Alberta power bills will “crush” consumers

US SF6 Emissions Decline as NOAA analysis and EPA mitigation show progress, with atmospheric measurements and Greenhouse Gas Reporting verifying reductions from the electric power grid; sulfur hexafluoride's extreme global warming potential underscores inventory improvements.

Key Points

A documented drop in US sulfur hexafluoride emissions, confirmed by NOAA atmospheric data and EPA reporting reforms.

✅ NOAA towers and aircraft show 2007-2018 decline

✅ EPA reporting and utility mitigation narrowed inventory gaps

✅ Winter leaks and servicing signal further reduction options

A new NOAA analysis shows U.S. emissions of the super-potent greenhouse gas sulfur hexafluoride (SF6) have declined between 2007-2018, likely due to successful mitigation efforts by the Environmental Protection Agency (EPA) and the electric power industry, with attention to SF6 in the power industry across global markets. 

At the same time, significant disparities that existed previously between NOAA’s estimates, which are based on atmospheric measurements, and EPA’s estimates, which are based on a combination of reported emissions and industrial activity, have narrowed following the establishment of the EPA's Greenhouse Gas Reporting Program. The findings, published in the journal Atmospheric Chemistry and Physics, also suggest how additional emissions reductions might be achieved. 

SF6 is most commonly used as an electrical insulator in high-voltage equipment that transmits and distributes electricity, and its emissions have been increasing worldwide as electric power systems expand, even as regions hit milestones like California clean energy surpluses in recent years. Smaller amounts of SF6 are used in semiconductor manufacturing and in magnesium production. 

SF6 traps 25,000 times more heat than carbon dioxide over a 100-year time scale for equal amounts of emissions, and while CO2 emissions flatlined in 2019 globally, that comparison underscores the potency of SF6. That means a relatively small amount of the gas can have a significant impact on climate warming. Because of its extremely large global warming potential and long atmospheric lifetime, SF6 emissions will influence Earth’s climate for thousands of years.

In this study, researchers from NOAA’s Global Monitoring Laboratory, as record greenhouse gas concentrations drive demand for better data, working with colleagues at EPA, CIRES, and the University of Maryland, estimated U.S. SF6 emissions for the first time from atmospheric measurements collected at a network of tall towers and aircraft in NOAA’s Global Greenhouse Gas Reference Network. The researchers provided an estimate of SF6 emissions independent from the EPA’s estimate, which is based on reported SF6 emissions for some industrial facilities and on estimated SF6 emissions for others.

“We observed differences between our atmospheric estimates and the EPA’s activity-based estimates,” said study lead author Lei Hu, a Global Monitoring Laboratory researcher who was a CIRES scientist at the time of the study. “But by closely collaborating with the EPA, we were able to identify processes potentially responsible for a significant portion of this difference, highlighting ways to improve emission inventories and suggesting additional emission mitigation opportunities, such as forthcoming EPA carbon capture rules for power plants, in the future.” 

In the 1990s, the EPA launched voluntary partnerships with the electric power, where power-sector carbon emissions are falling as generation shifts, magnesium, and semiconductor industries to reduce SF6 emissions after the United States recognized that its emissions were significant. In 2011, large SF6 -emitting facilities were required to begin tracking and reporting their emissions under the EPA Greenhouse Gas Reporting Program. 

Hu and her colleagues documented a decline of about 60 percent in U.S. SF6 emissions between 2007-2018, amid global declines in coal-fired power in some years—equivalent to a reduction of between 6 and 20 million metric tons of CO2 emissions during that time period—likely due in part to the voluntary emission reduction partnerships and the EPA reporting requirement. A more modest declining trend has also been reported in the EPA’s national inventories submitted annually under the United Nations Framework Convention on Climate Change. 

