#NOPC has + lots

[disorganizedkitten]

"So this is the WBWL trope, it's most commonly seen as a nature vs nurture exploration between a pair of twins and- what are you doing?"

Pouring a third, fourth, and fifth sibling into this mix. Looks up innocently. hm?

"Ah- no, stop that. Twins. This is a duology exploration! Of Dichotomies! Extremes! Twos!"

No??? Canon was about twos? Dichotomy between good and evil? Every other wbwl appears to be in threes, actually. Puts another sibling into the mix.

"No! Twins! You cannot- stop it!"

Triplets sound better, actually. Or seven? Seven sounds good.

"TWO!"

Except Voldemort makes it three! So actually I'm making it even again!

"No!"

Yes!

[inerginc]

GTM Smart Grid http://ift.tt/2eJlQnQ

Energy Secretary Rick Perry’s demand for market-disrupting price supports for coal and nuclear power plants has broken multiple rules for how energy policy is made, from upending the facts to subverting regular order. And it’s being pushed through on a hyper-fast, 60-day review period that’s not only unjustified by the Department of Energy report it cites as justification, but “practically and legally impossible” to meet. 

This is a collection of the critiques that have emerged since Friday’s shock DOE filing with the Federal Energy Regulatory Commission. In a rarely-used notice of public rule making (NOPR), DOE asked FERC to create market rules to provide compensation for power plants that, among other features, have a 90-day supply of fuel on hand — something that only coal and nuclear power plants can do. 

The NOPR cited the grid reliability study ordered by Perry in April to argue that baseload power plants need compensation to shore up grid reliability. But as we covered when it was released in July, that report doesn’t actually support that conclusion, stealing some of the thunder from clean energy and environmental groups’ arguments that the report was a Trojan horse for pro-coal and nuclear power policies all along. 

Friday’s NOPR seems to have vindicated those views, as well as drawn the fire of a much broader coalition of energy industry players. On Tuesday, FERC received a joint motion from a coalition representing literally every sector of the energy economy except coal and nuclear power, asking it to deny DOE’s request for an interim final rule to take effect within 60 days, and extend the comment period out to at least 90 days. 

The coalition includes the country’s biggest solar and wind trade groups and renewables boosters like American Council on Renewal Energy and the Advanced Energy Economy. But it also includes the Natural Gas Supply Association, the Interstate Natural Gas Association of America, and the American Petroleum Institute — a highly unusual set of bedfellows. 

“This is the first time we've filed a motion in conjunction with API,” Gil Jenkins, a spokesman for ACORE, told The Washington Post. “So  it’s unprecedented, just as this very action taken by DOE.” 

Also joining the motion were the American Public Power Association and National Rural Electric Cooperative Association, representing municipal and co-op utilities, and the Electricity Consumers Resource Council, representing big commercial and industrial power users. Even the generator group Electric Power Supply Association — the same one that sued FERC to overturn its Order 745 regulations allowing demand response equal play in capacity markets — has signed on. 

“This is one of the most significant proposed rules in decades related to the energy industry and, if finalized, would unquestionably have significant ramifications for wholesale markets under the Commission’s jurisdiction,” the group wrote. 

This view was shared across the energy industry spectrum this week. Former FERC chairman Jon Wellinghoff, a Democrat, told Utility Dive that the DOE rule would "blow up the markets” that the agency has spent the past four decades creating. Former FERC commissioner Nora Mead Brownell, a Republican, told RTO Insider that the proposal is “the antithesis of good economics. It’s going to destroy the markets [and] drive away investment in new, more efficient technologies.”

Even energy company CEOs are crying foul. At a Gulf Coast Power Association conference Tuesday in Austin, Texas, Dynergy CEO Bob Flexon called the NOPR a "red herring for subsidies" for nuclear and coal, while NRG Energy CEO Mauricio Gutierrez said that propping up coal and nuclear power plants, while leaving other resources open to competitive forces, would be “a recipe for disaster." 

