EPA Accused of Flouting Supreme Court

BC Hydro Deferred Regulatory Assets detail $5.5 billion in costs under rate-regulated accounting, to be recovered from ratepayers, highlighting B.C. Utilities Commission oversight, audit scrutiny, financial reporting impacts, and public utility governance.

Key Points

BC Hydro defers costs as regulatory assets to recover from ratepayers, influencing rates and financial reporting.

✅ $5.5B in deferred costs recorded as net regulatory assets

✅ Rate impacts tied to B.C. Utilities Commission oversight

✅ Auditor General to assess accounting and governance

Auditor General Carol Bellringer says BC Hydro has deferred $5.5 billion in expenses that it plans to recover from ratepayers in the future, as rates to rise by 3.75% over two years.

Bellringer focuses on the deferred expenses in a report on the public utility's use of rate-regulated accounting to control electricity rates for customers.

"As of March 31, 2018, BC Hydro reported a total net regulatory asset of $5.455 billion, which is what ratepayers owe," says the report. "BC Hydro expects to recover this from ratepayers in the future. For BC Hydro, this is an asset. For ratepayers, this is a debt."

She says rate-regulated accounting is used widely across North America, but cautions that Hydro has largely overridden the role of the independent B.C. Utilities Commission to regulate rates.

"We think it's important for the people of B.C. and our members of the legislative assembly to better understand rate-regulated accounting in order to appreciate the impact it has on the bottom line for BC Hydro, for government as a whole, for ratepayers and for taxpayers, especially following a three per cent rate increase in April 2018," Bellringer said in a conference call with reporters.

Last June, the B.C. government launched a two-phase review of BC Hydro to find cost savings and look at the direction of the Crown utility, amid calls for change from advocates.

The review came shortly after a planned government rate freeze was overturned by the utilities commission, which resulted in a three per cent rate increase in April 2018.

A statement by BC Hydro and the government says a key objective of the review due this month is to enhance the regulatory oversight of the commission.

Bellringer's office will become BC Hydro's auditor next year — and will be assessing the impact of regulation on the utility's financial reporting.

"It is a complex area and confidence in the regulatory system is critical to protect the public interest," wrote Bellringer.

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Quebec Churchill Falls power deal renewal spotlights Hydro-Que9bec's Labrador hydroelectricity, Churchill River contract extension, Gull Island prospects, and Innu Nation rights, as demand from EV battery manufacturing and the green economy outpaces provincial supply.

Key Points

Extending Quebec's low-price Churchill Falls contract to secure Labrador hydro and address Innu Nation rights.

✅ 1969 contract delivers ~30 TWh at very low fixed price.

✅ Newfoundland seeks higher rates, equity, and consultation.

✅ Innu Nation demands benefits, consent, and land remediation.

As Quebec prepares to ramp up electricity production to meet its ambitious economic goals, the government is trying to extend a power deal that has caused decades of resentment in Newfoundland and Labrador.

Around 15 per cent of Quebec's electricity comes from the Churchill Falls dam in Labrador, through a deal set to expire in 2041 that is widely seen as unfair. Quebec Premier François Legault not only wants to extend the agreement, he wants another dam on the Churchill River and, for now, has closed the door on nuclear power as an option to help make his province what he has called a "world leader for the green economy."

But renewing that contract "won't be easy," Normand Mousseau, scientific director of the Trottier Energy Institute at Polytechnique Montréal, said in a recent interview. Extending the Churchill Falls deal is not essential to meet Quebec's energy plans, but without it, Mousseau said, "we would have some problems."

The Legault government is enticing global companies, such as manufacturers of electric vehicle batteries, to set up shop in the province and access its hydroelectricity. But demand for Quebec's power has exceeded its supply, and Ontario has chosen not to renew a power-purchase deal with Quebec, limiting the government's vision.

Last month, Quebec's hydro utility released its strategic plan calling for a production increase of 60 terawatt hours by 2035, which represents the installed capacity of three of Hydro-Québec's largest facilities. Churchill Falls produces roughly 30 terawatt hours, and Quebec would need to replace that power if it can't strike a deal to extend the contract, Mousseau said.

If Quebec wants to keep buying power from Churchill Falls, the government is going to have to pay more, said Mousseau, who is also a physics professor at Université de Montréal. "We're paying one-fifth of a cent a kilowatt hour — that's not much," he said.

