Energy efficiency kits go to First Nations

Income Graduated Fixed Charge aligns CPUC billing with utility fixed costs, lowers usage rates, supports electrification, and shifts California investor-owned utilities' electric bills by income, with CARE and Climate Credit offsets for low-income households.

Key Points

A CPUC proposal: an income-based monthly fixed fee with lower usage rates to align costs and aid low-income customers.

✅ Income-tiered fixed fees: $0-$42; CARE: $14-$22, by utility territory

✅ Usage rates drop 16%-22% to support electrification and cost-reflective billing

✅ Lowest-income save ~$10-$20; some higher earners pay ~$10+ more monthly

The Public Advocates Office (PAO) for the California Public Utilities Commission (CPUC) has proposed adding a monthly income-based fixed charge on electric utility bills based on income level.  

The rate change is designed to lower bills for the lowest-income residents while aligning billing more directly with utility costs. 

PAO’s recommendation for the Income Graduated Fixed Charge places fees between $22 and $42 per month in the three major investor-owned utilities’ territories, including an SDG&E minimum charge debate under way, for customers not enrolled in the California Alternative Rates for Energy (CARE) program. As seen below, CARE customers would be charged between $14 per month and $22 a month, depending on income level and territory.

For households earning $50,000 or less per year, the fixed charge would be $0, but only if the California Climate Credit is applied to offset the fixed cost.

Meanwhile, usage-based electricity rates are lowered in the PAO proposal, part of major changes to electric bills statewide. Average rates would be reduced between 16% to 22% for the three major investor-owned utilities.

The lowest-income bracket of Californians is expected to save roughly $10 to $20 a month under the proposal, while middle-income customers may see costs rise by about $20 a month, even as lawmakers seek to overturn income-based charges in Sacramento.

“We anticipate the vast majority of low-income customers ($50,000 or less per year) will have their monthly bills decrease by $10 or more, and a small proportion of the highest income earners ($100,000+ per year) will see their monthly bills rise by $10 or more,” said the PAO.

The charges are an effort to help suppress ever-increasing electricity generation and transmission rates, which are among the highest in the country, with soaring electricity prices reported across California. Rates are expected to rise sharply as wildfire mitigation efforts are implemented by the utilities found at fault for their origin.

“We are very concerned. However, we do not see the increases stopping at this point,” Linda Serizawa, deputy director for energy, PAO, told pv magazine. “We think the pace and scale of the [rate] increases is growing faster than we would have anticipated for several years now.”

Consumer advocates and regulators face calls for action on surging electricity bills across the state.

The proposed changes are also meant to more directly couple billing with the fixed charges that utilities incur, as California considers revamping electricity rates to clean the grid. For example, activities like power line maintenance, energy efficiency programs, and wildfire prevention are not expected to vary with usage, so these activities would be funded through a fixed charge.

Michael Campbell of the PAO’s customer programs team, and leader of the proposed program, likened paying for grid enhancements and other social programs with utility rate increases to “paying for food stamps by taxing food.” Instead, a fixed charge would cover these costs.

PAO said the move to lower rates for usage should help encourage electrification as California moves to replace heating and cooling, appliances, and gas combustion cars with electrified counterparts. In addition, lower rates mean the cost burden of running these devices is improved.

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White Pines Project cancellation highlights Ontario's wind farm contract dispute in Prince Edward County, involving IESO approvals, Progressive Conservatives' legislation, potential court action, and costs to ratepayers amid green energy policy shifts.

Key Points

The termination effort for Ontario's White Pines wind farm contract, triggering legal, legislative, and cost disputes.

✅ Contract with IESO dates to 2009; final approval during election

✅ PCs seek legislation insulating taxpayers from litigation

✅ Cancellation could exceed $100M; cost impact on ratepayers

Cancelling an eastern Ontario green energy project that has been under development for nearly a decade could cost more than $100 million, the president of the company said Wednesday, warning that the dispute could be headed to the courts.

Ontario's governing Progressive Conservatives said this week that one of their first priorities during the legislature's summer sitting would be to cancel the contract for the White Pines Project in Prince Edward County.

Ian MacRae, president of WPD Canada, the company behind the project, said he was stunned by the news given that the project is weeks away from completion.

"What our lawyers are telling us is we have a completely valid contract that we've had since 2009 with the (Independent Electricity System Operator). ... There's no good reason for the government to breach that contract," he said.

