Third turbine for farm brings smiles

PG&E COVID-19 Shutoff Moratorium suspends service disconnections, offers flexible payment plans, and expands customer support with safety protocols, social distancing, and public health guidance for residential and commercial utility customers during the pandemic.

Key Points

A temporary halt to utility shutoffs with flexible payment plans to support PG&E customers during COVID-19.

✅ Suspends shutoffs for residential and commercial accounts

✅ Offers most flexible payment plans upon COVID-19 hardship

✅ Enhances safety: social distancing, PPE, remote work protocols

Pacific Gas and Electric Company has announced that due to the COVID-19 pandemic, it has voluntarily implemented a moratorium on service disconnections for non-payment, effective immediately. This suspension, similar to policies in New Jersey and New York, will apply to both residential and commercial customers and will remain in effect until further notice. To further support customers who may be impacted by the pandemic, PG&E will offer its most flexible pay plans to customers who indicate either an impact or hardship as a result of COVID-19. PG&E will continue to monitor current events and identify opportunities to support our customers and communities through concrete actions.

In addition to the moratorium on service shut-offs, PG&E’s response to the COVID-19 pandemic is focused on efforts to protect the health and safety of its customers, employees, contractors and the communities it serves, including ongoing wildfire risk reduction efforts that continue alongside its pandemic response. Actions the company has taken include providing guidance for employees who have direct customer contact to take social distancing precautionary measures, such as avoiding handshakes and wearing disposable nitrile gloves while in customers' homes, and continuing safety work related to power line-related fires across its service area.

Customers who visit local offices to pay bills and are sick or experiencing symptoms are being asked to use other payment options such as online or by phone, as seen when Texas utilities waived fees during the pandemic, at 1-877-704-8470.

“We recognize that this is a rapidly changing situation and an uncertain time for many of our customers. Our most important responsibility is the health and safety of our customers and employees. We also want to provide some relief from the stress and financial challenges many are facing during this worldwide, public health crisis, and with rates set to stabilize in 2025 the company remains focused on affordability. We understand that many of our customers may experience a personal financial strain due to the slowdown in the economy related to the pandemic, and programs like the Wildfire Assistance Program can help eligible customers,” said Chief Customer Officer and Senior Vice President Laurie Giammona.

Internally, the company is taking advanced cleaning measures, communicating best practices frequently with employees, and is asking its leaders to let employees work remotely if their job allows, while avoiding critical business disruption. PG&E has activated an enterprise-wide incident response team and is vigilantly monitoring the Centers for Disease Control and Prevention and World Health Organization for updates related to the virus. The company is committed to continue addressing customer service needs and does not expect any disruption in gas or electric service due to the public health crisis.

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CO2 Removal Technologies address climate change via negative emissions, including carbon capture, reforestation, soil carbon, biochar, BECCS, DAC, and mineralization, helping meet Paris Agreement targets while managing costs, land use, and infrastructure demands.

Key Points

Methods to extract or sequester atmospheric CO2, combining natural and engineered approaches to limit warming.

✅ Includes reforestation, soil carbon, biochar, BECCS, DAC, mineralization

✅ Balances climate goals with costs, land, energy, and infrastructure

✅ Key to Paris Agreement targets under 1.5-2.0 °C warming

The world is, on average, 1.1 degrees Celsius warmer today than it was in 1850. If this trend continues, our planet will be 2 – 3 degrees hotter by the end of this century, according to the Intergovernmental Panel on Climate Change (IPCC).

The main reason for this temperature rise is higher levels of atmospheric carbon dioxide, which cause the atmosphere to trap heat radiating from the Earth into space. Since 1850, the proportion of CO2 in the air has increased, with record greenhouse gas concentrations documented, from 0.029% to 0.041% (288 ppm to 414 ppm).

This is directly related to the burning of coal, oil and gas, which were created from forests, plankton and plants over millions of years. Back then, they stored CO2 and kept it out of the atmosphere, but as fossil fuels are burned, that CO2 is released. Other contributing factors include industrialized agriculture and slash-and-burn land clearing techniques, and emissions from SF6 in electrical equipment are also concerning today.

Over the past 50 years, more than 1200 billion tons of CO2 have been emitted into the planet's atmosphere — 36.6 billion tons in 2018 alone, though global emissions flatlined in 2019 before rising again. As a result, the global average temperature has risen by 0.8 degrees in just half a century.

