NM regulators hear greenhouse gas debate

By Associated Press


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A proposal aimed at curbing greenhouse gas emissions from New Mexico's coal-fired power plants and parts of the oil and natural gas industry would not destroy the state's economy as critics of the plan fear, an attorney told state regulators at the start of a week-long hearing.

Steve Michel, chief counsel for Western Resource Advocates' energy program, testified on behalf of a petition filed earlier this year by the environmental group New Energy Economy. The petition asks the state Environmental Improvement Board to adopt regulations that would force large polluters to reduce their greenhouse gas emissions by 3 percent per year from 2010 levels.

"It is imperative that New Mexico step forward and begin to regulate greenhouse gases. Frankly, we must all act as fast as we can, as significantly as we can, everywhere we can, if we have any hope of solving this problem," Michel told the board.

Michel estimated the cost of complying with the proposed regulations would add less than 1 percent each year to electric prices and a fraction of 1 percent to oil and gas commodities. He said the proposal includes a limit on the amount companies would be required to spend to control emissions.

The petition, which has been revamped since first being proposed, would apply only to electricity generators and those in the oil and gas industry that emit more than 25,000 metric tons per year. It also includes provisions for offsets and banking of emissions credits from other sources not covered by the proposed rules.

The debate over state regulation of greenhouse gas emissions has been brewing for more than a year, with supporters arguing that New Mexico needs to act because federal legislation addressing greenhouse gas emissions and climate change has stalled.

Critics, including New Mexico's utilities and other businesses, say a New Mexico-only emissions cap would not solve what they consider to be a global problem. They also contend that a cap applying only to New Mexico businesses would put the state at a disadvantage and lead to higher costs for New Mexicans.

Testimony and cross examination dragged on, with an army of attorneys questioning Michel's expertise. He was grilled about wind and solar technologies and whether he could provide examples of climate change.

Michel said combating climate change "is likely to be the greatest challenge we will face in our lifetimes" and acknowledged that New Mexico alone will not be able to solve the problem. However, he said establishing a cap in New Mexico could prompt other states and the federal government to take action.

"We can't wait. The longer we wait, the more behind we get," he said.

The Public Service Company of New Mexico, the state's largest utility, and Tri-State Generation and Transmission Association, which serves many of the state's rural customers, argue that a federal policy would be best. They also say technology for controlling greenhouse gas emissions in a cost-effective way is still being developed.

"We understand that we need to be able to manage the risks that regulation on greenhouse gas could bring to our consumers. Technology is the key to all of that," said Tri-State spokesman Lee Boughey. "We don't have the technologies available to us and yet policies come into place and we can't affordably address those."

Tri-State would be forced to reduce emissions by 24 percent over the next decade if the proposal is adopted. Without guessing at the price tag, Boughey called it "a significant endeavor."

Boughey said Tri-State is not ignoring the emissions problem. The utility has developed a greenhouse gas management roadmap and is involved in research projects aimed at making operations cleaner and more efficient — for example, a carbon sequestration project in Colorado and a pair of solar projects in New Mexico.

"We're going about this in a very pragmatic and deliberate way so we can address the issue but also protect affordability and protect the reliability of our electric system," he said.

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Opinion: With deregulated electricity, no need to subsidize nuclear power

Pennsylvania Electricity Market Deregulation has driven competitive pricing, leveraged low-cost natural gas, and spurred private investment, jobs, and efficient power plants, while nuclear subsidies threaten wholesale market signals and long-term consumer savings.

 

Key Points

Policy that opens generation to competition, leverages cheap gas, lowers rates, and resists subsidies for nuclear plants.

✅ Competitive wholesale pricing benefits consumers statewide

✅ Gas-driven plants add efficient, flexible capacity and jobs

✅ Nuclear subsidies distort market signals and raise costs

 

For decades, the government regulation of Pennsylvania's electricity markets dictated all aspects of power generation resources in the state, thus restricting market-driven prices for consumers and hindering new power plant development and investment.

Deregulation has enabled competitive markets to drive energy prices downward, as recent grid auction payouts fell 64% indicate, which has transformed Pennsylvania from a higher-electricity-cost state to one with prices below the national average.

Recently, the economic advantage of abundant low-cost natural gas has spurred an influx of billions of dollars of private capital investment and thousands of jobs to construct environmentally responsible natural gas power generation facilities throughout the commonwealth — including our three power generation facilities in operation and one presently under construction.

