“As you are aware, Talen is currently prevented from continuing to run without conversion beyond its stated deactivation date under [a Reliability Must Run] framework due to a private agreement it entered into with you. Neither PJM, the federally designated regional grid operator charged with maintaining grid reliability, nor the state of Maryland is a party to this agreement.” 

“We are facing an absolute step change in the risk environment surrounding reliability and energy assurance. In recent years, we’ve witnessed a decline in reliability, and the future projection does not offer a clear path to securing the reliable electricity supply that is essential for the health, safety, and prosperity of our communities.”

“I’m just struck when we’re talking about these reliability challenges, that in a nation that is so blessed with an abundant array of affordable, reliable energy resources like America is, it really doesn’t seem plausible that we should ever fall short. Yes, we have storms yes, there are power outages that are going to happen, but not having enough should never happen ever. So, we have is a crisis in leadership that all of us face. I include myself as a state regulator, and we have to fix that.”

“The art of ensuring reliability has not changed, even though the backdrop has. We are all guilty of complaining about long periods of gray skies, and although we don’t complain when the wind isn’t blowing our hair out of place, we can certainly acknowledge those times occur.  So, with more of the fleet made up of weather-dependent resources it’s just logical that a lack of fuel will cause them to be unavailable, and possibly for an extended period of time.”

“Reliability is something that is an expectation in our society, and it’s become easy to take it for granted.  Today, however, the landscape has changed significantly to make it much more complex to deliver electricity with the reliability our society has come to expect. Unfortunately, there is a focus on debating the virtues of different resources and letting that distract us from the realities of reliability, so I am hopeful we can get back to some of those today. These should not be seen as “grim” realities, but I like to think of them as “grid” realities.”

“Regulatory, policy, and environmental pressures on fossil-based generation resources that provide 60 percent of the nation’s electricity further threaten the reliability and flexibility of the grid. Because of these pressures, coupled with projections of electric demand growth, we are concerned about the reliability of the bulk-power system and the actions the Commission is taking or considering taking to ensure that it fulfills its mission to ‘assist consumers in obtaining reliable, safe, secure, and economically efficient energy services at a reasonable cost through appropriate regulatory and market means, and collaborative efforts.” 

“Regulatory, policy, and environmental pressures on fossil-based generation resources that provide 60 percent of the nation’s electricity further threaten the reliability and flexibility of the grid. Because of these pressures, coupled with projections of electric demand growth, we are concerned about the reliability of the bulk-power system and the actions the Commission is taking or considering taking to ensure that it fulfills its mission to ‘assist consumers in obtaining reliable, safe, secure, and economically efficient energy services at a reasonable cost through appropriate regulatory and market means, and collaborative efforts.” 

“This situation requires immediate attention. Failure to come to resolution on this issue could result in degraded grid reliability for over 1,000,000 Maryland consumers during peak hours, including the entirety of the city of Baltimore, for the years between the stated deactivation of Brandon Shores and the date whereby needed transmission can be constructed.”

“We are starting to see that these three objectives of reliability, affordability and decarbonization often conflict. I think it would be really helpful and I think it is really necessary to have ongoing, serious, fact-based conversations about those trade-offs to help inform policymakers – those who are elected and appointed by those who are elected – to make the right trade-offs because there are trade-offs to be made.”

“The proposal “requires stringent and unproven carbon dioxide emissions controls for coal-fired electric generating units to be implemented in unrealistic time frames. The plan would “usurp the authority and discretion” of the state agencies responsible for implementing environmental and energy policies.”

“Zone operators can require that the utilities in their zones bring certain resources to the table, they have those abilities. And so, I think it needs to go to the interconnection process where you’re bringing on or taking off resources. We need to start requiring that the resources that come on bring the attributes, they all have to have the same attributes or similar attributes, or a package of attributes.”

 “I’m just struck when we’re talking about these reliability challenges, that in a nation that is so blessed with an abundant array of affordable, reliable energy resources like America is, it really doesn’t seem plausible that we should ever fall short. Yes, we have storms yes, there are power outages that are going to happen, but not having enough should never happen ever. So, we have is a crisis in leadership that all of us face. I include myself as a state regulator, and we have to fix that.”