Atmospheric CO2 should remain at a minimum
In 2015, the world came together to sign the Paris Climate Agreement which set the goal of limiting global temperature rise to well below 2 degrees — 1.5 degrees, if possible.

The agreement limits the amount of CO2 that can be released into the atmosphere, providing a benchmark for the global energy transition now underway. According to the IPCC, if a maximum of around 300 billion tons were emitted, there would be a 50% chance of limiting global temperature rise to 1.5 degrees. If CO2 emissions remain the same, however, the CO2 'budget' would be used up in just seven years.

According to the IPCC's report on the 1.5 degree target, negative emissions are also necessary to achieve the climate targets.

Using reforestation to remove CO2
One planned measure to stop too much CO2 from being released into the atmosphere is reforestation. According to studies, 3.6 billion tons of CO2 — around 10% of current CO2 emissions — could be saved every year during the growth phase. However, a study by researchers at the Swiss Federal Institute of Technology, ETH Zurich, stresses that achieving this would require the use of land areas equivalent in size to the entire US.

Young trees at a reforestation project in Africa (picture-alliance/OKAPIA KG, Germany)
Reforestation has potential to tackle the climate crisis by capturing CO2. But it would require a large amount of space

More humus in the soil
Humus in the soil stores a lot of carbon. But this is being released through the industrialization of agriculture. The amount of humus in the soil can be increased by using catch crops and plants with deep roots as well as by working harvest remnants back into the ground and avoiding deep plowing. According to a study by the German Institute for International and Security Affairs (SWP) on using targeted CO2 extraction as a part of EU climate policy, between two and five billion tons of CO2 could be saved with a global build-up of humus reserves.

Biochar shows promise
Some scientists see biochar as a promising technology for keeping CO2 out of the atmosphere. Biochar is created when organic material is heated and pressurized in a zero or very low-oxygen environment. In powdered form, the biochar is then spread on arable land where it acts as a fertilizer. This also increases the amount of carbon content in the soil. According to the same study from the SWP, global application of this technology could save between 0.5 and two billion tons of CO2 every year.

Storing CO2 in the ground
Storing CO2 deep in the Earth is already well-known and practiced on Norway's oil fields, for example. However, the process is still controversial, as storing CO2 underground can lead to earthquakes and leakage in the long-term. A different method is currently being practiced in Iceland, in which CO2 is sequestered into porous basalt rock to be mineralized into stone. Both methods still require more research, however, with new DOE funding supporting carbon capture, utilization, and storage.

Capturing CO2 to be held underground is done by using chemical processes which effectively extract the gas from the ambient air, and some researchers are exploring CO2-to-electricity concepts for utilization. This method is known as direct air capture (DAC) and is already practiced in other parts of Europe.  As there is no limit to the amount of CO2 that can be captured, it is considered to have great potential. However, the main disadvantage is the cost — currently around €550 ($650) per ton. Some scientists believe that mass production of DAC systems could bring prices down to €50 per ton by 2050. It is already considered a key technology for future climate protection.

The inside of a carbon capture facility in the Netherlands (RWE AG)
Carbon capture facilities are still very expensive and take up a huge amount of space

Another way of extracting CO2 from the air is via biomass. Plants grow and are burned in a power plant to produce electricity. CO2 is then extracted from the exhaust gas of the power plant and stored deep in the Earth, with new U.S. power plant rules poised to test such carbon capture approaches.

The big problem with this technology, known as bio-energy carbon capture and storage (BECCS) is the huge amount of space required. According to Felix Creutzig from the Mercator Institute on Global Commons and Climate Change (MCC) in Berlin, it will therefore only play "a minor role" in CO2 removal technologies.

CO2 bound by rock minerals
In this process, carbonate and silicate rocks are mined, ground and scattered on agricultural land or on the surface water of the ocean, where they collect CO2 over a period of years. According to researchers, by the middle of this century it would be possible to capture two to four billion tons of CO2 every year using this technique. The main challenges are primarily the quantities of stone required, and building the necessary infrastructure. Concrete plans have not yet been researched.

Not an option: Fertilizing the sea with iron
The idea is use iron to fertilize the ocean, thereby increasing its nuturient content, which would allow plankton to grow stronger and capture more CO2. However, both the process and possible side effects are very controversial. "This is rarely treated as a serious option in research," concludes SWP study authors Oliver Geden and Felix Schenuit.

