Windaction.org comments to FERC regarding integration of renewables into the grid

Energy policy in the United States calls for the aggressive deployment of renewable generation within this decade. This policy has led to an explosion of renewable resources that operate largely off-peak, off-season and intermittently, and are located in rural areas with limited transmission. Conversely, there has been only limited development of renewable generation which operates largely on-peak, on-season, reliably or near load centers.

By the end of 2009, 35,000 megawatts of on-shore wind was installed in the United States, double that which was installed just two years ago. Barring systemic barriers imposed on renewables development, including transmission constraints, this trend is likely to continue. Based on the interconnection queues of each grid region, industrial wind is the dominant renewable resource representing more than 90% of the proposed generating capacity of all renewable energy projects in the United States.

Last January, the Federal Energy Regulatory Commission (FERC) issued a Notice of Inquiry (Docket No. RM10-11-000 ) seeking public comment on whether to reform any of its rules or procedures to better accomodate variable energy resources (VERs) such as wind, solar or non-storage hydro generating plants.

Windaction.org worked with energy expert, William P. Short III, to submit comments.

We state that the true impact of our current national renewable vision is the massive public cost needed to transform the U.S. power grid to accommodate variable energy resources, despite the fact that these resources are not guaranteed to deliver energy at the very time of day and year when we need it the most.

Current policies that encourage renewable generation at the State and Federal levels reward all renewables equally for placing a megawatt-hour of energy on the grid. There is no adjustment to the federal or state subsidies based on time of day or seasonal demand requirements nor is there a meaningful adjustment for location of the power facility. These policies have created artificial and unsustainable market pressures; thus, compelling system planners to respond with more transmission and the fast-tracking of renewable projects that may be not only not needed but actually of poor quality from a grid reliability perspective.

If renewable subsidies were to discriminate in favor of those renewables that produce close to load and during the time of day and year when the energy is most needed (i.e. capacity rather than energy), we would expect the response in the market to be almost immediate. The need for expansive transmission would drop off. More renewables would be proposed for sites closer to our population centers and that can service our peak demand periods. The market would decide which renewable solutions best met the goal. Rather than seeing 125 megawatts of unpredictable wind built we might get 25 megawatts of baseload biomass; rather than remote-sited solar generation in the Mojave desert requiring 100 to 200 miles of new transmission, we may see a greater effort to build rooftop solar in California's cities. Reliable generation would mean less need for storage, less redundant generation and a better opportunity for replacing fossil fuel generation with renewables rather than merely displacing some fuel.

While public policy regarding renewables has helped the emerging renewables market, it is time these policies were amended to better suit the public's needs. We recommend abandoning ill-defined plans to reinvent our existing electric system so it can better accommodate variable energy renewable sources, and focus on consumer-centric, market-based policies that will move us towards real world, reliable solutions for our renewable generation.

There is still time for interested parties to file comments with the FERC. The deadline for filing has been extended to April 12, 2010.