It’s Time for a Nonwires Alternative Coordinator for Maine

In 2009 Maine passed its Smart Grid Policy Act. One of its many provisions not implemented was the creation of a Nonwires Alternative Coordinator within the Public Utilities Commission. In 2017 the PUC chose to put this responsibility with the utilites themselves and asked them how they would do it. They have not yet answered. The following is testimony given in support of LD 1181, An Act to Reduce Electricity Costs Through Nonwires Alternatives, which would require the Coordinator be established immediately, but places the function within the Public Advocate’s office.

March 27, 2019

Senator Lawrence, Representative Berry, members of the Joint Committee, my name is Gerry Runte. I am a constituent of Senator Lawrence and live in York.  Thank you for the opportunity to testify today in support of LD 1181.

Advocacy for innovative rate regulatory structures that acknowledge and value the benefits of demand reduction and distributed generation, aka, Nonwires Alternatives, has occupied a major portion of my 44-year professional career, a career almost equally divided between senior management positions at investor owned electric utilities and at private firms in the alternative energy technology sector. Presently I operate a private consulting firm, Worthington Sawtelle LLC, assisting startups with their go-to-market strategies. I am also a senior consultant with CMG Consulting, a national firm specializing in smart grid and wholesale energy market development. I am here today as a private citizen and my comments do not represent the views of CMG Consulting.

Our electricity delivery systems have been rapidly evolving from the electric utility business models of the early 20th century when energy delivery was a one-way path from central generating stations to the end user. New technologies have and will continue to emerge that are transforming this model of energy delivery, one that looks much more like the multiple path connections of computer networks than the one-way pipelines of the past.   The best and most reliable and economical solution to serve new demand is no longer limited to the construction of more generation carried over more wire capacity: the optimum solution could include mitigating demand growth through efficiency and demand response programs, serving it with local distributed generation, energy storage, and managing the grid in real time.   

Consider distributed generation (DG). In addition to making electricity, DG can also be an important component of the electricity delivery system. DG can be used to enhance reliability, resiliency and efficiency, as well as maximize capital utilization.  The notion of local distributed generation benefiting distribution infrastructure is not a new concept. Pacific Gas & Electric’s research department identified a number of benefits to the distribution and transmission system in the late 1980’s and ultimately conducted a full-scale test by collocating a 500 kW solar array at their Kerman Substation to measure its benefits to their distribution infrastructure. The Kerman project demonstrated that the solar installation enhanced reliability through voltage support, reduced transformer maintenance by lowering required cooling at peak hours, deferred transmission capacity increases; offset peaking plant dispatch; deferred capital investments in substation upgrades; and enhanced system reliability by reducing capacity margins. While in the utility industry, I was involved with projects that used solar installations to prove similar benefits and large fuel cells to provide services to commercial users looking for significantly higher reliability and resiliency.

Yet where are we now, 26 years later? The benefits of Nonwires Alternatives have been quantified in detail in several utility systems and are well understood by the utilities themselves. Why, then, is distributed generation, not an integral component of transmission and distribution system planning options, except perhaps in California, Minnesota, District of Columbia, New York, and Massachusetts?

The answer is simple. Most electric utilities, including Maine’s two IOUs, operate within a regulatory structure that was designed to compensate monopolies delivering power in that one way, 20th century system I described earlier. This is a system purposely constructed to reward large capital investments in wires and large central generating stations to always be available to support economic growth. This system worked well for many years. Growth was met, electricity was abundant and available when needed to fuel the economy. But this system did not contemplate the rise of local generation or storage that could be discharged back into the system. Or technology with the ability to monitor, in real time, flows throughout the system or manage two-way power distribution. Utility business models are defined by the regulatory rules in which they operate. Investing capital in a new line or reinforcing an old one to meet growing peak demand is the only option in the playbook because that investment is recognized in rate base; buying locally generated electricity mitigate that peak would accomplish the same end, however the cost of buying that service is not recognized in rates and therefore that option has zero benefit to the utility because it is a benefit that it cannot value.

In addition to constraining utility planning to less optimum operation and costs, this regulatory structure has also limited the growth of distributed generation markets.  Yes, solar and wind have grown considerably in the last several years, but primarily as surrogates for large central generation using the old paradigm.  I can speak from experience that developers and marketers of distributed generation systems see additional markets for their products in those jurisdictions that are undergoing innovative regulatory reform.

There are many models that are currently in implementation or design to move utilities into 21st century regulatory structures that solve this problem.  Some states have instituted comprehensive rate regulatory reform which completely realign utility business models such that they can benefit from and value these new generation and communication technologies while lowering costs and increasing reliability. They are redesigning electricity delivery systems that are far more analogous to computer network that the old, one-way pipeline. Other states have instituted partial realignments through the creation of Distribution System Operators (NY) or a Distribution Power Authority (DC) who have jurisdiction over wired company plans and manage local market platforms that trade capacity, grid support and ancillary services, as well as demand reduction. In so doing, the utilities have been transformed from strong opponents to advocates of this new utility system paradigm because they have been able to alter their business models to take full advantage.

Change the rules and the business model will follow.