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Jersey Electricity Standby Charge proposes a grid-backup fee for commercial self-generators of renewable energy, with a review delaying implementation; potential tariff impacts include 10-15 percent price rises, cost recovery, and network reliability.

Key Points

A grid-backup fee for Jersey self-generating businesses to share network costs fairly and curb electricity price rises.

✅ Applies to commercial self-generation using renewables or not

✅ Excludes full exporters and pre-charge installations

✅ Aims to recover grid costs and avoid 10-15% price rises

Electricity prices could rise by ten to 15 per cent if a standby charge for some commercial customers is not implemented, the chief executive of Jersey Electricity has warned.

Jersey Electricity has proposed extending a monthly fee to commercial customers who generate their own power through renewable means but still wish to be connected to Jersey’s grid as a back-up, echoing Ontario energy storage efforts to shore up reliability.

The States recently unanimously backed a proposal lodged by Deputy Carolyn Labey to delay administering the levy until a review could be carried out, as seen in the UK grid's net-zero transformation debates influencing policy. The charge, was due to be implemented next month but will now not be introduced until May, or later if the review has not concluded.

But Chris Ambler, JE chief executive, warned that failing to implement the standby charge could lead to additional costs for customers.

Some of JE’s commercial customers have already been charged a standby fee after generating their own power through non-renewable means.

The charge does not apply to businesses which export all of their electricity back into the system as part of a buy-back scheme or those which install self-generation facilities before the charge is implemented.

Deputy Labey argued that the Island had done ‘absolutely nothing’ to support the use of renewable energies and instead were discouraging locally generated power by allowing JE to set a standby charge.

She added that she was pleased that the Council of Ministers had already starting reviewing the charges but the debate needed to go ahead to ensure the work continued after the May election.

During a States debate last month, she said: ‘It is increasingly concerning that we, as an island in the 21st century, are happy for our electricity to be provided to us by an unregulated, publicly listed for-profit company with a monopoly on energy.

‘I also think that introducing a charge on renewables at a time when the world is experiencing a revolution in renewable energies, including offshore vessel charging solutions, which are becoming increasingly economic, is something that needs to be investigated.

‘Jersey should be looking to diversify our electricity production and supply, to help protect us from price and currency fluctuations and to ensure that we, as an island, receive the best deal possible for Islanders.’

Mr Ambler said that any price increase would be dependent on the future take-up and use of renewable-energy technology in Jersey.

He said: ‘The cost impact would not be significant in the short term but in the long term it could be significant. I think that we are obliged to let our customers know that.

‘It is very difficult to assess but if we are not able to levy a fair charge, then, as electricity shortages in Canada have shown, we could see prices rise by ten to 15 per cent over time.’

Mr Ambler added that his company was in favour of the use of renewable energy, with a third of the company’s electricity being generated by hydroelectric sources, but that the costs of implementing it needed to be fairly distributed, given how big battery rule changes can affect project viability elsewhere in the market.

And he said that, while it was difficult to quantify how much could be lost if the standby charge was not implemented, it could cost the company over £10 million.

‘In 2014, we only increased our prices by one per cent,’ he said. ‘We are reviewing our prices at the moment but if we did put an increase in place it would be modest and it would not be linked to the standby charge.’

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Canadian Hydropower Transmission delivers HVDC clean energy via New England Clean Energy Connect and Champlain Hudson Power Express, linking HydroQuébec to Maine and New York grids for renewable energy, decarbonization, and lower wholesale electricity rates.

Key Points

HVDC delivery of HydroQuébec power to New England and New York via NECEC and CHPE, cutting emissions and costs.

✅ 1,200 MW via NECEC; 1,000 MW via CHPE.

✅ HVDC routes: 145-mile NECEC and 333-mile CHPE.

✅ Debates: land impacts, climate justice, wholesale rates.

As the sole residents of unorganized territory T5 R7 deep within Maine's North Woods, Duane Hanson and his wife, Sally Kwan, have watched the land around them—known for its natural beauty, diverse wildlife and recreational fishing—transformed by decades of development. 

But what troubles them most is what could happen in the next few months. State and corporate officials are pushing for construction of a 53-mile-long power line corridor cutting right through the woods and abutting the wild lands surrounding Hanson's property. 