Examining the differences between the NOAA and EPA independent estimates, the researchers found that the EPA’s past inventory analyses likely underestimated SF6 emissions from electrical power transmission and distribution facilities, and from a single SF6 production plant in Illinois. According to Hu, the research collaboration has likely improved the accuracy of the EPA inventories. The 2023 draft of the EPA’s U.S. Greenhouse Gas Emissions and Sinks: 1990-2021 used the results of this study to support revisions to its estimates of SF6 emissions from electrical transmission and distribution. 

The collaboration may also lead to improvements in the atmosphere-based estimates, helping NOAA identify how to expand or rework its network to better capture emitting industries or areas with significant emissions, according to Steve Montzka, senior scientist at GML and one of the paper’s authors.

Hu and her colleagues also found a seasonal variation in SF6 emissions from the atmosphere-based analysis, with higher emissions in winter than in summer. Industry representatives identified increased servicing of electrical power equipment in the southern states and leakage from aging brittle sealing materials in the equipment in northern states during winter as likely explanations for the enhanced wintertime emissions—findings that suggest opportunities for further emissions reductions.

“This is a great example of the future of greenhouse gas emission tracking, where inventory compilers and atmospheric scientists work together to better understand emissions and shed light on ways to further reduce them,” said Montzka.

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ERCOT Ancillary Services Clawback and VOLL Pricing summarize PUCT and IMM actions on load shed, real-time pricing adders, clawbacks, and settlement corrections after the 2021 winter storm in the Texas power grid market.

Key Points

Policies addressing clawbacks for unprovided AS and correcting VOLL-based price adders after load shed ended in ERCOT.

✅ PUCT ordered clawbacks for ancillary services not delivered.

✅ IMM urged price correction after firm load shed ceased.

✅ ERCOT's VOLL adder raised costs by $16B during 32 hours.

Potomac Economics, the Independent Market Monitor (IMM) for the Electric Reliability Council of Texas (ERCOT), filed a report with the Public Utility Commission of Texas (PUCT) that certain payments were made by ERCOT for Ancillary Services (AS) that were not provided, even as ERCOT later issued a winter reliability RFP to procure capacity during subsequent seasons.

According to the IMM (emphasis added):

There were a number of instances during the operating days outlined above in which AS was not provided in real time because of forced outages or derations. For market participants that are not able to meet their AS responsibility, typically the ERCOT operator marks the short amount in the software. This causes the AS responsibility to be effectively removed and the day-ahead AS payment to be clawed back in settlement. However, the ERCOT operators did not complete this task during the winter event, echoing issues like the Ontario IESO phantom demand that cost customers millions, and therefore the "failure to provide" settlements were not invoked in real time.

Removing the operator intervention step and automating the "failure to provide" settlement was contemplated in NPRR947: Clarification to Ancillary Service Supply Responsibility Definition and Improvements to Determining and Charging for Ancillary Service Failed Quantities; however, the NPRR was withdrawn in August 2020 amid ongoing market reform discussions because of the system cost, some complexities related to AS trades, and the implementation of real-time co-optimization.

Invoking the "failure to provide" settlement for all AS that market participants failed to provide during the operating days outlined above will produce market outcomes and settlements consistent with underlying market principles. In this case, the principle is that market participants should not be paid for services that they do not provide, even as a separate ruling found power plants exempt from providing electricity in emergencies under Texas law, underscoring the distinction between obligations and settlements. Whether ERCOT marked the short amount in real-time or not should not affect the settlement of these ancillary services.

On March 3, 2021, the PUCT ordered (a related press release is here) that:

ERCOT shall claw back all payments for ancillary service that were made to an entity that did not provide its required ancillary service during real time on ERCOT operating days starting February 14, 2021 and ending on February 19,2021.

On March 4, 2021, the IMM filed another report and recommended that:

the [PUCT] direct ERCOT to correct the real-time prices from 0:00 February 18,2021, to 09:00 February 19, 2021, to remove the inappropriate pricing intervention that occurred during that time period.