As you are aware, Maine began to address the design of a 21st century electricity system with its Smart Grid Policy Act in 2009. One element of that Act required the creation of a Nonwires Alternative Coordinator function within the Public Utilities Commission to ensure options using Nonwires Alternatives were given full consideration in system plans as an option, along with traditional wires investments. Unfortunately, the Nonwires Alternative Coordinator requirement was ignored for 8 years and then the function was effectively delegated to the IOU’s for implementation at some later date. Consequently, it appears that by abdicating this responsibility, the PUC is not a suitable governing body for the placement of the Nonwires Alternative Coordinator.

Make no mistake, changing the rules is no simple. Matter.  However, Maine can make up for lost time and begin the process of reforming how its electricity delivery system is regulated by taking this first step by establishing a Nonwires Alternative Coordinator. The Coordinator could be the source of guidance for the siting of new DG that optimize their enhancement of the distribution network. It could also pilot ways to incent utility leverage DG, with direct benefit to GHG reduction goals. This new office will be a win-win solution for both rate payers and IOU’s as Maine continues to advance its clean energy economy. The Public Advocate’s Office is a logical place from which the Coordinator to operate.

I urge your support and passage of LD 1181.

Thank you.

Gerry Runte

Managing Director


Climate Change Has Not Been Entirely Erased From US Government Priorities

The current administration has done its best to erase and ignore climate change as a growing threat to our economic and physical security. The topic has been removed from the EPA and other agency websites, as well as from the summary of the current National Defense Strategy (actual document is classified). Thus far, though, there is one holdout in government – the intelligence community. On February 13 the Senate select Committee on Intelligence received a briefing from several top members of the intelligence community. This was their annual World-Wide Threats briefing. The accompanying Statement for the Record by the Director of National Intelligence, Daniel Coats, provided much detail prior to the nearly 3-hour hearing. Even though oral discussion of the impacts of climate change on global threats to this country was absent in oral questioning, the written statement by Dan Coates, Director of National Intelligence, made it quite clear that climate has not been erased from their agenda.

In the Foreword of his statement, Coats lays out several drivers to threats, including the risk of interstate conflict; the threat of state and non-state weapons of mass destruction; slow economic growth and technology induced disruptions in job markets fueling populism; and  “challenges from urbanization and migration will persist, while the effects of air pollution, inadequate water, and climate change on human health and livelihood will become more noticeable.”

One of the eleven global threats outlined by Director Coats was “Environment and Climate Change.”  This section, in its entirety:

“The impacts of the long-term trends toward a warming climate, more air pollution, biodiversity loss, and water scarcity are likely to fuel economic and social discontent—and possibly upheaval—through 2018.The past 115 years have been the warmest period in the history of modern civilization, and the past few years have been the warmest years on record. Extreme weather events in a warmer world have the potential for greater impacts and can compound with other drivers to raise the risk of humanitarian disasters, conflict, water and food shortages, population migration, labor shortfalls, price shocks, and power outages. Research has not identified indicators of tipping points in climate-linked earth systems, suggesting a possibility of abrupt climate change.

  • Worsening air pollution from forest burning, agricultural waste incineration, urbanization, and rapid industrialization—with increasing public awareness—might drive protests against authorities, such as those recently in China, India, and Iran.
  • Accelerating biodiversity and species loss—driven by pollution, warming, unsustainable fishing, and acidifying oceans—will jeopardize vital ecosystems that support critical human systems. Recent estimates suggest that the current extinction rate is 100 to 1,000 times the natural extinction rate.
  • Water scarcity, compounded by gaps in cooperative management agreements for nearly half of the world’s international river basins, and new unilateral dam development are likely to heighten tension between countries.”

One area where the written statement is deficient is in failing to make any correlation between other threats and the issue of climate.  “Human displacement” is cited because of record high global displacements, raising the risk of disease outbreaks and political upheaval.  While much displacement is occurring because of conflict, displacement is also occurring as regions become less habitable due to the changing climate.  “Health” is another threat where climate change could be a major factor.  The document, however, is limited in its discussion, only addressing climatological patterns increasing the reach of mosquitos and ignoring its impact on the frequency and diversity of disease outbreaks worldwide.

Despite these deficiencies, it is somewhat reassuring to know there are still a few outposts of rational government operations.



Rick Perry’s Coal and Nuclear Subsidy NOPR

UPDATE: On January 8 FERC rejected the DOE NOPR

At the end of September Energy Secretary Perry sent a request to the Federal Energy Regulatory Agency to initiate a Notice of Proposed Rule (NOPR) to create “Grid Resiliency Pricing.” Under the guise of increasing grid reliability and resilience, the Trump Administration is doing nothing more than radically increasing subsidies to uneconomic coal and nuclear generating plants. This is simply an effort to artificially create demand for coal and bail out owners of nuclear generating stations.

The Administration is proposing that “fuel secure” generating stations receive “full recovery of costs” and a “fair rate of return.”  “Fuel secure” is defined as any generating station that maintains a 90 day supply of fuel on site, but might as well say “coal and nuclear generating stations” because those are the only types that can meet the proposed rule criteria.

The NOPR acknowledges that these plants would not be economic under normal market pricing schemes and are therefore subject to premature retirement.

