone layer, was bigger than the previous 12 months and higher than the average of the past decade.

What concerns scientists is the overall warming impact of all these increasing concentrations. Known as total radiative forcing, this effect has increased by 43% since 1990, and is not showing any indication of stopping.

There is no sign of a slowdown, let alone a decline, in greenhouse gases concentration in the atmosphere despite all the commitments under the Paris agreement on climate change and the ongoing global energy transition efforts," said WMO Secretary-General Petteri Taalas.

"We need to translate the commitments into action and increase the level of ambition for the sake of the future welfare of mankind," he added.

"It is worth recalling that the last time the Earth experienced a comparable concentration of CO2 was three to five million years ago. Back then, the temperature was 2-3C warmer, sea level was 10-20m higher than now," said Mr Taalas.

The UN Environment Programme will report shortly on the gap between what actions countries are taking to cut carbon, for example where Australia's emissions rose 2% recently, and what needs to be done to keep under the temperature targets agreed in the Paris climate pact.

Preliminary findings from this study, published during the UN Secretary General's special climate summit last September, indicated that emissions continued to rise during 2018, although global emissions flatlined in 2019 according to the IEA.

Both reports will help inform delegates from almost 200 countries who will meet in Madrid next week for COP25, following COP24 in Katowice the previous year, the annual round of international climate talks.

 

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Egypt Plans Power Link to Saudis in $1.6 Billion Project

Egypt-Saudi Electricity Interconnection enables cross-border power trading, 3,000 MW capacity, and peak-demand balancing across the Middle East, boosting grid stability, reliability, and energy security through an advanced electricity network, interconnector infrastructure, and GCC grid integration.

 

Key Points

A 3,000 MW grid link letting Egypt and Saudi Arabia trade power, balance peak demand, and boost regional reliability.

✅ $1.6B project; Egypt invests ~$600M; 2-year construction timeline

✅ 3,000 MW capacity; peak-load shifting; cross-border reliability

✅ Links GCC grid; complements Jordan and Libya interconnectors

 

Egypt will connect its electricity network to Saudi Arabia, joining a system in the Middle East that has allowed neighbors to share power, similar to the Scotland-England subsea project that will bring renewable power south.

The link will cost about $1.6 billion, with Egypt paying about $600 million, Egypt’s Electricity Minister Mohamed Shaker said Monday at a conference in Cairo, as the country pursues a smart grid transformation to modernize its network. Contracts to build the network will be signed in March or April, and construction is expected to take about two years, he said. In times of surplus, Egypt can export electricity and then import power during shortages.

"It will enable us to benefit from the difference in peak consumption,” Shaker said. “The reliability of the network will also increase.”

Transmissions of electricity across borders in the Gulf became possible in 2009, when a power grid connected Qatar, Kuwait, Saudi Arabia and Bahrain, a dynamic also seen when Ukraine joined Europe's grid under emergency conditions. The aim of the grid is to ensure that member countries of the Gulf Cooperation Council can import power in an emergency. Egypt, which is not in the GCC, may have been able to avert an electricity shortage it suffered in 2014 if the link with Saudi Arabia existed at the time, Shaker said.

The link with Saudi Arabia should have a capacity of 3,000 megawatts, he said. Egypt has a 450-megawatt link with Jordan and one with Libya at 200 megawatts, the minister said. Egypt will seek to use its strategic location to connect power grids in Asia, where the Philippines power grid efforts are raising standards, and elsewhere in Africa, he said.

In 2009, a power grid linked Qatar, Kuwait, Saudi Arabia and Bahrain, allowing the GCC states to transmit electricity across borders, much like proposals for a western Canadian grid that aim to improve regional reliability. 

 

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Attacks on power substations are growing. Why is the electric grid so hard to protect?

Power Grid Attacks surge across substations and transmission lines, straining critical infrastructure as DHS and FBI cite vandalism, domestic extremists, and cybersecurity risks impacting resilience, outages, and grid reliability nationwide.