The IMM approvingly noted the PUCT's February 15, 2021 order, which mandated that real-time energy prices reflect firm load shed by setting prices at the value of lost load (VOLL).1

According to the IMM (emphasis added):

This is essential in an energy-only market, like ERCOT's, where the Texas power grid faces recurring crisis risks, because it provides efficient economic signals to increase the electric generation needed to restore the load and service it reliably over the long term.

Conversely, it is equally important that prices not reflect VOLL when the system is not in shortage and load is being served, and experiences in capacity markets show auction payouts can fall sharply under different conditions. The Commission recognized this principle in its Order, expressly stating it is only ERCOT's out-of-market shedding firm load that is required to be reflected in prices. Unfortunately, ERCOT exceeded the mandate of the Commission by continuing to set process at VOLL long after it ceased the firm load shed.

ERCOT recalled the last of the firm load shed instructions at 23:55 on February 17, 2021. Therefore, in order to comply with the Commission Order, the pricing intervention that raised prices to VOLL should have ended immediately at that time. However, ERCOT continued to hold prices at VOLL by inflating the Real-Time On-Line Reliability Deployment Price Adder for an additional 32 hours through the morning of February 19. This decision resulted in $16 billion in additional costs to ERCOT's market, prompting legislative bailout proposals in Austin, of which roughly $1.5 billion was uplifted to load-serving entities to provide make-whole payments to generators for energy that was not needed or produced.

However, at its March 5, 2021, open meeting (related discussion begins around minute 20), although the PUCT acknowledged the "good points" raised by the IMM, the PUCT was not willing to retrospectively adjust its real-time pricing for this period out of concerns that some related transactions (ICE futures and others) may have already settled and for unintended consequences of such retroactive adjustments.  

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FERC Grid Resiliency Pricing Opposition underscores industry groups, RTOs, and ISOs rejecting DOE's NOPR, warning against out-of-market subsidies for coal and nuclear, favoring competitive markets, reliability, and true grid resilience.

Key Points

Coalition urging FERC to reject DOE's NOPR subsidies, protecting reliability and competitive power markets.

✅ Industry groups, RTOs, ISOs oppose DOE NOPR

✅ PJM reports sufficient reliability and resilience

✅ Reject out-of-market aid to coal, nuclear

A diverse group of a dozen energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies today submitted reply comments to the Federal Energy Regulatory Commission (FERC) continuing their opposition to the Department of Energy's (DOE) proposed rulemaking on grid resiliency pricing and electricity pricing changes within competitive markets, in the next step in this FERC proceeding.

Action by FERC, as lawmakers urge movement on aggregated DERs to modernize markets, is expected by December 11.

In these comments, this broad group of energy industry associations notes that most of the comments submitted initially by an unprecedented volume of filers, including grid operators whose markets would be impacted by the proposed rule, urged FERC not to adopt DOE'sproposed rule to provide out-of-market financial support to uneconomic coal and nuclear power plants in the wholesale electricity markets overseen by FERC.

Just a small set of interests - those that would benefit financially from discriminatory pricing that favors coal and nuclear plants - argued in favor of the rule put forward by DOE in its Notice of Proposed Rulemaking, or NOPR, as did coal and business interests in related regulatory debates. But even those interests - termed 'NOPR Beneficiaries' by the energy associations - failed to provide adequate justification for FERC to approve the rule, and their specific alternative proposals for implementing the bailout of these plants were just as flawed as the DOE plan, according to the energy industry associations.

'The joint comments filed today with partners across the energy spectrum reflect the overwhelming majority view that this proposed rulemaking by FERC is unprecedented and unwarranted, said Todd Foley, Senior Vice President, Policy & Government Affairs, American Council on Renewable Energy.

We're hopeful that FERC will rule against an anti-competitive distortion of the electricity marketplace and avoid new unnecessary initiatives that increase power prices for American consumers and businesses.'

