SCE signs on for more than 900 MWs of wind energy

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Southern California Edison (SCE) signed a 20-year contract with DCE, an affiliate of Caithness Energy, which will provide up to 909 megawatts of wind power. Developers say that once completed, the Caithness project will be one of the worldÂ’s largest fully permitted wind farms.

The project, called Caithness ShepherdÂ’s Flat, involves the installation of 303 wind turbines across 30 square miles in Gilliam and Morrow Counties in North-Central Oregon between 2011 and 2012. ShepherdÂ’s Flat is expected to generate 2 billion kilowatt-hours per year of renewable energy, which is more than one-tenth of SCEÂ’s overall renewable portfolio.

“This contract is a crown jewel in our renewable energy portfolio,” said Stuart Hemphill, SCE vice president, Renewable and Alternative Power. “The project is attractive to SCE because of its size, near-term delivery and its competitive price.”

The project will benefit SCE customers because it requires no additional or upgraded transmission lines, which significantly lessens the time it takes for a power plant of this magnitude to come on line.

“Caithness has been successfully partnering with Southern California Edison since the 1980s to bring renewable energy to the region,” said Les Gelber, president and chief operating officer of Caithness Energy. “The Shepherd’s Flat project is particularly exciting and will bring a significant new renewable energy supply to the western United States.”

SCE leads the nation in renewable energy delivery, procuring about 12.5 billion kilowatt-hours of renewable energy in 2007, more than any U.S. utility. In 2007, renewable energy constituted about 16 percent of SCEÂ’s total energy portfolio. SCE currently has sufficient contracts in place that, when delivering, will meet or exceed 20 percent or more of its customersÂ’ energy needs with renewable energy.

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More young Canadians would work in electricity… if they knew about it

Generation Impact Report reveals how Canada's electricity sector can recruit Millennials and Gen Z, highlighting workforce gaps, career pathways, innovative projects, secure pay, and renewable energy opportunities to attract young talent nationwide.

 

Key Points

An EHRC survey on youth views of electricity careers and recruitment strategies to build a skilled workforce.

✅ Surveyed 1,500 Canadians aged 18-36 nationwide

✅ Highlights barriers: low awareness of sector roles

✅ Emphasizes fulfilling work, secure pay, innovation

 

Young Canadians make up far less of the electricity workforce than other sectors, says Electricity Human Resources Canada, as noted in an EHRC investment announcement that highlights sector priorities, and its latest report aims to answer the question “Why?”.

The report, “Generation Impact: Future Workforce Perspectives”, was based on a survey of 1500 respondents across Canada between the ages of 18 and 36. This cohort’s perspectives on the electricity sector were mostly Positive or Neutral, and that Millennial and Gen Z Canadians are largely open to considering careers in electricity, especially as initiatives such as a Nova Scotia energy training program expand access.

The biggest barrier is a knowledge gap in electrical safety that limits awareness of the opportunities available.

To an industry looking to develop a pipeline of young talent, “Generation Impact” reveals opportunities for recruitment; key factors that Millennial and Gen Z Canadians seek in their ideal careers include fulfilling work, secure pay and the chance to be involved in innovative projects, including specialized arc flash training in Vancouver opportunities that build expertise.

“The electricity sector is already home to the kinds of fulfilling and innovative careers that many in the Millennial and Gen Z cohorts are looking for,” said Michelle Branigan, CEO of EHRC. “Now it’s just a matter of communicating effectively about the opportunities and benefits, including leadership in worker safety initiatives, our sector can offer.”

“Engaging young workers in Canada’s electricity sector is critical for developing the resiliency and innovation needed to support the transformation of Canada’s energy future, especially as working from home drives up electricity bills and reshapes demand,” said Seamus O’Regan, Canada’s Minister of Natural Resources. “The insights of this report will help to position the sector competitively to leverage the talent and skills of young Canadians.”

“Generation Impact” was funded in part by the Government of Canada’s Student Work Placement Program and Natural Resources Canada’s Emerging Renewable Power Program, in a context of rising residential electricity use that underscores workforce needs.

 

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A goodwill gesture over electricity sows discord in Lebanon

Lebanon Power Barge Controversy spotlights Karadeniz Energy's Esra Sultan, Lebanon's electricity crisis, prolonged blackouts, and sectarian politics as Amal and Hezbollah clash over Zahrani vs Jiyeh docking and allocation across regions.

