Consider costs of mandating solar thermal energy

Hertel-New York Interconnection delivers Hydro-Quebec renewable energy via a cross-border transmission line to New York City by 2025, supplying 1,250 MW through underground and underwater routes under a 25-year contract.

Key Points

A cross-border line delivering 1,250 MW of Hydro-Quebec hydropower to New York City via underground routes.

✅ 1,250 MW clean power to NYC by 2025

✅ 56.1 km underground, 1.6 km underwater in Quebec

✅ 25-year contract; Mohawk partnership revenue

Hydro-Quebec announced Thursday it has chosen the route for the Hertel-New York interconnection line, which will begin construction in the spring of 2023 in Quebec.

The project will deliver 1,250 megawatts of Quebec hydroelectricity to New York City starting in 2025, even as a recent electricity shortage report warns about rising demand at home.

It's a 25-year contract for Hydro-Quebec, the largest export contract for the province-owned company, and comes as hydrogen production investments gain traction in Eastern Canada.

The Crown corporation has not disclosed potential revenues from the project, but Premier François Legault mentioned on social media last September that a deal in principle worth more than $20 billion over 25 years was in the works.

The route includes a 56.1-kilometre underground and a 1.6-kilometre underwater section, similar to the Lake Erie Connector project planned under Lake Erie.

Eight municipalities in the Montérégie region will be affected: La Prairie, Saint-Philippe, Saint-Jacques-le-Mineur, Saint-Édouard, Saint-Patrice-de-Sherrington, Saint-Cyprien-de-Napierville, Saint-Bernard-de-Lacolle and Lacolle.

Across the country, new renewables such as wind projects in Yukon are receiving federal support, reflecting broader grid decarbonization.

The last part of the route will run along Fairbanks Creek to the Richelieu River, where it will connect with the American network.

Further south, there will be a 545-kilometre link between the Canada-U.S. border and New York City, while a separate Maine transmission approval advances a New England pathway for Quebec power.

Hydro-Quebec is holding two consultations on the project, on Dec. 8 in Lacolle and Dec. 9 in Saint-Jacques-le-Mineur.

Elsewhere in Atlantic Canada, EV-to-grid integration pilots are underway to test how vehicles can support the power system.

Once the route is in service, the Quebec line will be subject to a partnership between Hydro-Quebec and the Mohawk Council of Kahnawake, which will benefit from economic remunerations for 40 years.

To enhance reliability, grid-scale battery storage projects are also expanding in Ontario.

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Duke Energy Clean Energy Strategy advances renewables, battery storage, grid modernization, and energy efficiency to cut carbon, retire coal, and target net-zero by 2050 across the Carolinas with robust IRPs and capital investments.

Key Points

Plan to expand renewables, storage, and grid upgrades to cut carbon and reach net-zero electricity by 2050.

✅ 56B investment in renewables, storage, and grid modernization

✅ Targets 50% carbon reduction by 2030 and net-zero by 2050

✅ Retires coal units; expands energy efficiency and IRPs

Duke Energy says that the company will continue advancing its ambitious clean energy goals without the Atlantic Coast Pipeline (ACP) by investing in renewables, battery storage, energy efficiency programs and grid projects that support U.S. electrification efforts.

Duke Energy, the nation's largest electric utility, unveils its new logo. (PRNewsFoto/Duke Energy) (PRNewsfoto/Duke Energy)

Duke Energy's $56 billion capital investment plan will deliver significant customer benefits and create jobs at a time when policymakers at all levels are looking for ways to rebuild the economy in 2020 and beyond. These investments will deliver cleaner energy for customers and communities while enhancing the energy grid to provide greater reliability and resiliency.

"Sustainability and the reduction of carbon emissions are closely tied to our region's success," said Lynn Good, Duke Energy Chair, President and CEO. "In our recent Climate Report, we shared a vision of a cleaner electricity future with an increasing focus on renewables and battery storage in addition to a diverse mix of zero-carbon nuclear, natural gas, hydro and energy efficiency programs.

"Achieving this clean energy vision will require all of us working together to develop a plan that is smart, equitable and ensures the reliability and affordability that will spur economic growth in the region. While we're disappointed that we're not able to move forward with ACP, we will continue exploring ways to help our customers and communities, particularly in eastern North Carolina where the need is great," said Good.

