Elsinore water to gin up hydroelectric power

By Knight Ridder Tribune


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For the first time in more than two decades, a hydroelectric plant is being built in Southern California.

Nevada Hydro Co., in conjunction with Morgan Stanley Commodities, has established a limited liability corporation to build a hydroelectric power plant in Lake Elsinore. LEAPS Hydro LLC will build and operate the $1.1 billion Lake Elsinore Advanced Pump Storage project and the accompanying transmission lines.

The project is pending final license approval by the Federal Energy Regulatory Commission.

Construction will begin after both the commission and California grant final approvals, which will happen within the next six to eight months, said Chris Wysocki, a spokesman for Nevada Hydro. Construction of the transmission line that will connect San Diego Gas and Electric to Edison International in Northern California will take about 18 months to complete.

The hydroelectric plant will tie in to the transmission line to provide electricity to the San Diego area. The hydroelectric plant will take three to four years to complete. The plant will be operational in 2011. Construction is expected to produce more than 500 new jobs.

Siemens Power, Transmission and Distribution in Wendell, N.C., will build the hydroelectric plant and the transmission line. Once the hydroelectric plant is operational, it will require 20-30 full time employees. The plant will create power by recycling water between Lake Elsinore and an upper reservoir located in the Cleveland National Forest.

LEAPS will be ready to generate 500 megawatts on a moment's notice by releasing water from an upper reservoir in Decker Canyon into Lake Elsinore, Nevada Hydro Vice President Rex Wait said in a release. The water will be pumped back into the reservoir during times when power demand is low. The hydroelectric facility will deliver energy during high-demand periods.

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First US coal plant in years opens where no options exist

Alaska Coal-Fired CHP Plant opens near Usibelli mine, supplying electricity and district heat to UAF; remote location without gas pipelines, low wind and solar potential, and high heating demand shaped fuel choice.

 

Key Points

A 17 MW coal CHP at UAF producing power and campus heat, chosen for remoteness and lack of gas pipelines.

✅ 17 MW generator supplying electricity and district heat

✅ Near Usibelli mine; limited pipeline access shapes fuel

✅ Alternative options like LNG, wind, solar not cost-effective

 

One way to boost coal in the US: Find a spot near a mine with no access to oil or natural gas pipelines, where it’s not particularly windy and it’s dark much of the year.

That’s how the first coal-fired plant to open in the U.S. since 2015 bucked the trend in an industry that’s seen scores of facilities close in recent years. A 17-megawatt generator, built for $245 million, is set to open in April at the University of Alaska Fairbanks, just 100 miles from the state’s only coal mine.

“Geography really drove what options are available to us,” said Kari Burrell, the university’s vice chancellor for administrative services, in an interview. “We are not saying this is ideal by any means.”

The new plant is arriving as coal fuels about 25 percent of electrical generation in the U.S., down from 45 percent a decade earlier, even as some forecasts point to a near-term increase in coal-fired generation in 2021. A near-record 18 coal plants closed in 2018, and 14 more are expected to follow this year, according to BloombergNEF.

The biggest bright spot for U.S. coal miners recently has been exports to overseas power plants. At home, one of the few growth areas has been in pizza ovens.

There are a handful of other U.S. coal power projects that have been proposed, including plans to build an 850 megawatt facility in Georgia and an 895 megawatt plant in Kansas, even as a Minnesota utility reports declining coal returns across parts of its portfolio. But Ashley Burke, a spokeswoman for the National Mining Association, said she’s unaware of any U.S. plants actively under development besides the one in Alaska.

 

Future of power

“The future of power in the U.S. does not include coal,” Tessie Petion, an analyst for HSBC Holdings Plc, said in a research note, a view echoed by regions such as Alberta retiring coal power early in their transition.

Fairbanks sits on the banks of the Chena River, amid the vast subarctic forests in the heart of Alaska. The oil and gas fields of the state’s North slope are 500 miles north. The nearest major port is in Anchorage, 350 miles south.

The university’s new plant is a combined heat and power generator, which will create steam both to generate electricity and heat campus buildings. Before opting for coal, the school looked into using liquid natural gas, wind and solar, bio-mass and a host of other options, as new projects in Southeast Alaska seek lower electricity costs across the region. None of them penciled out, said Mike Ruckhaus, a senior project manager at the university.