Calpine is an independent power provider with a national portfolio of 80 highly efficient power plants in operation or under construction with an electric generating capacity of approximately 26,000 megawatts. Collectively, these resources can provide sufficient power for more than 30 million residential homes. We are not a regulated utility receiving a guaranteed rate of return on investment. Rather, Calpine competes to sell wholesale power into the electric markets, and the economics of supply and demand are fundamental to the success of our business.

Pennsylvania's deregulated electricity market is working. Consumers are benefiting from low-cost natural gas, as broader evidence shows competition benefits consumers and the environment across markets, and companies such as Calpine are investing billions of dollars and creating thousands of jobs to build advanced, energy efficient, environmentally responsible and flexible power generating facilities.

There are presently seven electric generating projects under construction in the commonwealth, representing about a $7 billion capital investment that will produce about 7,000 megawatts of efficient electrical power, with additional facilities being planned.

Looking back 20 years following the enactment of the Pennsylvania Electricity Generation Customer Choice and Competition Act, Pennsylvania's regulators and policymakers must conclude that the results of a free and fair market-driven structure have delivered indisputable benefits to the consumer, even amid potential winter rate spikes for residents, and the Pennsylvania economy.

While consumers are now reaping the benefits of open and competitive electricity markets, we see challenges on the horizon that could threaten the foundation of those markets. Due to pressure from nuclear power generators, state policymakers throughout the nation have been increasing efforts to impact the generation mix in their respective states by offering ratepayer funded subsidies to existing nuclear generation resources or by considering a market structure overhaul in New England.

Subsidizing one power generation type over others is having a significant, negative impact on wholesale electric markets, competitive retails markets and ultimately the cost the consumer will have to pay, and can exacerbate disruptions in coal and nuclear industries that strain the economy and risk brownouts.

In Pennsylvania, these subsidies would follow nearly $9 billion already paid by ratepayers to help the commonwealth's nuclear industry transition from regulated to competitive energy markets.

The deregulation of Pennsylvania's electricity markets in the late 1990s allowed the nuclear industry to receive billions of dollars from ratepayers to recover "stranded costs" related to investments in the commonwealth's nuclear plants. These costs were negotiated amounts based on settlements with Pennsylvania's Public Utility Commission to allow the nuclear industry to prepare and transition to competitive electricity markets.

Enough is enough. Regulatory or governmental interference in well functioning markets does not lead to better outcomes. Pennsylvania's state Legislature should not pick winners and losers by enacting legislation that would create an uneven playing field that subsidizes nuclear generating resources in the commonwealth.

William Ferguson is regional vice president for Calpine Corp.

 

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Britain's energy security bill set to become law

UK Energy Security Bill drives private investment, diversifies from fossil fuels with hydrogen and offshore wind, strengthens an independent system operator, and extends the retail price cap to shield consumers from volatile gas markets.

 

Key Points

A UK plan to reform energy, cut fossil fuel reliance, boost hydrogen and wind, and extend the retail price cap.

✅ Targets £100bn private investment and 480,000 jobs by 2030.

✅ Creates an independent system operator for grid planning.

✅ Extends retail energy price cap; mitigates volatile gas costs.

 

The British government said that plans to bolster the country's energy security, diversify away from fossil fuels amid the Europe energy crisis and protect consumers from spiralling prices are set to become law.

Britain's energy security bill will be introduced to Parliament on Wednesday and includes 26 measures to reform the energy system, including ending the gas-electricity price link, and reduce its dependency on fossil fuels and exposure to volatile gas prices.

Global energy prices have skyrocketed this year, and UK natural gas and electricity have risen sharply, particularly after Russia's invasion of Ukraine which has led to many European countries trying to reduce reliance on Russian pipeline gas and seek cheaper alternatives.

The bill will help drive 100 billion pounds ($119 billion) of private sector investment by 2030 into industries to diversify Britain's energy supply, including hydrogen and offshore wind, which could help lower costs as a 16% decrease in bills in April is anticipated, and create around 480,000 jobs by the end of the decade, the government said.

"We’re going to slash red tape, get investment into the UK, and grab as much global market share as possible in new technologies to make this plan a reality," Business and Energy Secretary Kwasi Kwarteng, amid high winter energy costs, said in a statement.