If its proponents succeed, Hanson fears the corridor may represent the beginning of the end of his ability to live "off the land" away from the noise of technology-obsessed modern society. Soon, that noise may be in his backyard. 

"I moved here to be in the pristine wilderness," said Hanson.
 
With his life in what he considers the last "wild" place left on the East Coast on the line, the stakes have never felt higher to Hanson—and many across New England, as well.

The corridor is part of the New England Clean Energy Connect, one of two major and highly controversial transmission line projects meant to deliver Canadian hydropower from the government-owned utility HydroQuébec, in a province that has closed the door on nuclear power, to New England electricity consumers. 

As New England states rush to green their electric grids and combat the accelerating climate crisis, the simultaneous push from Canada to expand the market for hydroelectric power from its vast water resources, including Manitoba's clean energy, has offered these states a critical lifeline at just the right moment. 

The other big hydropower transmission line project will deliver 1,000 megawatts of power, or enough to serve approximately one million residential customers, to the New York City metropolitan area, which includes the city, Long Island, and parts of the Hudson Valley, New Jersey, Connecticut and Pennsylvania. 

The 333-mile-long Champlain Hudson Power Express project will consist of two high voltage direct current cables running underground and underwater from Canada, beneath Lake Champlain and the Hudson River, to Astoria, Queens. 

There, the Champlain Hudson project will interconnect to a sector of the New York electricity grid where city and corporate officials say the hydropower supplied can help reduce the fossil fuels that currently comprise significantly more of the base load than in other parts of the state. Though New York has yet to finalize a contract with HydroQuébec over its hydropower purchase, developers plan to start construction on the $2.2 billion project in 2021 and say it will be operational in 2025. 

The New England project consists of 145 miles of new HVDC transmission line that will run largely above ground from the Canadian border, through Maine to Massachusetts. The $1 billion project, funded by Massachusetts electricity consumers, is expected to deliver 1,200 megawatts of clean energy to the New England energy grid, becoming the region's largest clean energy source. 

Central Maine Power, which will construct the Maine transmission corridor, says the project will decrease wholesale electric rates and create thousands of jobs. Company officials expect to receive all necessary permits and begin construction by the year's end, with the project completed and in service by 2020. 

With only months until developers start making both projects on-the-ground realities, they have seized public attention within, and beyond, their regions. 

Hanson is one among many concerned New England and New York residents who've joined the ranks of environmental activists in a contentious battle with public and corporate officials over the place of Canadian hydropower in their states' clean energy futures. 

Officials and transmission line proponents say importing Canadian hydropower offers an immediate and feasible way to help decarbonize electricity portfolios in New York and New England and to address existing transmission constraints that limit cross-border flows today, supporting their broader efforts to combat climate change. 

But some environmental activists say hydropower has a significant carbon footprint of its own. They fear the projects will make states look "greener" at the expense of the local environment, Indigenous communities, and ultimately, the climate. 

"We're talking about the most environmentally and economically just pathway" to decarbonization, said Annel Hernandez, associate director of the NYC Environmental Justice Alliance. "Canadian hydro is not going to provide that." 

To that end, environmental groups opposing Canadian hydropower say New York and New England should seize the moment to expedite local development of wind and solar power. 

Paul Gallay, president of the nonprofit environmental organization Riverkeeper—which withdrew its initial support for the Champlain Hudson Power Express last November— believes New York has the capacity to develop enough in-state renewable energy sources to meet its clean energy goals, without the new transmission line. 

Yet New York City's analysis shows clearly that Canadian hydropower is critical for its clean energy strategy, said Dan Zarrilli, director of OneNYC and New York City's chief climate policy adviser. 

"We need every bit of clean energy we can get our hands on," he said, to meet the city's goal of carbon neutrality by 2050 and help achieve the state's clean energy mandates. 

Removing Canadian hydropower from the equation, said Zarilli, would commit the city to the "unacceptable outcome" of burning more gas. The city's marginalized communities would likely suffer most from the resulting air pollution and associated health impacts. 

While the two camps debate Canadian hydropower's carbon footprint and what climate justice requires, this much is clear: When it comes to pursuing a zero-carbon future, there are no easy answers. 

