OPA Officially Files Proposed 20-Year Plan

US Electricity Demand 2018-2050 projects slower growth as energy consumption, power generation, air conditioning, and electric heating shift with efficiency standards, commercial floor space, industrial load, and household growth across the forecast horizon.

Key Points

A forecast of US power use across homes, commercial space, industrial load, and efficiency trends from 2018 to 2050.

✅ 2018 generation hit record; residential sales up 6%.

✅ Efficiency curbs demand; growth lags population and floor space.

✅ Commercial sales up 2%; industrial demand fell 3% in 2018.

Last year's Houston cold winter and hot summer drove power use to record levels, especially among households that rely on electricity for air conditioning during extreme weather conditions.

Electricity generation increased 4 per cent nationwide in 2018 and produced 4,178 million megawatt hours, driven in part by record natural gas generation across the U.S., surpassing the previous peak of 4,157 megawatt hours set in 2007, the Energy Department reported.

U.S. households bought 6 percent more electricity in 2018 than they did the previous year, despite longer-term declines in national consumption, reflecting the fact 87 percent of households cool their homes with air conditioning and 35 percent use electricity for heating.

Electricity sales to the commercial sector increased 2 percent in 2018 compared to the previous year while the industrial sector bought 3 percent less last year.

Going forward, the Energy Department forecasts that electricity consumption will grow at a slower pace than in recent decades, aligning with falling sales projections as technology improves and energy efficiency standards moderate consumption.

The economy and population growth are primary drivers of demand and the government predicts the number of households will grow at 0.7 percent per year from now until 2050 but electricity demand will grow only by 0.4 percent annually.

Likewise, commercial floor space is expected to increase 1 percent per year from now until 2050 but electricity sales will increase only by half that amount.

Globally, surging electricity demand is putting power systems under strain, providing context for these domestic trends.

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California Rooftop Solar Cost Shift examines PG&E rate hikes, net metering changes, and utility infrastructure spending impacts on low-income households, distributed generation, and clean energy adoption, potentially raising bills and undermining grid resilience.

Key Points

A claim that rooftop solar shifts fixed grid costs to others; critics cite PG&E rates, avoided costs, and impacts.

✅ PG&E rates outpace national average, underscoring cost drivers.

✅ Net metering cuts risk burdening low- and middle-income homes.

✅ Distributed generation avoids infrastructure spend and grid strain.

California is grappling with soaring electricity prices across the state, with Pacific Gas & Electric (PG&E) rates more than double the national average and increasing at an average of 12.5% annually over the past six years. In response, Governor Gavin Newsom issued an executive order directing state energy agencies to identify ways to reduce power costs. However, recent policy shifts targeting rooftop solar users may exacerbate the problem rather than alleviate it.

The "Cost Shift" Theory

A central justification for these pricing changes is the "cost shift" theory. This theory posits that homeowners with rooftop solar panels reduce their electricity consumption from the grid, thereby shifting the fixed costs of maintaining and operating the electrical grid onto non-solar customers. Proponents argue that this leads to higher rates for those without solar installations.

However, this theory is based on a flawed assumption: that PG&E owns 100% of the electricity generated by its customers and is entitled to full profits even for energy it does not deliver. In reality, rooftop solar users supply only about half of their energy needs and still pay for the rest. Moreover, their investments in solar infrastructure reduce grid strain and save ratepayers billions by avoiding costly infrastructure projects and reducing energy demand growth, aligning with efforts to revamp electricity rates to clean the grid as well.

Impact on Low- and Middle-Income Households

The majority of rooftop solar users are low- and middle-income households. These individuals often invest in solar panels to lower their energy bills and reduce their carbon footprint. Policy changes that undermine the financial viability of rooftop solar disproportionately affect these communities, and efforts to overturn income-based charges add uncertainty about affordability and access.

For instance, Assembly Bill 942 proposes to retroactively alter contracts for millions of solar consumers, cutting the compensation they receive from providing energy to the grid, raising questions about major changes to your electric bill that could follow if their home is sold or transferred. This would force those with solar leases—predominantly lower-income individuals—to buy out their contracts when selling their homes, potentially incurring significant financial burdens.