“New technologies are far from commercial viability. There is little doubt that technologies will mature and/or new technologies will develop that can effectively and efficiently provide the needed reliability attributes. But, we are not at that point, and we won’t be any time soon. There is another “constraint,” if you will, that has been often ignored lately.  Not only is reliability an expectation, but so too is affordability. Utilities could certainly install massive amounts of 4-hour batteries to provide the required attributes, but at massive cost. Simply put, time is needed to resolve this challenge, and, in the meantime, we have to maintain the existing sources of these attributes, understanding that their usage will decline.”

“Different resource types are different. There is a diversity of resources on the system right now. They all provide something that is needed for reliability, but none of them provide everything that is needed. The decarbonization goals being set by states and utilities mean we need significantly more renewable resources on the system. At the same time, however, we need resources that can run at high output for long periods of time to fill the void when Mother Nature is not providing renewable fuel or has forced large portions of the fleet out of service. In addition, we need highly flexible, dispatchable resources that can be moved up or down easily and quickly to counteract the variability that comes with weather-dependent resources.”

“The art of ensuring reliability has not changed, even though the backdrop has. We are all guilty of complaining about long periods of gray skies, and although we don’t complain when the wind isn’t blowing our hair out of place, we can certainly acknowledge those times occur.  So, with more of the fleet made up of weather-dependent resources it’s just logical that a lack of fuel will cause them to be unavailable, and possibly for an extended period of time.” 

“Reliability is something that is an expectation in our society, and it’s become easy to take it for granted.  Today, however, the landscape has changed significantly to make it much more complex to deliver electricity with the reliability our society has come to expect. Unfortunately, there is a focus on debating the virtues of different resources and letting that distract us from the realities of reliability, so I am hopeful we can get back to some of those today. These should not be seen as “grim” realities, but I like to think of them as “grid” realities.”

“The recent acceleration in the pace of fleet change is increasing risks to system reliability for MISO. Dispatchable generators that we need to ensure reliability are being removed from the system before new resources with the needed reliability attributes are being brought online.”

“Transforming the grid is easy in concept, it’s very difficult and challenging in practice; there are multiple moving parts, and the timing and coordination of making those decisions is critical. If the pace of retirements gets ahead of the pace of replacing the lost reliability attributes, that’s when we could get into a reliability situation.”

“The growth of renewables has had many benefits, but because the wind doesn’t always blow and the sun doesn’t always shine, as a grid operator SPP has to rely on other fuel sources to ensure demand can still be met when these intermittent resources are not available.”

“I don’t think adding renewables is the reliability challenge. It’s the retirement of conventional generation. That’s our challenge.”

“We need to take the analysis of reliability impacts to the next level – choosing compliance dates and deadlines carefully and after more detailed study and analysis than has generally occurred to date in the policymaking process.”

“We urge that reliability considerations be built into the analysis of potential policies rather than either being taken for granted or considered only as an afterthought once legislation is enacted.”

“… they could exacerbate the potential for reliability problems in the future to the extent that, again, we don’t get sufficient replacement resources to maintain overall resource adequacy and get the types of generator attributes that we need in order to replace what could retire.”

[Response to Rep. Griffith’s question on whether 2027 is the tipping point for when the grid is not reliable] “It could be that early if the pace at which replacement generation comes online does not accelerate.” 

“… we think that the rule should incorporate things such as reliability analysis into things like deadlines as well as the potential for reliability safety valves.”

“Beyond the overall resource adequacy question, dispatchable generation also provides, right now, the majority of the grid services we need; the flexibility, the ramping, those types of services that we need to balance the grid to operate the grid reliably.” 

“In 1990, two-thirds of the generating capacity in this country was coal and gas and today almost two-thirds of the generating capacity is still coal and gas. But what’s happened is in 1990 about half of our capacity was coal and only about 10% was gas, and now it’s reversed. In 1990 we were using gas almost exclusively for gas peakers, turn them on at peak and that’s it. Now, we’re running gas as baseload and that takes a lot more gas and we don’t have the infrastructure—that’s the real energy transition by the way, the coal to gas that’s taken place in this country since 1990.” 

