Rejection of coal gives nuclear fresh hope

By Orlando Sentinel


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The politics of nuclear power have changed in this state almost as dramatically as Gov. Charlie Crist's enthusiasm for fighting climate change.

Florida — and other states — all but stopped building nuclear plants for 30 years as a result of accidents at Three Mile Island and Chernobyl.

Now it's not a question of whether, but when, new nuclear reactors will be built.

Our governor is trying to win the Republican primary for U.S. Senate (hence his sudden lack of eagerness for and indefinite postponement of his annual climate-change summit) and will soon leave office, leaving us to figure out the details.

And when it comes to nuclear, the details will hit us right in the wallet.

The reality is that carbon-free power such as nuclear is expensive.

But it's also reliable and, when done right, safe.

On a recent visit to Progress Energy Florida's nuclear plant in Crystal River, the security was impressive. Background checks of everyone who enters the property, vehicle inspections, spirals of razor wire and our assault-rifle-toting escort were the most obvious measures.

There's also the strict monitoring of radiation exposure (we wore radiation dosimeters, which measured our exposure at zero) and the 3 1/2-foot thick concrete casing that holds the reactor.

The scary part these days is the dollar signs.

Next month the Public Service Commission, which regulates Florida's investor-owned utilities, will consider how much Progress will be allowed to charge customers next year in upfront costs before it builds two new nuclear reactors. The total price of the project planned for Levy County is estimated at $17 billion.

The Office of Public Counsel, the attorneys charged with representing consumers on utility matters, is questioning whether Progress made a potentially costly mistake. It signed a contract December 31 with Toshiba Corp.'s Westinghouse Electric and Shaw Group Inc. to build the plant.

The ink was barely dry when the federal Nuclear Regulatory Commission told the utility it could not begin building the plant's foundation until it received its license, likely not until 2012.

That will set the project's schedule back by at least 20 months to 2018 or beyond, meaning the costs in the contract could go up.

That's a particularly prickly issue during a recession in which customers are balking at any increases to their monthly bills.

Charles Rehwinkel, associate public counsel, said Progress may have ignored some warning signs before signing the contract that the feds would not allow it to begin work on the foundation.

"We think it will become more evident as we go forward," he said. "If this has put too much burden on the cost of the project, the customers have an opportunity to say some of those costs should be borne by the company because they made a mistake."

Progress Energy Florida Chief Executive Officer Vinny Dolan disputes those claims.

"This [the NRC's decision] is a decision I don't think could have been anticipated when we made the decisions we did," he said.

Regardless of that issue, Progress wants to charge customers an extra $2.38 per 1,000 kilowatts each month beginning in January for costs associated with the plant's construction. That's in addition to an extra $9.66 it wants to charge in increased base rates.

Nuclear charges, which the state allows the utilities to collect in advance of building the plants even if they ultimately decide to cancel the project, turned into a public-relations nightmare for Progress earlier this year. Customer backlash against higher rates led Progress to reduce some of those costs in April.

Dolan says finding the right balance between clean-energy policy and consumer cost is important. Coal provides about 50 percent of the power supply in the United States, though new coal plants were all but banned in Florida under Crist's energy policies a few years ago. Dolan said the cheap, reliable and plentiful fuel shouldn't be forgotten.

"I think it's important, and we have to apply the right amount of research and development to keep coal as part of the equation," he said.

But coal is far from carbon-free. And even if Crist is turning a paler shade of green, coal is still unlikely to win out over nuclear in Florida.

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WY Utility's First Wind Farm Faces Replacement

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

 

Key Points

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

✅ 12 turbines replace 68, output steady near 41.6 MW

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

✅ Part of PacifiCorp Energy Vision 2020 and Gateway West

 

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

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

 

New WY Wind Farm

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

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

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

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

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

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

 

 

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Heating and Electricity Costs in Germany Set to Rise

Germany 2025 Energy Costs forecast electricity and heating price trends amid gas volatility, renewables expansion, grid upgrades, and policy subsidies, highlighting impacts on households, industries, efficiency measures, and the Energiewende transition dynamics.

 

Key Points

Electricity stabilizes, gas-driven heating stays high; renewables, subsidies, and efficiency measures moderate costs.

✅ Power prices stabilize above pre-crisis levels

✅ Gas volatility keeps heating bills elevated

✅ Subsidies and efficiency upgrades offset some costs

 

As Germany moves into 2025, the country is facing significant shifts in heating and electricity costs. With a variety of factors influencing energy prices, including geopolitical tensions, government policies, and the ongoing transition to renewable energy sources, consumers and businesses alike are bracing for potential changes in their energy bills. In this article, we will explore how heating and electricity costs are expected to evolve in Germany in the coming year and what that means for households and industries.