The bill will establish a new independent system operator to coordinate and plan Britain's energy system, while MPs move to restrict prices for gas and electricity through oversight.

It will also enable the extension of a cap on retail energy prices beyond 2023, with the price cap cost under scrutiny, which limits the amount suppliers can charge for each unit of gas and electricity.

The bill will also enable the secretary of state to prevent potential disruptions to the downstream oil sector due to industrial action or malicious protests, the government added.

 

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Global CO2 emissions 'flatlined' in 2019, says IEA

2019 Global CO2 Emissions stayed flat, IEA reports, as renewable energy growth, wind and solar deployment, nuclear output, and coal-to-gas switching in advanced economies offset increases elsewhere, supporting climate goals and clean energy transitions.

 

Key Points

33 gigatonnes, unchanged YoY, as advanced economies cut power emissions via renewables, gas, and nuclear.

✅ IEA reports emissions flat at 33 Gt despite 2.9% GDP growth

✅ Advanced economies cut power-sector CO2 via wind, solar, gas

✅ Nuclear restarts and mild weather aided reductions

 

Despite widespread expectations of another increase, global energy-related CO2 emissions stopped growing in 2019, according to International Energy Agency (IEA) data released today. After two years of growth, global emissions were unchanged at 33 gigatonnes in 2019, a notable marker in the global energy transition narrative even as the world economy expanded by 2.9%.

This was primarily due to declining emissions from electricity generation in advanced economies, thanks to the expanding role of renewable sources (mainly wind and solar across many markets), fuel switching from coal to natural gas, and higher nuclear power generation, the Paris-based organisation says in the report.

"We now need to work hard to make sure that 2019 is remembered as a definitive peak in global emissions, not just another pause in growth," said Fatih Birol, the IEA's executive director. "We have the energy technologies to do this, and we have to make use of them all."

Higher nuclear power generation in advanced economies, particularly in Japan and South Korea, avoided over 50 Mt of CO2 emissions. Other factors included milder weather in several countries, and slower economic growth in some emerging markets. In China, emissions rose but were tempered by slower economic growth and higher output from low-carbon sources of electricity. Renewables continued to expand in China, and 2019 was also the first full year of operation for seven large-scale nuclear reactors in the country.

A significant decrease in emissions in advanced economies in 2019 offset continued growth elsewhere. The USA recorded the largest emissions decline on a country basis, with a fall of 140 million tonnes, or 2.9%. US emissions are now down by almost 1 gigatonne from their peak in 2000. Emissions in the European Union fell by 160 million tonnes, or 5%, in 2019 driven by reductions in the power sector as electricity producers move away from coal in the generation mix. Japan’s emissions fell by 45 million tonnes, or around 4%, the fastest pace of decline since 2009, as output from recently restarted nuclear reactors increased.

Emissions in the rest of the world grew by close to 400 million tonnes in 2019, with almost 80% of the increase coming from countries in Asia where coal-fired power generation continued to rise, and in Australia emissions rose 2% due to electricity and transport. Coal-fired power generation in advanced economies declined by nearly 15%, reflecting a sharp fall in coal-fired electricity across multiple markets, as a result of growth in renewables, coal-to-gas switching, a rise in nuclear power and weaker electricity demand.

The IEA will publish a World Energy Outlook Special Report in June that will map out how to cut global energy-related carbon emissions by one-third by 2030 and put the world on track for longer-term climate goals, a pathway that, in Canada, will require more electricity to hit net-zero. It will also hold an IEA Clean Energy Transitions Summit in Paris on 9 July, bringing together key government ministers, CEOs, investors and other major stakeholders.

Birol will discuss the results published today tomorrow at an IEA Speaker Series event at its headquarters with energy and climate ministers from Poland, which hosted COP24 in Katowice; Spain, which hosted COP25 in Madrid; and the UK, which will host COP26 in Glasgow this year, as greenhouse gas concentrations continue to break records worldwide.

 

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Soaring Electricity And Coal Use Are Proving Once Again, Roger Pielke Jr's "Iron Law Of Climate"

Global Electricity Demand Surge underscores rising coal generation, lagging renewables deployment, and escalating emissions, as nations prioritize reliable power; nuclear energy and grid decarbonization emerge as pivotal solutions to the electricity transition.