 

Key Points

Power Grid Attacks are deliberate strikes on substations and lines to disrupt power and weaken grid reliability.

✅ Physical attacks rose across multiple states and utilities.

✅ DHS and FBI warn of threats to critical infrastructure.

✅ Substation security and grid resilience upgrades urged.

 

Even before Christmas Day attacks on power substations in five states in the Pacific Northwest and Southeast, similar incidents of attacks, vandalism and suspicious activity were on the rise.

Federal energy reports through August – the most recent available – show an increase in physical attacks at electrical facilities across the nation this year, continuing a trend seen since 2017.

At least 108 human-related events were reported during the first eight months of 2022, compared with 99 in all of 2021 and 97 in 2020. More than a dozen cases of vandalism have been reported since September.

The attacks have prompted a flurry of calls to better protect the nation's power grid, with a renewed focus on protecting the U.S. power grid across sectors, but experts have warned for more than three decades that stepped-up protection was needed.

Attacks on power stations on the rise 
Twice this year, the Department of Homeland Security warned "a heightened threat environment" remains for the nation, including its critical infrastructure amid reports of suspected Russian breaches of power plant systems. 

At least 20 actual physical attacks were reported, compared with six in all of 2021. 
Suspicious-activity reports jumped three years ago, nearly doubling in 2020 to 32 events. In the first eight months of this year, 34 suspicious incidents were reported.
Total human-related incidents – including vandalism, suspicious activity and cyber events such as Russian hackers and U.S. utilities in recent years – are on track to be the highest since the reports started showing such activity in 2011.


Attacks reported in at least 5 states
Since September, attacks or potential attacks have been reported on at least 18 additional substations and one power plant in Florida, Oregon, Washington and the Carolinas. Several involved firearms.

  • In Florida: Six "intrusion events" occurred at Duke Energy substations in September, resulting in at least one brief power outage, according to the News Nation television network, which cited a report the utility sent to the Energy Department. Duke Energy spokesperson Ana Gibbs confirmed a related arrest, but the company declined to comment further.
  • In Oregon and Washington state: Substations were attacked at least six times in November and December, with firearms used in some cases, local news outlets reported. On Christmas Day, four additional substations were vandalized in Washington State, cutting power to more than 14,000 customers.
  • In North Carolina: A substation in Maysville was vandalized on Nov. 11. On Dec. 3, shootings that authorities called a "targeted attack" damaged two power substations in Moore County, leaving tens of thousands without power amid freezing temperatures.
  • In South Carolina: Days later, gunfire was reported near a hydropower plant, but police said the shooting was a "random act."

It's not yet clear whether any of the attacks were coordinated. After the North Carolina attacks, a coordinating council between the electric power industry and the federal government ordered a security evaluation.


FBI mum on its investigations
The FBI is looking into some of the attacks, including cyber intrusions where hackers accessed control rooms in past cases, but it hasn't said how many it's investigating or where. 

Shelley Lynch, a spokesperson for the FBI's Charlotte field office, confirmed the bureau was investigating the North Carolina attack. The Kershaw County Sheriff's Office reported the FBI was looking into the South Carolina incident.

Utilities in Oregon and Washington told news outlets they were cooperating with the FBI, but spokespeople for the agency's Seattle and Portland field offices said they couldn't confirm or deny an investigation.

Could domestic extremists be involved?
In January, the Department of Homeland Security said domestic extremists had been developing "credible, specific plans" since at least 2020, including a Neo-Nazi plot against power stations detailed in a federal complaint, and would continue to "encourage physical attacks against electrical infrastructure."

In February, three men who ascribed to white supremacy and Neo-Nazism pleaded guilty to federal crimes related to a scheme to attack the grid with rifles.

In a news release, Timothy Langan, assistant director of the FBI’s Counterterrorism Division, said the defendants "wanted to attack regional power substations and expected the damage would lead to economic distress and civil unrest."

 

Why is the power grid so hard to protect?
Industry experts, federal officials and others have warned in one report after another since at least 1990 that the power grid was at risk, and a recent grid vulnerability report card highlights dangerous weak points, said Granger Morgan, an engineering professor at Carnegie Mellon University who chaired three National Academies of Sciences reports.