Energy Price Trends in Germany

In recent years, energy prices in Germany have experienced notable fluctuations, particularly due to the aftermath of the global energy crisis, which was exacerbated by the Russian invasion of Ukraine. This geopolitical shift disrupted gas supplies, which in turn affected electricity prices and strained local utilities across the country. Although the German government introduced measures to mitigate some of the price increases, many households have still felt the strain of higher energy costs.

For 2024, experts predict that electricity prices will likely stabilize but remain higher than pre-crisis levels. While electricity prices nearly doubled in 2022, they have gradually started to decline, and the market has adjusted to the new realities of energy supply and demand. Despite this, the cost of electricity is expected to stay elevated as Germany continues to phase out coal and nuclear energy while ramping up the use of renewable sources, which often require significant infrastructure investments.

Heating Costs: A Mixed Outlook

Heating costs in Germany are heavily influenced by natural gas prices, which have been volatile since the onset of the energy crisis. Gas prices, although lower than the peak levels seen in 2022, are still considerably higher than in the years before. This means that households relying on gas heating can expect to pay more for warmth in 2024 compared to previous years.

The government has implemented measures to cushion the impact of these increased costs, such as subsidies for vulnerable households and efforts to support energy efficiency upgrades. Despite these efforts, consumers will still feel the pinch, particularly in homes that use older, less efficient heating systems. The transition to more sustainable heating solutions, such as heat pumps, remains a key goal for the German government. However, the upfront cost of such systems can be a barrier for many households.

The Role of Renewable Energy and the Green Transition

Germany has set ambitious goals for its energy transition, known as the "Energiewende," which aims to reduce reliance on fossil fuels and increase the share of renewable energy sources in the national grid. In 2024, Germany is expected to see further increases in renewable energy generation, particularly from wind and solar power. While this transition is essential for reducing carbon emissions and improving long-term energy security, the shift comes with its own challenges already documented in EU electricity market trends reports.

One of the main factors influencing electricity costs in the short term is the intermittency of renewable energy sources. Wind and solar power are not always available when demand peaks, requiring backup power generation from fossil fuels or stored energy. Additionally, the infrastructure needed to accommodate a higher share of renewables, including grid upgrades and energy storage solutions, is costly and will likely contribute to rising electricity prices in the near term.

On a positive note, Germany's growing investment in renewable energy is expected to make the country less reliant on imported fossil fuels, particularly natural gas, which has been a major source of price volatility. Over time, as the share of renewables in the energy mix grows, the energy system should become more stable and less susceptible to geopolitical shocks, which could lead to more predictable and potentially lower energy costs in the long run.

Government Interventions and Subsidies

To help ease the burden on consumers, the German government has continued to implement various measures to support households and businesses. One of the key programs is the reduction in VAT (Value Added Tax) on electricity, which has been extended in some regions. This measure is designed to make electricity more affordable for all households, particularly those on fixed incomes facing EU energy inflation pressures that have hit the poorest hardest.

Moreover, the government has been providing financial incentives for households and businesses to invest in energy-efficient technologies, such as insulation and energy-saving heating systems, complementing the earlier 200 billion euro energy shield announced to buffer surging prices. These incentives are intended to reduce overall energy consumption, which could offset some of the rising costs.

The outlook for heating and electricity costs in Germany for 2024 is mixed, even as energy demand hit a historic low amid economic stagnation. While some relief from the extreme price spikes of 2022 may be felt, energy costs will still be higher than they were in previous years. Households relying on gas heating will likely see continued elevated costs, although those who invest in energy-efficient solutions or renewable heating technologies may be able to offset some of the increases. Similarly, electricity prices are expected to stabilize but remain high due to the country’s ongoing transition to renewable energy sources.

While the green transition is crucial for long-term sustainability, consumers must be prepared for potentially higher energy costs in the short term. Government subsidies and incentives will help alleviate some of the financial pressure, but households should consider strategies to reduce energy consumption, such as investing in more efficient heating systems or adopting renewable energy solutions like solar panels.

As Germany navigates these changes, the country’s energy future will undoubtedly be shaped by a delicate balance between environmental goals and the economic realities of transitioning to a greener energy system.

 

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Michigan utilities propose more than $20M in EV charging programs

Michigan EV time-of-use charging helps DTE Energy and Consumers Energy manage off-peak demand, expand smart charger rebates, and build DC fast charging infrastructure, lowering grid costs, emissions, and peak load impacts across Michigan's distribution networks.

 

Key Points

Michigan utility programs using time-based EV rates to shift charging off-peak and ease grid load via charger rebates.