Under the 1969 contract, Quebec assumed most of the financial risk of building the Churchill Falls dam in exchange for the right to buy power at a fixed price. The deal has generated more than $28 billion for Hydro-Québec; it has returned $2 billion to Newfoundland and Labrador.

That lopsided deal has stoked anti-Quebec sentiment in Newfoundland and Labrador and contributed to nationalist politics, including threats of separation from Canada around a decade and a half ago, when Danny Williams was premier, said Jerry Bannister, a history professor at Dalhousie University.

"We tend to forget what it was like during the Williams era — he hauled down the Canadian flag," Bannister said. "There was a type of angry, combative nationalism which defined energy development. And particularly Muskrat Falls, it was payback, it was revenge."

Power from the Muskrat Falls generating station, also on the Churchill River, would be sold to Nova Scotia instead of Quebec. But that project has suffered technical problems and cost overruns since, and as of June 29, the price of Muskrat Falls had reached $13.5 billion; the province had estimated the total cost would be $7.4 billion when it sanctioned the project in 2012.

Anti-Quebec feelings may have subsided, but Bannister said the Churchill Falls deal continues to influence Newfoundland politics.

In September, Premier Andrew Furey said Legault would have to show him the money(opens in a new tab) to extend th Legault's office said Tuesday that discussions are ongoing, while the Newfoundland and Labrador government said in an emailed statement Thursday that it wants to maximize the value of its "assets and future opportunities" along the Churchill River.

Whatever negotiations are happening, Grand Chief Simon Pokue of the Innu Nation of Labrador(opens in a new tab) said he has been left out of them.

Churchill Falls flooded 6,500 square kilometres of traditional Innu land, Pokue said, adding that in response, the Innu Nation filed a $4 billion lawsuit against Hydro-Québec in 2020, which is ongoing.

"A lot of damage has been done to our lands, our land is flooded and we'll never see it again," Pokue said in a recent interview. "Nobody will ever repair that."

As well, a portion of Muskrat Falls profits was supposed to go to the Innu Nation, but the cost overruns and a refinancing deal between the federal government and Newfoundland and Labrador have limited whatever money they will see.

If Legault wants another dam on the Churchill River, at Gull Island, the Innu Nation needs to be paid the kind of money it was expecting from Muskrat Falls, he said.

"You did it once, but you're not going to do it again," Pokue said. "It's not going to start until we are consulted and involved."

Meanwhile, Quebec may face competition for Churchill Falls power, Mousseau said, with at least one Labrador mining company expressing interest in buying a significant portion of its output — though he added that the dam's capacity could be increased. The low price paid by Quebec has meant there has been little incentive to upgrade the plant's turbines.

As demand for electricity rises across the country, Mousseau said he thinks it would be better for provinces to work together, sharing expertise and costs, for example through NB Power deals to import more Quebec electricity as they look across provincial borders to find the best locations for projects, rather than acting as rivals.

"We need to talk and work with other provinces, and some propose an independent planning body to guide this, but for this you need to build confidence, and there's no confidence from the Newfoundland side with respect to Quebec," he said. "So that's a challenge: how do you work on this relationship that has been broken for 50 years?"e contract, but the two premiers have said little since.

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Peterborough Distribution Inc. Sale to Hydro One delivers a $105 million deal pending Ontario Energy Board approval, a 1% distribution rate cut, five-year rate freeze, job protections, and a new operations centre and fleet facility.

Key Points

A $105M acquisition of PDI by Hydro One, with OEB review, rate freeze, job protections, and a new operations centre.

✅ $105 million purchase; Ontario Energy Board approval required

✅ 1% distribution rate cut and a five-year rate freeze

✅ New operations centre; PDI employees offered roles at Hydro One

The City of Peterborough said Wednesday it has agreed to sell Peterborough Distribution Inc. to Hydro One for $105 million, amid a period when Hydro One shares fell after leadership changes.

The deal requires approval from the Ontario Energy Board before it can proceed.