Already a clean-energy leader, Duke Energy has reduced its carbon emissions by 39% from 2005 and remains on track to cut its carbon emissions by at least 50% by 2030, as peers like Alliant's carbon-neutral plan demonstrate broader industry momentum toward decarbonization. The company also has an ambitious clean energy goal of reaching net-zero emissions from electricity generation by 2050. 

In September 2020, Duke Energy plans to file its Integrated Resource Plans (IRP) for the Carolinas after an extensive process of working with the state's leaders, policymakers, customers and other stakeholders. The IRPs will include multiple scenarios to support a path to a cleaner energy future in the Carolinas, reflecting key utility trends shaping resource planning.

Since 2010, Duke Energy has retired 51 coal units totaling more than 6,500 megawatts (MW) and plans to retire at least an additional 900 MW by the end of 2024. In 2019, the company proposed to shorten the book lives of another approximately 7,700 MW of coal capacity in North Carolina and Indiana.

Duke Energy will host an analyst call in early August 2020 to discuss second quarter 2020 financial results and other business and financial updates. The company will also host its inaugural Environmental, Social and Governance (ESG) investor day in October 2020.

Duke Energy

Duke Energy is transforming its customers' experience, modernizing the energy grid, generating cleaner energy and expanding natural gas infrastructure to create a smarter energy future for the people and communities it serves. The Electric Utilities and Infrastructure unit's regulated utilities serve 7.8 million retail electric customers in six states: North Carolina, South Carolina, Florida, Indiana, Ohio and Kentucky. The Gas Utilities and Infrastructure unit distributes natural gas to 1.6 million customers in five states: North Carolina, South Carolina, Tennessee, Ohio and Kentucky. The Duke Energy Renewables unit operates wind and solar generation facilities across the U.S., as well as energy storage and microgrid projects.

Duke Energy was named to Fortune's 2020 "World's Most Admired Companies" list and Forbes' "America's Best Employers" list. More information about the company is available at duke-energy.com. The Duke Energy News Center contains news releases, fact sheets, photos, videos and other materials. Duke Energy's illumination features stories about people, innovations, community topics and environmental issues. Follow Duke Energy on Twitter, LinkedIn, Instagram and Facebook.

Forward-Looking Information

This document includes forward-looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. Forward-looking statements are based on management's beliefs and assumptions and can often be identified by terms and phrases that include "anticipate," "believe," "intend," "estimate," "expect," "continue," "should," "could," "may," "plan," "project," "predict," "will," "potential," "forecast," "target," "guidance," "outlook" or other similar terminology. Various factors may cause actual results to be materially different than the suggested outcomes within forward-looking statements; accordingly, there is no assurance that such results will be realized. These factors include, but are not limited to:

