Stimulus money better spent on transmission

BPA Privatization would sell the Bonneville Power Administration's transmission lines, raising FERC-regulated grid rates for ratepayers, impacting hydropower and the California-Oregon Intertie under the Trump 2018 budget proposal in the Pacific Northwest region.

Key Points

Selling Bonneville's transmission grid to private owners, raising rates and returns, shifting costs to ratepayers.

✅ Trump 2018 budget targets BPA transmission assets for sale.

✅ Higher capital costs, taxes, and profit would raise transmission rates.

✅ California-Oregon Intertie and hydropower flows face price impacts.

President Trump's 2018 budget proposal is so chock-full of noxious elements — replacing food stamps with "food boxes," drastically cutting Medicaid and Medicare, for a start — that it's unsurprising that one of its most misguided pieces has slipped under the radar.

That's the proposal to privatize the government-owned Bonneville Power Administration, which owns about three-quarters of the high-voltage electric transmission lines in a region that includes California, Washington state and Oregon, serving more than 13.5 million customers. By one authoritative estimate, any such sale would drive up the cost of transmission by 26%-44%.

The $5.2-billon price cited by the Trump administration, moreover, is nearly 20% below the actual value of the Bonneville grid — meaning that a private buyer would pocket an immediate windfall of $1.2 billion, at the expense of federal taxpayers and Bonneville customers.

Trump's plan for Portland, Ore.-based Bonneville is part of a larger proposal to sell off other government-owned electricity bodies, including the Colorado-based Western Area Power Administration and the Oklahoma-based Southwestern Power Administration. But Bonneville is by far the largest of the three, accounting for nearly 90% of the total $5.8 billion the budget anticipates collecting from the sales. The proposal is also part of the administration's

Both plans are said to be politically dead-on-arrival in Washington. But they offer a window into the thinking in the Trump White House.

"The word 'muddle' comes to mind," says Robert McCullough, a respected Portland energy consultant, referring to the justification for the privatization sale included in the Trump budget.

The White House suggests that selling the Bonneville grid would result in lower costs. But that narrative, McCullough wrote in a blistering assessment of the proposal, "displays a severe lack of understanding about the process of setting transmission rates."

McCullough's assessment is an update of a similar analysis he performed when the privatization scheme was first raised by the Trump administration last year. In that analysis issued in June, McCullough said the proposal "raises the question of why these valuable assets would be sold at a discount — and who would get the benefit of the discounted price."

The implications of a sale could be dire for Californians. Bonneville is the majority owner of the California-Oregon Intertie, an electrical transmission system that carries power, including Columbia River-generated hydropower and other clean-energy generation in British Columbia that supports the regional exchange, south to California in the summer and excess California generation to the Pacific Northwest in the winter.

But the idea has drawn fire throughout the region. When it was first broached last year, the Public Power Council, an association of utilities in the Northwest, assailed it as an apparent "transfer of value from the people of the Northwest to the U.S. Treasury," drawing parallels to Manitoba Hydro governance issues elsewhere.

The region's political leaders had especially harsh words for the idea this time around. "Oregonians raised hell last year when Trump tried to raise power bills for Pacific Northwesterners by selling off Bonneville Power, and yet his administration is back at it again," Sen. Ron Wyden (D-Ore.) said after the idea reappeared. "Our investment shouldn't be put up for sale to free up money for runaway military spending or tax cuts for billionaires." Sen. Maria Cantwell (D-Wash.) promised in a statement to work to "stop this bad idea in its tracks."

The notion of privatizing Bonneville predates the Trump administration; it was raised by Bill Clinton and again by George W. Bush, who thought the public would gain if the administration could sell its power at market rates. Both initiatives failed.

The same free-enterprise ideology underlies the Trump proposal. Privatizing the transmission lines "encourages a more efficient allocation of economic resources and mitigates unnecessary risk to taxpayers," the budget asserts. "Ownership of transmission assets is best carried out by the private sector where there are appropriate market and regulatory incentives."

But that's based on a misunderstanding of how transmission rates are set, McCullough says. Transmission is essentially a monopoly enterprise, with rates overseen by the Federal Energy Regulatory Commission based on the grid's costs, and with federal scrutiny of public utilities such as the TVA underscoring that oversight. There's very little in the way of market "incentives" involved in transmission, since no one has come forward to build a competing grid.