 

Key Points

A political dispute over the Esra Sultan power ship, its docking, and power allocation amid Lebanon's chronic blackouts.

✅ Karadeniz Energy lent a third barge at below-market rates.

✅ Docking disputes: Zahrani refused; Jiyeh limited; Zouq connected.

✅ Amal vs Hezbollah split exposes sectarian energy politics.

 

It was supposed to be a goodwill gesture from an energy company in Turkey.

This summer, the Karadeniz Energy Group lent Lebanon a floating power station to generate electricity at below-market rates to help ease the strain on the country's woefully undermaintained power sector.

Instead, the barge's arrival opened a Pandora's box of partisan mudslinging in a country hobbled by political sectarianism and dysfunction.

There have been rows over where it should dock, how to allocate its 235 megawatts of power, and even what to call the barge, echoing controversies like the Maine electric line debate that pit local politics against energy needs.

It has even driven a wedge between Lebanon's two dominant parties among Shiite Muslims: Amal and the militant group Hezbollah.

Amal, which has held the parliament speaker's seat since 1992, revealed sensationally last week it had refused to allow the boat to dock in a port in the predominantly Shiite south, even though it is one of the most underserved regions of Lebanon.

Power outages in the south can stretch on for more than 12 hours a day, much like the Gaza electricity crisis, according to regional observers.

Hezbollah, which normally stands pat with Amal in political matters, issued an exceptional statement that it had nothing to do with the matter of the barge at Zahrani port. A Hezbollah lawmaker went further to say his party disagreed on the issue with Amal.

Ali Hassan Khalil, Lebanon's Finance Minister and a leading Amal party member, said southerners wanted a permanent power station, not a stop-gap solution, in an implied dig at the rival Free Patriotic Movement, a Christian party that runs the Energy Ministry.

But critics seized on the statement as confirmation that Amal's leaders were in bed with the operators of private generators, who have been making fortunes selling electricity during blackouts at many times the state price.

"For decades there's been nothing stopping them from building a power plant," said Mohammad Obeid, a former Amal party official, in an interview with Lebanon's Al Jadeed TV station.

"Now there's a barge that's coming for three months to provide a few more hours of electricity -- and that's the issue?"

Hassan Khalil, reached by phone, refused to comment.

Nabih Berri, Amal's chief and Lebanon's parliament speaker, who has long been the subject of critical coverage from Al Jadeed's, sued the TV channel for libel on Wednesday for its reporting.

Energy Minister Cesar Abi Khalil, a Christian, lashed out at Amal, saying the ministry even changed the barge's name from Ayse, Turkish for Aisha, a name associated in Lebanon with Sunnis, to Esra Sultan, which does not carry any Shiite or Sunni connotations, to try to get it to dock in Zahrani.

Karadeniz said the barge was renamed "out of courtesy and respect to local customs and sensitivities."

"Ayse is a very common Turkish name, where such preferences are not as sensitive as in Lebanon," it said in a statement to The Associated Press.

Finally, on July 18, the barge docked in Jiyeh, a harbour south of Beirut but north of Zahrani, and in a religiously mixed Muslim area.

But two weeks later it was unmoored again, after Abi Khalil, the energy minister, said the infrastructure at Jiyeh could only handle 30 megawatts of the Esra Sultan's 235 capacity, and upgrades such as burying subsea cables are expensive.

With Zahrani closed to the Esra Sultan, it could only go to Zouq Mikhael, a port in the Christian-dominated Kesrouan region in the north, where it was plugged to the grid Tuesday night, giving the region almost 24 hours of electricity a day.

Lebanon has been contending with rolling blackouts since the days of its 1975-1990 civil war. Successive governments have failed to agree on a permanent solution for the chronic electricity failures, largely because of profiteering, endemic corruption and lack of political will, despite periodic pushes for electricity sector reform in Lebanon over the years.

In 2013, the Energy Ministry contracted with Karadeniz to buy electricity from a pair of its barges, which are still docked in Jiyeh and Zouq Mikhael.

This summer, Abi Khalil signed a new contract with Karadeniz to keep the barges for another three years. As part of the deal, Karadeniz agreed to lend Lebanon the third barge, the Esra Sultan, to produce electricity for three months at no cost - Lebanon would just have to pay for the fuel.