But the Edison Electric Institute utility trade group, which did not join the rest of the energy trade groups in Tuesday’s FERC filing, took a more neutral stance. In a Tuesday statement, EEI vice president of energy supply Richard McMahon said the NOPR shows DOE recognizes that "a balanced energy mix that includes 24/7 energy sources is vital to sustaining a secure, reliable, and resilient energy grid,” and that ”New market rules should recognize the role that all generation sources play in maintaining the reliability and resiliency of the energy grid.” 

Coal and nuclear-reliant FirstEnergy Corp. was one of the lonely voices in support of the ruling. “Correcting the faulty market conditions and keeping essential baseload generating plants operating will help ensure customers continue to receive safe, reliable and affordable supplies of electricity while maintaining the security of the electricity grid,” CEO Charles Jones said in a prepared statement.

Why 90 days of fuel supply doesn’t make the grid more resilient 

These views are complicated by the fact that DOE’s proposed "Grid Resiliency Pricing Rule” is lacking in so many details. Ari Peskoe, senior fellow in electricity law at the Harvard Law School Environmental Law Program Policy Initiative, pointed out in a Monday Interchange discussion with GTM Research head Shayle Kann. 

In simple terms, the rule does two things, Peskoe said. First, it defines reliability and resiliency attributes, including the 90-day fuel supply requirement. That in and of itself is a conclusion unsupported by the facts at hand, however, he said — a point echoed by multiple parties since Friday. 

“I called a lot of the arguments in the DOE proposal — well, they’re certainly cherrypicked, but they’re also often specious,” said Devin Hartman, electricity policy manager at R Street, a free-market think tank in Washington, D.C.. For example, the NOPC cites FERC and grid operators’ market design concerns as reasons for including 90-day fuel supply as a requirements — but what evidence does exist indicates that fuel supply problems are only a minuscule cause for power outages in the U.S., he said. 

To back that up, he pointed to an analysis published Tuesday by the Rhodium Group, which crunched DOE data on the causes of the 3.4 billion customer-hours of major electricity disruptions from 2012 to 2016. Of that time, only 2,815 hours, or 0.0007 percent of the total, was due to fuel supply problems, it found — and of those, 2,333 hours were due to fuel supply disruptions at a coal-fired power plant in Northern Minnesota. 

The real culprits for outages are instead severe weather, with Hurricane Sandy accounting for nearly one third of the total hours of power lost over that period, and severe weather accounting for nearly all the rest. Puerto Rico’s nearly complete power outage in the wake of Hurricane Maria has already accounted for nearly twice the total number of outage hours in 2016. 

DOE’s choice of 90 days of fuel stockpiles as the sole metric of reliability also fails to take into account the much deeper analysis presented in the DOE’s report, he noted. This built on existing work at FERC and the country’s big grid operators, calling for improvements in energy price formation and valuation of essential reliability services such as voltage support and frequency response.

Natural Resources Defense Council senior attorney John Moore told the House Energy and Commerce Subcommittee on Energy on Tuesday that the DOE proposal is “sowing confusion and suggesting the power grid will be imperiled if we don’t pay large subsidies to keep specific types of generators afloat. We can achieve a higher level of reliability at a lower cost and with less pollution by defining reliability and resiliency needs first.”

Kann asked Peskoe whether DOE or FERC were under legal obligation to consider these alternative metrics for reliability and resiliency. Peskoe replied that "FERC rules have to be non-discriminatory — that's a really fundamental premise they operate under." But that only strictly applies to rules that are "unduly discriminatory — they can discriminate if there's some valid purpose.” 

From “flimsy and vague” proposal to final rule in 60 days? 

Second, DOE’s NOPR seeks to define a special rate that these resources should provide, Peskoe said, which “kind of suggests that these resources are going to be taken out of the competitive market construct and are now going to be compensate based on cost of service rate making principles.” That’s the general view being taken by industry observers, since the rule would only apply to power plants in competitive wholesale markets, not those already subject to state or federal cost-of-service regulations. 

That's not entirely clear, however, because the NOPR also cites the need for markets to support the benefits and services of reliability and resiliency, and “being compensated for benefits and services is different than cost of service,” he said. That could open the options for other methods, such as some kind of “value of coal tariff” to mimic the value of solar tariff (VOST) proposals being fleshed out by a handful of states and utilities, or defining a new set of reliability and resilience attributes and creating a new market for them.”