The project, financed with university and state-municipal bonds, replaces a coal plant that went into service in 1964. University spokeswoman Marmian Grimes said it’s worth noting that the new plant will emit fewer emissions.

The coal will come from Usibelli Coal Mine Inc., a family-owned business that produces between 1.2 and 2 million tons per year from a mine along the Alaska railroad, according to the company’s website.

While any new plant is good news for coal miners, Clarksons Platou Securities Inc. analyst Jeremy Sussman said this one is "an isolated situation."

“We think the best producers can hope for domestically is a slow down in plant closures,” he said, even as jurisdictions like Alberta close their last coal plant entirely.

 

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WY Utility's First Wind Farm Faces Replacement

Foote Creek I Wind Farm Repowering upgrades Wyoming turbines with new nacelles, towers, and blades, cutting 68 units to 12 while sustaining 41.6 MW, under PacifiCorp and Rocky Mountain Power's Energy Vision 2020 plan.

 

Key Points

Replacement at Foote Creek Rim I, cutting to 12 turbines while sustaining about 41.6 MW using modern 2-4.2 MW units.

✅ 12 turbines replace 68, output steady near 41.6 MW

✅ New nacelles, towers, blades; taller 500 ft turbines

✅ Part of PacifiCorp Energy Vision 2020 and Gateway West

 

A Wyoming utility company has filed a permit to replace its first wind farm—originally commissioned in 1998, composed of over 65 turbines—amid new gas capacity competing with nuclear in Ohio, located at Foote Creek Rim I. The replacement would downsize the number of turbines to 12, which would still generate roughly the same energy output.

According to the Star Tribune, PacifiCorp’s new installation would involve new nacelles, new towers and new blades. The permit was filed with Carbon County.

 

New WY Wind Farm

The replacement wind turbines will stand more than twice as tall as the old: Those currently installed stand 200 feet tall, whereas their replacements will tower closer to 500 feet. Though this move is part of the company’s overall plan to expand its state wind fleet as some utilities respond to declining coal returns in the Midwest, the work going into the Foote Creek site is somewhat special, noted David Eskelsen, spokesperson for Rocky Mountain Power, the western arm of PacifiCorp.

“Foote Creek I repowering is somewhat different from the repowering projects announced in the (Energy Vision) 2020 initiative,” he said. “Foote Creek is a complete replacement of the existing 68 foundations, towers, turbine nacelles and rotors (blades).”

Currently, the turbines at Foote Creek have 600 kilowatts capacity each; the replacements’ maximum production ranges from 2 megawatts to 4.2 megawatts each, with the total output remaining steady at 41.4 megawatts, a scale similar to a 30-megawatt wind expansion in Eastern Kings, though there will be a slight capacity increase to 41.6 megawatts, according to the Star Tribune.

As part of the wind farm repowering initiative, PacifiCorp is to become full owner and operator of the Foote Creek site. When the farm was originally built, an Oregon-based water and electric board was 21 percent owner; 37 percent of the project’s output was tied into a contract with the Bonneville Power Administration.

Otherwise, PacifiCorp is moving to further expand its state wind fleet in line with initiatives like doubling renewable electricity by 2030 in Saskatchewan, with the addition of three new wind farms—to be located in Carbon, Albany and Converse counties—which may add up to 1,150 megawatts of power.

According to PacifiCorp, the company has more than 1,000 megawatts of owned wind generation capability, along with long-term purchase agreements for more than 600 megawatts from other wind farms owned by other entities. Energy Vision 2020 refers to a $3.5 billion investment and company move that is looking to upgrade the company's existing wind fleet with newer technology, adding 1,150 megawatts of new wind resources by 2020 and a a new 140-mile Gateway West transmission segment in Wyoming, comparable to a transmission project in Missouri just energized.

 

 

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Pandemic has already cost Hydro-Québec $130 million, CEO says

Hydro-Que9bec 2020 Profit Outlook faces COVID-19 headwinds as revenue drops, U.S. Northeast export demand weakens, and clean-energy infrastructure plans shift toward domestic investments, energy efficiency, EV charging stations, and grid upgrades to stabilize net income.

 

Key Points

A forecast of COVID-19 revenue declines, weaker U.S. exports, and a shift to energy efficiency and grid upgrades.