The government has also not reached out to discuss the cancellation, he said. Meanwhile, construction on the site is in full swing, he said.

"Over the last couple weeks we've had an average of 100 people on site every day," he said. "The footprint of the project is 100 per cent in. So, all the access roads, the concrete for the base foundations, much of the electrical infrastructure. The sub-station is nearing completion."

The project includes nine wind turbines meant to produce enough electricity to power just over 3,000 homes annually, even as Ontario looks to build on an electricity deal with Quebec for additional supply. All of the turbines are expected to be installed over the next three weeks, with testing scheduled for the following month.

MacRae couldn't say for certain who would have to pay for the cancellation, electricity ratepayers or taxpayers.

"Somehow that money would come from IESO and it would be my assumption that would end up somehow on the ratepayers, despite legislation to lower electricity rates now in place," he said. "We just need to see what the government has in mind and who will foot the bill."

Progressive Conservative house leader Todd Smith, who represents the riding where the project is being built, said the legislation to cancel the project will also insulate taxpayers from domestic litigation over the dismantling of green energy projects.

"This is something that the people of Prince Edward County have been fighting ... for seven years," he said. "This shouldn't have come as a surprise to anybody that this was at the top of the agenda for the incoming government, which has also eyed energy independence in recent decisions."

Smith questioned why Ontario's Independent Electricity System Operator gave the final approval for the project during the spring election campaign.

"There's a lot of questions about how this ever got greenlighted in the first place," he said. "This project was granted its notice to proceed two days into the election campaign ... when (the IESO) should have been in the caretaker mode."

Terry Young, the IESO's vice president of policy, engagement and innovation, said the agency could not comment because of the pending introduction of legislation to cancel the deal, following a recent auditor-regulator dispute that drew attention to oversight.

NDP Leader Andrea Horwath said the new Tory government is behaving like the previous Liberal government by cancelling energy projects and tearing up contracts amid ongoing debates over Ontario's hydro mess and affordability. She likened the Tory plan to the Liberal gas plant scandal that saw the government relocate two plants at a substantial cost to taxpayers.

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Yukon Renewable Energy Funding backs wind turbines, grid-scale battery storage, and transmission line upgrades, cutting diesel dependence, lowering greenhouse gas emissions, and strengthening Yukon Energy's isolated grid for remote communities, local jobs, and future growth.

Key Points

Federal support for Yukon projects adding wind, battery storage, and grid upgrades to cut diesel use and emissions.

✅ Three 100 kW wind turbines will power Destruction Bay.

✅ 8 MW battery storage smooths peaks and reduces diesel.

✅ Mayo-McQuesten 138 kV line upgrade boosts reliability.

Kluane First Nation in Yukon will receive a total of $3.1 million in funding from the federal government to install and operate wind turbines that will help reduce the community’s diesel reliance.

According to a release, the community will integrate three 100-kilowatt turbines in Destruction Bay, Yukon, providing a renewable energy source for their local power grid that will reduce greenhouse gas emissions and create local jobs in the community.

A $2-million investment from Natural Resources Canada came from the Clean Energy for Rural and Remote Communities Program, part of the Government of Canada’s Investing in Canada infrastructure plan, which supports green energy solutions across jurisdictions. Crown-Indigenous Relations’ and Northern Affairs Canada also contributed a $1.1-million investment from the Northern REACHE Program.

Also, the Government of Canada announced more than $39.2 million in funding for two Yukon Energy projects that will increase the reliability of Yukon’s electrical grid, including exploration of a potential connection to the B.C. grid to bolster resiliency, and help build the robust energy system needed to support future growth. The investment comes from the government’s Green Infrastructure Stream (GIS) of the Investing in Canada infrastructure plan.

Project 1: Grid-scale battery storage

The federal government is investing $16.5 million in Yukon Energy’s construction of a new battery storage system in Yukon. Once completed, the 8 MW battery will be the largest grid-connected battery in the North, and one of the largest in Canada, alongside major Ontario battery projects underway.

The new battery is a critical investment in Yukon Energy’s ability to meet growing demands for power and securing Yukon’s energy future. As an isolated grid, one of the largest challenges Yukon Energy faces is meeting peak demands for power during winter months, as electrification grows with EV adoption in the N.W.T. and beyond.