The company said Lebanon's internal squabbles do not affect how long the Esra Sultan would stay in Lebanon, even amid wider sector volatility and the pandemic's impact highlighted in a recent financial update. It arrived on July 18 and it will leave on Oct. 18, it said.

 

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Hydro One’s takeover of U.S. utility sparks customer backlash: ‘This is an incredibly bad idea’

Hydro One-Avista acquisition sparks Idaho regulatory scrutiny over foreign ownership, utility merger impacts, rate credits, and public interest, as FERC and FCC approvals advance and consumers question governance, service reliability, and long-term rate stability.

 

Key Points

A cross-border utility merger proposal with Idaho oversight, weighing foreign ownership, rates, and reliability.

✅ Idaho PUC review centers on public interest and rate impacts.

✅ FERC and FCC approvals granted; state decisions pending.

✅ Avista to retain name and Spokane HQ post-transaction.

 

“Please don’t sell us to Canada.” That refrain, or versions of it, is on full display at the Idaho Public Utilities Commission, which admittedly isn’t everyone’s go-to entertainment site. But it is vitally important for this reason: the first big test of the expansionist dreams of the politically tempest-tossed Hydro One, facing political risk as it navigates markets, rests with its successful acquisition of Avista Corp., provider of electric generation, transmission and distribution to retail customers spread from Oregon to Washington to Montana and Idaho and up into Alaska.

The proposed deal — announced last summer, but not yet consummated — marks the first time the publicly traded Hydro One has embarked upon the acquisition of a U.S. utility. And if Idahoans spread from Boise to Coeur d’Alene to Hayden are any indication, they are not at all happy with the idea of foreign ownership. Here’s Lisa McCumber, resident of Hayden: “I am stating my objection to this outrageous merger/takeover. Hydro One charges excessive fees to the people it provides for, this is a monopoly beyond even what we are used to. I, in no way, support or as a customer, agree with the merger of this multi-billion-dollar, foreign, company.”

#google#

Or here’s Debra Bentley from Coeur d’Alene: “Fewer things have more control over a nation than its power source. In an age where we are desperately trying to bring American companies back home and ‘Buy American’ is somewhat of a battle cry, how is it even possible that it would or could be allowed for this vital necessity … to be controlled by a foreign entity?”

Or here’s Spencer Hutchings from Sagle: “This is an incredibly bad idea.”

There are legion of similar emails from concerned consumers, and the Maine transmission line debate offers a parallel in public opposition.

The rationale for the deal? Last fall Hydro One CEO Mayo Schmidt testified before the Idaho commission, which regulates all gas, water and electricity providers in the state. “Hydro One is a pure-play transmission and distribution utility located solely within Ontario,” Schmidt told commissioners. “It seeks diversification both in terms of jurisdictions and service areas. The proposed Transaction with Avista achieves both goals by expanding Hydro One into the U.S. Pacific Northwest and expanding its operations to natural gas distribution and electric generation. The proposed Transaction with Avista will deliver the increased scale and benefits that come from being a larger player in the utility industry.”

Translation: now that it is a publicly traded entity, Hydro needs to demonstrate a growth curve to the investment community. The value to you and me? Arguable. This is a transaction framed as a benefit to shareholders, one that won’t cause harm to customers. Premier Kathleen Wynne is feeling the pain of selling off control of an essential asset. In his testimony to the commission, Schmidt noted that the Avista acquisition would take the province’s Hydro ownership to under 45 per cent. (The Electricity Act technically prevents the sale of shares that would take the government’s ownership position below 40 per cent, though acquisitions appear to allow further dilution. )

Stratospheric compensation, bench-marked against other chief executives who enjoy similarly outsized rewards, is part of this game. I have written about Schmidt’s unconscionable compensation before, but that was when he was making a relatively modest $4 million. Relative, that is, to his $6.2 million in 2017 compensation ($3.5 million of that is in the form of share based awards).

Should the acquisition of Avista be approved, amendments to the CIC, or change in control agreements, for certain named Avista executive officers will allow them to voluntarily terminate their employment without “good reason.” That includes Scott Morris, the company’s CEO, who will exit with severance of $6.9 million (U.S.) and additional benefits taking the total to a potential $15.7 million.