✅ Q1 profit fell 14%; net income $1.53B vs $1.77B

✅ Exports to U.S. Northeast weaker; revenue off ~$130M Mar-Jun

✅ Strategy: energy efficiency, EV charging, grid, dam upgrades

 

Hydro-Québec expects the coronavirus pandemic to chop “hundreds of millions of dollars” off 2020 profits, its new chief executive officer said.

COVID-19 has depressed revenue by about $130 million between March and June, Sophie Brochu said Monday, as residential electricity use rose even while overall consumption dropped. Shrinking electricity exports to the U.S. northeast are poised to compound the shortfall, she said.

“What we’re living through is not small. The impacts are real,” Brochu said on a conference call with reporters, noting that utilities such as Hydro One supported Ontario's COVID-19 response at the height of the pandemic. “I’m not talking about a billion. I’m talking about hundreds of millions. We have no idea how quickly the economy will restart. As we approach the fall we will have a better view.”

Hydro-Québec last month reported a 14-per-cent drop in first-quarter profit and warned full-year results would fall short of targets as the COVID-19 crisis weighs on power demand. Net income in the quarter was $1.53 billion compared with $1.77 billion a year ago, the company said.

Canada’s biggest electricity producer had earlier been targeting 2020 profit of between $2.8 billion and $3 billion, according to its current strategic plan and corporate structure currently in place.

The first quarter was the utility’s last under former CEO Eric Martel, who left to take over at jetmaker Bombardier Inc. Brochu, who previously ran Énergir, replaced him April 6.

To boost exports over time, Brochu said Hydro-Québec will look to strengthen ties with neighbours such as Ontario, where the Hydro One CEO is working to repair relations with government and investors, and the U.S. The CEO said she’s heartened by New York Governor Andrew Cuomo’s call last month for new power lines from Canada and upstate to promote clean energy.

“This is a clear, encouraging signal that must express itself through very concrete negotiations,” she said. “The United States is our backyard. This is true for Ontario, where key system staff lockdowns were even contemplated, and the Atlantic provinces as well. This is our ecosystem, and we intend to build on our footprint, on the relationships that we have.”

Though stricter environmental hurdles make it more complicated to get power lines built today than a decade ago, the CEO insists it’s still possible to sell electricity to neighbouring U.S. states.

“Is it more difficult today to build energy projects? The answer is yes,” she said. “Does this clog up the U.S. northeast market? Not at all. I believe this federation of ecosystems is very promising.”

In the meantime, Hydro-Québec is planning to speed up investments at home — for example, by building new charging stations that will be needed to serve a growing fleet of electric cars. The utility will also upgrade some of its Montreal-area facilities, as well as its massive dams on the Manicouagan River, Brochu said. The investments will result in additional capacity.

“Today we need to put water in the pump of Quebec, so we will concentrate our human and financial efforts here,” she said. “We are needed in Quebec.” 

Hydro-Québec is stepping up efforts to promote energy efficiency among its customer base, amid retroactive billing concerns, which Brochu said could postpone the need to build large dams.

“We have to move towards ‘no-regret moves.’ What’s a no-regret move? It’s energy efficiency,” Brochu said earlier Monday during a presentation to the Chamber of Commerce of Metropolitan Montreal, noting that Ontario debated peak rate relief for self-isolating customers. “This is healthy, it’s fundamental and it will contribute to Quebec’s economic rebound by lowering energy costs.”

Brochu also pledged to build a more diverse workforce after the company said last week that 8.2 per cent of staff belong to “visible and ethnic” minorities.

“This can be improved on,” she said. “What I’m expressing today is my determination, and that of the management team, to move the needle.”

 

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Tariff Threats Boost Support for Canadian Energy Projects

Canadian Energy Infrastructure Tariffs are reshaping pipelines, deregulation, and energy independence, as U.S. trade tensions accelerate approvals for Alberta oil sands, Trans Mountain expansion, and CAPP proposals amid regulatory reform and market diversification.

 

Key Points

U.S. tariff threats drive approvals, infrastructure, and diversification to strengthen Canada energy security.

✅ Tariff risk boosts support for pipelines and export routes

✅ Faster project approvals and deregulation gain political backing

✅ Diversifying markets reduces reliance on U.S. buyers

 

In recent months, the Canadian energy sector has experienced a shift in public and political attitudes toward infrastructure projects, particularly those related to oil and gas production. This shift has been largely influenced by the threat of tariffs from the United States, as well as growing concerns about energy independence and U.S.-Canada trade tensions more broadly.