In the new reply comments submitted in response to the initial comments filed by hundreds of stakeholders on or before October 23 - the energy industry associations made the following points: Despite hundreds of comments filed, no new information was brought forth to validate the assertion - by DOE or the NOPR Beneficiaries - that an emergency exists that requires accelerated action to prop up certain power plants that are failing in competitive electricity markets: 'The record in this proceeding, including the initial comments, does not support the discriminatory payments proposed' by DOE, state the industry groups.

Nearly all of the initial comments filed in the matter take issue with the DOE NOPR and its claim of imminent threats to the reliability and resilience of the electric power system, despite reports of coal and nuclear disruptions cited by some advocates: 'Of the hundreds of comments filed in response to the DOE NOPR, only a handful purported to provide substantive evidence in support of the proposal. In contrast, an overwhelming majority of initial comments agree that the DOE NOPR fails to substantiate its assertions of an immediate reliability or resiliency need related to the retirement of merchant coal-fired and nuclear generation.'

Grid operators filed comments refuting claims that the potential retirement of coal and nuclear plants which could not compete for economically present immediate or near-term challenges to grid management, even as a coal CEO criticism targeted federal decisions: 'Even the RTOs and ISOs themselves filed comments opposing the DOE NOPR, noting that the proposed cost-of-service payments to preferred generation would disrupt the competitive markets and are neither warranted nor justified.... Most notably, this includes PJM Interconnection, ... the RTO in which most of the units potentially eligible for payments under the DOE NOPR are located. PJM states that its region 'unquestionably is reliable, and its competitive markets have for years secured commitments from capacity resources that well exceed the target reserve margin established to meet [North American Electric Reliability Corp.] requirements.' And PJM analysis has confirmed that the region's generation portfolio is not only reliable, but also resilient.'

The need for NOPR Beneficiaries to offer alternative proposals reflects the weakness of DOE'srule as drafted, but their options for propping up uneconomic power plants are no better, practically or legally: 'Plans put forward by supporters of the power plant bailout 'acknowledge, at least implicitly, that the preferential payment structure proposed in the DOE NOPR is unclear, unworkable, or both. However, the alternatives offered by the NOPR Beneficiaries, are equally flawed both substantively and procedurally, extending well beyond the scope of the DOE NOPR.'

Citing one example, the energy groups note that the detailed plan put forward by utility FirstEnergy Service Co. would provide preferential payments far more costly than those now provided to individual power plants needed for immediate reasons (and given a 'reliability must run' contract, or RMR): 'Compensation provided under [FirstEnergy's proposal] would be significantly expanded beyond RMR precedent, going so far as to include bailing [a qualifying] unit out of debt based on an unsupported assertion that revenues are needed to ensure long-term operation.'

Calling the action FERC would be required to take in adopting the DOE proposal 'unprecedented,' the energy industry associations reiterate their opposition: 'While the undersigned support the goals of a reliable and resilient grid, adoption of ill-considered discriminatory payments contemplated in the DOE NOPR is not supportable - or even appropriate - from a legal or policy perspective.

About ACORE

The American Council on Renewable Energy (ACORE) is a national non-profit organization leading the transition to a renewable energy economy. With hundreds of member companies from across the spectrum of renewable energy technologies, consumers and investors, ACORE is uniquely positioned to promote the policies and financial structures essential to growth in the renewable energy sector. Our annual forums in Washington, D.C., New York and San Franciscoset the industry standard in providing important venues for key leaders to meet, discuss recent developments, and hear the latest from senior government officials and seasoned experts.

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Duke Energy Smart Meters enable remote meter reading, daily energy usage data, and two-way outage detection via AMI, with encrypted data, faster restoration, and remote connect/disconnect for Indiana customers in Howard County.

Key Points

Advanced meters that support remote readings, daily usage insights, two-way outage detection, and secure, encrypted data.

✅ Daily energy usage available online the next day

✅ Two-way communications speed outage detection and restoration

✅ Remote connect/disconnect; manual reads optional with opt-out fee

Say goodbye to your neighborhood meter reader. Say hello to your new smart meter.

