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Muskrat Falls rate mitigation offsets Newfoundland Power's rate stabilization decrease as NL Hydro begins cost recovery; Public Utilities Board approval enables collections while Labrador-Island Link nears commissioning, stabilizing electricity rates despite megaproject delays, overruns.

Key Points

Muskrat Falls rate mitigation is NL Hydro's cost recovery via power rates to stabilize bills as commissioning nears.

✅ Offsets 6.4% decrease with a 6.1% rate increase

✅ About 6% now funds NL Hydro's rate mitigation

✅ Collections begin as Labrador-Island Link nears commissioning

With their July electricity bill, Newfoundland Power customers have begun paying for Muskrat Falls, though a lump-sum credit was also announced to offset costs and bills haven't significantly increased — yet.

In a July newsletter, Newfoundland Power said electricity bills were set to decrease by 6.4 per cent as part of the annual rate stabilization adjustment, which reflects the cost of electricity generation.

Instead, that decrease has been offset by a 6.1 increase in electricity rates so Newfoundland and Labrador Hydro can begin recovering the cost of Muskrat Falls, with a $5.2-billion federal package also underpinning the project, the $13-billion hydroelectric megaproject that is billions over budget and years behind schedule.

That means for residential customers, electricity rates will decrease to 12.346 cents per kilowatt, though the basic customer charge will go up slightly from $15.81 to $15.83. According to an N.L. Hydro spokesperson, about six per cent of electricity bills will now go toward what it calls a "rate mitigation fund." 

N.L. Hydro claims victory in Muskrat Falls arbitration dispute with Astaldi
Software troubles blamed for $260M Muskrat Falls cost increase, with N.L. power rates stable for now
The spokesperson said N.L. Hydro is expecting the rate increase to result in $43 million this year, according to a recent financial update from the energy corporation — a tiny fraction of the project's cost. 

N.L. Hydro asked the Public Utilities Board to approve the rate increase, a process similar to Nova Scotia's recent 14% approval by its regulator, in May. In a letter, Energy, Industry and Technology Minister Andrew Parsons supported the increase, though he asked N.L. Hydro to keep electricity rates "as close to current levels as possible. 

Province modifies order in council
Muskrat Falls is not yet fully online — largely due to software problems with the Labrador-Island Link transmission line — and an order in council dictated that ratepayers on the island of Newfoundland would not begin paying for the project until the project was fully commissioned. 

The provincial government modified that order in council so N.L. Hydro can begin collecting costs associated with Muskrat Falls once the project is "nearing" commissioning.

In June, N.L. Hydro said the project was expected to finally be completed by the end of the year.

In an interview with CBC News, Progressive Conservative interim leader David Brazil said the decision to begin recovering the cost of Muskrat Falls from consumers should have been delayed.

"There was an opportunity here for people to get some reprieve when it came to their electricity bills and this administration chose not to do that, not to help the people while they're struggling," he said.

In a statement, Parsons said reducing the rate was not an option, and would have resulted in increased borrowing costs for Muskrat Falls.

"Reducing the rate for one year to have it increase significantly the following year is not consistent with rate mitigation and also places an increased financial burden on taxpayers one year from now," Parsons said.

Decision 'reasonable': Consumer advocate
Brazil said his party didn't know the payments from Muskrat Falls would start in July, and criticized the government for not being more transparent.

A person wearing a blue shirt and black blazer stands outside on a lawn.
N.L. consumer advocate Dennis Browne says it makes sense to begin recouping the cost of Muskrat Falls. (Garrett Barry/CBC)
Newfoundland and Labrador consumer advocate Dennis Browne said the decision to begin collecting costs from consumers was "reasonable."

"We're into a financial hole due to Muskrat Falls, and what has happened is in order to stabilize rates, we have gone into rate stabilization efforts," he said.

In February, the provincial and federal governments signed a complex agreement to shield ratepayers aimed at softening the worst of the financial impact from Muskrat Falls. Browne noted even with the agreement, the provincial government will have to pay hundreds of millions in order to stabilize electricity rates.

"Muskrat Falls would cost us $0.23 a kilowatt, and that is out of the range of affordability for most people, and that's why we're into rate mitigation," he said. "This was part of a rate mitigation effort, and I accepted it as part of that."