• The impact of the COVID-19 electricity demand shift on operations and revenues;
• State, federal and foreign legislative and regulatory initiatives, including costs of compliance with existing and future environmental requirements, including those related to climate change, as well as rulings that affect cost and investment recovery or have an impact on rate structures or market prices;
• The extent and timing of costs and liabilities to comply with federal and state laws, regulations and legal requirements related to coal ash remediation, including amounts for required closure of certain ash impoundments, are uncertain and difficult to estimate;
• The ability to recover eligible costs, including amounts associated with coal ash impoundment retirement obligations and costs related to significant weather events, and to earn an adequate return on investment through rate case proceedings and the regulatory process;
• The costs of decommissioning nuclear facilities could prove to be more extensive than amounts estimated and all costs may not be fully recoverable through the regulatory process;
• Costs and effects of legal and administrative proceedings, settlements, investigations and claims;
• Industrial, commercial and residential growth or decline in service territories or customer bases resulting from sustained downturns of the economy and the economic health of our service territories or variations in customer usage patterns, including energy efficiency and demand response efforts and use of alternative energy sources, such as self-generation and distributed generation technologies;
• Federal and state regulations, laws and other efforts designed to promote and expand the use of energy efficiency measures and distributed generation technologies, such as private solar and battery storage, in Duke Energy service territories could result in customers leaving the electric distribution system, excess generation resources as well as stranded costs;
• Advancements in technology;
• Additional competition in electric and natural gas markets and continued industry consolidation;
• The influence of weather and other natural phenomena on operations, including the economic, operational and other effects of severe storms, hurricanes, droughts, earthquakes and tornadoes, including extreme weather associated with climate change;
• The ability to successfully operate electric generating facilities and deliver electricity to customers including direct or indirect effects to the company resulting from an incident that affects the U.S. electric grid or generating resources;
• The ability to obtain the necessary permits and approvals and to complete necessary or desirable pipeline expansion or infrastructure projects in our natural gas business;
• Operational interruptions to our natural gas distribution and transmission activities;
• The availability of adequate interstate pipeline transportation capacity and natural gas supply;
• The impact on facilities and business from a terrorist attack, cybersecurity threats, data security breaches, operational accidents, information technology failures or other catastrophic events, such as fires, explosions, pandemic health events or other similar occurrences;
• The inherent risks associated with the operation of nuclear facilities, including environmental, health, safety, regulatory and financial risks, including the financial stability of third-party service providers;
• The timing and extent of changes in commodity prices and interest rates and the ability to recover such costs through the regulatory process, where appropriate, and their impact on liquidity positions and the value of underlying assets;
• The results of financing efforts, including the ability to obtain financing on favorable terms, which can be affected by various factors, including credit ratings, interest rate fluctuations, compliance with debt covenants and conditions and general market and economic conditions;
• Credit ratings of the Duke Energy Registrants may be different from what is expected;
• Declines in the market prices of equity and fixed-income securities and resultant cash funding requirements for defined benefit pension plans, other post-retirement benefit plans and nuclear decommissioning trust funds;
• Construction and development risks associated with the completion of the Duke Energy Registrants' capital investment projects, including risks related to financing, obtaining and complying with terms of permits, meeting construction budgets and schedules and satisfying operating and environmental performance standards, as well as the ability to recover costs from customers in a timely manner, or at all;
• Changes in rules for regional transmission organizations, including FERC debates on coal and nuclear subsidies and new and evolving capacity markets, and risks related to obligations created by the default of other participants;
• The ability to control operation and maintenance costs;
• The level of creditworthiness of counterparties to transactions;
• The ability to obtain adequate insurance at acceptable costs;
• Employee workforce factors, including the potential inability to attract and retain key personnel;
• The ability of subsidiaries to pay dividends or distributions to Duke Energy Corporation holding company (the Parent);
• The performance of projects undertaken by our nonregulated businesses and the success of efforts to invest in and develop new opportunities;
• The effect of accounting pronouncements issued periodically by accounting standard-setting bodies;
• The impact of U.S. tax legislation to our financial condition, results of operations or cash flows and our credit ratings;
• The impacts from potential impairments of goodwill or equity method investment carrying values; and
• The ability to implement our business strategy, including enhancing existing technology systems.
• Additional risks and uncertainties are identified and discussed in the Duke Energy Registrants' reports filed with the SEC and available at the SEC's website at sec.gov. In light of these risks, uncertainties and assumptions, the events described in the forward-looking statements might not occur or might occur to a different extent or at a different time than described. Forward-looking statements speak only as of the date they are made and the Duke Energy Registrants expressly disclaim an obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise.

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Connect the Grid Act links ERCOT to neighboring grids via high-voltage interconnections, enhancing reliability, resilience, and renewables integration. It enables power imports and exports with SPP, MISO, and the Western Interconnection under FERC oversight.

Key Points

A plan to link ERCOT with neighboring grids, improving reliability, enabling energy trade, and integrating renewables.

✅ High-voltage ties with SPP, MISO, and the Western Interconnection

✅ Enables imports during crises and exports of surplus power

✅ Brings ERCOT under FERC oversight; DoE to study Mexico links

In the aftermath of the devastating 2021 Texas blackouts, which exposed the vulnerabilities of the state's energy infrastructure, a significant legislative effort is underway to transform Texas from an energy island into a connected component of the broader U.S. power grid. Spearheaded by U.S. Representative Greg Casar, D-Austin, the proposed Connect the Grid Act is part of a push for smarter electricity infrastructure that seeks to remedy the isolation of the Electric Reliability Council of Texas (ERCOT) from neighboring power grids, a condition that significantly contributed to the crisis during Winter Storm Uri.

