On February 7, 2024, the US Department of Energy (DOE) and FEMA released a joint study suggesting that Puerto Rico has the potential to transition to 100% renewable energy. [1] The study highlights the feasibility of this transition, emphasizing the island's abundant renewable resources and the benefits of reducing dependence on imported fossil fuels. By harnessing solar, wind, and other renewable sources, Puerto Rico could enhance energy resilience, reduce greenhouse gas emissions, and lower energy costs for residents. The report underscores the importance of strategic planning, infrastructure investment, and policy support in realizing this ambitious goal. It also highlights the role of federal agencies in providing technical assistance and funding opportunities to support Puerto Rico's renewable energy transition. Overall, the study provides a roadmap for Puerto Rico to achieve energy independence and sustainability while enhancing its resilience to future disasters and climate change impacts.
[USA] DOE announces $34 million in funding for technologies to underground power lines
On January 16, 2024, the Department of Energy (DOE) announced $34 million for 12 projects across 11 states to strengthen and modernize America’s aging power grid through the development of cost-effective, high-speed, and safe undergrounding technologies.[1] Selected projects in the program, called the Grid Overhaul with Proactive, High-speed Undergrounding for Reliability, Resilience, and Security (GOPHURRS), will advance innovative solutions to help upgrade and expand the nation’s grid infrastructure—lowering costs, reducing inefficiencies, mitigating disruptions from extreme weather events, and accelerating the adoption of renewable clean energy resources.
The electric power distribution system in the U.S. has over 5.5 million line-miles with over 180 million power poles and is susceptible to damage by weather and its effects, accounting for a majority of power outages in the country each year. Extreme weather events fueled by climate change are increasing the frequency and intensity of power outages across the U.S. Undergrounding power lines can improve the system reliability for both transmission and distribution grids. Managed by DOE’s Advanced Research Projects Agency-Energy (ARPA-E), projects under the program will play a critical role in developing technologies to reduce costs, increase speed, and improve the safety of undergrounding operations.“Modernizing our nation’s power grid is essential to building a clean energy future that lowers energy costs for working Americans and strengthens our national security,” said U.S. Secretary of Energy Jennifer M. Granholm. “With today’s announcement, DOE is supporting teams across the country as they develop innovative approaches to burying power infrastructure underground—increasing our resilience and bringing our aging grid into the 21st Century.”
[1] https://arpa-e.energy.gov/news-and-media/press-releases/us-department-energy-announces-34-million-improve-reliability
[USA] Hertz announces plans to sell part of its EV rental fleet
On January 11, 2024, car rental company Hertz Global Holdings said it is selling about a third of its global fleet of electric vehicles (EVs), including 20,000 EVs from its U.S. fleet.[1] Hertz will use some of the proceeds to buy gasoline-powered vehicles. Previously, the company had aimed to convert 25% of its fleet to electric by the end of 2024. The company had also planned to order 100,000 Tesla vehicles by the end of 2022 and 65,000 units from Polestar over five years. In a regulatory filing with the Securities and Exchange Commission, the company cited low customer demand and high maintenance costs for EVs. Hertz expects about $245 million in charges related to depreciation expenses from the EV sale in the fourth quarter of 2023. Hertz said it would focus on improving profitability for the rest of its EV fleet.
[1] https://www.reuters.com/business/autos-transportation/hertz-sell-about-20000-evs-us-fleet-2024-01-11/
[USA] Puget Sound Energy and Form Energy partner to evaluate multi-day energy storage solutions
On January 5, 2024, Puget Sound Energy (PSE) and energy storage developer Form Energy announced that they had signed a memorandum of understanding (MOU) to look into deploying a pilot multiday energy storage system to help PSE meet state requirements for clean energy and customer expectations for reliable service.[1] The partnership will allow both companies to collaborate on the development of a 10 MW, 100-hour iron-air battery pilot within the utility’s service area. The companies will evaluate the potential benefits of Form Energy's technology, as well as determine an initial project configuration that could be deployed by the end of 2026.
Washington’s Clean Energy Transformation Act requires electric utilities to be coal free by 2025, carbon neutral by 2030, and 100% served by renewable and non-emitting resources by 2045. Utilities in the state must replace dispatchable fossil fuel generation while meeting the growing demand for electricity from electric vehicles and other end uses. Therefore, energy storage is emerging as a key solution. Multi-day energy storage can provide power over several days compared to most commercially available batteries that supply only about four hours of backup power. Energy storage systems are crucial for PSE, offsetting the need for the utility to build additional generation resources that are used only at times of high demand.