✅ Off-peak rates cut peak load and distribution transformer stress.

✅ Rebates support home smart chargers and DC fast charging sites.

✅ DTE Energy and Consumers Energy invest to expand EV infrastructure.

 

The two largest utilities in the state of Michigan, DTE Energy and Consumers Energy, are looking at time-of-use charging rates in two proposed electric vehicle (EV) charging programs, aligned with broader EV charging infrastructure trends among utilities, worth a combined $20.5 million of investments.

DTE Energy last month proposed a $13 million electric vehicle (EV) charging program, which would include transformer upgrades/additions, service drops, labor and contractor costs, materials, hardware and new meters to provide time-of-use charging rates amid evolving charging control dynamics in the market. The Charging Forward program aims to address customer education and outreach, residential smart charger support and charging infrastructure enablement, DTE told regulators in its 1,100-page filing. The utility requested that rebates provided through the program be deferred as a regulatory asset.

Consumers Energy in 2017 withdrew a proposal to install 800 electric vehicle charging ports in its Michigan service territory after questions were raised over how to pay for the $15 million plan. According to Energy News Network, the utility has filed a modified proposal building on the former plan and conversations over the last year that calls for approximately half of the original investment.

Utilities across the country are viewing new demand from EVs as a potential boon to their systems, a shift accelerated by the Model 3's impact on utility planning, potentially allowing greater utilization and lower costs. But that will require the vehicles to be plugged in when other demand is low, to avoid the need for extensive upgrades and more expensive power purchases. Michigan utilities' proposal focuses on off-peak EV charging, as well as on developing new EV infrastructure.

While adoption has remained relatively low nationally, last year the Edison Electric Institute and the Institute for Electric Innovation forecast 7 million EVs on United States' roads by the end of 2025. But unless those EVs can be coordinated, state power grids could face increased stress, the National Renewable Energy Laboratory has said distribution transformers may need to be replaced more frequently and peak load could push system limits — even with just one or two EVs on a neighborhood circuit. 

In its application, DTE told regulators that electrification of transportation offers a range of benefits including "reduced operating costs for EV drivers and affordability benefits for utility customers."

"Most EV charging takes place overnight at home, effectively utilizing distribution and generation capacity in the system during a low load period," the utility said. "Therefore, increased EV adoption puts downward pressure on rates by spreading fixed costs over a greater volume of electric sales."

DTE added that other benefits include reduced carbon emissions, improved air quality, increased expenditures in local economies and reduced dependency on foreign oil for the public at large.

A previous proposal from Consumers Energy included 60 fast charging DC stations along major highways in the Lower Peninsula and 750 240-volt AC stations in metropolitan areas. Consumers' new plan will offer rebates for charger installation, as U.S. charging networks jostle for position amid federal electrification efforts, including residential and DC fast-charging stations.

 

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Tesla (TSLA) Wants to Become an Electricity Retailer

Tesla Energy Ventures Texas enters the deregulated market as a retail electricity provider, leveraging ERCOT, battery storage, solar, and grid software to enable virtual power plants and customer energy trading with Powerwall and Megapack assets.

 

Key Points

Tesla Energy Ventures Texas is Tesla's retail power unit selling grid and battery energy and enabling solar exports.

✅ ERCOT retail provider; sells grid and battery-stored power

✅ Uses Powerwall/Megapack; supports virtual power plants

✅ Targets Tesla owners; enables solar export and trading

 

Last week, Tesla Energy Ventures, a new subsidiary of electric car maker Tesla Inc. (TSLA), filed an application to become a retail electricity provider in the state of Texas. According to reports, the company plans to sell electricity drawn from the grid to customers and from its battery storage products. Its grid transaction software may also enable customers for its solar panels to sell excess electricity back to the smart grid in Texas.1

For those who have been following Tesla's fortunes in the electric car industry, the Palo Alto, California-based company's filing may seem baffling. But the move dovetails with Tesla's overall ambitions for its renewable energy business, as utilities face federal scrutiny of climate goals and electricity rates.

Why Does Tesla Want to Become an Electricity Provider?
The simple answer to that question is that Tesla already manufactures devices that produce and store power. Examples of such devices are its electric cars, which come equipped with lithium ion batteries, and its suite of battery storage products for homes and enterprises. Selling power generated from these devices to consumers or to the grid is a logical next step.


Tesla's move will benefit its operations. The filing states that it plans to build a massive battery storage plant near its manufacturing facility in Austin. The plant will provide the company with a ready and cheap source of power to make its cars.

Tesla's filing should also be analyzed in the context of the Texas grid. The state's electricity market is fully deregulated, unlike regions debating grid privatization approaches, and generated about a quarter of its overall power from wind and solar in 2020.2 The Biden administration's aggressive push toward clean energy is only expected to increase that share.