When complete, the new system will store excess electricity generated during off-peak periods, complementing emerging vehicle-to-grid integration approaches, and provide Yukoners with access to more power during peak periods. This new energy storage system will create a more reliable power supply and help reduce the territory’s reliance on diesel fuel. Over the 20-year life of project, the new battery is expected to reduce carbon emissions in Yukon by more than 20,000 tonnes.

A location for the new battery energy storage system has not been identified. Yukon Energy will begin permitting of the project in 2020 with construction targeted to be complete by mid-2023.

Project 2: Replacing and upgrading the Mayo to McQuesten Transmission Line

Yukon Energy has received $22.7 million in federal funding to proceed with Stage 1 of the Stewart to Keno City Transmission Project – replacing and upgrading the 65 year-old transmission line between Mayo and McQuesten. The project also includes the addition of system protection equipment at the Stewart Crossing South substation. The Yukon government, through the Yukon Development Corporation, has already provided $3.5 million towards planning for the project.

Replacing the Mayo to McQuesten transmission line is critical to Yukon Energy’s ability to deliver safe and reliable electricity to customers in the Mayo and Keno regions, mirroring broader regional transmission initiatives that enhance grid resilience, and to support economic growth in Yukon. The transmission line has reached end-of-life and become increasingly unreliable for customers in the area.

The First Nation of Na-Cho Nyak Dun has expressed their support of this project. The project has also been approved by the Yukon Environmental and Socio-Economic Assessment Board.

Yukon Energy will begin replacing and upgrading the 31 km transmission line between Mayo and McQuesten in 2020. Construction is expected to be complete in late 2020. When finished, the new 138 kV transmission line will provide more reliable electricity to customers in the Mayo and Keno regions and be equipped to support industrial growth and development in the area, including the Victoria Gold Mine, with renewable power from the Yukon grid.

Planning work for the remainder of the Stewart to Keno City Transmission Project has been completed. Yukon Energy continues to explore funding opportunities that are needed to proceed with other stages of the project.

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Nuclear decarbonization leverages low-carbon electricity, process heat, and hydrogen from advanced reactors and SMRs to electrify industry, buildings, and transport, supporting net-zero strategies and grid flexibility alongside renewables with dispatchable baseload capacity.

Key Points

Nuclear decarbonization uses reactors to supply low-carbon power, heat, and hydrogen, cutting emissions across industry.

✅ Advanced reactors and SMRs enable high-temperature process heat

✅ Nuclear-powered electrolysis and HTSE produce low-carbon hydrogen

✅ District heating from reactors reduces pollution and coal use

By Dr Henri Paillere, Head of the Planning and Economics Studies Section of the IAEA

Decarbonising the power sector will not be sufficient to achieving net-zero emissions, with assessments indicating nuclear may be essential across sectors. We also need to decarbonise the non-power sectors - transport, buildings and industry - which represent 60% of emissions from the energy sector today. The way to do that is: electrification with low-carbon electricity as much as possible; using low-carbon heat sources; and using low-carbon fuels, including hydrogen, produced from clean electricity.
The International Energy Agency (IEA) says that: 'Almost half of the emissions reductions needed to reach net zero by 2050 will need to come from technologies that have not reached the market today.' So there is a need to innovate and push the research, development and deployment of technologies. That includes nuclear beyond electricity.

Today, most of the scenario projections see nuclear's role ONLY in the power sector, despite ongoing debates over whether nuclear power is in decline globally, but increased electrification will require more low-carbon electricity, so potentially more nuclear. Nuclear energy is also a source of low-carbon heat, and could also be used to produce low-carbon fuels such as hydrogen. This is a virtually untapped potential.

There is an opportunity for the nuclear energy sector - from advanced reactors, next-gen nuclear small modular reactors, and non-power applications - but it requires a level playing field, not only in terms of financing today's technologies, but also in terms of promoting innovation and supporting research up to market deployment. And of course technology readiness and economics will be key to their success.