According to the city, the deal includes a one per cent distribution rate reduction and a five-year freeze in distribution rates for customers, plus:

• A second five-year period with distribution rate increases limited to inflation and an earnings sharing mechanism to offset rates in year 11 and onward
• Protections for PDI employees with employees receiving employment offers to move to Hydro One
• A sale price of $105 million
• An agreement to develop a regional operations centre and new fleet maintenance facility in Peterborough

“Hydro One was unique in its ability to offer new investment and job creation in our community through the addition of a new operations centre to serve customers throughout the broader region,” Mayor Daryl Bennett said.

“We’re surrounded by Hydro One territory — in fact, we already have Hydro One customers within the City of Peterborough and new subdivisions will be in Hydro One territory. Hydro One will be able to create efficiencies by better utilizing its existing infrastructure, benefiting customers and supporting growth.”

The sale comes after months of negotiations amid investor concerns about Hydro One’s uncertainties. At one point, it looked like the sale wouldn’t go through, after it was announced that Hydro One had walked away from the bargaining table.

City council approved the sale of PDI in December 2016, despite a strong public opposition and debate over proposals to make hydro public again among some parties.

Elsewhere in Canada, political decisions around utilities have also sparked debate, as seen when Manitoba Hydro faced controversy over policy shifts.

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New England Grid Reform Initiative aligns governors with ISO New England to reshape market design, boost grid reliability, accelerate renewable energy and offshore wind, explore carbon pricing and forward clean energy markets, and bolster accountability.

Key Points

Five states aim to reform ISO New England markets, prioritize renewables and reliability, and test carbon pricing.

✅ Governors seek market design aligned with clean energy mandates

✅ ISO-NE accountability and stakeholder engagement prioritized

✅ Explore carbon pricing and forward clean energy market options

Weeks after initiating a broad overhaul of utility regulation within its borders, Connecticut has recruited four New England states, as Maine debates a 145-mile transmission line project to rework the regional grid that is overseen by ISO New England, the independent system operator charged with ensuring a reliable supply of electricity from power plants.

In a written statement Thursday morning, Gov. Ned Lamont said the current structure “has actively hindered” states’ efforts to phase out polluting power plants in favor of renewable sources like wind turbines and solar panels, while increasing costs “to fix market design failures” in his words. Lamont’s energy policy chief Katie Dykes has emerged as a vocal critic of ISO New England’s structure and priorities, in her role as commissioner of the Connecticut Department of Energy and Environmental Protection.

“When Connecticut opted to deregulate our electricity market, we wanted the benefits of competition — to achieve lower-cost energy, compatible with meeting our clean-energy goals,” Dykes said in a telephone interview Thursday afternoon. “We have a partner [in] ISO New England, to manage this grid and design a market that is not thwarting our clean-energy goals, but achieving them; and not ignoring consumers’ concerns. ... That’s really what we are looking to do — reclaim the benefits of competition and regional cooperation.”

Lamont and his counterparts in Massachusetts, Rhode Island, Vermont and Maine plan to release a “vision document” in their words on Friday through the New England States Committee on Electricity, after New Hampshire rejected a Quebec-Massachusetts transmission proposal that sought to import Canadian hydropower.

The initial documents made no mention of New Hampshire, which likewise obtains electricity through the wholesale markets managed by ISO New England and has seen clashes over the Northern Pass hydropower project in recent years; and whose Seabrook Station is one two nuclear power plants in New England alongside Dominion Energy’s Millstone Power Station in Waterford. Gov. Chris Sununu’s office did not respond immediately to a query on why New Hampshire is not participating.

Connecticut and the four other states outlined a few broad goals that they will hone over the coming months. Those include creating a better market structure and planning process supporting the conversion to renewables; improving grid reliability, with measures such as an emergency fuel stock program considered; and increasing the accountability of ISO New England to the states and by extension their ratepayer households and businesses.

ISO New England spokesperson Matt Kakley indicated the Holyoke, Mass.-based nonprofit will “engage with the states and our stakeholders” on the governors’ proposal, in an email response to a query. He did not elaborate on any immediate opportunities or challenges inherent in the governors’ proposal.

“Maintaining reliable, competitively-priced electricity through the clean energy transition will require broad collaboration,” Kakley stated. “The common vision of the New England governors will play an important role in the discussions currently underway on the future of the grid.”

Renewable revolution
ISO New England launched operations in 1999, running auctions through which power plant operators bid to supply electricity, including against long-term projections for future needs that can only be met through the construction or installation of new generation capacity.