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Electric Ireland Electricity Price Increase stems from rising wholesale costs as energy suppliers adjust tariffs. Customers face higher electricity bills, while gas remains unchanged; switching provider could deliver savings during winter.

Key Points

A 4% increase in Electric Ireland electricity prices from 1 Feb 2018, driven by wholesale costs; gas unchanged.

✅ 4% electricity rise effective 1 Feb 2018

✅ Increase attributed to rising wholesale energy costs

✅ Switching supplier may reduce bills and boost savings

ELECTRIC IRELAND has announced that it will increase its household electricity prices by 4% from 1 February 2018.

This comes just a week after both Bord Gáis Energy and SSE Airtricity announced increases in their gas and electricity prices, while national efforts to secure electricity supplies continue in parallel.

Electric Ireland has said that the electricity price increase is unavoidable due to the rising wholesale cost of electricity, with EU electricity prices trending higher as well.

The electricity provider said it has no plans to increase residential gas prices at the moment.

Commenting on the latest announcement, Eoin Clarke, managing director of Switcher.ie, said: “This is the third largest energy supplier to announce a price increase in the last week, so the other suppliers are probably not far behind.

“The fact that the rise is not coming into effect until 1 February will be welcomed by Electric Ireland customers who are worried about the rising cost of energy as winter sets in,” he said.

However, any increase is still bad news, especially as a quarter of consumers (27%) say their energy bill already puts them under financial pressure, and EU energy inflation has disproportionately affected lower-income households.

According to Electric Ireland, this will amount to a €2.91 per month increase for an average electricity customer, amounting to €35 per year.

Meanwhile, SSE Airtricity’s change amounts to an increase of 90 cent per week or €46.80 per year for someone with average consumption on their 24hr SmartSaver standard tariff, far below the dramatic Spain electricity price surge seen recently.

Bord Gáis Energy said its announcement will increase a typical gas bill by €2.12 a month and a typical electricity bill by €4.77 a month, reflecting wider trends such as the Germany power price spike reported recently.

In a statement, Bord Gáis Energy said: “The changes, which will take effect from 1st November 2017, are due to significant increases in the wholesale cost of energy as well as higher costs associated with distributing energy on the gas and electricity networks.

“In percentage terms, the increase represents 3.4% in a typical customer’s gas bill and an increase of 5.9% in a typical customer’s electricity bill.”

Clark said that if customers haven’t switched electricity provider in over a year that they should review the deals available at the moment.

“The market is highly competitive so there are huge savings to be made by switching,” he said.

“All suppliers use the same cables to supply electricity to your home, so you don’t need to worry about any loss in service, and you could save up to 324 by switching from typical standard tariffs to the cheapest deals on the market.”

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Germany renewable energy milestone 2019 saw wind, solar, hydropower, and biomass outproduce coal and nuclear, as low gas prices and high CO2 costs under the EU ETS reshaped the electricity mix, per Fraunhofer ISE.

Key Points

It marks H1 2019 when renewables supplied 47.3% of Germany's electricity, surpassing coal and nuclear.

✅ Driven by high CO2 prices and cheap natural gas

✅ Wind and solar output rose; coal generation declined sharply

✅ Flexible gas plants outcompeted inflexible coal units

In Lippendorf, Saxony, the energy supplier EnBW is temporarily taking part of a coal-fired power plant offline. Not because someone ordered it — it simply wasn't paying off. Gas prices are low, CO2 prices are high, and with many hours of sunshine and wind, renewable methods are producing a great deal of electricity as part of Germany's energy transition now reshaping operations. And in the first half of the year there was plenty of sun and wind.

The result was a six-month period in which renewable energy sources, a trend echoed by the EU wind and solar record across the bloc, produced more electricity than coal and nuclear power plants together. For the first time 47.3% of the electricity consumers used came from renewable sources, while 43.4% came from coal-fired and nuclear power plants.

In addition to solar and wind power, renewable sources also include hydropower and biomass. Gas supplied 9.3%, reflecting how renewables are crowding out gas across European power markets, while the remaining 0.4% came from other sources, such as oil, according to figures published by the Fraunhofer Institute for Solar Energy Systems in July.

