“Clean hydrogen is even further behind than CCS. Under proposed rules, state plans are due in the summer of 2026. It is virtually impossible for operators to make permanent decisions to meet that timeline. They will be forced into either retirement of essential dispatchable coal units, or curtailment of those units to capacity factors below 20% by 2032, and complete retirement by 2035, and curtailing the use of natural gas units to capacity factors below 20% starting in 2032. The disorderly retirement and elimination of baseload generation will leave the electricity grid with a significant deficit of dispatchable generation that cannot be replaced by intermittent resources especially during a time of economic growth.”

“We released a paper back in February about retirements. And we made a number of assumptions about retirements and came to a number of 40,000 megawatts between now and 2030. We’ve already been wrong about that in a number of faster retirements or retirements that we didn’t even see on the table.”

“… in a case where there’s a low level of replacement generation that actually comes on the system, and the retirements are as significant as we think they could be, we could start recognizing some shortages as early as 2027, 2028.”

“Replacement generation seeking to interconnect is made up primarily of intermittent and limited duration resources such as wind, solar and battery storage. These resources do not replace the resources that are retiring on a one for one basis, you need more megawatts of those resources to replace what’s retiring.”

“The rate of retirements of fossil fuel resources largely due to state and federal policies is clearly outpacing the construction of new renewable resources.”

“I want to make sure we have a heightened sense of urgency.” [Bear said MISO is up against a wave of generation retirements and similarly tapering reserves at PJM and SPP, which means MISO won’t be able to rely on imported power from neighbors in the future.] 

“The first rule of holes is if you’re in one, stop digging. “If the fundamental problem we’re facing is we’re shutting down dispatchable resources far too prematurely, then the answer is to stop shutting down dispatchable resources far too prematurely.”

“PJM has recently said that we are facing imminent resource scarcity and yet in the last procurement auction the capacity prices dropped. During times of scarcity, if a market functions correctly, obviously the prices should go up. This is proof that the subsidies are working ill on the markets right now.” 

“In the jurisdictional markets, the subsidies have effectively allowed intermittence to bid into the capacity markets at a price. Since the price signal that the electricity power is free, which it isn’t, it has depressed the prices for the entire market such that those units have to bid in their actual costs. [those units] are not going to clear the market and will not get a capacity ward. The result of that is premature retirement and the dispatchable resource are those that have things like fuel costs, regardless of what that fuel is. You have to put that fuel cost in, and they are pushed out of the market before their life is over, and the intermittence will end up making a larger percentage of the fleet going forward.”

“You can’t just shut down your dispatchable generation overnight or within the matter of a few years and think that you can keep the lights on by simply trying to replace. My point of the megawatt versus a megawatt is the capacity value of the wind or solar megawatt is simply not equal to the capacity value of a megawatt. You can’t just keep the grid running with a 1-1 replacement – the numbers don’t add up.” 

“I think it’s important to understand that FERC doesn’t order generating units to be built and FERC doesn’t order generating units to be shut down. We regulate the markets that have a big effect on how those decisions are made. In MISO, and really throughout the country, it’s states who decide what to build and states can decide what to retire. FERC has a huge impact because of the way we regulate the markets, but it all interacts.”

“… there’s an accusation there’s fear mongering going on with those of us expressing concerns about loss of dispatchable resources. I don’t think the head of NERC is fearmongering when he repeatedly says that this is a coming danger. I don’t think the head of PJM is fearmongering when he has said, we’re losing dispatchable resources at a rate we cannot sustain.” I don’t think the head of MISO is fearmongering when he says we’re losing dispatchable resources at a rate we can’t sustain.” I don’t think it’s fearmongering when the head of New York ISO last week said the same thing. I think we need to listen to the engineers, not the lobbyists. And I think we need to be doing what’s right for rate payers and not political narratives.”

“But I want to emphasize, states decide what units get built, states decide what units get shut down.”

“Well, building generating capacity takes time, but the biggest problem we have right now is we’re losing existing generating capacity that could be running and it’s shutting down and it’s shutting down prematurely. So, we’re losing assets that could be providing power right now.”

“First, coal plants are being prematurely retired. Second, there is no technology to deliver around-the-clock base load electricity to replace this retired generation. It has to be tested, proven, financeable, and also connected to the transmission grid by 2028 when all these coal plants are retired. In fact, it’s doubtful anything will be ready by about 2035.”

“Number one, the dispatchable generation we rely upon today to balance the grid is retiring, and it’s retiring at a rapid rate, and it’s retiring mostly driven by policy considerations. Second, electrification and large-scale data center construction is poised to create significant load growth in our footprint. Third, our new generation queue is largely intermittent, and so we need multiple megawatts of the new generation to replace one megawatt of the retiring generation. And, finally, the new generation is coming online slower than anticipated.” 

“I just want to note the markets have worked… But what is different is that there is this massive policy pressure. It’s really pressure for generators that are dispatchable to retire. And the retirement dates are not tied to demonstration that the replacement capacity is there.”

“We have significant concerns about this proposed rule landing at a time when the promises of job creation and job retraining in the coalfields remain little more than words on paper. The next round of coal-fired power plant closures is coming. But the coal-producing areas of the country are still reeling from the last round, and they are not prepared for this one.” 

“Based upon what we currently know about this proposal, it is not going to be upheld, and it just seems designed to scare more coal-fired power plants into retirement—the goal of the Biden administration.” 

“We are retiring dispatchable generating resources at a pace and in an amount that is far too fast and far too great, and it is threatening our ability to keep the lights on. Now the problem is not the addition of wind and solar and other renewable resources. The problem is the subtraction of dispatchable resources such as coal and gas.”

“In some cases, generational retirements are outpacing new installations, and this is resulting in reduced reserve margins.”

“When you do the math — when you look at the rate of retirements, you look at the rate of growth, and you add in the current rate of throughput for our queue — we are headed for some [resource adequacy problems]. And that trouble is likely to find us later in this decade.”

“We’re either replacing plants with less capacity, no capacity, or replacing them with renewables that are intermittent and not always available.”