ISO New England falls under the jurisdiction of the Federal Energy Regulatory Commission rather than the states whose electricity supplies it is tasked with ensuring. That has led to pointed criticism from Dykes and Connecticut legislators that ISO New England is out of touch with the state’s push to switch to renewable sources of electricity.

Entering October, ISO New England published an updated outlook that revealed 60 percent of proposed power generators in the region’s future “queue” are wind farms, primarily offshore installations like the proposed Park City Wind project of Avangrid and Revolution Wind from Eversource. But Dykes recently criticized as unnecessary an NTE Energy plant approved already by ISO New England for eastern Connecticut, which will be fueled by natural gas if all other regulatory approvals are granted.

The six New England states participate in the Regional Greenhouse Gas Initiative that caps carbon emissions by individual power plants, while allowing them to purchase unused allowances from each other with that revenue funneled to the states to support renewable energy and conservation programs. FERC is now considering the concept of carbon pricing, which would levy a tax on power plants based on their emissions, and it also faces pressure to act on aggregated DERs from lawmakers.

ISO New England is investigating the concepts of net carbon pricing and a “forward clean energy market” that would borrow elements of the existing forward capacity market, but designed to meet individual state objectives for the percentage of renewable power they want generated while ensuring adequate electricity is in place when weather does not cooperate.

The Connecticut Public Utilities Regulatory Authority is collecting on its own initiative industry input on modernization proposals, as New York regulators open a formal review of retail energy markets for comparison, that would add up to hundreds of millions of dollars, including utility-scale batteries to store power generated by offshore wind farms and solar arrays; and “smart” meters in homes and businesses to help electricity customers better manage their power use.

The New England Power Pool serves as a central forum for plant operators, commercial users and others like the Connecticut Office of Consumer Counsel, amid Massachusetts solar demand charge debates that affect distributed generation policy, with NEPOOL’s chair stating Thursday morning the group was still reviewing the governors’ announcement.

“NEPOOL has been engaged this year in meetings ... exploring the transition to a future grid in New England and potential pathways forward to support that transition,” stated Nancy Chafetz, chair of NEPOOL, in an email.

Connecticut’s issues with ISO New England boiled over this summer on the heels of a power-purchase agreement between Millstone owner Dominion and transmission grid operators Eversource and United Illuminating, which contributed to a sharp increase in customer bills.

A few weeks ago, Lamont signed into law a “Take Back the Grid” act that allows the Connecticut Public Utilities Regulatory Authority to factor in Eversource’s and Avangrid subsidiary United Illuminating’s past performance in maintaining electric reliability, in addition to any future needs for revenue based on needed upgrades. The law included an element for Connecticut to initiate a study of ISO New England’s role.

Eversource and Avangrid have voiced support for the switch to “performance-based” regulation in Connecticut. Eversource spokesperson Mitch Gross on Thursday cited the company’s view that any changes to the operation of New England’s wholesale power markets should occur within the existing ISO New England structure.

“We also recommend any examination of potential alternatives includes a thorough evaluation that ensures unfair costs would not be imposed on customers,” Gross stated in an email.

In a statement forwarded by Avangrid spokesperson Ed Crowder, the United Illuminating parent indicated it intends to have “a voice in this process” with the goal of continued grid reliability amid increased adoption of clean energy sources.

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FERC Grid Resiliency Pricing Opposition underscores industry groups, RTOs, and ISOs rejecting DOE's NOPR, warning against out-of-market subsidies for coal and nuclear, favoring competitive markets, reliability, and true grid resilience.

Key Points

Coalition urging FERC to reject DOE's NOPR subsidies, protecting reliability and competitive power markets.

✅ Industry groups, RTOs, ISOs oppose DOE NOPR

✅ PJM reports sufficient reliability and resilience

✅ Reject out-of-market aid to coal, nuclear

A diverse group of a dozen energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies today submitted reply comments to the Federal Energy Regulatory Commission (FERC) continuing their opposition to the Department of Energy's (DOE) proposed rulemaking on grid resiliency pricing and electricity pricing changes within competitive markets, in the next step in this FERC proceeding.

Action by FERC, as lawmakers urge movement on aggregated DERs to modernize markets, is expected by December 11.