DOE wants coal and nuclear plants to operate under monopoly pricing within what is supposed to be a wholesale electricity free market. Think about that for a moment.  An unabashedly free market Administration wants to impose what amounts to socialized medicine for certain sectors of the economy.

The NOPR alleges that these plants are essential for grid reliability and resiliency because: coal and nuclear plants that would otherwise be retired enhance grid resiliency during extreme weather such as the Polar Vortex of 2014; providing grid resiliency is not valued in wholesale markets and should be; the North American Reliability Council (NERC) agrees with DOE; the DOE staff report on reliability (a failed attempt by the Administration to claim renewable resources were a detriment to grid reliability); and (most importantly) “Congress is concerned.”

Let’s take a look at some of these assertions.

First, the threat of fuel supply disruptions. I give you Exhibit A1:

In actual fact, the greatest threat to grid resiliency from extreme weather is the quality of the transmission and distribution system. A system whose efficiency and resilience contribution could be vastly improved with a much more aggressive implementation of new smart technology.

While NERC may agree in principle that grid resiliency should be valued, the ISO/RTO Council, the organization representing all of North American wholesale power grids, has filed comment that the FERC should not issue the rule for several reasons, including “the NOPR would undermine competitive markets and Is legally Infirm.”2

The authors of the DOE Reliability study offered a few other recommendations that did not end up in the report, including the fact that what constitutes grid resiliency and how all the factors that affect it (such as fuel security) are not well understood and merit considerable analysis before a valid pricing method can be determined.3

Finally, the most important reason for the NOPR needs to be understood and properly characterized.  The DOE document says “Congress is concerned,” referencing a letter from the House Science and Technology Committee, a committee controlled by an extremely partisan group that promotes the interests of fossil fuel industry and unabashedly rejects climate science.

These, however, are the reasons on principle that the NOPR should be withdrawn.  There’s that other factor of cost.  Energy Innovations, LLC, evaluated the costs of implementing the NOPR under four different interpretations of how the pricing could go4, from a conservative estimate that covers the shortfall in cost from wholesale value to operating costs to break even (Reading 1), through to an aggressive case that not only offers full cost recovery but full return on capital and full dispatch even if under normal conditions the unit would not be so dispatched (Reading 4). The following table shows how these 4 interpretations might impact customers in the four regions that would be affected. (PJM = Middle Atlantic, Ohio, VA; ISO-NE =New England; MISO = Midwest; NYISO= New York State)

Source: Energy Innovations, LLC

This NOPR has the potential to significantly increase customer cost and have a dampening effect on the economy for very questionable reasons.


There is a certain irony in this attempt to reregulate from an Adminstration bound and determined to unregulate everything. One can only conclude that this is a hastily cobbled approach to bailout coal and nuclear interests that have found themselves uneconomic in wholesale power markets relative to other technologies. The NOPR ought to be rejected on its face.

If a sincere attempt is to be made to examine the issue of grid resilience and reliability, a much more careful and comprehensive analysis ought to occur.  This analysis needs to give consideration to a number of factors that can affect reliability and new technologies that could enhance reliability and resilience in a much more cost effective manner.

In the absence of pricing methodologies, enormous improvements in resilience and reliability have yet to be obtained through the implementation of smart transmission and distribution technologies on all networks. Rather than burdening customers to simply prop up failing technologies, consider investments in new ones that provide long term solutions.




2 Comments of the ISO/RTO Council on the September 28, 2017 Notice of Proposed Rulemaking by the Department of Energy



Latest Manufactured Scandal: the Uranium One Deal

The Clintons certainly have a knack for attracting  right wing ire over non-events.   So it seems is the case with the latest manufactured scandal, Uranium One (U1) and the Clinton Foundation.  Amid the calls for investigations from the right, certain elements of the media have grossly mischaracterized aspects of the deal, implying that it poses a threat to national security by selling 20% of all US uranium to Russia. And since the principal party on the Russian side make large contributions to the Clinton Foundation while the deal was going through approvals, national security was sacrificed to the greed of the corrupt Clintons.

I’ll leave it to others to opine on whether the Clintons should have seen this coming and perhaps not accepted the donations, particularly since they do, indeed, appear to have been made to grease the skids. The bottom line here will be that nothing was done illegally, however it will nonetheless leave a bad taste in a lot of people’s mouths.

But let’s take a look at the reality of this deal and all that the right-wing media seems to be implying.

They allowed a US company to be bought by the Russians!

U1 was never a US company.  It was a Canadian company headquartered in Toronto with some US assets.

They’re sending 20% of our uranium to Russia!

First, U1 does not hold 20% of US uranium. U1 is the owner of the Willow Creek mine in Wyoming. Theoretically, U1 controls 20% of production capacity, not reserves. In 2014 it only produced 11% of US total production.  By 2016 the percentage of U1 production fell to 1.1% of total US production because its costs are not economic relative to world market prices.

But that’s only a piece of the puzzle.  Most people don’t realize that the US nuclear power industry mostly runs on foreign, imported uranium.  The chart below shows the annual consumption and percentage of that consumption that is foreign.  For the last 20 years US uranium purchases averaged 85% foreign origin. Why? Because US uranium deposits have never been cheap to mine; foreign sources, including Canada, are a lot cheaper. In 2016 about half of foreign uranium bought in the US came from Canada and Kazakhstan.