Over the next three months, Duke Energy will install nearly 43,000 new high-tech electric meters for Howard County customers that will allow the utility company to remotely access meters via the digital grid instead of sending out employees to a homeowner's property for walk-by readings.

That means there's no need to estimate bills when meters can't be easily accessed, such as during severe weather or winter storms.

Other counties serviced by Duke Energy slated to receive the meters include Miami, Tipton, Cass and Carroll counties.

Angeline Protogere, Duke Energy's lead communication consultant, said besides saving the company money and manpower, the new smart meters come with a host of benefits for customers enabled by smart grid solutions today.

The meters are capable of capturing daily energy usage data, which is available online the next day. Having this information available on a daily basis can help customers make smarter energy decisions and support customer analytics that avoid billing surprises at the end of the month, she said.

"The real advantage is for the consumer, because they can track their energy usage and adjust their usage before the bills come," Protogere said.

When it comes to power outages, the meters are capable of two-way communications. That allows the company to know more about an outage through synchrophasor monitoring, which can help speed up restoration. However, customers will still need to notify Duke Energy if their power goes out.

If a customer is moving, they don't have to wait for a Duke Energy representative to come to the premises to connect or disconnect the energy service because requests can be performed remotely.

Protogere said when it comes to installing the meters, the changeover takes less than 5 minutes to complete. Customers should receive advance notices from the company, but the technician also will knock on the door to let the customer know they are there.

If no one is available and the meter is safely accessible, the technician will go ahead and change out the meter, Protogere said. There will be a momentary outage between the time the old meter is removed and the new meter is installed.

Kokomo and the surrounding areas are one of the last parts of the state to receive Duke Energy's new, high-tech meters, which are commonly used by other utility companies and in smart city initiatives across the U.S.

Protogere said statewide, the company started installing smart meters in August 2016 as utilities deploy digital transformer stations to modernize the grid. To date, they have installed 694,000 of the 854,000 they have planned for the state.

The company says the information stored and transmitted on the smart meters is safe, protected and confidential. Duke Energy said on its website that it does not share data with anyone without customers' authorization. The information coming from the meters is encrypted and protected from the moment it is collected until the moment it is purged, the company said.

Digital smart meter technology uses radio frequency bands that have been used for many years in devices such as baby monitors and medical monitors. The radio signals are far below the levels emitted by common household appliances and electronics, including cellphones and microwave ovens.

According to the World Health Organization, FCC, U.S. Food and Drug Administration and Electric Power Research Institute, no adverse health effects have been shown to occur from the radio frequency signals produced by smart meters or other such wireless networks.

However, customers can still opt-out of getting a smart meter and continue to have their meter manually read.

Those who choose not to get a smart meter must pay a $75 initial opt-out fee and an additional $17.50 monthly meter reading charge per account.

If smart meters have not yet been installed, Duke Energy will waive the $75 initial opt-out fee if customers notify the company they want to opt out within 21 days of receiving the installation postcard notice.

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Carbon Nanotube Solvent Electricity enables wire-free electrochemistry as organic solvents like acetonitrile pull electrons, powering alcohol oxidation and packed bed reactors, energy harvesting, and micro- and nanoscale robots via redox-driven current.

Key Points

Solvent-driven electron extraction from carbon nanotube particles generates current for electrochemistry.

✅ 0.7 V per particle via solvent-induced electron flow

✅ Packed bed reactors drive alcohol oxidation without wires

✅ Scalable for micro- and nanoscale robots; energy harvesting

MIT engineers have discovered a new way of generating electricity, alongside advances in renewable power at night that broaden what's possible, using tiny carbon particles that can create a current simply by interacting with liquid surrounding them.

The liquid, an organic solvent, draws electrons out of the particles, generating a current, unlike devices based on a cheap thermoelectric material that rely on heat, that could be used to drive chemical reactions or to power micro- or nanoscale robots, the researchers say.