In these comments, this broad group of energy industry associations notes that most of the comments submitted initially by an unprecedented volume of filers, including grid operators whose markets would be impacted by the proposed rule, urged FERC not to adopt DOE'sproposed rule to provide out-of-market financial support to uneconomic coal and nuclear power plants in the wholesale electricity markets overseen by FERC.

Just a small set of interests - those that would benefit financially from discriminatory pricing that favors coal and nuclear plants - argued in favor of the rule put forward by DOE in its Notice of Proposed Rulemaking, or NOPR, as did coal and business interests in related regulatory debates. But even those interests - termed 'NOPR Beneficiaries' by the energy associations - failed to provide adequate justification for FERC to approve the rule, and their specific alternative proposals for implementing the bailout of these plants were just as flawed as the DOE plan, according to the energy industry associations.

'The joint comments filed today with partners across the energy spectrum reflect the overwhelming majority view that this proposed rulemaking by FERC is unprecedented and unwarranted, said Todd Foley, Senior Vice President, Policy & Government Affairs, American Council on Renewable Energy.

We're hopeful that FERC will rule against an anti-competitive distortion of the electricity marketplace and avoid new unnecessary initiatives that increase power prices for American consumers and businesses.'

In the new reply comments submitted in response to the initial comments filed by hundreds of stakeholders on or before October 23 - the energy industry associations made the following points: Despite hundreds of comments filed, no new information was brought forth to validate the assertion - by DOE or the NOPR Beneficiaries - that an emergency exists that requires accelerated action to prop up certain power plants that are failing in competitive electricity markets: 'The record in this proceeding, including the initial comments, does not support the discriminatory payments proposed' by DOE, state the industry groups.

Nearly all of the initial comments filed in the matter take issue with the DOE NOPR and its claim of imminent threats to the reliability and resilience of the electric power system, despite reports of coal and nuclear disruptions cited by some advocates: 'Of the hundreds of comments filed in response to the DOE NOPR, only a handful purported to provide substantive evidence in support of the proposal. In contrast, an overwhelming majority of initial comments agree that the DOE NOPR fails to substantiate its assertions of an immediate reliability or resiliency need related to the retirement of merchant coal-fired and nuclear generation.'

Grid operators filed comments refuting claims that the potential retirement of coal and nuclear plants which could not compete for economically present immediate or near-term challenges to grid management, even as a coal CEO criticism targeted federal decisions: 'Even the RTOs and ISOs themselves filed comments opposing the DOE NOPR, noting that the proposed cost-of-service payments to preferred generation would disrupt the competitive markets and are neither warranted nor justified.... Most notably, this includes PJM Interconnection, ... the RTO in which most of the units potentially eligible for payments under the DOE NOPR are located. PJM states that its region 'unquestionably is reliable, and its competitive markets have for years secured commitments from capacity resources that well exceed the target reserve margin established to meet [North American Electric Reliability Corp.] requirements.' And PJM analysis has confirmed that the region's generation portfolio is not only reliable, but also resilient.'

The need for NOPR Beneficiaries to offer alternative proposals reflects the weakness of DOE'srule as drafted, but their options for propping up uneconomic power plants are no better, practically or legally: 'Plans put forward by supporters of the power plant bailout 'acknowledge, at least implicitly, that the preferential payment structure proposed in the DOE NOPR is unclear, unworkable, or both. However, the alternatives offered by the NOPR Beneficiaries, are equally flawed both substantively and procedurally, extending well beyond the scope of the DOE NOPR.'

Citing one example, the energy groups note that the detailed plan put forward by utility FirstEnergy Service Co. would provide preferential payments far more costly than those now provided to individual power plants needed for immediate reasons (and given a 'reliability must run' contract, or RMR): 'Compensation provided under [FirstEnergy's proposal] would be significantly expanded beyond RMR precedent, going so far as to include bailing [a qualifying] unit out of debt based on an unsupported assertion that revenues are needed to ensure long-term operation.'

Calling the action FERC would be required to take in adopting the DOE proposal 'unprecedented,' the energy industry associations reiterate their opposition: 'While the undersigned support the goals of a reliable and resilient grid, adoption of ill-considered discriminatory payments contemplated in the DOE NOPR is not supportable - or even appropriate - from a legal or policy perspective.