 

Key Points

A rapid post-lockdown rise in power consumption, outpacing renewables growth and driving higher coal use and emissions.

✅ Coal generation rises faster than wind and solar additions

✅ Emissions increase as economies prioritize reliable baseload power

✅ Nuclear power touted for rapid grid decarbonization

 

By Robert Bryce

As the Covid lockdowns are easing, the global economy is recovering and that recovery is fueling blistering growth in electricity use. The latest data from Ember, the London-based “climate and energy think tank focused on accelerating the global electricity transition,” show that global power demand soared by about 5% in the first half of 2021. That’s faster growth than was happening back in 2018 when electricity use was increasing by about 4% per year.

The numbers from Ember also show that despite lots of talk about the urgent need to reduce greenhouse gas emissions, coal demand for power generation continues to grow and emissions from the electric sector continue to grow: up by 5% over the first half of 2019. In addition, they show that while about half of the growth in electricity demand was met by wind and solar, as low-emissions sources are set to cover almost all new demand over the next three years, overall growth in electricity use is still outstripping the growth in renewables. 

The soaring use of electricity, and increasing emissions from power generation confirm the sage wisdom of Rasheed Wallace, the volatile former power forward with the Detroit Pistons and other NBA teams, and now an assistant coach at the  University of Memphis, who coined the catchphrase: “Ball don’t lie.” If Wallace or one of his teammates was called for a foul during a basketball game that he thought was undeserved, and the opposing player missed the ensuing free throws, Wallace would often holler, “ball don’t lie,” as if the basketball itself was pronouncing judgment on the referee’s errant call. 

I often think about Wallace’s catchphrase while looking at global energy and power trends and substitute my own phrase: numbers don’t lie.

Over the past few weeks Ember, BP, and the International Energy Agency have all published reports which come to the same two conclusions: that countries all around the world — and China's electricity sector in particular — are doing whatever they need to do to get the electricity they need to grow their economies. Second, they are using lots of coal to get that juice. 

As I discuss in my recent book, A Question of Power: Electricity and the Wealth of Nations, Electricity is the world’s most important and fastest-growing form of energy. The Ember data proves that. At a growth rate of 5%, global electricity use will double in about 14 years, and as surging electricity demand is putting power systems under strain around the world, the electricity sector also accounts for the biggest single share of global carbon dioxide emissions: about 25 percent. Thus, if we are to have any hope of cutting global emissions, the electricity sector is pivotal. Further, the soaring use of electricity shows that low-income people and countries around the world are not content to stay in the dark. They want to live high-energy lives with access to all the electronic riches that we take for granted.  

 Ember’s data clearly shows that decarbonizing the global electric grid will require finding a substitute for coal. Indeed, coal use may be plummeting in the U.S. and western Europe, where U.S. electricity consumption has been declining, but over the past two years, several developing countries including Mongolia, China, Bangladesh, Vietnam, Kazakhstan, Pakistan, and India, all boosted their use of coal. This was particularly obvious in China, where, between the first half of 2019 and the first half of 2021, electricity demand jumped by about 14%. Of that increase, coal-fired generation provided roughly twice as much new electricity as wind and solar combined. In Pakistan, electricity demand jumped by about 7%, and coal provided more than three times as much new electricity as nuclear and about three times as much as hydro. (Wind and solar did not grow at all in Pakistan over that period.) 

Hate coal all you like, but its century-long persistence in power generation proves its importance. That persistence proves that climate change concerns are not as important to most consumers and policymakers as reliable electricity. In 2010, Roger Pielke Jr. dubbed this the Iron Law of Climate Policy which says “When policies on emissions reductions collide with policies focused on economic growth, economic growth will win out every time.” Pielke elaborated on that point, saying the Iron Law is a “boundary condition on policy design that is every bit as limiting as is the second law of thermodynamics, and it holds everywhere around the world, in rich and poor countries alike. It says that even if people are willing to bear some costs to reduce emissions (and experience shows that they are), they are willing to go only so far.”

Over the past five years, I’ve written a book about electricity, co-produced a feature-length documentary film about it (Juice: How Electricity Explains the World), and launched a podcast that focuses largely on energy and power. I’m convinced that Pielke’s claim is exactly right and should be extended to electricity and dubbed the Iron Law of Electricity which says, “when forced to choose between dirty electricity and no electricity, people will choose dirty electricity every time.” I saw this at work in electricity-poor places all over the world, including India, Lebanon, and Puerto Rico. 