Second, under current law and the license from the US Nuclear Regulatory Commission, U1 is prohibited from exporting this uranium.  They would have to apply for an export license which, as you might gather, would be difficult to obtain. Bottom line- it all stays in country.

Where’s the beef?

Under any other circumstances this deal would be considered just one of many global transactions that happen to involve the US subsidiary of a foreign country, a transaction that ultimately had zero impact on US security of uranium supply, the industry as a whole and especially national security. Unfortunately, we now have the perfect storm of a) Hillary Clinton and the Clinton Foundation name involvement; b) a low information audience; c) the need on the right for any handy topic to divert attention from more serious matters; and d) “journalists” manufacturing another “outrage” of little substance.



US Nuclear Regulatory Commission Materials License SUA-1341

Uranium Marketing Annual Reports (2000, 2001, 2008, 2016), US Energy Information Agency

“Does Russia Really Own 20% of The US’ Uranium Reserves?” retrieved 10/27/2017

Is Biomass Carbon Neutral? Depends On How Much Time You Have

It is almost axiomatic within the renewables community that the combustion of biomass is carbon neutral.  That is to say that virtually all carbon released by burning will ultimately be offset by the absorption of carbon by new growth, provided the agricultural scheme deployed is renewable and sustainable. This assumption regarding the carbon neutrality of wood combustion is even being pushed in current Congressional legislation. While burning some biomass feedstocks might be carbon neutral, real questions arise when the fuel is wood, especially in the form of wood pellets.  A growing body of evidence concludes that the use of wood pellets can be highly detrimental to the environment and, in actual fact, emits as much or more carbon than fossil fuel.

It is true that the carbon released by combustion sooner or later is reabsorbed by sustainable forests.  The problem is timing.  The Paris accords had as its objective the promotion of measures that would keep global temperature rise to 1.5o C by 2030.  Realistically 2.5o C is probably the best achievable.  But either way, what is most crucial is reducing carbon over the next 15 or 20 years. A recent report by the National Resources Defense Council (NRDC) takes an in-depth look at this issue and. [1]

Burning wood pellets emits about 1.5 times the carbon per unit of energy than coal and 3 to 4 times the carbon per unit energy of natural gas. And it does so all at once.  This creates what’s called a carbon debt that gets repaid be reabsorption over time.  That time frame is quite long depending on the proportion of whole trees used to make the pellets.  The NRDC study cited above showed the following results.


Source: NRDC


Source: NRDC

The higher the portion of whole trees used (Figure 1) increases the time frame of paying off the carbon debt.  In the case of 70% trees burned today, the debt does not start to be paid off until 2065. If only 20% trees are used (Figure 3), where the source is primarily wood waste and forest debris, the carbon emissions are less, but the payoff times are the same. (The NRDC study looked at bottom land hardwood forests in the southeastern US for this data.)

“Premium” wood pellets tend to be solely from whole trees, both soft and hardwood.

These “payoff” times are well beyond the critical period when carbon reductions are necessary.  So while it is fair to say that wood pellet combustion is theoretically carbon neutral, the question is how long you are willing to wait for the carbon debt generated with combustion is “repaid” through subsequent sequestration.

During this critical time frame of the next 15 to 20 years, wood pellets from a high proportion of whole trees emit more carbon than any fossil fuel.  In lesser proportions, wood pellets are no better than coal or natural gas. Simply not using whole trees is an option, however other studies have noted that available forest residuals alone cannot meet current biomass demand.

As you might expect, this is a matter of considerable controversy and has become a hot political topic in 2016. The current Senate energy bill (S. 2012) includes a provision that directs the Environmental Protection Agency (EPA) to classify woody biomass as a carbon neutral. Doing so would allow biomass to be an allowable alternative to coal under the administration’s Clean Power Plan. Pending House and Senate Interior Appropriations bills include similar direction to the EPA.  Frankly it appears that, once again, business interests are attempting to ignore or override the scientific evidence.  The Obama Administration, in a July Statement of Administration Policy regarding one of the House Appropriations bills (H.R. 5538), offered the following statement:

Classification of Forest Biomass Fuels as Carbon-Neutral. ….The Administration strongly objects to language under the heading “Administrative Provisions—Environmental Protection Agency” in the bill, which would compel EPA to disregard the scientific recommendations of its own Science Advisory Board and other technical studies.”

There are ancillary effects to classifying biomass as an acceptable fossil alternative.  If biomass were not allowed as part of the solution, a greater amount of truly clean sources would be required to meet the Clean Power Plan goals. Using woody biomass for electricity generation suppresses the use of these sources.

Given the substantial financial and lobbying resources of the industries involved in this sector it seems unlikely that science will prevail.

But that’s the story for woody biomass sourced from trees.  Biomass from other sources can certainly be renewable, sustainable and be carbon neutral within reasonable time frames.