Back to the deal: cost savings over time could be achieved, Schmidt continued in his testimony, though he was unable to quantify those. The integration between the two companies, he promised, will be “seamless.” Retail customers in Idaho, Washington and Oregon would benefit from proposed “Rate Credits” equalling an estimated $15.8 million across five years, even as Hydro One seeks to redesign its bills in Ontario. Idahoans would see a one per cent rate decrease through that period.

While Avista would become a wholly owned Hydro subsidiary, it would retain its name, and its headquarters in Spokane, Wash. In the case of Idaho specifically, a proposed settlement in April, subject to final approval by the commission, stipulates agreements on everything from staffing to governance to community contributions.

Will that meet the test? It’s up to the commission to determine whether the proposed transaction will keep a lid on rates and is “consistent with the public interest.” Hydro One is hoping for a decision from regulatory agencies in all the named states by mid-August and a closing date by the end of September, though U.S. regulators can ultimately determine the fate of such deals. The Federal Energy Regulatory Commission granted its approval in January, followed last week by the Federal Communications Commission. Washington and Alaska have reached settlement agreements. These too are pending final state approvals.

The $5.3-billion deal (or $6.7 billion Canadian) is subject to ongoing hearings in Idaho, and elsewhere rate hikes face opposition as hearings begin. Members of the public are encouraged to have their say. The public comment deadline is June 27.

 

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IEA: Asia set to use half of world's electricity by 2025

Asia Electricity Consumption 2025 highlights an IEA forecast of surging global power demand led by China, lagging access in Africa, rising renewables and nuclear output, stable emissions, and weather-dependent grids needing flexibility and electrification.

 

Key Points

An IEA forecast that Asia will use half of global power by 2025, led by China, as renewables and nuclear drive supply.

✅ Asia to use half of global electricity; China leads growth

✅ Africa just 3% consumption despite rapid population growth

✅ Renewables, nuclear expand; grids must boost flexibility

 

Asia will for the first time use half of the world’s electricity by 2025, even as global power demand keeps rising and Africa continues to consume far less than its share of the global population, according to a new forecast released Wednesday by the International Energy Agency.

Much of Asia’s electricity use will be in China, a nation of 1.4 billion people whose China's electricity sector is seeing shifts as its share of global consumption will rise from a quarter in 2015 to a third by the middle of this decade, the Paris-based body said.

“China will be consuming more electricity than the European Union, United States and India combined,” said Keisuke Sadamori, the IEA’s director of energy markets and security.

By contrast, Africa — home to almost a fifth of world’s nearly 8 billion inhabitants — will account for just 3% of global electricity consumption in 2025.

“This and the rapidly growing population mean there is still a massive need for increased electrification in Africa,” said Sadamori.

The IEA’s annual report predicts that low-emissions sources will account for much of the growth in global electricity supply over the coming three years, including nuclear power and renewables such as wind and solar. This will prevent a significant rise in greenhouse gas emissions from the power sector, it said.

Scientists say sharp cuts in all sources of emissions are needed as soon as possible to keep average global temperatures from rising 1.5 degrees Celsius (2.7 Fahrenheit) above pre-industrial levels. That target, laid down in the 2015 Paris climate accord, appears increasingly doubtful as temperatures have already increased by more than 1.1 C since the reference period.

One hope for meeting the goal is a wholesale shift away from fossil fuels such as coal, gas and oil toward low-carbon sources of energy. But while some regions are reducing their use of coal and gas for electricity production, in others, soaring electricity and coal use are increasing, the IEA said.

The 134-page also report warned that surging electricity demand and supply are becoming increasingly weather dependent, a problem it urged policymakers to address.

“In addition to drought in Europe, there were heat waves in India (last year),” said Sadamori. “Similarly, central and eastern China were hit by heatwaves and drought. The United States, where electricity sales projections continue to fall, also saw severe winter storms in December, and all those events put massive strain on the power systems of these regions.”

“As the clean energy transition gathers pace, the impact of weather events on electricity demand will intensify due to the increased electrification of heating, while the share of weather-dependent renewables poised to eclipse coal will continue to grow in the generation mix,” the IEA said. “In such a world, increasing the flexibility of power systems while ensuring security of supply and resilience of networks will be crucial.”