Unfortunately, the DOE’s NOPR is quite vague on what it’s asking FERC to undertake, he said. The questions left unanswered by the NOPR, according to a series of tweets he published after its release, include:  “Is this cost-of-service ratemaking or is DOE suggesting that rate should be based on a plant’s ‘benefits and services? Does an eligible generator always receive this rate, or do they normally get paid LMP but receive this rate under certain circumstances? How does dispatch work if an eligible plant is not bidding into the market? Or is an eligible plant ‘bidding’ this special rate?”

These kinds of details, so common to traditional FERC rulemakings, are completely absent from DOE’s NOPR, he said. That would make it “practically and legally impossible” for FERC to actually comply with DOE’s request to have a final rule completed within the 15 days left between the end of the public comment period and the 60-day deadline it set out, he said. 

NRDC clean energy attorney Miles Farmer agreed in a Friday blog post, noting that “DOE’s proposal is so vague that FERC could not possibly adopt it as is, making it hard to see how FERC could possibly advance it in a manner that complies [with] the procedural requirements for a formal rulemaking proposal.” 

That’s the same reason that the 11 energy trade groups asked FERC to extend the comment period for the new rule. Despite the NOPR’s claims, the groups said, “both DOE and NERC recently released reports categorically concluding that there is no reliability emergency” that would require such a speed-up.

FERC this week filed notice that it was taking comments on the NOPR on the accelerated schedule, with Oct. 23 as the deadline for initial comments and Nov. 7 for reply comments. But it still hasn't ruled on the groups' proposal, leaving open the potential for extending its timeline. 

Jason Johns, partner in Stoel Rives’ energy practice, suggested in a blog post that the short timeframe could be “perhaps intended to allow Interim Chairman Chatterjee and Commissioner Powelson to take action on this notice alone before FERC has a full set of commissioners.” Chatterjee has already expressed his support of recognizing baseload power “as an essential part of the fuel mix” that must be “properly compensated to recognize the value they provide to the system.” 

But to remain legal, any action FERC takes will have to be rooted in several fundamental principles, Peskoe noted. First, it will have to find that existing grid operator tariffs are “unjust and unreasonable,” something that DOE’s NOPR does not take up. Second, it would have to show that the new rules being promulgated are “just and reasonable,” which is again difficult given that "FERC is going to have to address the total lack of detail in this document” on that matter. 

[disorganizedkitten]

(All) The Potter twins are disasters, more at four

Hi yes sometimes (often) I do the thing where you go 'oh!! what if! My universe! Met THIS UNIVERSE!! Gestures at a beloved fic written by someone else' but today/yesterday it was just... crack. Bc I read a lot of serious, very good, nicely thought out fics ripe with character development and strained interpersonal relations but all I write is just... ah yes. They love each other. It's not romantic, go celebrate that elsewhere. They just. Love. The explosion. Love go brr suckers.

Anyway highlights without stealing from others' fics include:

Potter twin idiots one and two apparently don't pack their own meds, but they have e/os bc obviously they'll manage to take their own meds on time but their bro is an idiot who'll forget his.

"Your meatsuit is revolting against your bones."

H "I am many things and against murder is not one of those." C "No one in this family is against murder." H "Kenny's against murder." C "Kenny has a body count?" H "Those were an accident and we don't talk about them."

Harry opens his mouth. "Harry, I don't know what you're thinking but it's obviously cursed so please don't." Harry closes his mouth.

Connor says something obviously Galaxy brain. "Oh wow, we've been here longer than twelve hours, my meds are wearing off."

Look, Theo and Ron could be enemies. They could be rivals. They could compete. But they're both smart enough to realize that they each have one (1) idiot Potter on their hands so they teamed up instead.

Iris, the Harry from another au, (Cobra Lily) plops down beside Hades (NOPC) and Hawthorne (Hyacinth). "Well, obviously foster kids are the best kids."