The Real Drivers of Rising Energy Costs

While rooftop solar users are being blamed for rising electricity rates, calls for action have mounted as the true culprits lie elsewhere. Unchecked utility infrastructure spending has been a significant factor in escalating costs. For example, PG&E's rates have increased rapidly, yet the utility's spending on infrastructure projects has often been criticized for inefficiency and lack of accountability. Instead of targeting solar users, policymakers should scrutinize utility profit motives and infrastructure investments to identify areas where costs can be reduced without sacrificing service quality.

California's approach to addressing rising electricity costs by targeting rooftop solar users is misguided. The "cost shift" theory is based on flawed assumptions and overlooks the substantial benefits that rooftop solar provides to the grid and ratepayers. To achieve a sustainable and equitable energy future, the state must focus on controlling utility spending, promoting clean energy access for all, especially as it exports its energy policies across the West, and ensuring that policies support—not undermine—the adoption of renewable energy technologies.

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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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EV Flood Fire Risks highlight climate change impacts, lithium-ion battery hazards, water damage, post-submersion inspection, first responder precautions, manufacturer safeguards, and insurance considerations for extreme weather, flood-prone areas, and hurricane aftermaths.

Key Points

Water-exposed EV lithium-ion batteries may ignite later, requiring inspection, isolation, and trained responders.

✅ Avoid driving through floodwaters; park on high ground.

✅ After submersion, isolate vehicle; seek qualified inspection.

✅ Inform first responders and insurers about EV water damage.

As climate change intensifies the frequency and severity of extreme weather events, concerns about electric vehicle (EV) safety in flood-prone areas have come to the forefront. Recent warnings from officials regarding the risks of electric vehicles catching fire due to flooding from Hurricane Idalia underscore the need for heightened awareness and preparedness among consumers and emergency responders, as well as attention to grid reliability during disasters.

The alarming incidents of EVs igniting after being submerged in floodwaters have raised critical questions about the safety of these vehicles during severe weather conditions. While electric vehicles are often touted for their environmental benefits and lower emissions, it is crucial to understand the potential risks associated with their battery systems when exposed to water, even as many drivers weigh whether to buy an electric car for daily use.

The Risks of Submerging Electric Vehicles

Electric vehicles primarily rely on lithium-ion batteries, which can be sensitive to water exposure. When these batteries are submerged, they risk short-circuiting, which may lead to fires. Unlike traditional gasoline vehicles, where fuel may leak out, the sealed nature of an EV’s battery can create hazardous situations when compromised. Experts warn that even after water exposure, the risk of fire can persist, sometimes occurring days or weeks later.

Officials emphasize the importance of vigilance in flood-prone areas, including planning for contingencies like mobile charging and energy storage that support recovery. If an electric vehicle has been submerged, it is crucial to have it inspected by a qualified technician before attempting to drive it again. Ignoring this can lead to catastrophic consequences not only for the vehicle owner but also for surrounding individuals and properties.

Official Warnings and Recommendations

In light of these dangers, safety officials have issued guidelines for electric vehicle owners in flood-prone areas. Key recommendations include:

1. Avoid Driving in Flooded Areas: The most straightforward advice is to refrain from driving through flooded streets, which can not only damage the vehicle but also pose risks to personal safety.

2. Inspection After Flooding: If an EV has been submerged, owners should seek immediate professional inspection. Technicians can evaluate the battery and electrical systems for damage and determine if the vehicle is safe to operate.

3. Inform Emergency Responders: In flood situations, informing emergency personnel about the presence of electric vehicles can help them mitigate risks during rescue operations, including firefighter health risks that may arise. First responders are trained to handle conventional vehicles but may need additional precautions when dealing with EVs.

Industry Response and Innovations

In response to rising concerns, electric vehicle manufacturers are working to enhance the safety features of their vehicles. This includes developing waterproof battery enclosures and improving drainage systems to prevent water intrusion, as well as exploring vehicle-to-home power for resilience during outages. Some manufacturers are also investing in research to improve battery chemistry, making them more resilient in extreme conditions.

The automotive industry recognizes that consumer education is equally important, particularly around utility impacts from mass-market EVs that affect planning. Manufacturers and safety organizations are encouraged to disseminate information about proper EV maintenance, the importance of inspections after flooding, and safety protocols for both owners and first responders.