The reports urged state and federal agencies to collaborate to make the system more resilient to attacks and natural disasters such as hurricanes and storms. 

"The system is inherently vulnerable, with the U.S. grid experiencing more blackouts than other developed nations in one study. It's spread all across the countryside," which makes the lines and substations easy targets, Morgan said. The grid includes more than 7,300 power plants, 160,000 miles of high-voltage power lines and 55,000 transmission substations.

One challenge is that there's no single entity whose responsibilities span the entire system, Morgan said. And the risks are only increasing as the grid expands to include renewable energy sources such as solar and wind, he said. 

 

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Negative Electricity Prices Amid Renewable Energy Surplus

France Negative Electricity Prices highlight surplus renewables as solar and wind output exceeds demand, driving grid flexibility, demand response, and storage signals while reshaping energy markets, lowering emissions, and improving economic efficiency and energy security.

 

Key Points

They occur when surplus solar and wind push wholesale power prices below zero, signaling flexible, low-carbon grids.

✅ Surplus solar and wind outpace demand, flipping price signals

✅ Incentivizes demand response, storage, and flexible loads

✅ Enhances decarbonization, energy security, and market efficiency

 

In a remarkable feat for renewable energy, France has recently experienced negative electricity prices due to an abundant supply of solar and wind power. This development highlights the country's progress towards sustainable energy solutions and underscores the potential of renewables to reshape global energy markets.

The Surge in Renewable Energy Supply

France's electricity grid benefited from a surplus of renewable energy generated by solar panels and wind turbines. During periods of peak production, such as sunny and windy days, the supply of electricity exceeded demand, leading to negative prices and reflecting how solar is reshaping price dynamics in Northern Europe.

Implications for Energy Markets

The occurrence of negative electricity prices reflects a shift towards a more flexible and responsive energy system. It demonstrates the capability of renewables to meet substantial portions of electricity demand reliably and economically, with evidence of falling wholesale prices in many markets, challenging traditional notions of energy supply and pricing dynamics.

Technological Advancements and Policy Support

Technological advancements in renewable energy infrastructure, coupled with supportive government policies and incentives, have played pivotal roles in France's achievement. Investments in solar farms, wind farms, and grid modernization, including the launch of France's largest battery storage platform by TagEnergy, have enhanced the efficiency and reliability of renewable energy integration into the national grid.

Economic and Environmental Benefits

The adoption of renewable energy sources not only reduces greenhouse gas emissions but also fosters economic growth and energy independence. By harnessing abundant solar and wind resources, France strengthens its energy security and reduces reliance on fossil fuels, contributing to long-term sustainability goals and reflecting a continental shift as renewable power has surpassed fossil fuels for the first time.

Challenges and Future Outlook

While France celebrates the success of negative electricity prices, challenges remain in scaling renewable energy deployment and optimizing grid management. Balancing supply and demand, integrating intermittent renewables, and investing in energy storage technologies are critical for ensuring grid stability and maximizing the benefits of renewable energy, particularly in addressing clean energy's curtailment challenge across modern grids.

Global Implications

France's experience with negative electricity prices serves as a model for other countries striving to transition to clean energy economies. It underscores the potential of renewables to drive economic prosperity, mitigate climate change impacts, and reshape global energy markets towards sustainability, as seen in Germany where solar-plus-storage is now cheaper than conventional power in several contexts.

Conclusion

France's achievement of negative electricity prices driven by renewable energy surplus marks a significant milestone in the global energy transition. By leveraging solar and wind power effectively, France demonstrates the feasibility and economic viability of renewable energy integration at scale. As countries worldwide seek to reduce carbon emissions and enhance energy resilience, France's example provides valuable insights and inspiration for advancing renewable energy agendas and accelerating towards a sustainable energy future.

 

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ACORE tells FERC that DOE Proposal to Subsidize Coal, Nuclear Power Plants is unsupported by Record

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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