[1] https://www.pse.com/en/press-release/details/Puget-Sound-Energy-partners-with-Form-Energy-to-evaluate-multi-day-energy-storage-solutions
[USA] PJM forecasts long-term electricity demand growth through 2039
On January 8, 2024, PJM Interconnection released its long-term load forecast, which laid out its predictions for estimated electricity demand growth.[1] The forecast estimated a 1.7% annual demand growth for summer peaks, 2% for winter peaks, and 2.4% for net energy over a 10-year planning horizon starting in 2024. The 2024 summer peak load is 151,254 MW, increasing to 178,895 MW in 2034 and 193,123 in 2039. Peak winter load is forecasted at 134,663 MW for the 2023–2024 winter, increasing to 164,824 MW in 2034 and 178,241 in 2039. Overall, total annual energy use throughout the PJM footprint is expected to increase nearly 40% by 2039, from 800,000 GWh to about 1.1 million GWh.
According to the long-term forecast, rising energy demand in PJM’s footprint, which includes all or part of 13 states and the District of Columbia, is increasingly driven by the development of data centers throughout the PJM footprint. Further, the acceleration of the accelerating electrification of transportation and industry is a big factor. Currently, PJM has about 500,000 light-duty electric vehicles (EVs) as of 2024, and S&P Global is forecasting about 23 million light-duty EVs by 2039, a growth rate of just under 30% annually during that period. Also, PJM has about 25,000 medium- and heavy-duty EVs as of 2024, and S&P Global is forecasting about 1.45 million medium- and heavy-duty EVs by 2039, 30% annual growth rate.
[1] https://insidelines.pjm.com/pjm-publishes-2024-long-term-load-forecast/
[USA] Biden administration grants $623M in funding for EV charging infrastructure
On January 11, 2024, the Department of Transportation (DOT) announced $623 million in grants to build out the electric vehicle (EV) charging network.[1] The Biden administration aims to build at least 500,000 publicly available chargers by 2030. The grants announced by DOT are part of the Bipartisan Infrastructure Law’s $2.5 billion Charging and Fueling Infrastructure (CFI) Discretionary Grant Program. They will fund 47 EV charging and alternative-fueling infrastructure projects in 22 states and Puerto Rico, including the construction of about 7,500 EV charging ports. As part of the announcement, the Federal Highway Administration will award $311 million to 36 community projects, including two Indian Tribes in Alaska and Arizona. Community projects invest in EV charging and hydrogen fueling infrastructure in urban and rural communities. Another $312 million in funding will go to 11 corridor recipients whose projects are located along roadways designated as Alternative Fuel Corridors. Corridor projects will fill gaps in the core national charging and alternative-fueling network.
More than 70% of the announced CFI funding will support project sites in disadvantaged communities, advancing the Biden administration’s Justice40 Initiative, which set a goal of 40% of the overall benefits of federal investments flowing to disadvantaged communities. EV chargers constructed with CFI funds must follow the same standards established for chargers funded under the National Electric Vehicle Infrastructure (NEVI) formula program, including domestic manufacturing and workforce standards.
[1] https://highways.dot.gov/newsroom/biden-harris-administration-announces-623-million-grants-continue-building-out-electric
[USA] Avangrid, CIP announce first power from Vineyard Wind 1 has been delivered to New England grid
On January 3, 2024, Avangrid and Copenhagen Infrastructure Partners (CIP) announced that power from the first turbine of the Vineyard Wind project was delivered to the New England grid for the first time.[1] As part of the initial commissioning process, on January 2, 2024, the turbine delivered approximately 5 MW of power, with additional testing expected to happen both on and offshore in the coming weeks. Vineyard Wind is an 806 MW project consisting of consist of 62 wind turbines and located 15 miles off the coast of Martha’s Vineyard, Massachusetts. The project began offshore construction in late 2022, achieved steel-in-the-water in June 2023, and completed the nation’s first offshore substation in July 2023. Power from the project interconnects to the New England grid in Barnstable and is transmitted by underground cables that connect to a substation further inland on Cape Cod. Avangrid and CIP jointly own Vineyard Wind. The project is being developed and constructed by Avangrid and Vineyard Offshore, CIP’s affiliate development company working on U.S. offshore projects. The developers expect to have five turbines operating at full capacity early in 2024.