About ACORE

The American Council on Renewable Energy (ACORE) is a national non-profit organization leading the transition to a renewable energy economy. With hundreds of member companies from across the spectrum of renewable energy technologies, consumers and investors, ACORE is uniquely positioned to promote the policies and financial structures essential to growth in the renewable energy sector. Our annual forums in Washington, D.C., New York and San Franciscoset the industry standard in providing important venues for key leaders to meet, discuss recent developments, and hear the latest from senior government officials and seasoned experts.

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US Climate Alliance 100% Renewables 2035 accelerates clean energy, electrification, and decarbonization, replacing coal and gas with wind, solar, and storage to cut air pollution, lower energy bills, create jobs, and advance environmental justice.

Key Points

A state-level target for alliance members to meet all electricity demand with renewable energy by 2035.

✅ 100% RES can meet rising demand from electrification

✅ Major health gains from reduced SO2, NOx, and particulates

✅ Jobs grow, energy burdens fall, climate resilience improves

The Union of Concerned Scientists joined with COPAL (Minnesota), GreenRoots (Massachusetts), and the Michigan Environmental Justice Coalition, to better understand the feasibility and implications of leadership states meeting 100 percent of their electricity needs with renewable energy by 2035, a target reflected in federal clean electricity goals under discussion today.

We focused on 24 member states of the United States Climate Alliance, a bipartisan coalition of governors committed to the goals of the 2015 Paris Climate Agreement. We analyzed two main scenarios: business as usual versus 100 percent renewable electricity standards, in line with many state clean energy targets now in place.

Our analysis shows that:

Climate Alliance states can meet 100 percent of their electricity consumption with renewable energy by 2035, as independent assessments of zero-emissions feasibility suggest. This holds true even with strong increases in demand due to the electrification of transportation and heating.

A transition to renewables yields strong benefits in terms of health, climate, economies, and energy affordability.

To ensure an equitable transition, states should broaden access to clean energy technologies and decision making to include environmental justice and fossil fuel-dependent communitieswhile directly phasing out coal and gas plants.

Demands for climate action surround us. Every day brings news of devastating "this is not normal" extreme weather: record-breaking heat waves, precipitation, flooding, wildfires. To build resilience and mitigate the worst impacts of the climate crisis requires immediate action to reduce heat-trapping emissions and transition to renewable energy, including practical decarbonization strategies adopted by states.

On the Road to 100 Percent Renewables explores actions at one critical level: how leadership states can address climate change by reducing heat-trapping emissions in key sectors of the economy as well as by considering the impacts of our energy choices. A collaboration of the Union of Concerned Scientists and local environmental justice groups COPAL (Minnesota), GreenRoots (Massachusetts), and the Michigan Environmental Justice Coalition, with contributions from the national Initiative for Energy Justice, assessed the potential to accelerate the use of renewable energy dramatically through state-level renewable electricity standards (RESs), major drivers of clean energy in recent decades. In addition, the partners worked with Greenlink Analytics, an energy research organization, to assess how RESs most directly affect people's lives, such as changes in public health, jobs, and energy bills for households.

Focusing on 24 members of the United States Climate Alliance (USCA), the study assesses the implications of meeting 100 percent of electricity consumption in these states, including examples like Rhode Island's 100% by 2030 plan that inform policy design, with renewable energy in the near term. The alliance is a bipartisan coalition of governors committed to reducing heat-trapping emissions consistent with the goals of the 2015 Paris climate agreement.[1]

On the Road to 100 Percent Renewables looks at three types of results from a transition to 100 percent RES policies: improvements in public health from decreasing the use of coal and gas2 power plants; net job creation from switching to more labor-oriented clean energy; and reduced household energy bills from using cleaner sources of energy. The study assumes a strong push to electrify transportation and heating to address harmful emissions from the current use of fossil fuels in these sectors. Our core policy scenario does not focus on electricity generation itself, nor does it mandate retiring coal, gas, and nuclear power plants or assess new policies to drive renewable energy in non-USCA states.

Our analysis shows that:

USCA states can meet 100 percent of their electricity consumption with renewable energy by 2035 even with strong increases in demand due to electrifying transportation and heating.

A transition to renewables yields strong benefits in terms of health, climate, economies, and energy affordability.

Renewable electricity standards must be paired with policies that address not only electricity consumption but also electricity generation, including modern grid infrastructure upgrades that enable higher renewable shares, both to transition away from fossil fuels more quickly and to ensure an equitable transition in which all communities experience the benefits of a clean energy economy.