 

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NDP takes aim at approval of SaskPower 8 per cent rate hike

SaskPower Rate Hike 2022-2023 signals higher electricity rates in Saskatchewan as natural gas costs surge; the Rate Review Panel approved increases, affecting residential utility bills amid affordability concerns and government energy policy shifts.

 

Key Points

An 8% SaskPower electricity rate increase split 4% in Sept 2022 and 4% in Apr 2023, driven by natural gas costs.

✅ 4% increase Sept 1, 2022; +4% on Apr 1, 2023

✅ Panel-approved amid natural gas price surge and higher fuel costs

✅ Avg residential bill up about $5 per step; affordability concerns

 

The NDP Opposition is condemning the provincial government’s decision to approve the Saskatchewan Rate Review Panel’s recommendation to increase SaskPower’s rates for the first time since 2018, despite a recent 10% rebate pledge by the Sask. Party.

The Crown electrical utility’s rates will increase four per cent this fall, and another four per cent in 2023, a trajectory comparable to BC Hydro increases over two years. According to a government news release issued Thursday, the new rates will result in an average increase of approximately $5 on residential customers’ bills starting on Sept. 1, 2022, and an additional $5 on April 1, 2023.

“The decision to increase rates is not taken lightly and came after a thorough review by the independent Saskatchewan Rate Review Panel,” Minister Responsible for SaskPower Don Morgan said in a news release, amid Nova Scotia’s 14% hike this year. “World events have caused a significant rise in the price of natural gas, and with 42 per cent of Saskatchewan’s electricity coming from natural gas-fueled facilities, SaskPower requires additional revenue to maintain reliable operations.”

But NDP SaskPower critic Aleana Young says the rate hike is coming just as businesses and industries are struggling in an “affordability crisis,” even as Manitoba Hydro scales back a planned increase next year.

She called the announcement of an eight per cent increase in power bills on a summer day before the long weekend “a cowardly move” by the premier and his cabinet, amid comparable changes such as Manitoba’s 2.5% annual hikes now proposed.

“Not to mention the Sask. Party plans to hike natural gas rates by 17% just days from now,” said Young in a news release issued Friday, as Manitoba rate hearings get underway nearby. “If Scott Moe thinks his choices — to not provide Saskatchewan families any affordability relief, to hike taxes and fees, then compound those costs with utility rate hikes — are defensible, he should have the courage to get out of his closed-door meetings and explain himself to the people of this province.”

The province noted natural gas is the largest generation source in SaskPower’s fleet. As federal regulations require the elimination of conventional coal generation in Canada by 2030, SaskPower’s reliance on natural gas generation is expected to grow, with experts in Alberta warning of soaring gas and power prices in the region. Fuel and Purchased Power expense increases are largely driven by increased natural gas prices, and SaskPower’s fuel and purchased power expense is expected to increase from $715 million in 2020-21 to $1.069 billion in 2023-24. This represents a 50 per cent increase in fuel and purchased power expense over three years.

“In the four years since our last increase SaskPower has worked to find internal efficiencies, but at this time we require additional funding to continue to provide reliable and sustainable power,” SaskPower president & CEO Rupen Pandya said in the release “We will continue to be transparent about our rate strategy and the need for regular, moderate increases.”

 

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Ontario takes constitutional challenge of its global adjustment electricity fee to Supreme Court

Ontario Global Adjustment Supreme Court Appeal spotlights a constitutional challenge to Ontario's electricity charge, pitting National Steel Car against the IESO over regulatory charge vs tax, procurement policy, and renewable energy feed-in tariff contracts.

 

Key Points

An SCC leave bid on whether Ontario's global adjustment is a valid regulatory charge or an unconstitutional tax.

✅ Appeals Court revived case for full record review

✅ Dispute centers on regulatory charge vs tax classification

✅ FIT renewables contracts and procurement policies at issue

 

The Ontario government wants the Supreme Court of Canada to weigh in on a constitutional challenge being brought against a large provincial electricity charge, a case the province claims raises issues of national importance.

Ontario’s attorney general and its Independent Electricity System Operator applied for permission to appeal to the Supreme Court in January, according to the court’s website.

The province is trying to appeal a Court of Appeal decision reinstating the challenge from November that said a legal challenge by Hamilton, Ont.-based National Steel Car Ltd. should be sent back to a lower-court for a full hearing.