Scott Burrows, the CEO of Pembina Pipeline Corp., noted in a conference call that the potential for U.S. tariffs on Canadian energy imports has spurred a renewed sense of urgency and receptiveness toward energy infrastructure projects in Canada. With U.S. President Donald Trump’s proposed tariffs Trump tariff threat on Canadian imports, particularly a 10% tariff on energy products, there is increasing recognition within Canada that these projects are essential for the country’s long-term economic and energy security.

While the direct impact of the tariffs is not immediate, industry leaders are optimistic about the long-term benefits of deregulation and faster project approvals, even as some see Biden as better for Canada’s energy sector overall. Burrows highlighted that while it will take time for the full effects to materialize, there are significant "tailwinds" in favor of faster energy infrastructure development. This includes the possibility of more streamlined regulatory processes and a shift toward more efficient project timelines, which could significantly benefit the Canadian energy sector.

This changing landscape is particularly important for Alberta’s oil production, which is one of the largest contributors to Canada’s energy output. The Canadian Association of Petroleum Producers (CAPP) has responded to the growing tariff threat by releasing an “energy platform,” outlining recommendations for Ottawa to help mitigate the risks posed by the evolving trade situation. The platform includes calls for improved infrastructure, such as pipelines and transportation systems, and priorities like clean grids and batteries, to ensure that Canadian energy can reach global markets more effectively.

The tariff threat has also sparked a wider conversation about the need for Canada to strengthen its energy infrastructure and reduce its dependency on the U.S. for energy exports. With the potential for escalating trade tensions, there is a growing push for Canadian energy resources to be processed and utilized more domestically, though cutting Quebec’s energy exports during a tariff war. This has led to increased political support for projects like the Trans Mountain pipeline expansion, which aims to connect Alberta’s oil sands to new markets in Asia via the west coast.

However, the energy sector’s push for deregulation and quicker approvals has raised concerns among environmental groups and Indigenous communities. Critics argue that fast-tracking energy projects could lead to inadequate environmental assessments and greater risks to local ecosystems. These concerns underscore the tension between economic development and environmental protection in the energy sector.

Despite these concerns, there is a clear consensus that Canada’s energy industry needs to evolve to meet the challenges posed by shifting trade dynamics, even as polls show support for energy and mineral tariffs in the current dispute. The proposed U.S. tariffs have made it increasingly clear that the country’s energy infrastructure needs significant investment and modernization to ensure that Canada can maintain its status as a reliable and competitive energy supplier on the global stage.

As the deadline for the tariff decision approaches, and as Ford threatens to cut U.S. electricity exports, Canada’s energy sector is bracing for the potential fallout, while also preparing to capitalize on any opportunities that may arise from the changing trade environment. The next few months will be critical in determining how Canadian policymakers, businesses, and environmental groups navigate the complex intersection of energy, trade, and regulatory reform.

While the threat of U.S. tariffs may be unsettling, it is also serving as a catalyst for much-needed changes in Canada’s energy policy. The push for faster approvals and deregulation may help address some of the immediate concerns facing the sector, but it will be crucial for the government to balance economic interests with environmental and social considerations as the country moves forward in its energy transition.

 

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Will Iraq have enough electricity for coming hot summer days?

Iraq Electricity Crisis intensifies as summer heat drives demand; households face power outages, reliance on private generators, distorted tariffs, and strained grid capacity despite government reforms, Siemens upgrades, and IEA warnings.

 

Key Points

A supply-demand gap causing outages, generator reliance, and grid inefficiencies across Iraq, worsened by summer peaks.

✅ Siemens deal to upgrade generation and grid

✅ Progressive tariffs to curb demand and waste

✅ Private generators fill gaps but raise costs

 

At a demonstration in June 2018, protesters in Basra loaded a black box resembling a coffin with the inscription “Electricity” onto the roof of a car. This was one demonstration of how much of a political issue electricity is in Iraq.

With what is likely to be another hot summer ahead, there is increasing pressure on the Baghdad government to improve access to electricity and water.

Many Iraqis blame the government for not providing adequate services despite the country’s oil wealth. Protests in southern Iraq last year turned violent, with demonstrators attacking governmental and political parties’ buildings; in neighboring Iran, blackouts also sparked protests over outages.