C "Wait do we need to eat. How long have we been here?"

Alt: C "Oh sure, this pocket dimension gauntlet from azkaban halts all our bodily functions so we don't need water or food, but I still burn through my Adderall, screw this."

Connor and Harry making fun of the others in sign because there are too many parselmouths to make snarky comments in parseltongue

"Please understand, I am a disaster and Harry is the only reason I'm still alive."

Connor randomly zones out and when someone else asks him what's going on "I'm trying to figure out if my parasite ended up in a pocket dimension too bc Nagini and Voldemort are gossiping about their kid. Pretty sure they don't have a kid." H "No they have a kid. You've met him." C "Wut" H "He haunts his little sister, remember?" C "Wait him? "But he's not a snake?"

Casually breaking the fourth and fifth walls bc Undead Rights

Hades is a master of smiling brightly and 'oversharing' so the others keep writing him off as an idiot, meanwhile he's using his blood to burn through the floor and see if he can get them through this bs obstacle course.

For the record, Hawthorne is having the time of his life, and Iris is very excited to talk to another human horcrux. They're very rare, you know.

(Sorrel and Charlie, the respective twins, are chilling. Sorrel is still pretending he's not related to Hawthorne. Charlie is supporting his sister's dreams of becoming a dark lady.)

I'd like to again bring up that these idiots don't pack their own meds. "Mm let's see," Connor bends his knee up and starts pulling things out of his boot. "Basilisk venom, atomoxetine, a knife, a hair tie, where the heck is my adderall?" Meanwhile, Hades pulls out a bottle of adderall, snacks, a human femur, nail polish, a vial of blood, three knives, a flashlight, more snacks, etc.

Harry routinely spouts disturbing random factoids about the human body. "There's a bone in your ear, smaller than my nail, and if I steal it you'll start walking into things because it runs your sense of balance." / "Oh look, you're shedding your skin." / "Hit him hard enough there and he'll die." / "You can live without a lot of organs you know," / "Eyeballs are just nerve goo that refract light."

"What's a horcrux?" Some poor soul asks. Iris, Charlie, Hades, and Con all zone in on them. H "A cowards way to immortality." Con "Freaking Painful," I "Useful," Ch "Annoying" all, more seriously. "An abhorration to magic's nature."

(Harry, in the corner, pouting bc horcruxes are a disgrace to necromancy: djdkfls I will burn them)

Iris, Thorne, and Hades all grew up with enough muggle influence they use memes to communicate.

snorts. "Soul magic go brr"

The normal ones: :eyes:

"You have outlived kings and empires, be proud." "Harry when was there an empire that lasted less than fifteen years"

"Hiss hiss suckers."

"Wait we've been separated for two hours and you didn't adopt all your alternate selves?" eldritch head tilt

Harry, seeing something that looks lethal: Touches it. (Con: Hades no!)

Con, seeing a really sharp knife: Slaps. Is cut. Proceeds to be excited. Harry: Calls him an idiot and heals the cut b4 also celebrating

Con: We could trade lives but I'm pretty sure that would end in disaster bc there's no way you'd survive my sister. AU person: Squints. I thought you had a brother?

When reunited, they stop for a minute and stare, slowly tilting their heads further and further until they have to turn their necks and then their torsos, going upside down. Outsider: "What are you doing?" Pts: "Ensuring his identity."

Also shoutout to Harry who can just tell it's Con bc his soul is a hot mess n Harry can see souls, but goes through the identity ritual anyway bc it makes Con feel better

"Does this remind you of operation kill the bwl or if it just me?" "It's definitely just you."

"Oh sure, you get impaled one time and no one lets you live it down."

"I'm relatively sure he's died by poison so many times it addled his brains." "This coming from the boy with a maniac sharing his headspace!" "Yeah but I can block out the maniac!"

Connor: Purposefully sets Harry up to spend twenty minutes insulting horcruxes and also voldemort

(threat) "I will end our bloodline." "Harry we're both ace. Our bloodline is ending anyway. This is why adoption exists."

C: "You're why adoption exists."