On process heat and district heating, I would draw attention to the fact there have been decades of experience in nuclear district heating. Not well spread, but experience nonetheless, in Russia, Hungary and Switzerland. Last year, we had two new projects. One floating nuclear power plant in Russia (Akademik Lomonosov), which provides not only electricity but district heating to the region of Pevek where it is connected. And in China, the Haiyang nuclear power plant (AP1000 technology) has started delivering commercial district heating. In China, there is an additional motivation to reducing emissions, namely to cut air pollution because in northern China a lot of the heating in winter is provided by coal-fired boilers. By going nuclear with district heating they are therefore cutting down on this pollution and helping with reducing carbon emissions as well. And Poland is looking at high-temperature reactors to replace its fleet of coal-fired boilers and so that's a technology that could also be a game-changer on the industry side.

There have also been decades of research into the production of hydrogen using nuclear energy, but no real deployment. Now, from a climate point of view, there is a clear drive to find substitute fuels for the hydrocarbon fuels that we use today, and multiple new nuclear stations are seen by industry leaders as necessary to meet net-zero targets. In the near term, we will be able to produce hydrogen with electrolysis using low-carbon electricity, from renewables and nuclear. But the cheapest source of low-carbon power is from the long-term operation of existing nuclear power plants which, combined with their high capacity factors, can give the cheapest low-carbon hydrogen of all.

In the mid to long term, there is research on-going with processes that are more efficient than low-temperature electrolysis, which is high temperature steam electrolysis or thermal splitting of water. These may offer higher efficiencies and effectiveness but they also require advanced reactors that are still under development. Demonstration projects are being considered in several countries and we at the IAEA are developing a publication that looks into the business opportunities for nuclear production of hydrogen from existing reactors. In some countries, there is a need to boost the economics of the existing fleet, especially in the electricity systems where you have low or even negative market prices for electricity. So, we are looking at other products that have higher values to improve the competitiveness of existing nuclear power plants.

The future means not only looking at electricity, but also at industry and transport, and so integrated energy systems. Electricity will be the main workhorse of our global decarbonisation effort, but through heat and hydrogen. How you model this is the object of a lot of research work being done by different institutes and we at the IAEA are developing some modelling capabilities with the objective of optimising low-carbon emissions and overall costs.

This is just a picture of what the future might look like: a low-carbon power system with nuclear lightwater reactors (large reactors, small modular reactors and fast reactors) drawing on the green industrial revolution reactor waves in planning; solar, wind, anything that produces low-carbon electricity that can be used to electrify industry, transport, and the heating and cooling of buildings. But we know there is a need for high-temperature process steam that electricity cannot bring but which can be delivered directly by high-temperature reactors. And there are a number of ways of producing low-carbon hydrogen. The beauty of hydrogen is that it can be stored and it could possibly be injected into gas networks that could be run in the future on 100% hydrogen, and this could be converted back into electricity.

So, for decarbonising power, there are many options - nuclear, hydro, variable renewables, with renewables poised to surpass coal in global generation, and fossil with carbon capture and storage - and it's up to countries and industries to invest in the ones they prefer. We find that nuclear can actually reduce the overall cost of systems due to its dispatchability and the fact that variable renewables have a cost because of their intermittency. There is a need for appropriate market designs and the role of governments to encourage investments in nuclear.

Decarbonising other sectors will be as important as decarbonising electricity, from ways to produce low-carbon heat and low-carbon hydrogen. It's not so obvious who will be the clear winners, but I would say that since nuclear can produce all three low-carbon vectors - electricity, heat and hydrogen - it should have the advantage.
We at the IAEA will be organising a webinar next month with the IEA looking at long-term nuclear projections in a net-zero world, building on IAEA analysis on COVID-19 and low-carbon electricity insights. That will be our contribution from the point of view of nuclear to the IEA's special report on roadmaps to net zero that it will publish in May.

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Wall Street Fossil Fuel Pivot signals banks reassessing ESG, net-zero, and decarbonization goals, reviving oil, gas, and coal financing while recalibrating clean energy exposure amid policy shifts, regulatory rollbacks, and investment risk realignment.

Key Points

A shift as major U.S. banks ease ESG limits to fund oil, gas, coal while rebalancing alongside renewables.

✅ Banks revisit lending to oil, gas, and coal after policy shifts.

✅ ESG and net-zero commitments face reassessment amid returns.

✅ Renewables compete for capital as risk models are updated.

The global energy finance sector, worth a staggering $1.4 trillion, is undergoing a significant transformation, largely due to former President Donald Trump's renewed support for the oil, gas, and coal industries. Wall Street, which had previously aligned itself with global climate initiatives and the energy transition and net-zero goals, is now reassessing its strategy and pivoting toward a more fossil-fuel-friendly stance.