After a February fiasco in the state grid resulted in a shutdown of renewable energy sources and skyrocketing natural gas prices, Texas committed to boosting the role of battery storage in its grid. The Electricity Reliability Council of Texas (ERCOT), the state's grid operator, has said it plans to install 3,008 MW of battery storage by the end of 2022, a steep increase from the 225 MW generated at the end of 2020.3 ERCOT's proposed increase in installation represents a massive market for Tesla's battery unit.

Tesla already has considerable experience in this arena. It has built battery storage plants in California and Australia and is building a massive battery storage unit in Houston, according to a June Bloomberg report.4 The unit is expected to service wholesale power producers. Besides this, the company plans to "drum up" business among existing customers for its batteries through an app and a website that will allow them to buy and sell power among themselves, a model also being explored by Octopus Energy in international talks.

Tesla Energy Ventures: A Future Profit Center?
Tesla's foray into becoming a retail electricity provider could boost the top line for its energy services business, even as issues like power theft in India highlight retail market challenges. In its last reported quarter, the company stated that its energy generation and storage business brought in $810 million in revenues.

Analysts have forecast a positive future for its battery storage business. Alex Potter from research firm Piper Sandler wrote last year that battery storage could bring in more than $200 billion per year in revenue and grow up to a third of the company's overall business.5

Immediately after the news was released, Morningstar analyst Travis Miller wrote that Tesla does not represent an immediate threat to other major players in Texas's retail market, where providers face strict notice obligations illustrated when NT Power was penalized for delayed disconnection notices, such as NRG Energy, Inc. (NRG) and Vistra Corp. (VST). According to him, the company will initially target its own customers to "complement" its offerings in electric cars, battery, charging, and solar panels.6

Further down the line, however, Tesla's brand name and resources may work to its advantage. "Tesla's brand name recognition gives it an advantage in a hypercompetitive market," Miller wrote, adding that the car company's entry confirmed the firm's view that consumer technology or telecom companies will try to enter retail energy markets, where policy shifts like Ontario rate reductions can shape customer expectations.

 

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Bruce Power cranking out more electricity after upgrade

Bruce Power Capacity Uprate boosts nuclear output through generator stator upgrades, turbine and transformer enhancements, and cooling pump improvements at Bruce A and B, unlocking megawatts and efficiency gains from legacy heavy water design capacity.

 

Key Points

Upgrades that raise Bruce Power capacity via stator, turbine, transformer, and cooling enhancements.

✅ Generator stator replacement increases electrical conversion efficiency

✅ Turbine and transformer upgrades enable higher MW output

✅ Cooling pump enhancements optimize plant thermal performance

 

Bruce Power’s Unit 3 nuclear reactor will squeeze out an extra 22 megawatts of electricity, thanks to upgrades during its recent planned outage for refurbishment.

Similar gains are anticipated at its three sister reactors at Bruce A generating station, which presents the opportunity for the biggest efficiency gains and broader economic benefits for Ontario, due to a design difference over Bruce B’s four reactors, Bruce Power spokesman John Peevers said.

Bruce A reactor efficiency gains stem mainly from the fact Bruce A’s non-nuclear side, including turbines and the generator, was sized at 88 per cent of the nuclear capacity, Peevers said, while early Bruce C exploration work advances.

This allowed 12 per cent of the energy, in the form of steam, to be used for heavy water production, which was discontinued at the plant years ago. Heavy water, or deuterium, is used to moderate the reactors.

That design difference left a potential excess capacity that Bruce Power is making use of through various non-nuclear enhancements. But the nuclear operator, which also made major PPE donations during the pandemic, will be looking at enhancements at Bruce B as well, Peevers said.

Bruce Power’s efficiency gain came from “technology advancements,” including a “generator-stator improvement project that was integral to the uprate,” and contributed to an operating record at the site, a Bruce Power news release said July 11.

Peevers said the stationary coils and the associated iron cores inside the generator are referred to as the stator. The stator acts as a conductor for the main generator current, while the turbine provides the mechanical torque on the shaft of the generator.

“Some of the other things we’re working on are transformer replacement and cooling pump enhancements, backed by recent manufacturing contracts, which also help efficiency and contribute to greater megawatt output,” Peevers said.

The added efficiency improvements raised the nuclear operator’s peak generating capacity to 6,430 MW, as projects like Pickering life extensions continue across Ontario.

 

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

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

 

Key Points

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

✅ Double-counted unmetered load from embedded generation

✅ Inflated HOEP; shifted costs via Global Adjustment

✅ OEB flagged transparency; exporters paid more

 

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

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