“It is very hard” to deal with the electricity issues, said Iraqi journalist Methaq al-Fayyadh, adding that the lack of reliable electricity was not a new problem and affects most parts of the country.

Dozens of people protested June 1 in Karbala against prices for new generators and demanded an improvement to the electricity situation.

In anticipation of high temperatures during Eid al-Fitr, the Electricity Ministry called on governorates to adhere to allocated quotas and told the public to ration electricity.

“Outages remain a daily occurrence for most households because increasing generating capacity has been outrun by increasing demand for electricity, as surging demand worldwide demonstrates,” noted the International Energy Agency (IAE) in April.

This is particularly the case, the authors said, as the hot summer months, when temperatures can top 50 degrees Celsius, drive up the use of air conditioning.

The Iraqi government has made improving the electricity supply one of its priorities, including nuclear power plans under consideration. The Electricity Ministry, headed by Luay al-Khatteeb, announced in May that national electricity production had reached 17 gigawatts.

Khatteeb presented comparative electricity data for May from 2018 and 2019, indicating production increases on every day of the month. IEA data indicate that available electricity supply has increased over the past five years and the gap between supply and demand has widened.

The government signed an agreement with German company Siemens this year to upgrade Iraq’s electricity grid, and in parallel deals with Iran to rehabilitate and develop the grid were finalized, according to Iranian officials. The agreement “includes the addition of new and highly efficient power generation capacity, rehabilitation and upgrade of existing plants and the expansion of transmission and distribution networks,” Siemens said.

The Iraqi prime minister’s office said the 4-year plan would be worth $15.7 billion. The first phase includes the installation of 13 transformer stations, cooling systems for power stations and building a 500-megawatt, gas-fired power plant south of Baghdad.

In an interview with Al-Monitor, Khatteeb said radical changes would happen in 2020, stating that the current situation was not “ideal” but “better” because of steps taken to create more energy, amid discussions on energy cooperation with Iran that could shape implementation.

Robert Tollast, of the Iraq Energy Institute, said the economics of the electricity system is distorted. Subsidies ensured that electricity provided by the national grid is almost free, he said. However, while the subsidies were designed to help the poor, the tariff system disadvantages them and does not create incentives to consume electricity more efficiently, he said.

A large part of families’ electricity expenditures goes to operators of privately owned generators, which run on fuel. These neighbourhood generators are used to close gaps in the electricity supply but are expensive, and regional fuel arrangements such as ENOC’s swap of Iraqi fuel have highlighted supply constraints. Generator operators have sometimes worked with armed groups to prevent upgrades to the grid that could hurt their business.

Until 1990, the Iraq electricity sector was considered among the best in the region. That legacy was destroyed by successive wars and international sanctions. With Iraq’s population growing at a rate of 1 million per year, peak demand is projected to double by 2030 if left unchecked, the IEA estimated.

Tollast said efforts to improve the distribution system and increase capacity are key but it is important “to tackle the problem from the demand side.” This entails implementing a progressive tariff scheme so users pay more if they consume more, he said. There is a “tremendous use of energy per capita in Iraq,” Tollast said.

In the current tariff structure, consumers pay a fixed price if they use more than 4,000-kilowatt hours per year, a relatively low amount, meaning the price per unit drops the more one consumes.

Any change to the tariff system must be accompanied by a “political campaign” to explain the changes, said Tollast, adding that more investment in the electricity sector and a “change in culture” of using electricity was needed. “The current system is unsustainable, even with high oil prices,” he said.

Fayyadh said people don’t expect the government will be able to fix the electricity issue before summer, having failed to do so in the past.

Tollast struck a more optimistic tone, saying it was unlikely that Iran, which supplies about 40% of Iraq’s power, would cut its export of electricity to Iraq this year as it did in 2018. He added that the water situation was better than last year when the country experienced drought. Iraq has also been processing more flare gas, which can be used to generate electricity.

“There is an expectation that this year might not be as bad as last year,” he concluded.

 

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Ontario's electricity operator kept quiet about phantom demand that cost customers millions

IESO Fictitious Demand Error inflated HOEP in the Ontario electricity market, after embedded generation was mis-modeled; the OEB says double-counted load lifted wholesale prices and shifted costs via the Global Adjustment.