[1] https://www.vineyardwind.com/press-releases/2024/1/3/cip-avangrid-announce-first-power-from-nation-leading-vineyard-wind-1-project
[USA] EPSA study examines system-wide costs of integrating energy resources in PJM
On December 18, 2023, the Electric Power Supply Association (EPSA) released a new analysis that looks at the impacts of different energy resource options on the reliability of the electric grid.[1] The report is an effort to better look at the “full-cycle” levelized cost of electricity (LCOE), including the impact of regional costs, interconnection costs, curtailment costs, and the cost of ensuring that all units can provide an equivalent level of resource adequacy to the grid. It also seeks to provide a fuller picture of the true costs of integrating different energy resources onto the grid—with important implications for policymakers, regulators, and voters. The analysis was conducted by FTI Consulting on behalf of EPSA and utilized publicly available data from PJM Interconnection, which covers more than 65 million Americans across 13 states and the District of Columbia. The metric was developed using PJM’s cost and demand forecasts looking ahead to 2026.
A key finding of the study was that the cost of providing resource adequacy services is more than 100% of the traditional LCOE cost of wind and solar units. In addition, while traditional LCOE is lower for wind and solar units compared to combined cycle natural gas units in PJM in 2026, when accounting for the full cost of connecting to the system and providing resource adequacy services, natural gas plants are more competitive. The study also found that tax credits are crucial for making carbon capture and storage (CCS)-equipped units economical, even at the low technology costs assumed by the National Renewable Energy Laboratory (NREL). Further, small modular nuclear (SMR) nuclear units are competitive with other forms of non-emitting generation when accounting for the full cost of connecting to the system and providing resource adequacy services at the technology costs assumed by NREL.
[1] https://epsa.org/new-analysis-examines-system-wide-costs-of-energy-transition/
[USA] California awards Form Energy $30 million grant for state’s largest long-duration energy storage project
On December 13, 2023, the California Energy Commission (CEC) approved a $30 million grant to long-duration energy storage developer Form Energy to build the state's largest long-duration energy storage project, capable of discharging energy to the grid for 100 hours.[1] The 5 MW/500 MWh iron-air battery storage project will be built at a Pacific Gas & Electric (PG&E) substation in Mendocino County. It is expected to come online by the end of 2025 and will help support grid reliability and demonstrate solutions needed to meet the state’s climate and clean energy goals. Form Energy’s iron-air battery is based on “reversible rusting,” meaning the system discharges energy by absorbing oxygen from the air and converting iron to rust and charges by using electrical current to convert the rust back to iron. The technology has lower costs compared to lithium-ion battery production.
The award is one of three approved under the commission’s Long-Duration Energy Storage program, which invests in the demonstration of non-lithium-ion technologies across California to create a diverse portfolio of energy storage technologies. As of August 2023, the state had 6,600 MW of battery storage, operating at the current industry standard of 4 to 6 hours of discharge. The number is projected to increase to 8,600 MW by the end of 2023. The state estimates more than 48 GW of battery storage and 4 GW of long-duration storage will be needed to meet the goal of 100% clean electricity by 2045.
[1] https://www.energy.ca.gov/news/2023-12/cec-awards-30-million-100-hour-long-duration-energy-storage-project
[USA] NERC report finds rising peak demand and planned retirements create blackout risks for most of the U.S.
In its annual Long-Term Reliability Assessment released on December 13, 2023, the North American Reliability Corp. (NERC) said rising peak demand and the planned retirement of 83 GW of fossil fuel and nuclear generation over the next ten years creates a blackout risk for most of the U.S.[1] According to the report, while most regions should have sufficient electricity supply in normal weather, the Northeast and the Western half of the U.S. are at risk of blackouts in extreme conditions. The Midcontinent Independent System Operator (MISO), the grid operator for much of the Midwest and central South regions, faces a 4.7 GW shortfall starting in 2028 if generator retirements progress as expected, despite the planned addition of more than 12 GW. NERC noted that there are 50 GW of generation with signed generation interconnection agreements that are not online and another 200+ GW of new resources in the interconnection queue that are still being evaluated. NERC also identified a potential shortfall in planned reserves in Southeastern Electric Reliability Council-Central (SERC-Central) in the 2025-2027 period as demand increases faster than the transitioning resource mix grows.