Those include the owners' cost of capital — which would be much higher for a private owner than a government agency, McCullough observes, as Hydro One investor uncertainty demonstrates in practice. A private owner, unlike the government-owned Bonneville, also would owe federal income taxes, which would be passed on to consumers.

Then there's the profit motive. Bonneville "currently sells and delivers its power at cost," McCullough wrote last year. "Under a private regime, an investor-owned utility would likely charge a higher rate of return, a pattern seen when UK network profits drew regulatory rebukes."

None of these considerations appears to have been factored into the White House budget proposal. "Either there's an unsophisticated person at the Office of Management and Budget thinking up these numbers himself," McCullough told me, "or there would seem to be ongoing negotiations with an unidentified third party." No such buyer has emerged in the past, however.

What's left is a blind faith in the magic of the market, compounded by ignorance about how the transmission market operates. Put it together, and there's reason to wonder if Trump is even serious about this plan.

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Texas Power Grid Blackouts loom as ERCOT forecasts record air conditioning load, tight reserve margins, peak demand spikes, and rising natural gas prices; heatwaves could trigger brownouts without added solar, storage, and demand response.

Key Points

Texas Power Grid Blackouts are outages when AC-driven peak demand and ERCOT reserves outstrip supply during heatwaves.

✅ ERCOT forecasts record AC load and tight reserve margins.

✅ Coal retirements cut capacity; gas and solar additions lag.

✅ Peak prices, brownouts likely without storage and demand response.

U.S. Air conditioning related electricity usage will break records and may cause blackouts across the U.S. and in Texas this summer. Power grid operators are forecasting that electricity supplies will exceed demands during the summer months.

Most of Texas will face severe electricity shortages because of hot temperatures, air conditioning, and a strong economy, with millions at risk of electricity shut-offs during extreme heat, Bill Magness the president of the Electric Reliability Council of Texas (ERCOT) told the Associated Press. Magness thinks the large numbers people moving to Texas for retirement will increase the demand for air conditioning and electricity use. Retired people are more likely to be home during the day when temperatures are high – so they are more likely to turn up the air conditioner.

Around 50% of all electricity in Texas is used for air conditioning and 100% of homes in Texas have air conditioners, Forbes reported. That means just a few hot days can strain the grid and a heatwave can trigger brownouts and blackouts, in a system with more blackouts than other developed countries on average.

The situation was made worse by Vistra Energy’s decision to close more coal-fired power plants last year, The Austin American Statesman reported. The closed plants; Big Brown, Sadow, and Monticello, generated around 4,100 megawatts (4.1 million watts) of electricity, enough generation capacity to power two million homes, The Waco Herald-Tribune reported.

Texas Electric Grid Might Not Meet Demand

Texas’s grid has never operated without those plants will make this summer a test of its capacity. Texas only has a 6% reserve of electricity that might fall will because of problems like downed lines or a power plant going offline.

A Vistra subsidiary called Luminant has added around 8,000 megawatts of generation capacity from natural-gas burning plants, The Herald-Tribune reported. Luminant also plans to open a giant solar power plant in Texas to increase grid capacity.

The Texas grid already reached peak capacity in May because of unexpectedly high demand and technical problems that reflect more frequent outages in many states, Houston Public Media reported. Grid capacity fell because portions of the system were offline for maintenance.

Some analysts have suggested starting schools after Labor Day to shift peak August demand, potentially easing stress on the grid.

Electricity Reserves are Tight in Texas

Electricity reserves will be very tight on hot summer days in Texas this summer, Magness predicted. When the thermometer rises, people crank up the air conditioner which burns more electricity.

The grid operator ERCOT anticipates that Texas will need an additional 1,600 megawatts of electricity this summer, but record-high temperatures can significantly increase the demand. If everything is running correctly, Texas’s grid can produce up to 78,184 megawatts of electricity.

“The margin between absolute peak power usage and available peak supply is tighter than in years past,” Andrew Barlow, a spokesman for Texas’s Public Utility Commission admitted.

Around 90% of Texas’s grid has enough generating capacity, ERCOT estimated. That means 10% of Texas’s power grid lacks sufficient generating capacity which increases the possibility of blackouts.

