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Coalition Calls for EU Hydrogen Quota for Shipping

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Energy providers, shipping companies and NGOs call on the EU to introduce a minimum quota of 6% sustainable and scalable hydrogen fuels by 2030

A broad coalition of energy providers, shipping companies and NGOs — including Siemens Energy, Viking Cruises, Green Power Denmark and Brussels-based organisations Hydrogen Europe and Transport & Environment (T&E) — has called on the EU to introduce a minimum quota of 6% sustainable and scalable hydrogen fuels by 2030.

Last year the European Commission, the EU’s executive body, proposed a shipping fuel law (FuelEU Maritime Regulation) aimed at increasing the uptake of alternative marine fuels. Unfortunately, the law fails to guarantee the competitiveness of sustainable and scalable e-fuels, and risks promoting cheaper, unsustainable fuels. The coalition therefore calls on the European Parliament and EU Council to improve the proposal by including a dedicated e-fuels sub quota in the proposed regulation.

Delphine Gozillon, sustainable shipping officer at T&E, said:

“An ambitious shipping fuels law will be key to set the shipping sector on course for full decarbonisation. Sustainable e-fuels are currently too expensive compared to other alternatives such as fossil LNG and biofuels, holding back investments in production facilities, refuelling infrastructure in ports and zero-emission ships. However, with a bit of a push e-fuels produced from renewable hydrogen can be scalable. That’s why we need a quota to get the ball rolling and encourage companies to start investing in clean shipping fuels. Shipping does not need to be a dirty industry forever.”

A list of all the coalition’s demands can be found here.

Download the letter.

Courtesy of Transport & Environment.

Featured image courtesy of Maersk.

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Tesla’s Policy Lead Testifies at PUCT Open Meeting As Tesla Focuses on Supporting the Texas Grid

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Tesla’s US Energy Markets Policy Lead, Arushi Sharma Frank, was recently asked to testify at a Public Utility Commission of Texas Open Meeting. A photo of Frank wearing an LFDECARB tee shirt popped up on Twitter. The tee shirt itself is a message focused on decarbonization by the group Bros for Decarbonization. You can learn more about the group here.

Frank confirmed that it was an impromptu request to testify. She also shared exactly what she talked about.

The document Frank shared was a filing receipt for supplemental comments from Tesla signed by Frank. There’s also a video of her testimony which you can watch here. In the document, Tesla said that it appreciated the opportunity to share its comments regarding PUCT’s discussions that were held on June 16, 2022 — the open meeting regarding Tesla’s proposal OBDRR041 as well as its prior work demonstrating how virtual power plants (VPPs) work.

I recently published an article about Tesla’s VPP workshop, which was related to OBDRR041. Tesla also said that it appreciated the Commission’s comments related to its Distributed Energy Resource (DER) pilot projects. Tesla especially supported the conversation between Commission representatives and the staff at the Electric Reliability Council of Texas (ERCOT), as well as with the market participants. The conversation covered the real implementation of the system through a pilot as opposed to a task force approach. The latter, Frank noted, could unnecessarily create delays in implementing a grid service solution for DERs.

Looking At The Document & Tesla’s Statements

The Commission’s decision to encourage ERCOT to get stakeholders together and develop a pilot project allowing the market solution of exports from VPPs to be tested is also something Tesla expressed its appreciation for. This allowed for addressing issues raised by utilities and other market participants that have concerns about the potential impacts of site-exporting DERs on distribution facilities. It also allowed for a discussion of the net impact and benefits to the transmission grid.

Tesla also clarified and provided information as a response to a few discussion topics and questions that were raised at the open meeting. These topics included the OBDRR041 status, the ERCOT Pilot Proposal, and a question posed to Tesla by Chairman Lake at the open meeting.

OBDRR041 status

Tesla noted that since the OBDRR041 is currently tabled at the ERCOT Technical Advisory Committee, it would not seek a vote until there was further development of issues and positions from ERCOT and the potential members of the committee.

“At this time, Tesla believes that OBDRR041 may remain tabled at the Technical Advisory Committee pending consideration of the feasibility of a Virtual Power Plant pilot as the Commission proposed at the Open Meeting.”