“The world that we are operating is a lot more complex, so to maintain the reliability we’ve become accustomed to, we will need to adjust our markets and processes.” [Remarks to the Board – saying MISO and members have been “fortunate” to preside over smooth operations and manage them with simpler market tools. However, he said a multitude of renewable resources and increasingly unstable weather is poised to further drive volatility and riskier operations.]

[While MISO remains fuel neutral] “We’re big fans of reliability.” 

“We’re facing reality very, very simply. I think everybody knows that,” Christie said. “The question is, is there going to be the political will to make a turn in policy and recognize that we’re not going to get to where everybody wants to get, which is a lower-carbon grid, without reality being part of the equation, because reality will track you down. We’re headed to some bad outcomes and none of us want to be around when those outcomes hit, because that’s when the finger-pointing starts.” 

“Right now, when it comes to the reliability of our grid, the United States is facing a rendezvous with reality. Reality is just around the corner. You may think you can avoid it for a while, but reality will track you down. And reality is tracking us down when it comes to the reliability of our grid.”

“We like to play games. You create the rules of the game, and everyone plays it, and it’s all about who can get the lowest cost because we’ve turned electricity into a commodity instead of an essential service. At some point, there has to be a financial metric rule, some payments, something somewhere to pay for that reliability. Otherwise, everyone’s going to keep playing the game and just chasing the cheapest electron.”

[In calling for fairness in meeting reliability commitments] “We’re propping up reliability, but we get paid nothing for it. When the wind blows hard enough or the sun shines bright enough, we have to pay the market to just keep our resources online to prop up the market to be there for reliability. So when [prices] go negative, I’m paying to keep that resource online.”

“We know we can’t afford a 100% reliable system. We’re going to have to make important tradeoffs between reliability and those three parameters [frequency, duration and scale] and how much we will be paid to avoid that. Resilience and reliability is not free.”

“A wind drought, solar drought, cloud cover, unexpected cloud cover, extreme cold weather affects the ability of large amounts of generation to operate, so this whole notion of kind of random failure being the driver of how much generation we need isn’t sufficient.”

“These results (Summertime Capacity Projections) continue to illustrate the reliability risk we face and reinforce the need for dispatchable, long-duration resources to be maintained and brought online to manage the transition to weather-dependent, low-carbon resources.”

“The spinning mass that has been the basis for our generation fleet for ages is what allows us to ride through the voltage disturbances that are inevitable in a dynamic system like this. And even if you have grid-forming inverters, the likelihood that they would have that level of resilience given the fact that intermittents can turn on and off in a moment’s notice is very unlikely.”

“The US is heading towards a reliability crisis in our electric markets. This reliability crisis is being driven by two primary factors. The first is the effect of subsidies and the second is the commission’s… abandonment of its long-standing commitment to the rule of law.”

“We are heading for potentially very dire consequences, potentially catastrophic consequences in the United States in terms of the reliability of our grid.”

“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.”

“The combination of inverter resources and batteries is a very powerful one. But you need to be cognizant of the scale and duration of protection that you are getting. Four hours is four hours, which is terrific if you have got a three-and-a-half-hour event. If you have a two-week outage associated with a major hurricane, if you have six weeks of cloud cover that you can’t generate from, you need longer-duration storage than four hours.”

“… one of the important things that these plants provide is the ability for the grid to maintain voltage and maintain frequency and to resist disturbances. Other resources can’t do that nearly as well as large spinning mass generation. And that’s why the loss of coal plants and natural gas plants and nuclear plants is so concerning from a grid reliability perspective.”

“Our assessments demonstrate that the electric grid is operating ever closer to the edge where more frequent and more serious disruptions are increasingly likely.”

“As an engineering matter, there is no substitute for reliable, dispatchable generation. Intermittent renewable resources like wind and solar are simply incapable, by themselves, of ensuring the stability of the bulk electric system.”