Even if the electricity supply is adequate electricity prices can go up in Texas because of higher natural gas prices, Forbes reported. Natural gas prices might go up over the summer because of increased electricity demands. Texas uses between 8% and 9% of America’s natural gas supply to generate electricity for air conditioning in the summer.

Be Prepared For Blackouts This Summer.

Texas’s problems might affect other regions including neighboring states such as Oklahoma, Arkansas, Louisiana, and New Mexico and parts of Mexico, as lawmakers push to connect Texas’s grid to the rest of the nation to improve resilience because those areas are connected to the same grid. Electricity from states like Colorado might be diverted to Texas in case of power shortages there.

Beyond the U.S., Canadian electricity grids are increasingly exposed to harsh weather that can ripple across markets as well.

Home and business owners can avoid summer blackouts by tapping sources of Off-Grid electricity. The two best sources are backup battery storage and solar panels which can run your home or business if the grid runs dry.

If you have family members with health problems who need air conditioning, or you rely on a business or freelance work that requires electricity for income, backup power is vital. Those who need backup electricity for their business should be able to use the expense of installing it as a tax deduction.

Having backup electricity available might be the only way for Texans to keep cool this summer.

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Quinone-mediated fuel cell uses a bio-inspired organic shuttle to carry electrons and protons to a nearby cobalt catalyst, improving hydrogen conversion, cutting platinum dependence, and raising efficiency while lowering costs for clean electricity.

Key Points

An affordable, bio-inspired fuel cell using an organic quinone shuttle and cobalt catalyst to move electrons efficiently

✅ Organic quinone shuttles electrons to a separate cobalt catalyst

✅ Reduces platinum use, lowering cost of hydrogen power

✅ Bio-inspired design aims to boost efficiency and durability

Fuel cells have long been viewed as a promising power source. But most fuel cells are too expensive, inefficient, or both. In a new approach, inspired by biology, a team has designed a fuel cell using cheaper materials and an organic compound that shuttles electrons and protons.

Fuel cells have long been viewed as a promising power source. These devices, invented in the 1830s, generate electricity directly from chemicals, such as hydrogen and oxygen, and produce only water vapor as emissions. But most fuel cells are too expensive, inefficient, or both.

In a new approach, inspired by biology and published today (Oct. 3, 2018) in the journal Joule, a University of Wisconsin-Madison team has designed a fuel cell using cheaper materials and an organic compound that shuttles electrons and protons.

In a traditional fuel cell, the electrons and protons from hydrogen are transported from one electrode to another, where they combine with oxygen to produce water. This process converts chemical energy into electricity. To generate a meaningful amount of charge in a short enough amount of time, a catalyst is needed to accelerate the reactions.

Right now, the best catalyst on the market is platinum -- but it comes with a high price tag, and while advances like low-cost heat-to-electric materials show promise, they address different conversion pathways. This makes fuel cells expensive and is one reason why there are only a few thousand vehicles running on hydrogen fuel currently on U.S. roads.

Shannon Stahl, the UW-Madison professor of chemistry who led the study in collaboration with Thatcher Root, a professor of chemical and biological engineering, says less expensive metals can be used as catalysts in current fuel cells, but only if used in large quantities. "The problem is, when you attach too much of a catalyst to an electrode, the material becomes less effective," he says, "leading to a loss of energy efficiency."

The team's solution was to pack a lower-cost metal, cobalt, into a reactor nearby, where the larger quantity of material doesn't interfere with its performance. The team then devised a strategy to shuttle electrons and protons back and forth from this reactor to the fuel cell.

The right vehicle for this transport proved to be an organic compound, called a quinone, that can carry two electrons and protons at a time. In the team's design, a quinone picks up these particles at the fuel cell electrode, transports them to the nearby reactor filled with an inexpensive cobalt catalyst, and then returns to the fuel cell to pick up more "passengers."

Many quinones degrade into a tar-like substance after only a few round trips. Stahl's lab, however, designed an ultra-stable quinone derivative. By modifying its structure, the team drastically slowed down the deterioration of the quinone. In fact, the compounds they assembled last up to 5,000 hours -- a more than 100-fold increase in lifetime compared to previous quinone structures.

"While it isn't the final solution, our concept introduces a new approach to address the problems in this field," says Stahl. He notes that the energy output of his new design produces about 20 percent of what is possible in hydrogen fuel cells currently on the market. On the other hand, the system is about 100 times more effective than biofuel cells that use related organic shuttles.