ERCOT Pilot Proposal

Tesla expressed its views on the formal ERCOT Pilot Proposal that was introduced at the Open Meeting. Tesla noted that for a formal ERCOT pilot approach to be a feasible alternative to OBDRR041, a pilot should :

Have ERCOT’s support and the market’s acceptance and approval from ERCOT’s governing board.
Be amenable to commercialization in that sufficient participants could be aggregated across sufficient distribution service areas (more than one, but in capped quantities, in each service area as described in a proposed pilot framework).
Adequately capture data addressing clearly identified distribution utility concerns, in parallel to or as part of the pilot’s scope.
Have provisions to ensure market services compensation commensurate with grid services provided by pilot participants
Have an identified “start date” and “end date” which are technically feasible for involved parties.

In addition to that last point, Tesla added that the following are requirements in Section 25.361 (k) regarding pilot development and approval:

“ERCOT may conduct a pilot project upon approval of the scope and purposes of the pilot project by the governing board of ERCOT. Proposals for approval of pilot projects shall be made to the governing board only by ERCOT staff, after consultation with affected market participants and commission staff designated by the executive director.

“The ERCOT governing board shall ensure that there is an opportunity for adequate stakeholder review and comment on any proposed pilot project.”

Tesla noted that pilot  project proposals approved by the ERCOT governing board should include the following:

The scope and purposes of the pilot project;
The designation of temporary exceptions from ERCOT rules that ERCOT expects to authorize as part of the pilot project;
Criteria and reporting mechanisms to determine whether and when ERCOT should propose changes to ERCOT rules based on the results of a pilot project.
An estimate of costs ERCOT will incur attributable to the pilot project.
An estimated date of completion of the pilot project.

Tesla’s Response To Chairman Lake

Tesla expressed its appreciation for Chairman Lake, who stated that “nothing teaches like experience, so the sooner you get something in the field, the more you learn faster.”

Tesla also responded to a question posed by the chairman and said that it’s concerned that it will not be able to scope a pilot program in a Non-Opt-in-Entity (NOIE) area. Currently, Texas homeowners are unable to participate in VPPs due to the law. Tesla said:

“Primarily, this approach may not be economically rational as it could mean a substantial resource investment in a pilot that is not scalable to a commercial retail offer where Tesla could continue to directly serve those customers and grow the program’s strength and viability.

“The customers in a pilot should be able to continue to benefit from the value for their systems beyond the end-date of the pilot, in a commercially viable solution – but with a NOIE-only pilot, Tesla would have no control, legally or otherwise, over the continued participation of such customers once the pilot closes, even if a viable market participation framework is implemented following that pilot’ s conclusion.

“Any formal program participation of those customers would be solely at the option of the NOIE serving those customers. More simply, the purpose of a pilot is to study a solution that can be scaled following adoption of market rules based on pilot learnings. To build a program off the learnings of a pilot, the customer base involved in the pilot should be able to continue service under that formalized program, so that parties involved are not running the risk of raising a wholly new set of unstudied issues in a new distribution system type that was not part of the pilot.”

Frank also shared a link to over 60 pages of data from Tesla. Deep dive coming soon.

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Diving Into Tesla’s 60+ Pages of PUCT Filings (Mostly Data)

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Tesla has over 60 pages of Public Utility Commission of Texas (PUCT) filings that have recently been shared publicly, and we’re about to dive into them. Grab some water and a coffee and let’s go.

Tesla and its team, including its US Energy Markets Policy Lead, Arushi Sharma Frank, have been working hard to help Texan Powerwall customers be able to take part in virtual power plant (VPP) pilot programs. In May, Tesla held a VPP workshop for the Electric Reliability Council of Texas (ERCOT) and Frank was one of the key leaders hosting the meeting.

Recently, Frank was asked to testify at an open meeting of the PUCT, and there she shared Tesla’s comments and statements addressing questions and other concerns relating to VPPs.

Frank tweeted a thank you to the PUCT for the opportunity of allowing Tesla to provide comments. In addition, she followed up with two more tweets, with one mentioning her favorite part of the filings — Tesla describing a phenomenon called “clumping.” Clumping is a reference to capturing the full value of distributed energy renewables capacity in an aggregate load resource (ALR).

63 Pages Of Data For PUCT

In total, there were 63 pages. I’m only going to go over some of the data briefly. I think it’s important to highlight Tesla’s hard work because if Texas allows its residents who own Powerwall batteries systems to participate in VPPs, this opens the door for other states in the Deep South to at least consider clean energy solutions for various problems, especially grid-related. Texas is well known for its grid instability, and if it allows Tesla Powerwall customers to take part in VPPs, this could mean saving lives during disasters.