[1] NRDC Issue Brief “Think Wood Pellets are Green? Think Again.” May 2015

Risk Based Planning and Global Insurers Key to a Global Transition to a Low-Carbon Economy

The following article was written to answer the question “In your view, what are the policies that governments should take to encourage public-private partnership and enable the private sector to develop the goods and services necessary for a global transition to a low-carbon economy by 2030?” as a submission to the 2016 Masdar Engage Blogging Contest.

NASA space program public–private partnerships are frequently recommended as a model to achieve aggressive carbon mitigation goals.   A far more sophisticated approach than used by NASA will be required, involving a much broader array of participants including government; research and development organizations; energy and energy efficiency businesses; and the global insurance industry.  These groups must be coordinated and managed using a dynamic strategic planning process.

Dynamic, Risk Based Strategic Planning

Risk based strategic planning (RBSP) begins with a defined set of end states – in this case the specific milestones for emission reductions –  and the construction of several technology development scenarios to achieve them. An inventory of current technologies that could address these goals which are available or in development is taken and the risks associated with each are assessed, including the likelihood of commercialization, energy and market economics, access to financial resources, potential regulatory barriers and environmental impact.  Using risk thresholds, the portfolio is culled to optimize achievement of scenario goals.  The process is continuous with assessments conducted on a regular basis to pare and shape the portfolio.  Such an approach would allow for a systematic optimization of carbon mitigation through technology development.

Stakeholder Roles

R&D organizations and the private sector involved with energy generation and energy efficiency will contribute to the process by providing input to its development and management as well as implementing the technology development defined in the RBSP process.  Their traditional roles will continue, albeit managed somewhat differently.  The roles of government and the insurance industry, however, are unique to this plan.


In addition to the traditional policy direction, government needs to be directly involved in the creation and management of the RBSP process.  This cannot be done using the traditional “ivory tower” approach.  Government must articulate directional policies and provide the foundation for the creation and management of the RBSP in close cooperation with all of the stakeholders. Given its risk based approach and the assessment techniques necessary, the insurance industry’s involvement will be key.  In addition, government can provide financial resources to and incentives to mitigate the financial risks associated with each technology’s development and commercialization.

Government has another important role as it relates to loosening exclusionary intellectual property as well as anti-trust regulation.  IP protection, at least as it is currently being conducted, is a barrier to rapid and collaborative technology development. One need only consider the beneficial impact of limiting IP exclusivity on the U.S. aviation industry between the world wars or the integrated circuit industry in the 50’s and 60’s.  All parties need to be willing to share IP and have the ability to collaborate in ways that would be illegal under current anti-trust regulation.

Global Insurance

The Insurance industry routinely influences public and private decisions in many areas of our economy, some less apparent than others.  Global reinsurance companies are well aware of the long term liabilities inherent in increasingly extreme weather and the rise in global temperatures.  Quietly this industry has been modifying policies for insureds that reward efforts to reduce carbon and increase energy efficiency for the past 20 years.  Global insurance would play a vital role by applying its core competencies of sophisticated risk assessment and mitigation to the RBSP process as well as aligning its own products with the goals of the process.

Fundamental changes in the roles of government and industry, as well as inviting the global insurance industry to play a very significant role, will be necessary to achieve the COP21 goal of limiting the rise in global temperature to 2 degrees C by 2030.

Guest Post: Ontario Adaption to New Energy Economy

Guest post is from Emma White from was founded in 2011 by migration lawyers and it provides professional consular service to Australia. Emma White is an environment enthusiast and wiling to devote her knowledge to make a better world.

How Ontario is getting ready to join the new energy economy in Canada

Canada is not that far behind the U.S. and Europe when it comes to implementing the new energy economy. The city of Ontario is looking forward to have a clean, ground-breaking and profitable energy economy due to the weakening of the oil sector in Canada. If Ontario can make this happen, then Canada will be leading the pack of countries when it comes to a clean and profitable energy sector. It will also be a new element that is added to the already present renewable energy assets. It has been discovered that with the new energy economy, more jobs will be available for people in Ontario and elsewhere in Canada. It has also been discovered that air pollution-related deaths will be decreased drastically due to the implementation of renewable energy sources. More and more places around the world have begun to realise the importance of renewable energy sources and Ontario is no different.

Renewable Energy Sector for Electricity

Ontario has already invested in a huge renewable energy sector that consists of wind and solar generation, which is an addition to its hydro stations. The only problem is sometimes it produces more electricity than what the city of Ontario needs. There have been ideas and solutions given, such as selling the excess electricity to the neighbouring countries, but even that is a problem when these neighbouring countries are looking for solutions too for their excess electricity. The only solution left in this situation is to give neighbouring places the excess electricity for free or even pay them to absorb the excess electricity. This is why Ontario is has created a program when it comes to energy storage solutions that will secure a storage capacity that is able to withhold 50 megawatts of energy.

More Ideas for New Energy Economy Storage Solutions

By using wind, solar, hydroelectricity and bioenergy as renewable energy sources, Ontario is not the only city in Canada riding on the new energy economy train, other cities in Canada are working hard with their new inventions for a new energy economy. In Toronto at the MaRs centre, Hydrogenics Corp. is converting electricity into hydrogen, which will be used as an addition to natural gas. Renewable Energy Systems Canada Inc. is also busy creating newer, better and more efficient batteries. Hydrostor is occupied storing compressed air, which can be used to generate electricity whenever required, from the water pressure of Lake Ontario off Toronto Island. More ways are being given to help expand renewable energy generation. More ideas are being produced to encourage energy conservation. More planning is being put to promote the conception of clean energy jobs.