Pielke, a professor at the University of Colorado as well as a highly regarded author on the politics of climate change and sports governance, has since elaborated on the Iron Law. During an interview in Juice, he explained it thusly: “The Iron Law says we’re not going to reduce emissions by willingly getting poor. Rich people aren't going to want to get poorer, poor people aren't going to want to get poorer.” He continued, “If there is one thing that we can count on it is that policymakers will be rewarded by populations if they make people wealthier. We're doing everything we can to try to get richer as nations, as communities, as individuals. If we want to reduce emissions, we really have only one place to go and that's technology.”

Pielke’s point reminds me of another of my favorite energy analysts, Robert Rapier, who made a salient point in his Forbes column last week. He wrote, “Despite the blistering growth rate of renewables, it’s important to keep in mind that overall global energy consumption is growing. Even though global renewable energy consumption has increased by about 21 exajoules in the past decade, overall energy consumption has increased by 51 exajoules. Increased fossil fuel consumption made up most of this growth, with every category of fossil fuels showing increased consumption over the decade.” 

The punchline here – despite my tangential reference to Rasheed Wallace — is obvious: The claims that massive reductions in global carbon dioxide emissions must happen soon are being mocked by the numbers. Countries around the world are acting in their interest, particularly when it comes to their electricity needs and that is resulting in big increases in emissions. As Ember concludes in their report, wind and solar are growing, and some analyses suggest renewables could eclipse coal by 2025, but the “electricity transition” is “not happening fast enough.”

Ember explains that in the first half of 2021, wind and solar output exceeded the output of the world’s nuclear reactors for the first time. It also noted that over the past two years, “Nuclear generation fell by 2% compared to pre-pandemic levels, as closures at older plants across the OECD, especially amid debates over European nuclear trends, exceeded the new capacity in China.” While that may cheer anti-nuclear activists at groups like Greenpeace and Friends of the Earth, the truth is obvious: the only way – repeat, the only way – the electric sector will achieve significant reductions in carbon dioxide emissions is if we can replace lots of coal-fired generation with nuclear reactors and do so in relatively short order, meaning the next decade or so. Renewables are politically popular and they are growing, but they cannot, will not, be able to match the soaring demand for the electricity that is needed to sustain modern economies and bring developing countries out of the darkness and into modernity. 

Countries like China, Vietnam, India, and others need an alternative to coal for power generation. They need new nuclear reactors that are smaller, safer, and cheaper than the existing designs. And they need it soon. I will be writing about those reactors in future columns.

 

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Alberta Faces Challenges with Solar Energy Expansion

Alberta Solar Energy Expansion confronts high installation costs, grid integration and storage needs, and environmental impact, while incentives, infrastructure upgrades, and renewable targets aim to balance reliability, land use, and emissions reductions provincewide.

 

Key Points

Alberta Solar Energy Expansion is growth in solar tempered by costs, grid limits, environmental impact, and incentives.

✅ High capex and financing challenge utility-scale projects

✅ Grid integration needs storage, transmission, and flexibility

✅ Site selection must mitigate land and wildlife impacts

 

Alberta's push towards expanding solar power is encountering significant financial and environmental hurdles. The province's ambitious plans to boost solar power generation have been met with both enthusiasm and skepticism as stakeholders grapple with the complexities of integrating large-scale solar projects into the existing energy framework.

The Alberta government has been actively promoting solar energy as part of its strategy to diversify the energy mix in a province that is a powerhouse for both green energy and fossil fuels today and reduce greenhouse gas emissions. Recent developments have highlighted the potential of solar power to contribute to Alberta's clean energy goals. However, the path forward is fraught with challenges related to costs, environmental impact, and infrastructure needs.

One of the primary issues facing the solar energy sector in Alberta is the high cost of solar installations. Despite decreasing costs for solar technology in recent years, the upfront investment required for large-scale solar farms remains substantial, even as some facilities have been contracted at lower cost than natural gas in Alberta today. This financial barrier has led to concerns about the economic viability of solar projects and their ability to compete with other forms of energy, such as natural gas and oil, which have traditionally dominated Alberta's energy landscape.