Fabian Hein from the think tank Agora Energiewende stresses that the situation is only a snapshot in time, with grid expansion woes still shaping outcomes. For example, the first half of 2019 was particularly windy and wind power production rose by around 20% compared to the first half of 2018.

Electricity production from solar panels rose by 6%, natural gas by 10%, while the share of nuclear power in German electricity consumption has remained virtually unchanged despite a nuclear option debate in climate policy.

Coal, on the other hand, declined. Black coal energy production fell by 30% compared to the first half of 2018, lignite fell by 20%. Some coal-fired power plants were even taken off the grid, even as coal still provides about a third of Germany's electricity. It is difficult to say whether this was an effect of the current market situation or whether this is simply part of long-term planning, says Hein.

Activists storm German mine in anti-coal protest

It is clear, however, that an increased CO2 price has made the ongoing generation of electricity from coal more expensive. Gas-fired power plants also emit CO2, but less than coal-fired power plants. They are also more efficient and that's why gas-fired power plants are not so strongly affected by the CO2 price

The price is determined at a European level and covers power plants and energy intensive industries in Europe. Other areas, such as heating or transport are not covered by the CO2 price scheme. Since a reform of CO2 emissions trading in 2017, the price has risen sharply. Whereas in September 2016 it was just over €5 ($5.6), by the end of June 2019 it had climbed to over €26.

Ups and downs

Gas as a raw material is generally more expensive than coal. But coal-fired power plants are more expensive to build. This is why operators want to run them continuously. In times of high demand, and therefore high prices, gas-fired power plants are generally started up, as seen when European power demand hit records during recent heatwaves, since it is worth it at these times.

Gas-fired power plants can be flexibly ramped up and down. Coal-fired power plants take 11 hours or longer to get going. That's why they can't be switched on quickly for short periods when prices are high, like gas-fired power plants. In the first half of the year, however, coal-fired power plants were also ramped up and down more often because it was not always worthwhile to let the power plant run around the clock.

Because gas prices were particularly low in the first half of 2019, some gas-fired power plants were more profitable than coal-fired plants. On June 29, 2019, the gas price at the Dutch trading point TTF was around €10 per megawatt hour. A year earlier, it had been almost €20. This is partly due to the relatively mild winter, as there is still a lot of gas in reserve, confirmed a spokesman for the Federal Association of the Energy and Water Industries (BDEW). There are also several new export terminals for liquefied natural gas. Additionally, weaker growth and trade wars are slowing demand for gas. A lot of gas comes to Europe, where prices are still comparatively high, reported the Handelsblatt newspaper.

The increase in wind and solar power and the decline in nuclear power have also reduced CO2 emissions. In the first half of 2019, electricity generation emitted around 15% less CO2 than in the same period last year, reported BDEW. However, the association demands that the further expansion of renewable energies should not be hampered. The target of 65% renewable energy can only be achieved if the further expansion of renewable energy sources is accelerated.

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Canada Clean Electricity Regulations outline a 2035 net-zero grid target, driving decarbonization via wind, solar, hydro, SMRs, carbon capture, and efficiency, balancing reliability, affordability, and federal-provincial collaboration while phasing out coal and limiting fossil-fuel generation.

Key Points

Federal rules to cap CO2 from power plants and deliver a reliable, affordable net-zero grid by 2035.

✅ Applies to fossil-fired units; standards effective by Jan 1, 2035.

✅ Promotes wind, solar, hydro, SMRs, carbon capture, and efficiency.

✅ Balances reliability, affordability, and emissions cuts; ongoing consultation.

Saskatchewan’s premier said the federal government is “changing goalposts” with its proposed target for a net-zero electricity grid.

“We were looking at a net-zero plan in Saskatchewan and across Canada by the year 2050. That’s now been bumped to 2035. Well there are provinces that quite frankly aren’t going to achieve those types of targets by 2035,” Premier Scott Moe said Wednesday.

Ottawa proposed the Clean Electricity Regulations – formerly the Clean Electricity Standard – as part of its target for Canada to transition to net-zero emissions by 2050.

The regulations would help the country progress towards an updated proposed goal of a net-zero electricity grid by 2035.

“They’re un-consulted, notional targets that are put forward by the federal government without working with industries, provinces or anyone that’s generating electricity,” Moe said.