This shift represents a major change from the earlier stance, where many of the largest U.S. banks and financial institutions took a firm stance on decarbonization push, including limiting their exposure to fossil-fuel projects. Just a few years ago, these institutions were vocal supporters of the global push for a sustainable future, with many committing to support clean energy solutions and abandon investments in high-carbon energy sources.

However, with the change in administration and the resurgence of support for traditional energy sectors under Trump’s policies, these same banks are now rethinking their strategies. Financial institutions are increasingly discussing the possibility of lifting long-standing restrictions that limited their investments in controversial fossil-fuel projects, including coal mining, where emissions drop as coal declines, and offshore drilling. The change reflects a broader realignment within the energy finance sector, with Wall Street reexamining its role in shaping the future of energy.

One of the most significant developments is the Biden administration’s policy reversal, which emphasized reducing the U.S. carbon footprint in favor of carbon-free electricity strategies. Under Trump, however, there has been a renewed focus on supporting the traditional energy sectors. His administration has pushed to reduce regulatory burdens on fossil-fuel companies, particularly oil and gas, while simultaneously reintroducing favorable tax incentives for the coal and gas industries. This is a stark contrast to the Biden administration's efforts to incentivize the transition toward renewable energy and zero-emissions goals.

Trump's policies have, in effect, sent a strong signal to financial markets that the fossil-fuel industry could see a resurgence. U.S. banks, which had previously distanced themselves from financing oil and gas ventures due to the pressure from environmental activists and ESG (Environmental, Social, and Governance) investors, as seen in investor pressure on Duke Energy, are now reconsidering their positions. Major players like JPMorgan Chase and Goldman Sachs are reportedly having internal discussions about revisiting financing for energy projects that involve high carbon emissions, including controversial oil extraction and gas drilling initiatives.

The implications of this shift are far-reaching. In the past, a growing number of institutional investors had embraced ESG principles, with the goal of supporting the transition to renewable energy sources. However, Trump’s pro-fossil fuel stance appears to be emboldening Wall Street’s biggest players to rethink their commitment to green investing. Some are now advocating for a “balanced approach” that would allow for continued investment in traditional energy sectors, while also acknowledging the growing importance of renewable energy investments, a trend echoed by European oil majors going electric in recent years.

This reversal has led to confusion among investors and analysts, who are now grappling with how to navigate a rapidly changing landscape. Wall Street's newfound support for the fossil-fuel industry comes amid a backdrop of global concerns about climate change. Many investors, who had previously embraced policies aimed at curbing the effects of global warming, are now finding it harder to reconcile their environmental commitments with the shift toward fossil-fuel-heavy portfolios. The reemergence of fossil-fuel-friendly policies is forcing institutional investors to rethink their long-term strategies.

The consequences of this policy shift are also being felt by renewable energy companies, which now face increased competition for investment dollars from traditional energy sectors. The shift towards oil and gas projects has made it more challenging for renewable energy companies to attract the same level of financial backing, even as demand for clean energy continues to rise and as doubling electricity investment becomes a key policy call. This could result in a deceleration of renewable energy projects, potentially delaying the progress needed to meet the world’s climate targets.

Despite this, some analysts remain optimistic that the long-term shift toward green energy is inevitable, even if fossil-fuel investments gain a temporary boost. As the world continues to grapple with the effects of climate change, and as technological advancements in clean energy continue to reduce costs, the transition to renewables is likely to persist, regardless of the political climate.

The shift in Wall Street’s approach to energy investments, spurred by Trump’s pro-fossil fuel policies, is reshaping the $1.4 trillion global energy finance market. While the pivot towards fossil fuels may offer short-term gains, the long-term trajectory for energy markets remains firmly in the direction of renewables. The next few years will be crucial in determining whether financial institutions can balance the demand for short-term profitability with their long-term environmental responsibilities.

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Nunavut electricity rate increase sees QEC raise domestic electricity rates 6.6% over two years, affecting customer rates, base rates, subsidies, and kWh overage charges across communities, with public housing exempt and territory-wide pricing denied.

Key Points

A 6.6% QEC hike over 2018-2019, affecting customer rates, subsidies, and kWh overage; public housing remains exempt.