To address the growing risk, the report recommended building new gas capacity, expanding the transmission network, and developing grid planning processes to better account for variable resources and the interconnected nature of the power and gas sectors.
[1] https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_LTRA_2023.pdf
[USA] ComEd announces expansion of 765 kV substation in Illinois to support wind and solar interconnection
On December 12, 2023, ComEd announced an expansion of its 765 kW Wilton Center substation, which the utility says will support utility-scale onshore wind and solar projects in Illinois and the larger PJM energy market.[1] The substation expansion is expected to be completed in late 2026. The Wilton Center substation, constructed in 1968 near Joliet, Illinois, supports ComEd’s highest voltage transmission lines, which are used for long-distance power transmission because they minimize the amount of power lost as electricity moves from one location to the next. The facility will be expanded by approximately 50%. Work will include adding new circuit breakers, transformers, relay switches, network data, and control systems. When the expansion is completed, the substation should be able to support five wind farms and two solar farms with the capacity for up to 2,450 MW of renewable energy.
Currently, ComEd is currently working on 13 wind projects throughout Illinois, amounting to 3,120 MW of potential wind generation. One of the projects that will be supported by the Wilton Center substation is the 850 MW Heritage Prairie wind farm. The farm, which also includes 300 MW of solar generation, will be the largest wind interconnection in northern Illinois and the largest onshore wind project to date in PJM.
[1] https://www.businesswire.com/news/home/20231212571627/en/ComEd-Expanding-High-Voltage-Substation-in-Wilton-Center-to-Enable-Largest-Cluster-of-Wind-and-Solar-Projects-in-Illinois-and-PJM-Region
[Japan] BP enters Japan’s power market
On November 27, 2023, BP announced that it has entered Japan’s power market after receiving approval from the Ministry of Economy, Trade and Industry (METI).[1] BP Energy Japan (BPEJ), part of the company’s trading and shipping business, will operate the new business. In a statement, BP said the move was part of its plan to expand its investment in several areas of growth, including renewable energy and electricity. BP, which has been a supplier of liquefied natural gas (LNG), oil, petroleum products, and lubricants to Japan for over 60 years, plans to expand into low-carbon energy in the coming decades as it seeks to create a business model that can survive the global transition away from fossil fuels.
[1] https://www.bp.com/content/dam/bp/country-sites/ja_jp/japan/home/%E3%83%8B%E3%83%A5%E3%83%BC%E3%82%B9/pressrelease/documents/2023/BPEJ%20Announcement_231127%20FINAL.pdf
[USA] DOE report: Salton Sea's lithium supply could fuel U.S. clean energy expansion
A report released by the Department of Energy (DOE) on November 28, 2023, found that given expected technology advances, California’s Salton Sea region could produce more than 3,400 kilotons of lithium, enough to support over 375 million batteries for electric vehicles (EVs).[1] The mineral is critical for reaching the Biden administration’s goal of net-zero emissions by 2050 as it is key in the production of batteries for storage and EVs. Currently, the U.S. relies primarily on imported lithium. However, the DOE’s Lawrence Berkeley National Laboratory (LBNL) found that with technology advancements, the vast supply of lithium in the Salton Sea could be obtained via direct lithium extraction (DLE) from geothermal brines, a byproduct of geothermal electricity generation that often has high concentrations of minerals. The Salton Sea Known Geothermal Resource Area (KGRA) has about 400 MW of installed geothermal capacity, and up to 2,950 MW is possible in the region. According to a report from the California Energy Commission, Salton Sea KGRA is believed to have the highest concentration of lithium contained in geothermal brines in the world.