Currently, the states in this analysis meet their electricity needs with differing mixes of electricity sourcesfossil fuels, nuclear, and renewables. Yet across the states, the study shows significant declines in fossil fuel use from transitioning to clean electricity; the use of solar and wind powerthe dominant renewablesgrows substantially:

In the study's "No New Policy" scenario"business as usual"coal and gas generation stay largely at current levels over the next two decades. Electricity generation from wind and solar grows due to both current policies and lowest costs.

In a "100% RES" scenario, each USCA state puts in place a 100 percent renewable electricity standard. Gas generation falls, although some continues for export to non-USCA states. Coal generation essentially disappears by 2040. Wind and solar generation combined grow to seven times current levels, and three times as much as in the No New Policy scenario.

A focus on meeting in-state electricity consumption in the 100% RES scenario yields important outcomes. Reductions in electricity from coal and gas plants in the USCA states reduce power plant pollution, including emissions of sulfur dioxide and nitrogen oxides. By 2040, this leads to 6,000 to 13,000 fewer premature deaths than in the No New Policy scenario, as well as 140,000 fewer cases of asthma exacerbation and 700,000 fewer lost workdays. The value of the additional public health benefits in the USCA states totals almost $280 billion over the two decades. In a more detailed analysis of three USCA statesMassachusetts, Michigan, and Minnesotathe 100% RES scenario leads to almost 200,000 more added jobs in building and installing new electric generation capacity than the No New Policy scenario.

The 100% RES scenario also reduces average energy burdens, the portion of household income spent on energy. Even considering household costs solely for electricity and gas, energy burdens in the 100% RES scenario are at or below those in the No New Policy scenario in each USCA state in most or all years. The average energy burden across those states declines from 3.7 percent of income in 2020 to 3.0 percent in 2040 in the 100% RES scenario, compared with 3.3 percent in 2040 in the No New Policy scenario.

Decreasing the use of fossil fuels through increasing the use of renewables and accelerating electrification reduces emissions of carbon dioxide (CO2), with implications for climate, public health, and economies. Annual CO2 emissions from power plants in USCA states decrease 58 percent from 2020 to 2040 in the 100% RES scenario compared with 12 percent in the No New Policy scenario.

The study also reveals gaps to be filled beyond eliminating fossil fuel pollution from communities, such as the persistence of gas generation to sell power to neighboring states, reflecting barriers to a fully renewable grid that policy must address. Further, it stresses the importance of policies targeting just and equitable outcomes in the move to renewable energy.

Moving away from fossil fuels in communities most affected by harmful air pollution should be a top priority in comprehensive energy policies. Many communities continue to bear far too large a share of the negative impacts from decades of siting the infrastructure for the nation's fossil fuel power sector in or near marginalized neighborhoods. This pattern will likely persist if the issue is not acknowledged and addressed. State policies should mandate a priority on reducing emissions in communities overburdened by pollution and avoiding investments inconsistent with the need to remove heat-trapping emissions and air pollution at an accelerated rate. And communities must be centrally involved in decisionmaking around any policies and rules that affect them directly, including proposals to change electricity generation, both to retire fossil fuel plants and to build the renewable energy infrastructure.

Key recommendations in On the Road to 100 Percent Renewables address moving away from fossil fuels, increasing investment in renewable energy, and reducing CO2 emissions. They aim to ensure that communities most affected by a history of environmental racism and pollution share in the benefits of the transition: cleaner air, equitable access to good-paying jobs and entrepreneurship alternatives, affordable energy, and the resilience that renewable energy, electrification, energy efficiency, and energy storage can provide. While many communities can benefit from the transition, strong justice and equity policies will avoid perpetuating inequities in the electricity system. State support to historically underserved communities for investing in solar, energy efficiency, energy storage, and electrification will encourage local investment, community wealth-building, and the resilience benefits the transition to renewable energy can provide.

A national clean electricity standard and strong pollution standards should complement state action to drive swift decarbonization and pollution reduction across the United States. Even so, states are well positioned to simultaneously address climate change and decades of inequities in the power system. While it does not substitute for much-needed national and international leadership, strong state action is crucial to achieving an equitable clean energy future.

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