The blackouts, which left millions without power and resulted in significant loss of life and economic damage, underscored the inherent risks of Texas's unique energy infrastructure. Unlike the rest of the continental U.S., Texas's grid operates independently, limiting its ability to import electricity during emergencies. This isolation was a critical factor in the state's inability to respond effectively to the increased demand for power during the storm.

Recognizing the urgent need for a more resilient and integrated energy system, Rep. Casar's legislation aims to establish high-voltage connections between ERCOT and adjacent grid-operating organizations, including the Southern Power Pool, MISO, and the Western Interconnection. This would not only improve the reliability of Texas's power supply by enabling energy imports during crises but also allow the state to export surplus energy, thereby enhancing the economic efficiency and sustainability of its energy market.

The Connect the Grid Act proposes a range for the new connections' transfer capabilities, aiming to significantly boost the amount of power that can be shared between Texas and its neighbors. Such interconnectivity is anticipated to reduce energy costs for consumers by mitigating scarcity and enabling access to Texas's vast renewable energy resources, even as grid modernization affordability remains a point of debate among stakeholders. However, the bill faces opposition due to concerns over federal oversight, as it would bring ERCOT under the jurisdiction of the Federal Energy Regulatory Commission (FERC).

Some analysts note that policies such as later school start dates can ease late-summer peak demand as well.

At a press conference held at the IBEW Local 520 headquarters, Rep. Casar, along with environmental groups, labor unions, and frontline workers, highlighted the benefits of the proposed legislation. The bill also includes provisions for a Department of Energy study on the potential benefits of interconnecting with Mexico, and parallels proposals for macrogrids in Canada that seek greater reliability across borders.

The Connect the Grid Act reflects a broader national trend towards increasing the interconnectivity of regional power grids, a move deemed essential for the transition to renewable energy and combating climate change risks to the U.S. grid through expanded interconnection. By enabling the flow of clean energy from renewable-rich areas like Texas to energy-hungry urban centers, the legislation supports a more sustainable and resilient national energy infrastructure.

Critics of Texas's grid independence, including energy experts and federal regulators, have long advocated for such interconnections. They argue that increased access to neighboring grids could have mitigated the effects of the 2021 blackouts and emphasize the importance of a grid that can withstand extreme weather events. The Federal Energy Regulatory Commission and the North American Electric Reliability Corp. have both explored mandates and studies to promote electricity transfer between regional grids, while states like California grid upgrades are investing to modernize networks as well, highlighting the national importance of grid interconnectivity.

Despite the potential challenges of increased federal regulation, proponents of the Connect the Grid Act argue that the benefits of interconnection far outweigh the drawbacks. By reducing energy costs, enhancing grid reliability, and promoting renewable energy, the legislation aims to secure a more sustainable and equitable energy future for Texas and the nation.

If passed, the Connect the Grid Act would mark a historic shift in Texas's energy policy, ending the state's long-standing isolation and positioning it as a key player in the national and potentially international energy landscape, and echoes calls for a western Canadian electricity grid to strengthen regional ties. The bill sets a completion deadline of January 1, 2035, for the construction of the new connections, with other projects, like the one by Pattern Energy, potentially connecting ERCOT to parts of the Southeastern grid even earlier, by 2029. This legislative effort represents a critical step towards ensuring that Texas can meet its energy needs reliably and sustainably, while also contributing to the broader goal of transitioning to a cleaner, more resilient power system.

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NGCP-SGCC Partnership drives transmission grid modernization in the Philippines, boosting high-voltage capacity, reliability, and resilience, while developing engineering talent via the Trailblazers Program to meet Southeast Asia best practices and utility standards.

Key Points

A partnership to modernize the Philippines' grid, boost high-voltage capacity, and upskill NGCP engineers.

✅ Modernizes transmission assets and grid reliability nationwide

✅ Trailblazers Program develops NGCP's engineering leadership

✅ SGCC knowledge transfer on UHV, high-voltage, and best practices

The National Grid Corp. of the Philippines (NGCP) is building on its partnership with State Grid Corp of China (SGCC) to expand and modernize transmission facilities, as well as enhance the capabilities of its personnel to advance the country's grid network, aligning with smart grid transformation in Egypt seen in other markets. NGCP Internal Affairs Department head Edwin Natividad said the grid operator is implementing various development programs with SGCC to make the country's power grid among the best power utilities in Asia.