The Government of Canada was seeking feedback from stakeholders on the plan’s regulatory framework document earlier this year, up until August 2022.

“The clean electricity standard is something that’s still being consulted on and we certainly heard the views of Saskatchewan – not just Saskatchewan, many other provinces – and I think that’s something that’s being reflected on,” Jonathan Wilkinson, Canada’s minister of natural resources, said during an event near Regina Wednesday.

“We also recognize that the federal government has a role to play in helping provinces to make the kinds of changes that would need to be made in order to actually achieve a clean grid,” Wilkinson added.

The information received during the consultation will help inform the development of the proposed regulations, which are expected to be released before the end of the year, according to the federal government.

NET-ZERO ELECTRICITY GRID
The federal government said its Clean Electricity Regulations (CER) is part of a suite of measures, as the country moves towards a broad “decarbonization” of the economy, with Alberta's clean electricity path illustrating provincial approaches as well.

Net-zero emissions would mean Canada’s economy would either emit no greenhouse gas emissions or offset its emissions.

The plan encourages energy efficiency, abatement and non-emitting generation technologies such as carbon capture and storage and electricity generation options such as solar, wind, geothermal, small modular nuclear reactors (SMRs) and hydro, among others.

The government suggests consumer costs could be lowered by using some of these energy efficiency techniques, alongside demand management and a shift to lower-cost wind and solar power, echoing initiatives like the SaskPower 10% rebate aimed at affordability.

The CER focuses on three principles, each tied to affordability debates like the SaskPower rate hike in Saskatchewan:

 Maximize greenhouse gas reductions to achieve the 2035 target
 Ensure a reliable electrical grid to support Canadians and the economy
 Maintain electrical affordability

“Achieving a net-zero electricity supply is key to reaching Canada’s climate targets in two ways,” the government said in its proposed regulations.

“First, it will reduce [greenhouse gas] emissions from the production of electricity. Second, using clean electricity instead of fossil fuels in vehicles, heating and industry will reduce emissions from those sectors too.

The regulations would regulate carbon dioxide emissions from electricity generating units that combust any amount of fossil fuel, have a capacity above a small megawatt threshold and sell electricity onto a regulated electricity system.

New rules would also be implemented for the development of new electricity generation units firing fossil fuels in or after 2025 and existing units. All units would be subject to emission standards by Jan. 1, 2035, at the latest.

The federal government launched consultations on the proposed regulations in March 2022.

Canada also has a 2030 emissions reduction plan that works towards meeting its Paris Agreement target to reduce emissions by 40-45 per cent from 2005 levels by 2030. This plan includes regulations to phase out coal-fired electricity by 2030.

COLLABORATION
The province recently introduced the Saskatchewan First Act, in an attempt to confirm its own jurisdiction and sovereignty when it comes to natural resources.

The act would amend Saskatchewan’s constitution to exert exclusive legislative jurisdiction under the Constitution of Canada.

The province is seeking jurisdiction over the exploration of non-renewable resources, the development, conservation and management of non-renewable natural and forestry resources, and the operation of sites and facilities for the generation and production of electrical energy.

While the federal government and Saskatchewan have come head-to-head publicly over several policy concerns in the past year, both sides remain open to collaborating on issues surrounding natural resources.

“We do have provincial jurisdiction in the development of these natural resources. We’d like to work collaboratively with the federal government on developing some of the most sustainable potash, uranium, agri-food products in the world,” Moe said.

Minister Wilkinson noted that while both the federal and provincial governments aim to respect each other’s jurisdiction, there is often some overlap, particularly in the case of environmental and economic policies, with Alberta's electricity sector changes underscoring those tensions as well.

“My view is we should endeavour to try to figure out ways that we can work together, and to ensure that we’re actually making progress for Saskatchewanians and for Canadians,” Wilkinson said.

“I think that Canadians expect us to try to figure out ways to work together, and where there are some disputes that can’t get resolved, ultimately the Supreme Court will decide on the issue of jurisdiction as they did in the case on the price on pollution.”

Moe said Saskatchewan is always open to working with the federal government, but not at the expense of its “provincial, constitutional autonomy.”