✅ 3.3% on May 1, 2018; 3.3% on Apr 1, 2019

✅ Subsidy caps: 1,000 kWh Oct-Mar; 700 kWh Apr-Sep

✅ Territory-wide base rate denied; public housing exempt

Ahead of the Nunavut government's approval of the general rate increase for the Qulliq Energy Corporation, many Nunavummiut wondered how the change would impact their electricity bills.

QEC's request for a 6.6-per-cent increase was approved by the government last week. The increase will be spread out over two years, a pattern similar to BC Hydro's two-year rate plan, with the first increase (3.3 per cent) effective May 1, 2018. The remaining 3.3 per cent will be applied on April 1, 2019.

Public housing units, however, are exempt from the government's increase altogether.

The power corporation also asked for a territory-wide rate, so every community would pay the same base rate (we'll go over specific terms in a minute if you're not familiar with them). But that request was denied, even as Manitoba Hydro scaled back increases next year, and QEC will now take the next two years reassessing each community's base rate.

#google#

So, what does this mean for your home's power bill? Well, there's a few things you need to know, which we'll get to in a second.

But in essence, as long as you don't go over the government-subsidized monthly electricity usage limit, you're paying an extra 3.61 cents per kilowatt hour (kWh).

To be clear, we're talking about non-government domestic rates — basically, private homeowners — and those living in a government-owned unit but pay for their own power.

The basics

First, some quick terminology. The "base rate" term we're going to use (and used above) in this story refers to the community rate. As in, what QEC charges customers in every community. The "customer rate" is the rate customers actually pay, after the government's subsidy.

The first thing you need to know is everyone in Nunavut starts off by paying the same customer rate, unlike jurisdictions using a price cap to limit spikes.

That's because the government subsidizes electricity costs, and that subsidy is different in every community, because the base rate is different.

For example, Iqaluit's new base rate after the 3.3 per cent increase (remember, the 6.6 per cent is being applied over two years) is 56.69 cents per kWh, while Kugaaruk's base rate rose to 112.34 cents per kWh. Those, by the way, are the territory's lowest and highest respective base rates.

However, customers in both Iqaluit and Kugaaruk will each now pay 28.35 cents per kWh because, remember, the government subsidizes the base rates in every community.

Now, remember earlier we mentioned a "government-subsidized monthly electricity usage limit?" That's where customers in various communities start to pay different amounts.

As simply as we can explain it, the government will only cover so much electricity usage in a month, in every household.

Between October and March, the government will subsidize the first 1,000 kilowatt hours, and only 700 kilowatt hours from April to September. QEC says the average Nunavut home will use about 500 kilowatt hours every month over the course of a year.

But if your household goes over that limit, you're at the mercy of your community's base rate for any extra electricity you use. Homes in Kugaaruk in December, for instance, will have to pay that 122.34 cents for every extra kilowatt hour it uses, while homes in Iqaluit only have to pay 56.69 cents per kWh for its extra electricity.

That's where many Nunavummiut have criticized the current rate structure, because smaller communities are paying more for their extra costs than larger communities.

QEC had hoped — as it had asked for — to change the structure so every community pays the same base rate. So regardless of if people go over their electricity usage limits for the government subsidy, everyone would pay the same overage rates.

But the government denied that request.

New rate is actually lower

The one thing we should highlight, however, is the new rate after the increase is actually lower than what customers were paying in 2014.

For the past seven months, customers have been getting power from QEC at a discount, whereas Newfoundland customers began paying for Muskrat Falls during the same period, to different effect.

That's because when QEC sets its rates, it does so based on global oil price forecasts. Since 2014, the price of oil worldwide has slumped, and so QEC was able to purchase it at less than it had anticipated.

When that happens, and QEC makes more than $1 million within a six month period thanks to the lower oil prices, it refunds the excess profits back to customers through a discount on electricity base rates — a mechanism similar to a lump-sum credit used elsewhere — the government subsidy, however, doesn't change so the savings are passed on directly to customers.

Now, the 6.6 per cent increase to electricity rates, is actually being applied to the discounted base rate from the last seven months.

So again, while customers are paying more than they have been for the last seven months, it's lower than what they were paying in 2014.

Lastly, to be clear, all the figures used in this story are only for domestic non-government rates. Commercial rates and changes have not been explored in this story, given the differences in subsidy and rate application.

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