H "At this point i have like, seven parents, it should be illegal to adopt me." C "Like three of those are actually ancles." H "Please tell me you did not just call the DBs ankles"

H "Sometimes family is you, your dark artifact brother, your time travelling aunt, the dead family members you wanted to keep chillin with, your muggle uncle, your wizard uncle, your mass murdering dog, the serial killer smoke, and the fifteen muggleborn families you adopted to protect from racist politics." C "I think you forgot like... seventy people."

"Yo now that there are more of us I need names. But like, don't actually give me your names, I spend way too much time with faeries for that to be safe."

[disorganizedkitten]

When I say an au of an au of an au of an au...

Two flow charts so they look pretty-  Anyway! This is the growth of the au I keep rambling about when I remember Tumblr exists! It looks prettier in blue.

 This has been so much fun guys, you have no idea.

 Breakdown beneath the cut

 Godfamily- Heavily based off/inspired by Lullabyknell’s who discovered your secret. It was gonna be Reg raising Harry as the neighbor kid bc his impulse control is a lie. They wrote letters to Neville and when Sirius broke out Harry just portkeyed him to Regulus. Harry n Nev get their Godfamily n Reg n Siri have kids to love. Much fluff. Very Regulus. Brings me joy

NOPC 1.0 > Most of what came from here has been split between 2.0 and the Mathverse.  Most of what’s been posted on tumblr. It's literally Godfamily but with a twin au. Neville talked to Connor abt the random letter he got from someone claiming to be Con's brother and they started investigating the missing Potter. They become friends with Harry, visit sometimes, and end up as their own Golden Trio. Regulus is still faking death but watches out for all of them. The Dunbars may or may not live next door?

1.0 was active as I considered muggleborn musical group (Justin Finch-Fletchly, Su Li, Michael Corner, Dean Thomas, Fay Dunbar; they took their turns) and came up with the basic idea for Fay’s tragic backstory, but it wasn’t until 2.0 that everything was ironed out.

 NOPC 2.0- Actually a thing. Exists. Has over 100 pages written. Biggest project in a while. T’was born between November (when 1.0 was born) and February/March when 2.0 began to be written. I did write a good amount for 1.0 first, and then more development happened. 2.0 is what I generally talk about on discord, Regulus is legally alive, Vivian is a time traveler, the Potters are iffy but hopefully not 1-dimensional, most everyone is neurodivergent, the two Delphis, etc. So much fun. @lennarts​ is my Alpha reader and @etoiles-jaunes and @Ganymede have beta’d different parts. They’re all amazing. (They will be properly tagged once I find their blogs 0_0)

 P sure the title was started from something said in the 4th installment of Sarcasm and Slytherin and then I started playing with it. Technically, it has three titles. Not Our Parents, Our Parents’ Children, They combine into (Not) Our Parents (’ Children) which isn’t very pretty rn but it’s like a venn diagram.

Delphi Is Not Paid Enough For This BS- A series. Wherein Delphi Riddle was born earlier, works in the DoM with her bff/gf(?), is chronically exasperated, and has a few aus of it's own, such as the au where she's the DADA teacher in 1995 instead of Umbridge and the one where she learns Harry's a horcrux as a kid and adopts him while trying to remove it safely, etc. Outside of the aus, it’s just me exploring her character from NOPC more, because I love her.

Mathverse- Actually named It’s Only Right As A Math Problem, is a more canon compliant/trope-specific version of NOPC, with way less plotlines and hopefully the same amount of shenanigans. The title is for the twins themselves - one sold his soul during Godric’s Hollow, the other became a Horcrux. There’s only the right soul/body ratio when they’re together.

 I love them.

 Locked- New. Only an idea, right now; what if the reason the Potters never returned for Harry was because the blood wards locked them out too?

There Is Magic In Every Living Thing- The only one posted so far. Lots of fun. Dormroom shenanigans for the Slytherins, plot is... something. Following canon mostly, I guess. Plot is definitely not the focus, I’m focusing on the boys and their relationships. And practicing writing their abilities/affinities, whoop

 Connor isn’t Harry’s twin, but he’s still an annoying older brother.