The Role of Insurance Companies

As the risks associated with electric vehicle flooding become more apparent, insurance companies are also reassessing their policies. With increasing incidences of extreme weather, insurers are likely to adapt coverage options related to water damage and fire risks specific to electric vehicles. Policyholders should consult with their insurance providers to ensure they understand their coverage in the event of flooding.

Preparing for the Future

With the increasing adoption of electric vehicles, it is vital to prepare for the challenges posed by climate change and evolving state power grids capacity. Community awareness campaigns can play a significant role in educating residents about the risks and safety measures associated with electric vehicles during flooding events. By fostering a well-informed public, the likelihood of accidents and emergencies can be reduced.

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ACCC energy underwriting guarantee proposes government-backed certainty for new generation, cutting electricity prices and supporting gas, pumped hydro, renewables, batteries, and potentially coal-fired power, addressing market failure without direct subsidies.

Key Points

A tech-neutral, government-backed plan underwriting new generation revenue to increase certainty and cut power prices.

✅ Government guarantee provides a revenue floor for new generators.

✅ Technology neutral: coal, gas, renewables, pumped hydro, batteries.

✅ Intended to reduce bills by up to $400 and address market failure.

Australian Taxpayers won't directly fund any new power plants despite some Coalition MPs seizing on a new report to call for a coal-fired power station.

The Australian Competition and Consumer Commission recommended the government give financial certainty to new power plants, guaranteeing energy will be bought at a cheap price if it can't be sold, as part of an electricity market plan to avoid threats to supply.

It's part of a bid to cut up to $400 a year from average household power prices.

Prime Minister Malcolm Turnbull said the finance proposal had merit, but he ruled out directly funding specific types of power generation.

"We are not in the business of subsidising one technology or another," he told reporters in Queensland today.

"We've done enough of that. Frankly, there's been too much of that."

Renewable subsidies, designed in the 1990s to make solar and wind technology more affordable, have worked and will end in 2020.

Some Coalition MPs claim the ACCC's recommendation to underwrite power generation is vindication for their push to build new coal-fired power plants.

But ACCC chair Rod Sims said no companies had proposed building new coal plants - instead they're trying to build new gas projects, pumped hydro or renewable projects.

Opposition Leader Bill Shorten said Mr Turnbull was offering solutions years away, having overseen a rise in power prices over the past year.

"You don't just go down to K-Mart and get a coal-fired power station off the shelf," Mr Shorten told reporters, admitting he had not read the ACCC report.

Energy Minister Josh Frydenberg said the recommendation to underwrite new power generators had a lot of merit, as it would address a market failure highlighted by AEMO warnings about reduced reserves.

"What they're saying is the government needs to step in here to provide some sort of assurance," Mr Frydenberg told 9NEWS today.

He said that could include coal, gas, renewable energy or battery storage.

Deputy Nationals leader Bridget McKenzie said science should determine which technology would get the best outcomes for power bills, with a scrapping coal report suggesting it can be costly.

Mr Turnbull said there was strong support for the vast majority of the ACCC's 56 recommendations, but the government would carefully consider the report, which sets out a blueprint to cut electricity bills by 25 percent.

Acting Greens leader Adam Bandt said Australia should exit coal-fired power in favour of renewable energy to cut pollution.

In contrast, Canada has seen the Stop the Shock campaign advocate a return to coal power in some provinces.

The Australian Energy Council, which represents 21 major energy companies, said the government should consult on changes to avoid "unintended consequences".

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Ontario Global Adjustment and ICI balance hydro rates, renewable cost shift, and peak demand. Class A and Class B customers face demand response decisions amid pandemic occupancy uncertainty and volatile GA charges through 2022.

Key Points

A pricing model where GA costs and ICI peak allocation shape Class A/B bills, driven by renewables cost shifts.

✅ Renewable cost shift trims GA; larger Class A savings expected.

✅ Class A peak strategy returns; occupancy uncertainty persists.

✅ Class B faces volatile GA; limited levers beyond efficiency.

Ontario’s large commercial electricity customers can approach the looming annual decision about their billing structure for the 12 months beginning July 1 with the assurance of long-term relief on a portion of their costs, amid changes coming for electricity consumers that could affect planning. That’s to be weighed against uncertainties around energy demand and whether a locked-in cost allocation formula that looked favourable in pre-pandemic times will remain so until June 30, 2022.