Additionally, there are environmental concerns associated with the development of solar farms. While solar energy is considered a clean and renewable resource, the construction of large solar installations can have environmental implications. These include potential impacts on local wildlife habitats, land use changes, where approaches like agrivoltaics can co-locate farming and solar, and the ecological effects of large-scale land clearing. As solar projects expand, balancing the benefits of renewable energy with the need to protect natural ecosystems becomes increasingly important.

Another significant challenge is the integration of solar power into Alberta's existing energy grid. Solar energy production is variable and dependent on weather conditions, especially with Alberta's limited hydro capacity for flexibility, which can create difficulties in maintaining a stable and reliable energy supply. The need for infrastructure upgrades and energy storage solutions is crucial to address these challenges and ensure that solar power can be effectively utilized alongside other energy sources.

Despite these challenges, the Alberta government remains committed to advancing solar energy as a key component of its renewable energy strategy. Recent initiatives include financial incentives and support programs aimed at encouraging investment in solar projects and supporting a renewable energy surge that could power thousands of jobs across Alberta today. These measures are designed to help offset the high costs associated with solar installations and make the technology more accessible to businesses and homeowners alike.

Local communities and businesses are also playing a role in the growth of solar energy in Alberta. Many are exploring opportunities to invest in solar power as a means of reducing energy costs and supporting sustainability efforts and, increasingly, to sell renewable energy into the market as demand grows. These smaller-scale projects contribute to the overall expansion of solar energy and demonstrate the potential for widespread adoption across the province.

The Alberta government has also been working to address the environmental concerns associated with solar energy development. Efforts are underway to implement best practices for minimizing environmental impacts and ensuring that solar projects are developed in an environmentally responsible manner. This includes conducting environmental assessments and working with stakeholders to address potential issues before projects are approved and built.

In summary, while Alberta's solar energy initiatives hold promise for advancing the province's clean energy goals, they are also met with significant financial and environmental challenges. Addressing these issues will be crucial to the successful expansion of solar power in Alberta. The government's ongoing efforts to support solar projects through incentives and infrastructure improvements, coupled with responsible environmental practices, will play a key role in determining the future of solar energy in the province.

 

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Criminals posing as Toronto Hydro are sending out fraudulent messages

Toronto Hydro Scam Warning urges customers to spot phishing emails, fraudulent texts, fake bills, and door-to-door threats demanding bitcoin or prepaid cards, with disconnection threats; report scams to the Canadian Anti-Fraud Centre.

 

Key Points

Advisory on phishing, fake bills, and payment scams posing as Toronto Hydro, with steps to avoid fraud and report.

✅ Hang up suspicious calls; never pay via bitcoin or prepaid cards.

✅ Do not click links in emails or texts; compare bills and account numbers.

✅ Report fraud to the Canadian Anti-Fraud Centre: 1-888-495-8501.

 

Toronto Hydro has sent out a notice that criminals posing as Toronto Hydro are sending out fraudulent texts, letters and emails, similar to a recent BC Hydro scam reported in British Columbia.

The warning comes in a tweet, along with suggestions on how to protect yourself from fraud, especially as policy debates like an NDP public hydro plan can generate confusing messages.

According to Toronto Hydro, fraudsters are contacting people by phone, text, email, fake electricity bills, and even travelling door-to-door.

They threaten to disconnect the power unless an immediate payment is made, even though legitimate utilities must follow proper disconnection notices processes. The website states that in some cases, criminals request payment via pre-paid credit card or bitcoin.

It’s written on the website that Toronto Hydro does not accept these methods of payment, and they do not threaten to immediately disconnect power, a reminder that stories about power theft abroad are not a model for local billing.

If you suspect you are being targeted, you should immediately hang up any suspicious phone calls. Don’t click on any links in emails or texts asking you to accept electronic transfers, as scammers may impersonate well-known utilities during high-profile news such as Hydro One profit changes to appear credible.

Avoid sharing any personal information over the phone or in-person, and do not make any payments related to Smart Meter Deposits, as this fee does not exist and rate-setting is overseen by the Ontario Energy Board in Ontario.

And remember to always compare bills to previous ones, including the amount and account number, since major accounting decisions like a BC Hydro deferral report can fuel confusing narratives.

To report fraudulent activity, please contact:
Canadian Anti-Fraud Centre at 1-888-495-8501; quote file number 844396

 

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