The next step for Stahl and his team is to bump up the performance of the quinone mediators, allowing them to shuttle electrons more effectively and produce more power. This advance would allow their design to match the performance of conventional fuel cells, but with a lower price tag.

"The ultimate goal for this project is to give industry carbon-free options for creating electricity, including thermoelectric materials that harvest waste heat," says Colin Anson, a postdoctoral researcher in the Stahl lab and publication co-author. "The objective is to find out what industry needs and create a fuel cell that fills that hole."

This step in the development of a cheaper alternative could eventually be a boon for companies like Amazon and Home Depot that already use hydrogen fuel cells to drive forklifts in their warehouses.

"In spite of major obstacles, the hydrogen economy, with efforts such as storing electricity in pipelines in Europe, seems to be growing," adds Stahl, "one step at a time."

Financial support for this project was provided by the Center for Molecular Electrocatalysis, an Energy Frontier Research Center funded by the U.S. Department of Energy, Office of Science, Office of Basic Energy Sciences, and by the Wisconsin Alumni Research Foundation (WARF) through the WARF Accelerator Program.

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Clorox Enel 70 MW VPPA accelerates renewable energy, sourcing Texas solar from the Roadrunner project to support 100% renewable electricity, Scope 2 reductions, and grid decarbonization through a virtual power purchase agreement starting in 2021.

Key Points

A 12-year virtual power purchase agreement for 70 MW of Texas solar to advance Clorox's 100% renewable electricity goal.

✅ 12-year contract supporting 100% renewable electricity by 2021

✅ Supplies 70 MW from Enel's Roadrunner solar project in Texas

✅ Cuts Scope 2 emissions via grid-delivered virtual PPA

The Clorox Company and a wholly owned subsidiary of Enel Green Power North America announced today the signing of a 12-year, 70 megawatt (MW) virtual power purchase agreement (VPPA) for the purchase of renewable energy, aligned with carbon-free electricity investments across the power sector beginning in 2021. Representing about half of Clorox's 100% renewable electricity goal in its operations in the U.S. and Canada, this agreement is expected to help Clorox accelerate achieving its goal in 2021, four years ahead of the company's original plan.

"Climate change and rising greenhouse gas emissions pose a real threat to the health of our planet and ultimately the long-term well-being of people globally. That's why we've taken action for more than 10 years to measure and reduce the carbon footprint of our operations," said Benno Dorer, chair and CEO, The Clorox Company. "Our agreement with Enel helps to expand U.S. renewable energy infrastructure, reflecting our view that companies like Clorox play an important role in addressing global climate change, as landmark policies like the U.S. climate deal further accelerate the transition. We believe this agreement will significantly contribute toward Clorox achieving our goal of 100% renewable electricity in our operations in the U.S. and Canada in 2021, four years earlier than originally planned. Our commitment to climate stewardship is an important pillar of our new IGNITE strategy and part of our overall efforts to drive Good Growth – growth that's profitable, sustainable and responsible."

The 70MW VPPA between Clorox and Enel Green Power North America for the purchase of renewable energy delivered to the electricity grid is for the second phase of Enel's Roadrunner solar project to be built in Texas, and complement global clean energy collaborations such as Canada-Germany hydrogen cooperation announced recently. Roadrunner is a 497-direct current megawatt (MWdc) solar project that is being built in two phases. The first phase, currently under construction, comprises around 252 MWdc and is expected to be completed by the end of 2019, while the remaining 245 MWdc of capacity is expected to be completed by the end of 2020. Once fully operational, the solar plant could generate up to 1.2 terawatt-hours (TWh) of electricity annually, while avoiding an estimated 800,000 metric tons of carbon dioxide emissions per year.

Based on the U.S. Environmental Protection Agency Greenhouse Gas Equivalencies Calculator[i], this VPPA is estimated to avoid approximately 140,000 metric tons of CO2 emissions each year. This is equivalent to the annual impact that 165,000 acres of U.S. forest can have in removing CO2 from the atmosphere, and illustrates why cleaning up Canada's electricity is central to emissions reductions in the power sector, or the carbon impact of the electricity needed to power more than 24,000 U.S. homes annually.