Hydropower's Carbon Footprint
Many people take for granted that because hydropower production doesn't involve burning fossil fuels, it's a carbon-neutral endeavor. But that's not always the case, depending on where hydropower is sourced. 

Large-scale hydropower projects often involve the creation of hydroelectric dams and reservoirs, and, in some cases, repowering existing dams to generate clean electricity. The release and flow of water from the reservoir through the dam provides the energy necessary to generate hydropower, which long-distance power lines, or transmission lines, carry to its intended destination—in this case, New England and New York. 

The initial process of flooding land to create a hydroelectric reservoir can have a sizable carbon footprint, especially in heavily vegetated areas. It causes the vegetation and soil underwater to decompose, releasing carbon dioxide and methane—a greenhouse gas 84 times more potent over a 20-year period than carbon dioxide. 

Hydropower accounts for 60 percent of Canada's electricity generation, and HydroQuébec has planned to increase capacity to 37,000 MW in 2021, with the nation second only to China in the percentage of the world's total hydroelectricity it generates. By contrast, hydropower only accounts for seven percent of U.S. utility-scale electricity generation, making it a foreign concept to many Americans. 

As New England works to introduce substantial amounts of Canadian hydropower to its electricity grid, hydropower proponents are promoting it as a prime source for clean electricity, and new NB Power agreements are expanding regional transfers within Canada as well. 

Last fall, Central Maine Power formed its own political action committee, Clean Energy Matters, to advance the New England hydropower project. Together with HydroQuébec, the Maine utility has spent nearly $17 million campaigning for the project this year. 

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NB Power Smart Meter Opt-Out Fees reflect cost causation principles set before the Energy and Utilities Board, covering meter reading charges, transmitter-disable options, rollout targets, and education plans across New Brunswick's smart metering program.

Key Points

Fees NB Power may apply to customers opting out of smart meters, reflecting cost causation and meter-reading costs.

✅ Based on cost causation and meter reading expenses

✅ BC and Quebec charge monthly opt-out surcharges

✅ Policy finalized during rollout after EUB review

NB Power customers who do not want a smart meter installed on their home could be facing a stiff fee for that decision, but so far the utility is not saying how much it might be.  

"It will be based on the principles of cost causation, but we have not gotten into the detail of what that fee would be at this point," said NB Power Senior Vice President of Operations Lori Clark at Energy and Utilities Board hearings on Friday.

In other jurisdictions that have already adopted smart meters, customers not wanting to participate have faced hundreds of dollars in extra charges, while Texas utilities' pullback from smart-home networks shows approaches can differ.

In British Columbia, power customers are charged a meter reading fee of $32.40 per month if they refuse a smart meter, or $20 per month if they accept a smart meter but insist its radio transmitter be turned off. That's a cost of between $240 and $388.80 per year for customers to opt out.

In Quebec, smart meters were installed beginning in 2012. Customers who refused the devices were initially charged $98 to opt out plus a meter reading fee of $17 per month. That was eventually cut by Quebec's energy board in 2014 to a $15 refusal fee and a $5 per month meter reading surcharge.

NB Power said it may be a year or more before it settles on its own fee.

"The opt out policy will be developed and implemented as part of the roll out.  It will be one of the last things we do," said Clark.

Customers need to be on board

NB Power is in front of the New Brunswick Energy and Utilities Board seeking permission to spend $122.7 million to install 350,000 smart meters province wide, as neighboring markets grapple with major rate increases that heighten affordability concerns.  

The meters are capable of transmitting consumption data of customers back to NB Power in real time, which the utility said will allow for a number of innovations in pricing and service, and help address old meter inaccuracies that affected some households.

The meters require near universal adoption by customers to maximize their financial benefit — like eliminating more than $20 million a year NB Power currently spends to read meters manually. The utility has said the switch will not succeed if too many customers opt out.

"We certainly wouldn't be looking at making an investment of this size without having the customer with us," said Clark.

On Thursday, Kent County resident Daniel LeBlanc, who along with Roger Richard, is opposing the introduction of smart meters for health reasons, predicted a cool reception for the technology in many parts of the province, given concerns that include health effects and billing disputes in Nova Scotia reported elsewhere.

"If one were to ask most of the people in the rural areas, I'm not sure you would get a lot of takers for this infrastructure," said LeBlanc, who is concerned with the long-term effect microwave frequencies used by the meters to transmit data may have on human health.