Promoting New Energy Economy in Ontario

The government of Ontario has been promoting the new energy economy to its people and how they can help through the little things. Steps, such as buying food and goods that are made in Ontario are being highlighted to its people. Ontario is also promoting clean travel by urging its people to travel more on bikes and public transport, which will make for lesser cars on the road. Residents are also being requested to start drinking water directly from the tap instead of using water bottles. Aside from these promotions, the government of Ontario is also asking its people what they want to see as part of the new energy economy.

Slow Steps towards New Energy Economy

Canada wants a clean-energy economy and the country wants it fast, but not at all costs. This is why all the cities in Canada are taking steps towards a new energy economy. The reasons why Canada wants all of its cities to move towards a new energy economy are for its economic and social well-being as well as for the health of its people, especially children. It is a well-known fact that the current oilsands mining situation comes with bad health impacts, which is why this country wants a clean-energy economy. More jobs are becoming available for sectors that work under the new energy economy, as more and more solar panels and wind turbines are being built. In Ontario, wind energy is growing significantly, which makes more domestic and foreign companies wanting to invest in this city.


German Electricity Rates Projected To Return to 2015 Levels by 2035

In 2015 Germany enacted a law whose short title is the Renewable Energy Sources Act of 2014 (Erneuerbare-Energien-Gesetz, or EEG 2014).  EEG 2014 formalizes the fundamental shift in energy policy in Germany, the Energiewende, from a coal and nuclear system to one which requires the mix of electricity generation in Germany to reach 40% – 45% renewable sources by 2025 and 55%- 60% renewable sources by 2035.  This is to be encouraged by feed in tariffs that guarantee prices for new renewable entrants while requiring grid operators to receive and purchase electricity from these sources.  As expected, EEG 2014 met with some criticism, primarily a claim that it would be too expensive. Agora Energiewende, an energy policy group, commissioned the Oeko Institute e.V. to model the effects of EEG 2014 specifically on its likely impact on consumer electricity rates.  The report* concluded that:

  • The cost of electricity to consumers increases through to 2023 by between one and two cents per kwh, but then declines at a rate of between two and four cents/kwh until 2035. In 2035 rates are forecasted to be the same as 2015 – 8 to 10 cents/kwh.
  • By 2035 60 percent of German electricity will come from renewable energy sources, from about 28% today.
  • As the real costs for renewable generation decline, the primary drivers to the incremental costs of the German Energy Plan become the actual demand levels and the extent to which energy intensive industries are subsidized.
  • Investments in renewable energy increase through 2023 and then decline, however renewable energy’s share of the generation mix continues to rise.

The assumed generation mix that was used in the reference case for this study is presented in the figure below:

EEG Ref Generation

Source: Oeko Institut 2015, EEG Model

This translates to the following projected share of the overall electricity source mix for renewables:

EEG Renew Share

Source: Oeko Institut 2015, EEG Model

EEG 2014 provides for the following feed in tariffs, cents/kWh:

2015 2025 2035
Onshore Wind 8.9 7.2 5.3
Offshore Wind 19.4 14.3 10.9
Solar 11.0 10.3 8.4
Biomass 17.7 16.0 14.5
Geothermal 25.2 19.6 15.2
Hydro 11.7 11.2 10.6
Average Mix 14.8 10.6 8.1

Source: Angora Energiewende

Note that the system average feed in tariff declines over time.  Nonetheless, these tariffs are significantly higher than wholesale power costs from conventional sources.  Under EEG 2014, transmission system operators (TSOs) are permitted to charge electric utilities an “EEG Levy” to compensate them for paying these feed in tariffs and the utilities pass these charges on to consumers.

The EEG Levy assumed in this analysis, along with the base cost of electricity, is shown in the following graphic.

EEG Rates

Source: Oeko Institut 2015, EEG Model


Based on the assumptions inherent in this analysis, the overall cost of electricity to the consumer rises a few cents in the early 2020’s and then declines to rates comparable to rates experienced in 2010.

The Big Loophole

Not all consumers are subject to the EEG Levy, however.  Many electricity intensive industrial and commercial end users have received exemptions from the EEG Levy, a point of considerable controversy in the country.  58 TWh are totally exempted and 110 Twh are partially exempted. Most notably residential customers pay full freight.  Were there less exemptions, the EEG Levy would be much lower, as shown in the figure below.  No exemptions for any customer basically cuts the levy in half.

EEG Loophole

Source: Oeko Institut 2015, EEG Model

The EEG Levy cannot be viewed in isolation, however.  No doubt applying the levy to all industries would have some concomitant effect on the economy and some exempting is necessary.  That said, however, even with loopholes, maintaining a relatively flat trajectory on consumer rates while radically increasing the renewable energy mix in electricity generation to over 60% will be quite an achievement.