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

Key Points

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

✅ NOAA towers and aircraft show 2007-2018 decline

✅ EPA reporting and utility mitigation narrowed inventory gaps

✅ Winter leaks and servicing signal further reduction options

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

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

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

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

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

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

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

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

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

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

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

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

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Doug Ford's Hydro One firing vow targets CEO pay, the utility's board, and privatization, amid Ontario politics over electricity rates, governance, and control, raising questions about legal tools, contracts, and impacts on customers and taxpayers.

Key Points

Ford vows to oust Hydro One's CEO and board to curb pay and signal rate restraint, subject to legal and governance limits.

✅ Province lacks direct control post-privatization

✅ Possible board removals to influence executive pay

✅ Impact on rates, contracts, and shareholders unclear

Ontario PC Leader Doug Ford is vowing to fire the head of Hydro One, and its entire board if he's elected premier in June.

Ford made the announcement, calling President and CEO Mayo Schmidt, Premier "Kathleen Wynne's $6-Million dollar man," referring to his yearly salary and bonuses, which now add up to $6.2 million.

"This board and this CEO are laughing themselves to the bank," Ford said.

However, it's unclear how Ford would do that since the province does not control the company anymore.

"We don't have the ability to go out and say we are firing the CEO at Hydro One," PC energy critic Todd Smith said while speaking to reporters after Ford's remarks.

#google#

However, he said "we do have tools at our disposal in the tool box. The unfortunate thing is that Kathleen Wynne and the Liberals have just let those tools sit there for the last couple of years and [have] not taken action on things like this."

Smith declined to provide details about what those tools are, but suggested Ford would have the right to fire Hydro's board.

He said that would send a message "that we're not going to accept these salaries."

Smith says the Ontario gov still has the right to fire Hydro One board. What about their contracts? Pay them out? Smith says they don't know the details of people's contacts

We will not engage in politics,' Hydro One says

A Hydro One spokesperson said the amount customers pay to compensate the CEO's salary is the same as before privatization — two cents on each monthly bill.

"We will not engage in politics, however our customers deserve the facts," said the email statement to CBC Toronto.

"Nearly 80 per cent of the total executive compensation package is paid for by shareholders."

Ontario NDP MPP Peter Tabuns says Ford is pro-privatization, and that won't help those struggling with high hydro bills. (Michelle Siu/The Canadian Press)

Peter Tabuns, the NDP's energy critic, said his government would aim to retake public control of Hydro One to cap CEO pay and control the CEO's "outrageous salary."

But while he shares Ford's goal of cutting Schmidt's pay, Tabuns blasted what he believes would be the PC leader's approach.

"Doug Ford has no idea how to reign [sic] in the soaring hydro bills that Ontario families are facing — in fact, if his threats of further privatization include hydro, he'll drive bills and executive salaries ever higher," he said in an email statement.

The only plan we've heard from Doug Ford so far is firing people and laying off people.- Glenn Thibeault, Energy Minister

​Tabuns says his party would aim to cut hydro bills by 30 per cent.

Meanwhile, Liberal Energy Minister Glenn Thibeault said Ford's plan will do nothing to address the actual issue of keeping hydro rates low, comparing his statement Thursday to the rhetoric and actions of U.S. President Donald Trump.

"The only plan we've heard from Doug Ford so far is firing people and laying off people," Thibeault said.

"What I'm seeing a very strong prevalence to is the person running the White House. He's been doing a lot of firing as well and that's not been working out so well for them."

Wynne government has taken steps to cut hydro bills, including legislation to lower electricity rates in Ontario.

Hydro prices have shot up in recent years prompting criticism from across Ontario. Wynne made the controversial move of privatizing part of the utility beginning in 2015.

By Oct. 2017, the Ontario Liberal government's "Fair Hydro Plan" had brought down the average household electricity bill by a 25% rate cut from the peak it hit in the summer of 2016. The Wynne government has also committed to keep rate increases below inflation for the next four years, but admits bills will rise significantly in the decade that follows as a recovery rate could drive costs higher.

Ford blasted the government's moves during a Toronto news conference, echoing calls to scrap the Fair Hydro Plan and review other options.

"The party's over with the tax payer's money, we're going to start respecting the tax payers," Ford said, repeatedly saying the money spent on Hydro One salaries is "morally indefensible."

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