"We have to look at policies aligned with best global practices, including smart grid solutions increasingly adopted worldwide, that we can choose in adopting in the Philippines too," he said. One of NGCP's flagship development program is the Trailblazers Program, the company's strategy to further develop engineers "who will not just be technical experts, but also be the change agents and movers in the NGCP organization as well as in the Philippines' power sector," Natividad said.

"Having the support of the largest utility in the world gives us comfort that this program is designed and implemented by the best in the power industry," he said. Under the program, high performing personnel participating will be prepared for bigger roles later on in their careers at NGCP.

Business ( Article MRec ), pagematch: 1, sectionmatch: 1 "The advantage of such a pool is that it provides flexibility and, eventually, organizational self-sufficiency around the current and future talent needs of NGCP," Natividad said. Now on its third edition, the Trailblazers Program has already sent 76 personnel since it started in November 2016. Natividad said more than 16 of those who previously attended similar programs have already assumed higher roles in NGCP.

Apart from technical skills development, NGCP's partnership with SGCC also provides technical development to improve on the physical transmission assets. "If you will compare the facilities being handled by SGCC with other countries, in terms of handling high voltage capability, SGCC is way ahead.

The higher the voltage it's going to be more difficult to handle," Natividad said, adding they can handle more power to distribute to power distributors. As an example, SGCC's transmission facilities can handle high voltage to as much as 1,000 kiloVolts (kV), whereas the Philippines only has one high voltage facility, the interconnection between Luzon and Visayas, which can handle 500 kV, echoing proposals for macrogrids in Canada to improve reliability.

Natividad said NGCP was the first and biggest investment of SGCC outside of China before it made investments in other parts of the world, even as cybersecurity concerns in Britain have influenced supplier choices. A consortium among businessmen Henry Sy Jr., Robert Coyuito Jr., and SGCC as technical partner, NGCP holds a 25-year concession contract to operate and maintain the country's transmission grid.

Earlier, Sy, NGCP president and CEO, said the company is targeting to become the best utility firm in Southeast Asia. Since it took over the operations and maintenance of the country's power transmission network in 2009, the grid operator has introduced major physical and technological upgrades to ageing state-owned lines and facilities, while in Great Britain an independent operator model is being advanced to reshape system operations.

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U.S. Electricity Trade by State, 2013-2017 highlights EIA grid patterns, interstate imports and exports, cross-border flows with Canada and Mexico, net exporters and importers, and market regions like ISOs and RTOs shaping consumption and generation.

Key Points

Brief EIA overview of interstate and cross-border power flows, ranking top net importers and exporters.

✅ Pennsylvania was the largest net exporter, averaging 59 million MWh.

✅ California was the largest net importer, averaging 77 million MWh.

✅ Top cross-border: NY, CA, VT, MN, MI imports; WA, TX, CA, NY, MT exports.

According to the U.S. Energy Information Administration (EIA) State Electricity Profiles, from 2013 to 2017, Pennsylvania was the largest net exporter of electricity, while California was the largest net importer.

Pennsylvania exported an annual average of 59 million megawatt-hours (MWh), while California imported an average of 77 million MWh annually.

Based on the share of total consumption in each state, the District of Columbia, Maryland, Massachusetts, Idaho and Delaware were the five largest power-importing states between 2013 and 2017, highlighting how some clean states import 'dirty' electricity as consumption outpaces local generation. Wyoming, West Virginia, North Dakota, Montana and New Hampshire were the five largest power-exporting states. Wyoming and West Virginia were net power exporting states between 2013 and 2017.

New York, California, Vermont, Minnesota and Michigan imported the most electricity from Canada or Mexico on average from 2013 to 2017, reflecting the U.S. look to Canada for green power during that period. Similarly, Washington, Texas, California, New York, and Montana exported the most electricity to Canada or Mexico, on average, during the same period.