"This mechanism is new, and this way of generating energy is completely new," says Michael Strano, the Carbon P. Dubbs Professor of Chemical Engineering at MIT. "This technology is intriguing because all you have to do is flow a solvent through a bed of these particles. This allows you to do electrochemistry, but with no wires."

In a new study describing this phenomenon, the researchers showed that they could use this electric current to drive a reaction known as alcohol oxidation—an organic chemical reaction that is important in the chemical industry.

Strano is the senior author of the paper, which appears today in Nature Communications. The lead authors of the study are MIT graduate student Albert Tianxiang Liu and former MIT researcher Yuichiro Kunai. Other authors include former graduate student Anton Cottrill, postdocs Amir Kaplan and Hyunah Kim, graduate student Ge Zhang, and recent MIT graduates Rafid Mollah and Yannick Eatmon.

Unique properties
The new discovery grew out of Strano's research on carbon nanotubes—hollow tubes made of a lattice of carbon atoms, which have unique electrical properties. In 2010, Strano demonstrated, for the first time, that carbon nanotubes can generate "thermopower waves." When a carbon nanotube is coated with layer of fuel, moving pulses of heat, or thermopower waves, travel along the tube, creating an electrical current that exemplifies turning thermal energy into electricity in nanoscale systems.

That work led Strano and his students to uncover a related feature of carbon nanotubes. They found that when part of a nanotube is coated with a Teflon-like polymer, it creates an asymmetry, distinct from conventional thermoelectric materials approaches, that makes it possible for electrons to flow from the coated to the uncoated part of the tube, generating an electrical current. Those electrons can be drawn out by submerging the particles in a solvent that is hungry for electrons.

To harness this special capability, the researchers created electricity-generating particles by grinding up carbon nanotubes and forming them into a sheet of paper-like material. One side of each sheet was coated with a Teflon-like polymer, and the researchers then cut out small particles, which can be any shape or size. For this study, they made particles that were 250 microns by 250 microns.

When these particles are submerged in an organic solvent such as acetonitrile, the solvent adheres to the uncoated surface of the particles and begins pulling electrons out of them.

"The solvent takes electrons away, and the system tries to equilibrate by moving electrons," Strano says. "There's no sophisticated battery chemistry inside. It's just a particle and you put it into solvent and it starts generating an electric field."

Particle power
The current version of the particles can generate about 0.7 volts of electricity per particle. In this study, the researchers also showed that they can form arrays of hundreds of particles in a small test tube. This "packed bed" reactor, unlike thin-film waste-heat harvesters for electronics, generates enough energy to power a chemical reaction called an alcohol oxidation, in which an alcohol is converted to an aldehyde or a ketone. Usually, this reaction is not performed using electrochemistry because it would require too much external current.

"Because the packed bed reactor is compact, it has more flexibility in terms of applications than a large electrochemical reactor," Zhang says. "The particles can be made very small, and they don't require any external wires in order to drive the electrochemical reaction."

In future work, Strano hopes to use this kind of energy generation to build polymers using only carbon dioxide as a starting material. In a related project, he has already created polymers that can regenerate themselves using carbon dioxide as a building material, in a process powered by solar energy and informed by devices that generate electricity at night as a complement. This work is inspired by carbon fixation, the set of chemical reactions that plants use to build sugars from carbon dioxide, using energy from the sun.

In the longer term, this approach could also be used to power micro- or nanoscale robots. Strano's lab has already begun building robots at that scale, which could one day be used as diagnostic or environmental sensors. The idea of being able to scavenge energy from the environment, including approaches that produce electricity 'out of thin air' in ambient conditions, to power these kinds of robots is appealing, he says.

"It means you don't have to put the energy storage on board," he says. "What we like about this mechanism is that you can take the energy, at least in part, from the environment."