That issue is before the EUB next week.

Haven't tested the waters

NB Power acknowledged it has not measured public opinion on adopting smart meters but is confident it can convince customers it is a good idea for them and the utility, even as seasonal rate proposals in New Brunswick have prompted consumer backlash.

"People don't understand what the smart meter is," said Clark. "We need to educate our customers first to allow them to make an informed decision so that will be part of the roll out plan."

Clark noted that smart meters, helped by stiff opting out penalties, were eventually accepted by 98 per cent of customers in British Columbia and by 97.4 per cent of customers in Quebec.

"We will check and adjust along the way if there are issues with customer uptake," said Clark.

"This is very similar to what has been done in other jurisdictions and they haven't had those challenges."

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California income-based utility charges face bipartisan pushback as the PUC weighs fixed fees for PG&E, SDG&E, and Southern California Edison, reshaping rate design, electricity affordability, energy equity, and privacy amid proposed per-kWh reductions.

Key Points

PUC-approved fixed fees tied to household income for PG&E, SDG&E, and SCE, offset by lower per-kWh rates.

✅ Proposed fixed fees: $51 SCE, $73.31 SDG&E, $50.92 PG&E

✅ Critics warn admin, privacy, legal risks and higher bills for savers

✅ Backers say lower-income pay less; kWh rates cut ~33% in PG&E area

Efforts are being made across California's political landscape to derail a legislative initiative that introduced income-based utility charges for customers of Southern California Edison and other major utilities.

Legislators from both the Democratic and Republican parties have proposed bills aimed at nullifying the 2022 legislation that established a sliding scale for utility charges based on customer income, a decision made in a late-hour session and subsequently endorsed by Governor Gavin Newsom.

The plan, pending final approval from the state Public Utilities Commission (PUC) — all of whose current members were appointed by Governor Newsom — would enable utilities like Southern California Edison, San Diego Gas & Electric, and PG&E to apply new income-based charges as early as this July.

Among the state legislators pushing back against the income-based charge scheme are Democrats Jacqui Irwin and Marc Berman, along with Republicans Janet Nguyen, Kelly Seyarto, Rosilicie Ochoa Bogh, Scott Wilk, Brian Dahle, Shannon Grove, and Roger Niello.

A cadre of specialists, including economist Ahmad Faruqui who has advised all three utilities implicated in the fee proposal, have outlined several concerns regarding the PUC's pending decision.

Faruqui and his colleagues argue that the proposed charges are excessively high in comparison to national standards, reflecting soaring electricity prices across the state, potentially leading to administrative challenges, legal disputes, and negative unintended outcomes, such as penalizing energy-conservative consumers.

Advocates for the income-based fee model, including The Utility Reform Network (TURN) and the National Resources Defense Council, argue it would result in higher charges for wealthier consumers and reduced fees for those with lower incomes. They also believe that the utilities plan to decrease per kilowatt-hour rates as part of a broader rate structure review to balance out the new fees.

However, even supporters like TURN and the Natural Resources Defense Council acknowledge that the income-based fee model is not a comprehensive solution to making soaring electricity bills more affordable.

If implemented, California would have the highest income-based utility fees in the country, with averages far surpassing the national average of $11.15, as reported by EQ Research:

• Southern California Edison would charge $51.
• San Diego Gas & Electric would levy $73.31.
• PG&E would set fees at $50.92.

The proposal has raised concerns among state legislators about the additional financial burden on Californians already struggling with high electricity costs.

Critics highlight several practical challenges, including the PUC's task of assessing customers' income levels, a process fraught with privacy concerns, potential errors, and constitutional questions regarding access to tax information.

Economists have pointed out further complications, such as the difficulty in accurately assessing incomes for out-of-state property owners and the variability of customers' incomes over time.

The proposed income-based charges would differ by income bracket within the PG&E service area, for example, with lower-income households facing lower fixed charges and higher-income households facing higher charges, alongside a proposed 33% reduction in electricity rates to help mitigate the fixed charge impact.

Yet, the economists warn that most customers, particularly low-usage customers, could end up paying more, essentially rewarding higher consumption and penalizing efficiency.

This legislative approach, they caution, could inadvertently increase costs for moderate users across all income brackets, a sign of major changes to electric bills that could emerge, challenging the very goals it aims to achieve by promoting energy inefficiency.

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