Electricity routinely flows among the Lower 48 states and, to a lesser extent, between the United States and Canada and Mexico. From 2013 to 2017, Pennsylvania was the largest net exporter of electricity, sending an annual average of 59 million megawatthours (MWh) outside the state. California was the largest net importer, receiving an average of 77 million MWh annually.

Based on the share of total consumption within each state, the District of Columbia, Maryland, Massachusetts, Idaho, and Delaware were the five largest power-importing states between 2013 and 2017. Wyoming, West Virginia, North Dakota, Montana, and New Hampshire were the five largest power-exporting states. States with major population centers and relatively less generating capacity within their state boundaries tend to have higher ratios of net electricity imports to total electricity consumption, as utilities devote more to electricity delivery than to power production in many markets.

Wyoming and West Virginia were net power exporting states (they exported more power to other states than they consumed) between 2013 and 2017. Customers residing in these two states are not necessarily at an economic disadvantage or advantage compared with customers in neighboring states when considering their electricity bills and fees and market dynamics. However, large amounts of power trading may affect a state’s revenue derived from power generation.

Some states also import and export electricity outside the United States to Canada or Mexico, even as Canada's electricity exports face trade tensions today. New York, California, Vermont, Minnesota, and Michigan are the five states that imported the most electricity from Canada or Mexico on average from 2013 through 2017. Similarly, Washington, Texas (where electricity production and consumption lead the nation), California, New York, and Montana are the five states that exported the most electricity to Canada or Mexico, on average, for the same period.

Many states within the continental United States fall within integrated market regions, referred to as independent system operators or regional transmission organizations. These integrated market regions allow electricity to flow freely between states or parts of states within their boundaries.

EIA’s State Electricity Profiles provide details about the supply and disposition of electricity for each state, including net trade with other states and international imports and exports, and help you understand where your electricity comes from more clearly.

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Maryland Renewable Energy Violations highlight RPS compliance gaps as facilities selling renewable energy certificates, including waste-to-energy, biomass, and paper mills, face emissions and permit issues, prompting PSC and Attorney General scrutiny of environmental standards.

Key Points

Alleged RPS noncompliance by REC-eligible plants, prompting PSC review and potential decertification under Maryland law.

✅ Complaint targets waste-to-energy, biomass plants, and paper mills

✅ Facilities risk loss of REC certification for environmental violations

✅ PSC may investigate nonreporting; AG reviewing evidence

Many facilities that supply Maryland with renewable energy have exceeded pollution limits or otherwise broken environmental rules, violating a state law, according to a complaint sent by environmental groups to state energy and law enforcement officials.

Maryland law says that any company that contributes to a state renewable energy goal — half the state’s energy portfolio must come from renewable sources by 2030 — must “substantially comply” with rules on air and water quality and waste management. The complaint says more than two dozen power generators, including paper mills and trash incinerators, have records of formal or informal enforcement actions by environmental authorities.

For years, environmental groups have criticized Maryland policy that counts power plants that produce planet-warming carbon dioxide and health-threatening pollution as “renewable” energy generation, and similar tensions have emerged in California’s reliance on fossil fuels despite ambitious targets, but lawmakers concerned about protecting industrial jobs have resisted reforms. The renewable label qualifies the companies for subsidies drawn from energy bills across the state.

In a complaint filed this week, the groups asked the attorney general and Public Service Commission to step in.

“We’re subsidizing companies to produce dirty energy, but we’re also using ratepayer money to support companies that in many instances are paying environmental fines or just flouting the law,” said Timothy Whitehouse, executive director of Public Employees for Environmental Responsibility. “There’s no one to hold them to account in Maryland.”

A spokeswoman for Attorney General Brian Frosh said his office would review the complaint, which was signed by Whitehouse and Mike Ewall, executive director of the Energy Justice Network.

Public Service Commission officials said the facilities must notify them if found out of compliance with environmental rules, while at the federal level FERC action on aggregated DERs is shaping market participation, and the commission can then revoke certification under the state renewable energy program. In a statement, commission officials said they would launch an investigation if any facility had failed to notify them of any environmental violations, and encouraged anyone with evidence of such a transgression to file a complaint.

Companies named in the document accused the groups of painting an inaccurate picture.