Included in the filings were comments from Tesla, a request from Tesla that the Commission direct ERCOT to prioritize several actions such as allowing ALRs (Aggregated Load Resources) to provide injection capacity from individual sites in a framework by December 2022, an informal narrative of Tesla’s VPP demonstration in ERCOT, and 47 slide pages detailing the ERCOT/Tesla ancillary service demonstration.

I think the most important part for us outsiders observing here is the 47 slides, because they highlighted a lot of data that shows just how the Texas grid will benefit from VPPs. The 47 slides showed several key meetings between Tesla and ERCOT about the demo program.

Key Meeting Between Tesla & ERCOT Shows Tesla Has Been Working Hard Trying To Convince Texas To Allow VPPs

In March, there were four meetings in which Tesla defined clumping, Frank’s favorite part, as well as two telemetry signal approaches. Following that were weekly meetings around the demo results with the last demo result being April 15, 2022. On April 9, Tesla and ERCOT revisited clumping and the two telemetry signals approach.

This tells me and anyone paying close attention that Tesla has been quietly working with ERCOT to help the Texas grid for quite some time. This, I think, is a good thing, especially for Texas.

Tesla Seeks To Register The First ALR In ERCOT

According to the documents, Tesla wants to register the first ALR in ERCOT and participate in services that are currently unavailable. These services include non-spin and sCED load reduction dispatch. Tesla wants to do this with the full value of grid services that injecting devices can provide in an ALR.

Tesla said that it will lead efforts to modify the utility’s ALR Policy Other Binding Document to make it fit with practical operational, registration, and qualification issues. It clarified that ERCOT can exchange two telemetry points with an aggregation-qualified scheduling entity (QSE).

Tesla ERCOT Demo Tests

Tesla’s first demo looked at the comparison of battery and premise-level telemetry. Below is a chart showing the initial conditions, test steps, data collected, and pass criteria.

Table courtesy of Tesla

This first test results show that VPPs work beautifully in Texas. According to the results, the load decreased during the evening while in the morning it decreased while exporting to the grid. And during the daytime, the exporting of energy to the grid only increased. Tesla explained further:

“Discharging from the customer’s battery using a step function can clearly be identified in the premise-level data.

“At different times of day, premise-level data will look differently, depending on the current load:

1. Evening time: during the evening peak, user load is typically high, and discharging the battery will show up as a decrease in premise-level load.

2. Morning time: during the night/morning time, user load is typically lower, and discharging the battery will both decrease load, and export energy to the grid.

3. Daytime: during the daytime, solar is exporting to the grid, and discharging the battery will increase the export.”

You can view the full demo, test results, and all of Tesla’s comments here.

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Tesla Vision Expanded to Australia, New Zealand, & Japan

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Australia, New Zealand, and Japan are now able to use Tesla Vision, a camera-based and neural network Autopilot feature that helps drivers to drive safely when the feature is on.

Tesla recently expanded Tesla Vision, its camera-based Autopilot, to Australia and New Zealand, Teslarati reported. In May 2021, Tesla started shipping its Models 3 and Y vehicles equipped with Tesla Vision, and now Tesla owners in both countries will be able to utilize Tesla Vision and its active safety measures in place of the previous system using radar.

Tesmanian reported that Tesla also expanded its Tesla Vision safety feature to Japan. Tesla Vision relies only on cameras and neural network processing. According to Tesmanian, Autosteer will be limited to a maximum speed of 140 km/h, which is 87 mph.

Although some of the features will be temporarily limited or inactive for Australia, New Zealand, and Japan, they will be fully restored over time through several over-the-air updates. During Tesla’s Q1 2021 earnings call, CEO Elon Musk noted that Tesla Vision would work better than human vision since it has eight cameras — almost like having eyes in the back and on the sides of your head.

This would make vehicles with Tesla’s pure vision solution dramatically safer than the average person. Unlike people, Tesla Vision isn’t texting and driving, getting behind the wheel while intoxicated, or doing other things such as falling asleep.

Tesla initially announced this in a post that was shared on the r/TeslaMotors subreddit.

“We are continuing the transition to Tesla Vision, our camera-based Autopilot system. Model 3 and Model Y vehicles built from June 2022 for the Australian market now utilize our camera-based Tesla vision, which relies on Tesla’s advanced suite of cameras and neural net processing to deliver Autopilot and related features.”

It’s good to see Tesla expanding its Vision suite to new markets. Not only will Tesla gain much needed feedback, but it will help improve safety on the roads in these markets.

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