[1] https://www.energy.gov/eere/articles/us-department-energy-analysis-confirms-californias-salton-sea-region-be-rich-domestic#:~:text=Conducted%20by%20DOE's%20Lawrence%20Berkeley,the%20total%20number%20of%20vehicles
[USA] BOEM approves sixth commercial-scale offshore wind project
On November 21, 2023, the Bureau of Ocean Management (BOEM) announced that it has approved the Empire Wind offshore wind project, the sixth approval of a commercial-scale offshore wind energy project under the Biden administration.[1] The president aims to deploy 30 GW of offshore wind energy capacity by 2030. BOEM has committed to advancing 16 offshore wind projects by 2025. Empire Wind US LLC, a joint venture of Equinor and BP, will develop two offshore wind facilities: Empire Wind 1 and Empire Wind 2. The projects will be about 12 nautical miles (nm) south of Long Island, New York, and have a capacity of 2,076 MW. BOEM estimates that the projects will support over 830 jobs annually during construction and about 300 jobs annually during operations. The Record of Decision includes measures aimed at avoiding, minimizing, and mitigating the potential impacts that may result from the project. Those measures include a commitment from Empire Wind to establish fishery mitigation funds to compensate commercial and for-hire recreational fishers for any losses directly arising from the project.
[1] https://www.doi.gov/pressreleases/biden-harris-administration-approves-sixth-offshore-wind-project
[USA] EIA: North American LNG capacity to increase 113% by 2027
An analysis released by the Energy Information Administration (EIA) on November 13, 2023, found that North America’s capacity to ship liquefied natural gas overseas is expected to more than double through 2027.[1] North America’s liquefied natural gas (LNG) export capacity will increase 113% to 24.3 billion cubic feet per day (Bcf/d) from 11.4 Bcf/d today. The EIA attributed this increase to LNG export terminals coming online in Mexico and Canada, as well as LNG projects under construction in the U.S. By the end of 2027, the EIA estimates LNG export capacity will grow by 1.1 Bcf/d in Mexico, 2.1 Bcf/d in Canada, and 9.7 Bcf/d in the United States. Five LNG projects are under construction in Texas and Louisiana, the EIA said. In Mexico, developers are currently constructing three projects—Fast LNG Altamira offshore and onshore and Fast LNG Lakach, both located on Mexico's east coast, and Energia Costa Azul, located on Mexico's west coast. Two LNG export projects with a combined capacity of 2.1 Bcf/d are under construction in British Columbia on Canada’s west coast.
[USA] DOE offers $3.5B for battery manufacturing
On November 15, 2023, the Department of Energy (DOE) announced up to $3.5 billion from the Bipartisan Infrastructure Law (BIL) to boost domestic production of advanced batteries and battery materials.[1] The funding is part of President Biden’s Investing in America agenda and will create new, retrofitted, and expanded domestic facilities for battery-grade processed critical minerals, battery precursor materials, battery components, and cell and pack manufacturing. The opportunity is administered by DOE’s Office of Manufacturing and Energy Supply Chains (MESC). This funding opportunity is the second phase of $6 billion in total provided by the BIL. In the first phase, the DOE awarded fifteen projects that could catalyze over $5.8 billion in public/private investment. This next phase will boost domestic battery materials processing as well as battery production. The DOE said it will prioritize projects that create jobs for low- and moderate-income communities and support the administration’s Justice40 Initiative, a plan that 40% of overall benefits from federal investments go to underserved communities.
The DOE will prioritize next-generation technologies and battery chemistries in addition to lithium-based technologies. Other focus areas include precursor production and manufacturing for medium- and heavy-duty vehicle markets. The department said it “is also calling for projects that will increase separation of battery-grade critical materials, expand production facilities for cathode and anode materials production, and expand battery component manufacturing facilities (i.e., projects that will attract further investment into topic areas solicited in the program’s first phase).” Concept papers are due January 9, 2024, while applications are due March 19, 2024.
[1] https://www.energy.gov/articles/biden-harris-administration-announces-35-billion-strengthen-domestic-battery-manufacturing
[USA] ExxonMobil to produce lithium in Arkansas
On November 13, 2023, ExxonMobil announced plans to become a leading producer of lithium.[1] The company’s first phase of North American lithium production has begun in southwest Arkansas. ExxonMobil acquired the rights to 120,000 gross acres of the Smackover formation in southern Arkansas – considered one of the most prolific lithium resources of its type in North America—in early 2023. ExxonMobil said it “is working with local and state officials to enable the successful scale-up of Arkansas’ emerging lithium industry.” ExxonMobil will use conventional oil and gas drilling methods to access lithium-rich saltwater from reservoirs about 10,000 feet underground, then utilize direct lithium extraction (DLE) technology to separate lithium from the saltwater. The lithium will be converted onsite to battery-grade material, while the remaining saltwater will be re-injected into the underground reservoirs. The process produces lower carbon emissions than hard rock mining and requires less land.