“This complaint is based on misleading arguments designed to halt waste-to-energy practices that have clear environmental benefits recognized by the global scientific community,” said Jim Connolly, vice president of environment, health and safety for Wheelabrator, which owns a Baltimore trash incinerator.

Maryland launched its renewable energy program in 2004, diversifying the state’s energy portfolio with more environmentally friendly sources of power, even as regional debates over a Maine-Québec transmission line highlight cross-border impacts. Under the program, separate from the electricity they generate and sell to the grid, renewable power facilities can sell what are known as renewable energy certificates. Utilities such as Baltimore Gas and Electric Co. are required to buy a growing number of the certificates each year, essentially subsidizing the renewable energy facilities with money from ratepayer bills.

A dozen types of power generation qualify to sell the certificates: Solar, wind, geothermal and hydroelectric plants, as well as “biomass” facilities that burn wood and other organic matter, waste-to-energy plants that burn household trash and paper mills that burn a byproduct known as black liquor.

The complaint focuses on waste incinerators, biomass plants and paper mills, all of which environmental groups have cast as counter to the renewable energy program’s environmental goals, even as ACORE criticized a coal and nuclear subsidy proposal in federal proceedings.

“By subsidizing these corporations, Maryland is diverting the hard-earned income of Maryland ratepayers to wealthy corporations with poor environmental compliance records and undermining the state’s transition to clean renewable energy,” Whitehouse and Ewall wrote.

For example, they note that the Wheelabrator plant in Southwest Baltimore has been fined for exceeding mercury limits in the past. That occurred in 2011, when the plant settled with state regulators for violations in 2010 and 2009.

Connolly said there is “no question” the facility complies with Maryland’s renewable energy law.

Incinerators in Montgomery County and in Fairfax County, Virginia, that are owned by Covanta and sell the energy certificates in Maryland have been cited for accidental fires inside both facilities. The Maryland incinerator violated emissions rules in 2014, the same year that New Jersey forbade the Virginia facility from selling energy certificates into that state’s renewable energy program over concerns it wasn’t following ash testing regulations.

James Regan, a spokesman for Covanta, said both facilities “have excellent compliance records and they operate well below their permitted limits.” He said the Virginia facility is complying with ash testing requirements, and that both facilities emit far lower levels of pollutants such as particulate matter than vehicles do.

“It’s clear to us there’s a lot of misleading and wrong information in this document," Regan said.

The Environmental Protection Agency endorsed waste-to-energy facilities under former President Barack Obama because, while burning household trash emits carbon dioxide, scientists said that still had a smaller impact on global warming than sending trash to landfills, even as industry groups have backed the EPA in a legal challenge to the ACE rule as regulatory approaches shifted.

Environmentalists and community groups say the facilities still are harmful because they emit high levels of pollutants such as mercury, nitrogen oxides and lead. The concerns prompted Baltimore City Council to pass an ordinance in February that tightened emissions limits on the Wheelabrator facility, even as the new EPA pollution limits for coal and gas plants are being proposed, so dramatically that the company said it would no longer be able to operate once the rules go into effect in 2022.

The complaint does not mention the century-old Luke paper mill in Western Maryland that long faced criticism for its participation in the renewable energy program, but which owner Verso Co. closed this year.

It does say several of paper company WestRock’s mills in North Carolina and Virginia have faced both formal and informal EPA enforcement actions for violation of the Clean Water Act, including evolving EPA wastewater limits for power plants and other facilities, and the Clean Air Act. A WestRock spokesperson could not be reached for comment.

The complaint also says a large biomass facility in South Boston, Virginia, owned by the Northern Virginia Electric Cooperative has a record of noncompliance with the Clean Air Act over three years.

John Rainey, the plant’s operations director, said it “experienced some small exceedances to its permit limits,” but that it addressed the issues with Virginia environmental officials and has installed new technology.

All those plants have sold credits in Maryland.

Whitehouse said the environmental groups’ goal is to clean up Maryland’s renewable energy program. They did not file a lawsuit because he said there was no clear cause of action to take the state to court, but said he hopes the complaint nonetheless spurs action.

“It’s not acceptable in a clean energy program that we’re subsidizing some of the most dirty sources of energy,” he said. “Those sources aren’t even in compliance with the law, and no one seems to care.”

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