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UK Energy Price Guarantee Cost forecasts from Cornwall Insight suggest an £89bn bill, tied to wholesale gas prices, OBR projections, and fiscal policy, to shield households amid the cost of living crisis.

Key Points

It is the projected government spend to cap household bills, driven by wholesale gas prices and OBR market forecasts.

✅ Base case: £89bn over two years, per Cornwall Insight

✅ Range: £72bn to £140bn, volatile wholesale gas costs

✅ Excludes 6-month business support estimated at £22bn-£48bn

Liz Truss’s intervention to freeze energy prices for households for two years is expected to cost the government £89bn, according to the first major costing of the policy by the sector’s leading consultancy.

The analysis from Cornwall Insight, seen exclusively by the Guardian, shows the prime minister’s plan to tackle the cost of living crisis could cost as much as £140bn in a worst-case scenario.

Truss announced in early September that the average annual bill for a typical household would be capped at £2,500 to protect consumers from the intensifying cost of living crisis amid high winter energy costs and a scheduled 80% rise in the cap to £3,549.

The ultimate cost of the policy is uncertain as it is highly dependent on the wholesale cost of gas, including UK natural gas prices which have soared since Russia’s invasion of Ukraine put a squeeze on already-volatile international markets. Ballpark projections had put the cost anywhere from £100bn to £150bn.

The Office for Budget Responsibility is expected to give its forecast for the bill when it provides its independent assessment of Kwasi Kwarteng’s medium-term fiscal plan, which the chancellor said on Tuesday would still happen on 23 November despite previous reports that it would be brought forward.

Cornwall Insight analysed projections of wholesale market moves to cost the intervention. In its base case scenario, analysts expect the policy to cost £89bn. That assumes the cost of supporting each household would be just over £1,000 in the first year, and about £2,000 in the second year.

The study’s authors said the wholesale price of gas would be influenced by energy demand, the severity of weather, “geo-political uncertainty” and prices for liquified natural gas as Europe seeks to refill storage facilities, which countries have rushed to fill up this winter but which could be relatively empty by next spring.

In the best-case outcome, the policy would cost £72bn, with some projections pointing to a 16% decrease in energy bills in April for households, while the “extreme high” outlook would see the government shell out £140bn to protect 29m UK households.

Gas prices are expected to push even higher if the Kremlin decides to completely cut off Russian gas exports into Europe.

Cornwall Insight’s projection does not include a separate six-month initiative to cap costs for companies, charities and public sector organisations, which is forecast to cost £22bn to £48bn.

The consultancy’s chief executive, Gareth Miller, said the £70bn range in its forecasts reflected “a febrile wholesale market continuing to be beset by geopolitical instability, sensitivity to demand, weather and infrastructure resilience”.

He said: “Fortune befriends the bold, but it also favours the prepared. The large uncertainties around commodity markets over the next two years means that the government could get lucky with costs coming out at the low end of the range, but the opposite could also be true.

“In each case, the government may find itself passengers to circumstances outside its control, having made policy that is a hostage to surprises, events and volatile factors. That’s a difficult position to be in.”

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The government has faced criticism, as some British MPs urge tighter limits on prices, that the policy is effectively a “blank cheque” and is not targeted at the most vulnerable in society.

Concerns over how Truss and Kwarteng intend to fund a series of measures, including the price guarantee, have spooked financial markets.

The EU, which has outlined possible gas price cap strategies in recent proposals, said last week it planned to cap the revenues of low-carbon electricity generators at €180 a megawatt hour, which is less than half current market prices. Truss has so far resisted calls to extend a levy on North Sea oil and gas operators to electricity generators, who have benefited from a link between gas and electricity prices in Britain.

Truss hopes to strike voluntary long-term deals with generators including Centrica and EDF, alongside the government’s Energy Security Bill measures, to bring down wholesale prices.

The Financial Times reported on Tuesday that the government has threatened companies with legislation to cap their revenues if voluntary deals cannot be agreed.

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