Lithium is essential to the production of lithium-ion batteries. Demand for lithium is expected to quadruple by 2030, but nearly all lithium is currently produced outside North America. The first production target for the project is set for 2027, and the company is evaluating growth opportunities globally. By 2030, ExxonMobil aims to be producing enough lithium to supply the manufacturing needs of over a million electric vehicles (EVs) per year.
[1] https://corporate.exxonmobil.com/news/news-releases/2023/1113_exxonmobil-drilling-first-lithium-well-in-arkansas
[USA] PG&E has undergrounded 197 miles of power lines in 2023
On November 1, 2023, Pacific Gas and Electric Company (PG&E) announced as of October 30, 197 miles of powerlines have been undergrounded and energized so far in 2023.[1] That tops the 180 miles of undergrounded powerlines in 2022 and the 73 miles in 2021, which was the year that the utility’s 10,000-mile Undergrounding Program was launched. The end-of-the-year target for 2023 is 350 miles. According to PG&E, undergrounding eliminates nearly 98% of the risk of wildfire ignition from electrical equipment for about $3.40 per month per customer from 2023-2026. According to the press release, an average of about 20 miles of undergrounded line will be energized each week through the end of the year. PG&E customers in Placerville, Murphys, Elk, and Potter Valley are among those now being served and protected by underground powerlines. Expanding PG&E's electric system underground in High Fire-Risk Areas (HFRAs) will help reduce wildfires caused by utility equipment, improve reliability, and reduce the need for safety-related power outages.
[1] https://www.pge.com/en/newsroom.html?pageID=b19403d2-b47d-495d-9124-851ffea6771f&ts=1698796800979
[USA] NARUC releases report analyzing nuclear in utility IRPs
On November 8, 2023, the National Association of Regulatory Utility Commissioners (NARUC) released a new report analyzing 17 utility integrated resource plan (IRP) filings submitted between August 2019 and March 2023 to identify important trends regarding nuclear energy for consideration by state utility regulators.[1] The report, titled Nuclear Generation in Long-Term Utility Resource Planning, identified three overarching trends. First, most regulated utilities are aware of advanced nuclear technologies, but the limited time horizon in many IRPs while the anticipated deployment dates for many advanced technologies fall outside that time frame. Furthermore, uncertainties around the technological maturity, costs, and financial risks, as well as persistent state-level prohibitions on the construction of new nuclear facilities, can deter utilities from including advanced nuclear in IRPs.
A second finding of the report is that several utilities included in NARUC’s review—PacifiCorp, Idaho Power, Duke Energy Carolinas, Duke Energy Progress, and the Tennessee Valley Authority—have explicitly included advanced nuclear in their IRPs. Third, most utilities propose keeping existing nuclear resources online to maintain reliability and progress toward decarbonization goals. This plan includes keeping ownership stakes in nuclear plants and extending the operating life of existing nuclear units. Key benefits of keeping existing nuclear online include employment, economic contributions to local communities, reliability, and clean energy.
[1] https://www.naruc.org/about-naruc/press-releases/new-report-reviews-nuclear-energy-in-long-term-utility-resource-planning/
[USA] Pennsylvania court rules against plan to join RGGI
On November 1, 2023, the Pennsylvania Commonwealth Court ruled in a 4-1 decision that former Governor Tom Wolf’s (D) move to join the Regional Greenhouse Gas Initiative (RGGI) through executive action was an illegal tax.[1] RGGI is the longest-running mandatory greenhouse reduction program in the U.S. and includes eleven states, though Virginia Governor Glenn Youngkin (R) is attempting to leave the program. Pennsylvania would be the first major fossil-fuel-producing state to join the initiative. Former Governor Wolf sought to join RGGI in 2019 but was opposed by the Republican majority General Assembly. The state’s participation in RGGI had been on pause for over a year as Judge Michael Wojcik (D) had issued a preliminary injunction. According to the court, without authorization from the state legislature, RGGI is an unlawful tax. Judge Wojcik wrote in the majority opinion, “Stated simply, to pass constitutional muster, the Commonwealth’s participation in RGGI may only be achieved through legislation duly enacted by the Pennsylvania General Assembly, and not merely through the Rulemaking promulgated by" Pennsylvania regulators.
[1] https://cases.justia.com/pennsylvania/commonwealth-court/2023-247-m-d-2022.pdf?ts=1698852322