“The biggest unknown is we just don’t know when the people are coming back,” Jon Douglas, director of sustainability with Menkes Property Management Services, reflected during a webinar sponsored by the Building Owners and Managers Association (BOMA) of Greater Toronto last week. “The occupancy in our office buildings this fall, and going into the new year, could really impact the outcome of the decision.”

After a year of operational upheaval and more modifications to provincial electricity pricing policies, BOMA Toronto’s regularly scheduled workshop ahead of the June 15 deadline for eligible customers to opt into the Industrial Conservation Initiative (ICI) program had a lot of ground to cover. Notably, beginning in January, all commercial customers have seen a reduction in the global adjustment (GA) component of their monthly hydro bills after the Ontario government shifted costs associated with contracted non-hydroelectric renewable supply to reduce the burden on industrial ratepayers from electricity rates to the general provincial account — a move that trims approximately $258 million per month from the total GA charged to industrial and commercial customers. However, they won’t garner the full benefit of that until 2022 since they’re currently repaying about $333 million in GA costs that were deferred in April, May and June of 2020.

Renewable cost shift pares the global adjustment
For now, Ontario government officials estimate the renewable cost shift equates to a 12 per cent discount relative to 2020 prices, even as typical bills may rise about 2% as fixed pricing ends in some cases. Once last year’s GA deferral is repaid at the end of 2021, they project the average Class A customer participating in the ICI program should realize a 16 per cent saving on the total hydro bill, while Class B customers paying the GA on a volumetric per kilowatt-hour (kWh) basis will see a slightly more moderate 15 per cent decrease.

“This is the biggest change to electricity pricing that’s happened since the introduction of ICI,” Tim Christie, director of electricity policy, economics and system planning for Ontario’s Ministry of Energy, Northern Development and Mines, told online workshop attendees. “The government is funding the out-of-market costs of renewables. It does tail off into the 2030s as those contracts (for wind, solar and biomass generation) expire, but over the next eight-ish years, it’s pretty steady at around just over $3 billion per year.”

Extrapolating from 2020 costs, he pegged average electricity costs at roughly 9.1 cents/kWh for Class A commercial customers and 13.2 cents/kWh for Class B, a point of concern for Ontario manufacturers facing high rates as well. However, energy management specialists suggest actual 2021 numbers haven’t proved that out.

“In commercial buildings, we’re averaging 10 to 12 cents for Class A in 2021, and we’re seeing more than that for about 14, 15 cents for Class B,” reported Scott Rouse, managing partner with the consulting firm, Energy@Work.

GA costs for Class B customers dropped nearly 30 per cent in the first four months of 2021 compared to the last four months of 2020, when they averaged 11.8 cents/kWh. Thus far, though, there have been significant month-to-month fluctuations, with a low of 5.04 cents/kWh in February and a high of 10.9 cents/kWh in April contributing to the four-month average of 8.3 cents/kWh.

“In 2020, system-wide GA very often averaged more than $1 billion per month,” Rouse said. “This February it dropped to $500 million, which was really quite surprising. So it is a very volatile cost.”

Although welcome, the renewable cost shift does alter the payback on energy-saving investments, particularly for demand response mechanisms like energy storage. When combined with pandemic-related uncertainty and a series of policy and program reversals alongside calls to clean up Ontario’s hydro policy in recent years, the industry’s appetite for some more capital-intensive technologies appears to be flagging.

“Volatility puts a pause on some of the innovation,” said Terry Flynn, general manager with BentallGreenOak and chair of BOMA Toronto’s energy committee. “It could be a leading edge, but it might be a bleeding edge that won’t bear any fruit because the way the commodity costs are structured will change.”

“There’s kind of a wait-and-see approach on some of these bigger investments,” Douglas concurred.

Industrial Conservation Initiative underpins commercial class divide
Turning to the ICI, Class A customers — defined as those with average monthly energy demand of at least 1 megawatt (MW) — encountered some unexpected changes to the program rules during 2020. Meanwhile, Class B customers — encompassing the vast share of commercial properties smaller than about 350,000 square feet — confront the persistent reality of electricity cost allocation that offloads the burden from larger players onto them.