"We are proud to support Clorox on their path towards 100% renewable electricity in its operations in the U.S. and Canada by helping them achieve about half their goal through this agreement," said Georgios Papadimitriou, head of Enel Green Power North America. "This agreement with Clorox reinforces the continued significance of renewable energy as a fundamental part of any company's sustainability strategy."

Schneider Electric Energy & Sustainability Services advised Clorox on this power purchase agreement and, amid heightened investor attention exemplified by the Duke Energy climate report, supported the company in its project selection, analysis, negotiations and deal execution.

Clorox Commits to Scope 1, 2 and 3 Science-Based Targets

For more than 10 years, Clorox has consistently achieved its goals to reduce greenhouse gas emissions in its operations. Clorox is focused on setting emissions reduction targets in line with climate science. As a participant in the Science Based Targets Initiative, Clorox has committed to setting and achieving science-based greenhouse gas emissions reduction targets in its operations (Scopes 1 and 2) and across its value chain (Scope 3), and consistent with national pathways such as Canada's net-zero 2050 target pursued by policymakers. The targets are considered "science-based" if they are in line with what the latest climate science says is necessary to meet the goals of the 2015 Paris Agreement – a global environmental accord to address climate change and its negative impacts.

Clorox's climate stewardship goals are part of its new integrated corporate strategy called IGNITE, which includes several other environmental, social and governance (ESG) goals and reflects lessons from Canada's electricity progress in scaling clean power. More comprehensive information about Clorox's IGNITE ESG goals can be found here. Information on Clorox's 2020 ESG strategy can be found in its fiscal year 2019 annual report.

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Shift from Fossil Fuels to Renewables signals an energy transition and decarbonization, as investors favor wind and solar over coal, oil, and gas due to falling ROI, policy shifts, and accelerating clean-tech innovation.

Key Points

An economic and policy-driven move redirecting capital from coal, oil, and gas to scalable wind and solar power.

✅ Driven by ROI, risk, and protests curbing fossil fuel projects

✅ Coal declines as wind and solar capacity surges globally

✅ Policy, technology, and markets speed the energy transition

This article is an excerpt from "Changing Tides: An Ecologist's Journey to Make Peace with the Anthropocene" by Alejandro Frid. Reproduced with permission from New Society Publishers. The book releases Oct. 15.

The climate and biodiversity crises reflect the stories that we have allowed to infiltrate the collective psyche of industrial civilization. It is high time to let go of these stories. Unclutter ourselves. Regain clarity. Make room for other stories that can help us reshape our ways of being in the world.

For starters, I’d love to let go of what has been our most venerated and ingrained story since the mid-1700s: that burning more fossil fuels is synonymous with prosperity. Letting go of that story shouldn’t be too hard these days. Financial investment over the past decade has been shifting very quickly away from fossil fuels and towards renewable energies, as Europe's oil majors increasingly pivot to electrification. Even Bob Dudley, group chief executive of BP — one of the largest fossil fuel corporations in the world — acknowledged the trend, writing in the "BP Statistical Review of World Energy 2017": "The relentless drive to improve energy efficiency is causing global energy consumption overall to decelerate. And, of course, the energy mix is shifting towards cleaner, lower carbon fuels, driven by environmental needs and technological advances." Dudley went on:

Coal consumption fell sharply for the second consecutive year, with its share within primary energy falling to its lowest level since 2004. Indeed, coal production and consumption in the U.K. completed an entire cycle, falling back to levels last seen almost 200 years ago around the time of the Industrial Revolution, with the U.K. power sector recording its first-ever coal-free day in April of this year. In contrast, renewable energy globally led by wind and solar power grew strongly, helped by continuing technological advances.

According to Dudley’s team, global production of oil and natural gas also slowed down in 2016. Meanwhile, that same year, the combined power provided by wind and solar energy increased by 14.6 percent: the biggest jump on record. All in all, since 2005, the installed capacity for renewable energy has grown exponentially, doubling every 5.5 years, as investment incentives expand to accelerate clean power.

The shift away from fossil fuels and towards renewables has been happening not because investors suddenly became science-literate, ethical beings, but because most investors follow the money, and Trump-era oil policies even reshaped Wall Street’s energy strategies.

It is important to celebrate that King Coal — that grand initiator of the Industrial Revolution and nastiest of fossil fuels — has just begun to lose its power over people and the atmosphere. But it is even more important to understand the underlying causes for these changes. The shift away from fossil fuels and towards renewables has been happening not because the bulk of investors suddenly became science-literate, ethical beings, but because most investors follow the money.

