Comments - Energy Submission - by Doug Lewin

Please see this reference, the part of it which calculates the unsubsidized levelized cost of energy. https://www.lazard.com/media/0hqfye2m/lazards-levelized-cost-of-energy-version-120-vfinal.pdf. It’s not as favorable as you seem to think. And as you write, it’s not intended for grid reliability planning—but renewables intermittency and lack of reliability impose costs on the grid which have to be paid. The inverters in use in the Texas grid are grid-following (GFL) inverters, which have no inertia. As a result of that lack of inertia, ERCOT is paying over a billion dollars to install 6 synchronous condensors in west Texas and elsewhere. The cost of those are not included in the LCOE, even though they are the direct result of the amount of wind and solar on the grid.

Texas has experienced two substantial outages related to those inverters, one in 2021, and another in 2022. The second knocked 2.2 GW of generation of the grid, which was classified as a NERC 3a category outage. Fortunately, they did not create a cascading outage which took down the entire grid. Those incidents are referred to as Odessa I and Odessa II.

In 2021, ENTSO_E, the European system operator, wrote that the lack of inertia related to the increasing amount of wind and solar on the grid posed a reliability risk to the grid. They recommended installation of synchronous condensers, and converting the inverters from grid-following inverters to grid-forming inverters (GFMs), which are capable of providing synthetic inertia to the grid, as well as being islanded. It wasn’t done. On April 28th of this year, Spain and Portugal experienced a total blackout, when an estimated 71 to 74 percent of the power was being supplied by renewables.

NERC, in it’s 2025 reliability assessment wrote of the increasing risk of outages related to the lack of dispatchable thermal generation on all of the U.S. and Canadian grids, and predicted that MISO was at risk of rolling blackouts this summer, because of retirement of thermal generation unable to compete on the market with subsidized renewables. And that’s already happened in Louisiana.

https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_SRA_2025.pdf

ERCOT has current projects investigating gird-forming inverters, and has an Inverter Based Resource Working Group (IBRWG) to resolve the problems created by renewables on the grid.

LCOE is a scam which ignores the reliability cost of renewables.