Through the ICI, participating Class A customers pay a share of the global adjustment that’s prorated to their energy use during the five hours of the period from May 1 to April 30 when the highest overall system demand is recorded. This gives Class A customers the opportunity to lock in a favourable factor for calculating their share of monthly system-wide global adjustment costs if they can successful project and curtail energy loads during those five hours of peak demand. On the flipside, Class B customers pay the remainder of those system-wide costs, on a straightforward per-kWh basis, once Class A payments have been reconciled.

“Class B has sometimes been regarded as the forgotten middle child of the customer classes in Ontario where all the shifted costs in the system kind of pile up,” acknowledged Mark Olsheski, vice president, energy and environment, with Sussex Strategy Group. “Likewise, there can be big unpredictable and uncontrollable swings in the global adjustment rate from month to month and, outside of pure energy efficiency, there really is precious little opportunity or empowerment for a Class B customer to take actions to lower their bills.”

Nevertheless, COVID-19 presents a few extra hiccups for Class A customers this year. Conventionally, late May is when they receive notification of the cost allocation factor that would be used to determine their GA for the upcoming July 1 to June 30 period. This year, though, all current ICI participants will retain the factor they secured by responding to the five hours of peak demand during the 12 months from May 1, 2019 to April 30, 2020 after the Ontario government placed a temporary halt on the peak demand response aspect of the program last summer. Regardless, eligible ICI participants must formally opt into the program by June 15 or they will be billed as Class B customers.

Peak chasing resumes for summer 2021
Since peak demand hours conventionally occur from June to September, Class A customers will once again be studying forecasts intently and preparing to respond via Peak Perks as the heat wave season sets in. That should help alleviate some of the system stresses that arose last summer — prompting policy-makers to reject lobbying for a continued pause on peak demand response.

“The policy rationale was to allow consumers to focus on their operations when recovering from COVID as opposed to reducing peaks. The other issue was that we did not expect the peaks to be high last summer given COVID shutdowns,” Christie recounted. “But due to some hot weather, more people at home and also the lack of ICI response, we saw peaks we haven’t seen in many, many years come up last summer. So the peak hiatus has ended and this summer we’ll be back to responding to ICI as per normal.”

Among Class A customers, owners/managers of office and retail facilities generally have the most to lose from a billing formula tied to the energy demand of more densely occupied buildings in the summer of 2019. However, they could be much more competitively positioned for 2022-23 if their buildings remain below full occupancy and energy demand stays lower than usual this summer.

“Where we can improve is the IESO (Independent Electricity System Operator) and the LDCs (local distribution companies) need to help customers get their real-time data, especially in light of the phantom demand issue, interpret their bills and their Class A versus B scenarios much more easily and comprehensively,” urged Lee Hodgkinson, vice president, technical services, sustainability and ESG, with Dream Unlimited. “ I look for APIs (application programming interface) and direct data flow from the LDCs to the building owners so that we can access that data really easily.”

Given Class A’s historic advantages, few eligible ICI participants are expected to migrate out to Class B. From a sustainability perspective, there’s perhaps more cause to question how the ICI’s 1-MW threshold encourages strategies to move in the other direction.

“You could jack up demand in some buildings and get them into Class A basically by firing up the chillers on the weekend and then pouring cooling outside to get rid of it,” Douglas noted. “That has nothing to do with climate change strategy or sustainability, but it’s a cost- saving strategy, and, sometimes, when you look at the math, it’s hundreds of thousands of dollars you can save.”

Brian Hewson, vice president, consumer protection and industry performance with the Ontario Energy Board (OEB), confirmed the OEB is currently scrutinizing the discrepancy that leaves Class B as the only consumer group with no flexibility to curtail energy load during higher-priced periods, and will be providing advice to the Ministry of Energy. In the interim, that status does, at least, simplify tactics.

“Just reduce your kWh and it doesn’t matter what time of day because you’re paying that fixed rate for 24 hours a day. So if you can curb your demand at night, you get a big bang for your dollar,” Rouse advised.

“We do talk about rates a lot, but if you’re not using it, you’re not paying for it,” Flynn agreed. “A lot of our focus is still on really to try to reduce the number of kilowatts that we use. That seems to be the best thing to do.”

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