 

Key Points

An IESO modeling flaw that double-counted load, inflating HOEP and charges in Ontario's wholesale market.

✅ Double-counted unmetered load from embedded generation

✅ Inflated HOEP; shifted costs via Global Adjustment

✅ OEB flagged transparency; exporters paid more

 

For almost a year, the operator of Ontario’s electricity system erroneously counted enough phantom demand to power a small city, causing prices to spike and hundreds of millions of dollars in extra charges to consumers, according to the provincial energy regulator.

The Independent Electricity System Operator (IESO) also failed to tell anyone about the error once it noticed and fixed it.

The error likely added between $450 million and $560 million to hourly rates and other charges before it was fixed in April 2017, according to a report released this month by the Ontario Energy Board’s Market Surveillance Panel.

It did this by adding as much as 220 MW of “fictitious demand” to the market starting in May 2016, when the IESO started paying consumers who reduced their demand for power during peak periods. This involved the integration of small-scale embedded generation (largely made up of solar) into its wholesale model for the first time.

The mistake assumed maximum consumption at such sites without meters, and double-counted that consumption.

The OEB said the mistake particularly hurt exporters and some end-users, who did not benefit from a related reduction of a global adjustment rate applicable to other customers.

“The most direct impact of the increase in HOEP (Hourly Ontario Energy Price) was felt by Ontario consumers and exporters of electricity, who paid an artificially high HOEP, to the benefit of generators and importers,” the OEB said.

The mix-up did not result in an equivalent increase in total system costs, because changes to the HOEP are offset by inverse changes to a electricity cost allocation mechanism such as the Global Adjustment rate, the OEB noted.


A chart from the OEB's report shows the time of day when fictitious demand was added to the system, and its influence on hourly rates.

Peak time spikes
The OEB said that the fictitious demand “regularly inflated” the hourly price of energy and other costs calculated as a direct function of it.

For almost a year, Ontario's electricity system operator @IESO_Tweets erroneously counted enough phantom demand to power a small city, causing price spikes and hundreds of millions in charges to consumers, @OntEnergyBoard says. @5thEstate reports.

It estimated the average increase to the HOEP was as much as $4.50/MWh, but that price spikes, compounded by scheduled OEB rate changes, would have been much higher during busier times, such as the mid-morning and early evening.

“In times of tight supply, the addition of fictitious demand often had a dramatic inflationary impact on the HOEP,” the report said.

That meant on one summer evening in 2016 the hourly rate jumped to $1,619/MWh, it said, which was the fourth highest in the history of the Ontario wholesale electricity market.

“Additional demand is met by scheduling increasingly expensive supply, thus increasing the market price. In instances where supply is tight and the supply stack is steep, small increases in demand can cause significant increases in the market price.

The OEB questioned why, as of September this year, the IESO had failed to notify its customers or the broader public, amid a broader auditor-regulator dispute that drew political attention, about the mistake and its effect on prices.

“It's time for greater transparency on where electricity costs are really coming from,” said Sarah Buchanan, clean energy program manager at Environmental Defence.

“Ontario will be making big decisions in the coming years about whether to keep our electricity grid clean, or burn more fossil fuels to keep the lights on,” she added. “These decisions need to be informed by the best possible evidence, and that can't happen if critical information is hidden.”

In a response to the OEB report on Monday, the IESO said its own initial analysis found that the error likely pushed wholesale electricity payments up by $225 million. That calculation assumed that the higher prices would have changed consumer behaviour, while upcoming electricity auctions were cited as a way to lower costs, it said.

In response to questions, a spokesperson said residential and small commercial consumers would have saved $11 million in electricity costs over the 11-month period, even as a typical bill increase loomed province-wide, while larger consumers would have paid an extra $14 million.

That is because residential and small commercial customers pay some costs via time-of-use rates, including a temporary recovery rate framework, the IESO said, while larger customers pay them in a way that reflects their share of overall electricity use during the five highest demand hours of the year.

The IESO said it could not compensate those that had paid too much, given the complexity of the system, and that the modelling error did not have a significant impact on ratepayers.

While acknowledging the effects of the mistake would vary among its customers, the IESO said the net market impact was less than $10 million, amid ongoing legislation to lower electricity rates in Ontario.

It said it would improve testing of its processes prior to deployment and agreed to publicly disclose errors that significantly affect the wholesale market in the future.

 

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