*Agora Energiewende “Die Entwicklung der EEG-Kosten bis 2035” May 2015:

The Recent “Mind Bogglingly Stupid”* Arguments Against Fuel Cell Vehicles

During a press conference at the Automotive News World Congress in February Elon Musk was famously quoted saying hydrogen fuel cells are “extremely silly,” and that fuel cell electric vehicles (FCEVs) are “incredibly dumb.” He made two arguments to support this view – that electrolysis to generate hydrogen is way less efficient than using solar to charge vehicle batteries and that hydrogen was an unsafe fuel. So this is pretty transparent: it’s just the old slam-your-competition marketing ploy.  Musk’s Tesla must feel pretty threatened by the spate of fuel cell electric vehicles coming on the market, especially in Japan and California. But then a month later we get Climate Progress publishing an article by Joe Romm seconding Musk’s view and supporting his opinion with actual charts.   Romm’s analysis, with all its credentials, is no better than Musk’s uninformed off the cuff commentary.

Romm essentially recycles an article he published in Scientific American in 2006 where his primary criticism, as I interpret it, follows this equation:


REI=> (CHG) or (EWMFC) => EMP


REI=Renewable power in

CHG= Charge battery

EWMFC=Electrolyze water for hydrogen, make fuel cell

MP=Energy expended motive power

In the case of a FCEV fueled with hydrogen from renewably generated electrolysis, only 20% to 25% of REI ends up as EMP.  An electric vehicle (EV) charged with renewably generated electricity gets 75% to 80% of REI.


That’s it.  The sum total of the argument. Note the complete absence of any economics. Eliminating cost (and the discussion of other paths for zero emission FCEVs) relegates this whole argument to the realm of fierce debates over how many angels dance on the head of a pin.  Perhaps intellectually challenging, but irrelevant to the market or to policy decisions.  Think about it: install a solar array at a particular cost. Use its output to operate an electrolysis unit for hydrogen or use it to charge batteries.  Is one more efficient in the use of solar power? Sure.  But does it matter? No. Either way you have a true zero emission vehicle.  And as long as the cost per mile is competitive, it makes sense in the market place. Might the battery vehicle be a little cheaper in cost per mile? Perhaps, but what if the end user is willing to value range, where the FCEV wins hands down?

The reality, however, is that we are on the cusp of a new market of lower emission vehicles.  The zero emission world is still a good distance away because economics are a real factor.  That means we need EVs and FCEVs, and it also means that they are not completely “green” but rather olive drab.  EVs in most places will not be charged with renewable electricity but from whatever the local grid supplies, and that can be pretty dirty.  Most FCEVs will get their hydrogen from natural gas – its use in a fuel cell is an improvement over direct combustion but still results in carbon emissions.

The bottom line here is that simplistic assertions are no more than that, and while soundbites in headlines attract, they are not analysis and should not be taken seriously.

** Headline in EV World, July 7, 2014 “Musk: Fuel Cells ‘Mind Bogglingly Stupid'”

Is That Fuel Cell Economic? Forget cents/kWh or GGE

It’s very easy to find graphics that compare the cost of several forms of emerging energy technologies.  In the case of fuel cells, since they make electricity to perform a task, the metric used is the cost of a unit of electricity: (pick your currency) per kilowatt-hour or cents/kWh.  In vehicular applications, an attempt is made to equate hydrogen fuel with gasoline, generating the absurdly fictitious “gallon of gasoline (or liter of petrol) equivalent” or GGE.  If you see these metrics used, you are witnessing one of the greatest failures of the fuel cell industry: its inability to articulate its worth.

Allow me to demonstrate how daft and self-defeating these comparisons can be.  We all use batteries in our daily lives.  Batteries generate electricity, which we put to good use.  The going rate for AA batteries is broad, but to pick a number, a 4 pack of Energizer batteries is $4.01, or about $1/battery.

Each battery provides a little less than 3 watt hours of electricity.  That means that if you compared AA batteries with other forms of generation, its output would be about $330/kWh.    Now let’s take that value and do the conventional comparison with other generation forms, shown below.  Note that this uses a logarithmic scale.

Clearly it looks horribly expensive.  But here’s the thing- we don’t value the AA battery for its costs of electricity, we value it for its convenience and size.  Relative to other kinds of electricity generation, it costs a fortune, but only because we are using the wrong metric.  A friend and mentor reminds me frequently that what is being sold is the product of the product, not the product itself.  And so it goes with fuel cells.

This is readily apparent in three applications where fuel cells are deemed commercial and where sales are happening every day: remote telecommunications backup power; uninterrupted storage and as replacement drives for battery systems in materials handling equipment.  In each case, what make the fuel cell commercially viable is its context in an economic system that values the attributes of its output, not the actual output itself.  Consider any of the following factors:

  • Avoided costs of equipment to achieve desired level of enhanced:
    • Reliability
    • Power Quality
  • Avoided costs of battery maintenance and disposal
  • Value of quiet operation
  • Avoided fees and penalties for emissions for certain industries
  • Longer operational periods in EPA non-attainment areas
  • Much longer operation in battery replacement applications
  • Portability

Each one can be valued and monetized in the overall economic equation.