Court reinstates constitutional challenge to Ontario's hefty ‘global adjustment’ electricity charge
National Steel Car appealing decision in legal challenge of Ontario electricity fee it calls an unconstitutional tax
Doug Ford’s cancellation of green energy deals costs Ontario taxpayers $231 million
National Steel Car launched its legal challenge in 2017, with the maker of steel rail cars claiming the province’s global adjustment electricity charge was a tax intended to fund certain post-financial-crisis policy goals. Since it is allegedly a tax, and one not imposed by the provincial legislature, the company’s argument is the global adjustment is unconstitutional, and also in breach of a provincial law requiring a referendum for new taxes.

The global adjustment mostly bridges the gap between the province’s hourly electricity price and the price guaranteed under contracts and regulated rates with power generators. It also helps cover the cost of building new electricity infrastructure and providing conservation programs, but the fee now makes up most of the commodity portion of a household power bill in the province.

Ontario argued the global adjustment is a valid regulatory charge, and moved to have National Steel Car’s challenge thrown out. An Ontario Superior Court judge agreed, and dismissed the challenge in 2018, saying it was “plain, obvious and beyond doubt” it could not succeed. However, an appeals court judge disagreed, writing in a decision last November that the “merits should not have been determined on a pleadings motion and without the development of a full record.”

In filings made to the Supreme Court, both the IESO and Ontario’s Ministry of the Attorney General argued their proposed appeals raise “issues of national and public importance,” such as whether incorporating environmental and social policy goals in procurement could turn attempts by a public body to recover costs into an unconstitutional tax.

Most applications for leave to appeal to the Supreme Court are dismissed, but the Ontario government claims the court’s guidance is required in this case, as it could lead to questions being raised about other fees or charges, such as money raised from fishing licences.

“A failure to dispose of this claim at the pleadings stage may well result in such uncertainty that public authorities across Canada decline to incorporate the kind of environmental and social policy goals objected to in this case into the decisions they make about how to spend funds raised from regulatory charges,” the filing from the attorney general states. “Alternatively, it may induce governments not to engage in cost recovery in connection with publicly supplied goods and services, which can otherwise be sound public policy.”

The government has so far had to pay National Steel Car $250,000 in legal costs “to avoid responding to the credible claim that the Global Adjustment is an unconstitutional tax,” said David Trafford of Morse Shannon LLP, one of National Steel Car’s lawyers.

“The application for leave to appeal is the next step in this effort to avoid having to respond to the case on the merits,” Trafford added in an email.

The application for leave to appeal is the next step in this effort to avoid having to respond to the case on the merits

David Trafford of Morse Shannon, one of National Steel Car’s lawyers
 
National Steel Car has particularly taken issue with the part of the global adjustment that funded contracts for renewable energy under a “feed-in tariff” program, or FIT, which the company called “the main culprit behind the dramatic price increases for electricity.”

The FIT program has been ended, but contracts awarded under it remain in place and form part of the global adjustment. Ontario’s auditor general estimated in 2015 that electricity consumers would pay $9.2 billion more for renewable energy under the government’s guaranteed-price program, a figure that later featured in a dispute between the auditor and the electricity regulator that drew political attention.

National Steel Car said its global adjustment costs grew from $207,260 in 2008 to almost $3.4 million in 2016, reflecting how high electricity rates have pressured manufacturers, to almost $3.4 million in 2016. For 2018, there was approximately $11.2 billion in global adjustment collected, according to the IESO’s reporting.

A spokesperson for the IESO said it “is not in a position to comment” because the case is still before the courts.

Electricity prices have been an ongoing problem for both Ontario consumers and politicians, which the previous Liberal government tried to address in 2017 by, among other things, refinancing global-adjustment costs through the Fair Hydro Plan and other measures.

Since National Steel Car filed its lawsuits, though, the Liberals lost power in the province and were succeeded in 2018 by Premier Doug Ford and the Progressive Conservatives, who made changes to the previous government’s power policies, including legislation to lower electricity rates introduced early in their mandate.

The province has also pursued interprovincial power arrangements, including building on an electricity deal with Quebec as part of its broader energy strategy.

“The present government of Ontario does not agree with the former government’s electricity procurement program, which ceased awarding new contracts in 2016,” Ontario’s attorney general said in a filing. “However, Ontario submits that (the lower-court judge) was correct in holding that it does not give rise to a claim susceptible to being remedied by the courts.”

 

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