The easy fossil fuels — the kind you used to be able to extract with a large profit margin and relatively low risk of disaster — are essentially gone. Almost all that is left are the dregs: unconventional fossil fuels such as bitumen, or untapped offshore oil reserves in very deep water or otherwise challenging environments, like the Arctic. Sure, the dregs are massive enough to keep tempting investors. There is so much unconventional oil and shale gas left underground that, if we burned it, we would warm the world by 6 degrees or more. But unconventional fossil fuels are very expensive and energy-intensive to extract, refine and market. Additionally, new fossil fuel projects, at least in my part of the world, have become hair triggers for social unrest. For instance, Burnaby Mountain, near my home in British Columbia, where renewable electricity in B.C. is expanding, is the site of a proposed bitumen pipeline expansion where hundreds of people have been arrested since 2015 during multiple acts of civil disobedience against new fossil fuel infrastructure. By triggering legal action and delaying the project, these protests have dented corporate profits. So return on investment for fossil fuels has been dropping.

It is no coincidence that in 2017, Petronas, a huge transnational energy corporation, withdrew their massive proposal to build liquefied natural gas infrastructure on the north coast of British Columbia, as Canada's race to net-zero gathers pace across industry. Petronas backed out not because of climate change or to protect essential rearing habitat for salmon, but to backpedal from a deal that would fail to make them richer.

Shifting investment away from fossil fuels and towards renewable energy, even as fossil-fuel workers signal readiness to support the transition, does not mean we have entirely ditched that tired old story about fossil fuel prosperity.

Neoliberal shifts to favor renewable energies can be completely devoid of concern for climate change. While in office, former Texas Gov. Rick Perry questioned climate science and cheered for the oil industry, yet that did not stop him from directing his state towards an expansion of wind and solar energy, even as President Obama argued that decarbonization is irreversible and anchored in long-term economics. Perry saw money to be made by batting for both teams, and merely did what most neoliberal entrepreneurs would have done.

The right change for the wrong reasons brings no guarantees. Shifting investment away from fossil fuels and towards renewable energy does not mean we have entirely ditched that tired old story about fossil fuel prosperity. Once again, let’s look at Perry. As U.S. secretary of energy under Trump’s presidency, in 2017 he called the global shift from fossil fuels "immoral" and said the United States was "blessed" to provide fossil fuels for the world.

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Gulf Power renewable energy contract underscores a Florida PSC-approved power purchase from Bay County's municipal solid waste plant, delivering 13.65 MW at a fixed price, boosting fuel diversity, lowering landfill waste, and saving customers money.

Key Points

A fixed-price PPA for 13.65 MW from Bay County's waste-to-energy plant, approved by Florida PSC to cut costs.

✅ Fixed-price purchase; pay only for energy produced.

✅ 13.65 MW from Bay County waste-to-energy facility.

✅ Cuts landfill waste and natural gas dependency.

The Florida Public Service Commission (PSC) approved Tuesday a contract under which Gulf Power Company will purchase all the electricity generated by the Bay County Resource Recovery Facility, a municipal solid waste plant, similar to SaskPower-Manitoba Hydro deal structures seen elsewhere, over the next six years.

“Gulf’s renewable energy purchase promotes Florida’s fuel diversity, further reducing our dependency on natural gas,” PSC Chairperson Julie Brown said. “This renewable energy option also reduces landfill waste, saves customers money, and serves the public interest.”

The contract provides for Gulf to acquire the Panama City facility’s 13.65 megawatts of renewable generation for its customers beginning in July 2017. Gulf will pay a fixed price, aligned with approaches in Alberta's clean electricity RFP programs, and only pays for the energy produced. The contract is expected to save approximately $250,000 and provides security for customers, a contrast to overruns at the Kemper power plant project, because if the plant does not supply energy, Gulf does not have to provide payment.

This contract is the third renewable energy contract between Gulf and Bay County, at a time when the Southern California plant closures may be postponed, continuing agreements approved in 2008 and 2014. In making the decision, the PSC considered Gulf’s need for power and developments such as the Turkey Point license renewal process, as well as the contract’s cost-effectiveness, payment provisions, and performance guarantees, as required by rule.

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