Total Cost of Ownership (TCO)

A far better metric and methodology for evaluating the commercial viability of fuel cells is total cost of ownership (TCO), a form of life cycle cost analysis.  Investopedia defines TCO as “The purchase price of an asset plus the costs of operation. When choosing among alternatives in a purchasing decision, buyers should look not just at an item’s short-term price, which is its purchase price, but also at its long-term price, which is its total cost of ownership. The item with the lower total cost of ownership will be the better value in the long run.”

Materials Handling Equipment

Use of TCO is best illustrated by the business case for fuel cell replacements in electric drive systems for materials handling equipment.  Virtually all indoor forklift trucks are battery powered electric units. A recent DOE report provides a detailed analysis, summarized below.[i]

The relevant costs of ownership include the following items:

  • Cost of the bare forklift
  • Cost of the required battery or fuel cell systems
  • Cost of battery changing and charging or hydrogen fueling infrastructure
  • Labor costs of battery changing or hydrogen fueling
  • Cost of energy required by the forklifts
  • Cost of facility space for infrastructure (indoor and outdoor)
  • Cost of lift truck maintenance
  • Cost of battery or fuel cell system maintenance.

When each of these cost elements are evaluated, the following table results for a hypothetical Class I or Class II forklift:

Total Annual Cost of Ownership
Cost Element Battery Drive Forklift Fuel Cell Drive Forklift
Amortized cost of truck $2,800 $2,800
Amortized cost of Battery or Fuel Cell Unit $2,300 $2,600
Per Truck Cost of Charging Battery/ Fuel Cell Hydrogen Fueling Infrastructure $1,400 $3,700
Labor Cost for Charging or Refueling $4,400 $800
Cost of Electricity/Hydrogen $500 $2,400
Infrastructure Warehouse Space $1,900 $500
Forklift Maintenance $2,800 $2,800
Battery/ Fuel Cell Maintenance $3.600 $2,200
Total Cost of Annual Ownership $19,700 $17,800


If one only looked at the total costs of the forklift plus drive unit, the fuel cell unit is more expensive.  Add in the cost of charging batteries, the cost of hydrogen and the charging/fueling infrastructure, the fuel cell looks that much worse. Now factor in the productivity costs or gains: the labor cost for refueling a fuel cell is far less than that of a battery unit; the warehouse costs are far less, as is the maintenance costs of the drive units.  At this level of analysis, the fuel cell drive is the clear winner, although it represents a discrete set of values.  An analysis which looks at the sensitivity of each of these parameters underscores the clear choice of the fuel cell drive unit.

Source: NREL

There are other increases to productivity for the fuel cell that these analyses do not capture.  Over a normal shift, the battery loses capacity such that near the end of a shift it cannot lift the same amount of material to the same heights.  Fuel cell units retain their power as long as they have fuel available.  In some cases, more electric drives need to be purchased to compensate for long battery recharge times and the diminished capacity of units over shifts.  Finally, while the costs of battery maintenance are included above, the environmental cost of battery disposal are not.  Fuel cell units do not have that problem.

A similar analysis can be performed for remote telecom site backup.  In this case, the fuel could either be a liquid (operating a methanol fuel cell), or compressed hydrogen.  Diesel generators or battery units require maintenance, with very high labor costs attributed to simply getting to the site and returning.  A fuel cell unit, once installed and made ready for operation, eliminates a considerable amount of potential labor costs.  In addition, it does its work without emissions and without noise.

Gallon of Gas Equivalent

The GGE metric, when applied to hydrogen fuel cells, is one of the most inappropriate attempts to compare one type of fuel system with another.  Clearly it was created on the assumption that it would be easy for the general public to understand.  All it does is obfuscate reality.  GGE works as a comparison basis when we are talking about fuel use in an internal combustion engine which resides in a vehicle that was designed with an internal combustion engine.  Period.  The only time GGE would apply to a hydrogen fueled vehicle would be if hydrogen was being combusted in a conventional engine.  Further, GGE by definition relies on petroleum economics to set price and petroleum market dynamics have nothing to do with the cost of hydrogen.  A fuel cell vehicle is designed to accommodate a fuel cell and make best use of its attributes.  It is far more efficient than combustion engines and makes best use of the available electricity to incorporate features not found in today’s vehicles.

The introduction of fuel cell vehicles offers the opportunity for end users to think about their transportation quite differently from what is on the road today.  Instead we persist in talking about these new vehicles in terms that do not fit.  Most egregious is the continued use of GGE as a filter to determine where R&D funding should go for hydrogen vehicles and refueling infrastructure.  For several years, if someone guessed that a particular project or concept could not beat $3.50 GGE it was rejected.  Achieving lowest cost is certainly a goal but using the wrong yardstick is just plain stupid.

A far more appropriate metric for comparing new and emerging vehicles (and the R&D associated with them) is cost per distance.  This metric would apply to fuel cells and to electric vehicles.

Emerging Energy Metrics

As new forms of energy emerge in this new energy economy as much care needs to be taken in their evaluation to assure that we take fully into account the change in perspective that comes with them.  The risk in using old methods to consider new concepts is that we miss altogether their potential.

[i] Ramsden, Ted USDOE “An Evaluation of the Total Cost of Ownership of Fuel Cell-Powered Material Handling Equipment” NREL/TP-5600-56408. April 2013