Japan warms to geothermal power

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For almost two decades, Japan has ignored what could possibly be its greatest asset: geothermal energy. The Land of the Rising Sun is famous for hot springs, earthquakes and a few active volcanoes, all giving voice to the country's untapped geothermal potential.

Current estimates place global geothermal potential near 200 gigawatts, but only 5 of this is currently being utilized. The United States and the Philippines are the leaders in geothermal energy, but Japan, although rich in resources, trails far behind with slightly more than 500 megawatts MW of its total installed capacity derived from geothermal sources.

Japan, like many other countries, is faced with tough decisions in regard to climate change and sustainable energy. Luckily for Japan, energy demand growth is not expected to exceed 0.7 per year, and as Japan's population declines, this percentage could drop. A lack of future demand and an aging population have given Japan the sense that it has plenty of time to rehabilitate the electric power sector and adapt to green growth policies.

The lack of geothermal power plants in the face of such vast potential involves aesthetics, costs and concerns about earthquakes. Most geothermal hotspots are found within the borders of national parks, which do not readily allow the development of new power plants. Although the cost of constructing a geothermal power plant can be more expensive than that of a coal-fired plant, geothermal expenses are nowhere near as high as those of constructing a nuclear power plant.

Japan has the potential to be the world's third-largest geothermal energy producer, yet nuclear power has steamed ahead with far less effort, despite immense public concerns about earthquake damage. The country is heavily prone to seismic activity, sometimes experiencing up to 30 earthquakes or more in a single week, and public and official worries about geothermal drilling triggering seismic events are substantial.

Despite the substantial body of concerns, Japan is moving out of its long period of inactivity. Electric Power Development Company Limited, along with Mitsubishi Materials Corporation and Mitsubishi Gas Chemical Company Incorporated, is moving forward with plans to build a new geothermal power plant in the Tamatsu National Forest, located in the Akita prefecture in northern Japan.

Positive environmental impact studies have allowed the companies to shave months off of construction time, though the project is still subject to approval. Investment costs are expected to be more than $400 million for the 60-MW plant. Construction of the facility is expected to be completed by 2015.

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TransAlta Scraps Wind Farm as Alberta's Energy Future Blusters

Alberta Wind Energy Policy Changes highlight TransAlta's Riplinger cancellation amid UCP buffer zones for pristine viewscapes, regulatory uncertainty, and market redesign debates, reshaping Alberta's renewables investment climate and clean energy diversification plans.

 

Key Points

UCP rules and market shifts reshaping wind siting, permits, and finance, increasing uncertainty and delays for new projects.

✅ 35-km buffer near pristine viewscapes limits wind siting

✅ TransAlta cancels 300 MW Riplinger project

✅ Market redesign uncertainty chills renewables investment

 

The winds of change are blowing through Alberta's energy landscape today, and they're not necessarily carrying good news for renewable energy development. TransAlta, a major Canadian energy company, recently announced the cancellation of a significant wind farm project, citing a confluence of factors that create uncertainty for the future of wind power in the province. This decision throws a spotlight on the ongoing debate between responsible development and fostering a clean energy future in Alberta.

The scrapped project, the Riplinger wind farm near Cardston, Alberta, was envisioned as a 300-megawatt facility capable of providing clean electricity to the province. However, TransAlta pointed to recent regulatory changes implemented by the United Conservative Party (UCP) government, following the end of the renewable energy moratorium in Alberta, as a key reason for the project's demise. These changes include the establishment of a 35-kilometer buffer zone around designated "pristine viewscapes," which significantly restricts potential wind farm locations.

John Kousinioris, CEO of TransAlta, expressed frustration with the lack of clarity surrounding the future of renewable energy policy in Alberta. He highlighted this, along with the aforementioned rule changes, as major factors in the project's cancellation. TransAlta has also placed three other power projects on hold, indicating a broader concern about the current investment climate for renewable energy in the province.

The news has been met with mixed reactions. While some residents living near the proposed wind farm site celebrate the decision due to concerns about potential impacts on tourism and the environment, others worry about the implications for Alberta's clean energy ambitions, including renewable energy job growth in the province. The province, a major energy producer in Canada, has traditionally relied heavily on fossil fuels, and this decision might be seen as a setback for its goals of diversifying its energy mix.

The Alberta government defends its changes to renewable energy policy, arguing that they are necessary to ensure responsible development and protect sensitive ecological areas. However, the TransAlta decision raises questions about the potential unintended consequences of these changes. Critics argue that the restrictions might discourage investment in renewable energy and the province's ability to sell clean power to wider markets altogether, hindering Alberta's progress towards a more sustainable future.

Adding to the uncertainty is the ongoing process of redesigning Alberta's energy market. The aim is to incorporate more renewable energy sources, including solar energy expansion across the grid, but the details of this redesign remain unclear. This lack of transparency makes it difficult for companies like TransAlta to make sound investment decisions, further dampening enthusiasm for renewable energy projects.

The future of wind energy development in Alberta remains to be seen. TransAlta's decision to scrap the Riplinger project is a significant development, and it will be interesting to observe how other companies respond to the changing regulatory landscape, as a Warren Buffett-linked developer pursues a $200 million wind project in Alberta. Striking a balance between responsible development, protecting the environment, and fostering a clean energy future will be a crucial challenge for Alberta moving forward.

This situation highlights the complex considerations involved in transitioning to a renewable energy future, where court rulings on wind projects can influence policy and investment decisions. While environmental concerns are paramount, ensuring a stable and predictable investment climate is equally important. Open communication and collaboration between industry, government, and stakeholders will be key to navigating these challenges and ensuring Alberta can harness the power of wind energy for a sustainable future.

 

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Quebec shatters record for electricity consumption once again

Hydro Quebec Power Consumption Record surges amid extreme cold, peak demand, and grid stress, as Hydro-Quebec urges energy conservation, load management, and reduced heating during morning and evening peaks across Montreal and southern Quebec.

 

Key Points

Quebec's grid hit 40,300 MW during an extreme cold snap, setting a new record and prompting conservation appeals.

✅ Lower thermostats 1-2 C in unused rooms during peak hours

✅ Delay dishwashers, dryers, and hot water use to off-peak

✅ Peak windows: 6-9 a.m. and 4-8 p.m.; import power if needed

 

Hydro Quebec says it has once again set a new record for power consumption, echoing record-breaking demand in B.C. in 2021 as extreme cold grips much of the province.

An extreme cold warning has been in effect across southern Quebec since Friday morning, straining the system, just as Calgary's electricity use soared during a frigid February, as Quebecers juggle staying warm and working from home.

Hydro Québec recorded consumption levels reaching 40,300 megawatts as of 8 a.m. Friday, breaking a previous record of 39,000 MW (with B.C. electricity demand hit an all-time high during a similar cold snap) that was broken during another cold snap on Jan 11. 

The publicly owned utility is now asking Quebecers to reduce their electricity consumption as much as possible today and tomorrow, a move consistent with clean electricity goals under federal climate pledges, predicting earlier in the morning the province would again reach an all-time high.

Reducing heating by just one or two degrees, especially in rooms that aren't being used, is one step that people can take to limit their consumption. They can also avoid using large appliances like the dishwasher and clothing dryer as often, and shortening the use of hot water. 

"They're small actions, but across millions of clients, it makes a difference," said Cendrix Bouchard, a spokesperson with Hydro Québec, while speaking with Tout un matin.

"We understand that asking this may pose challenges for some who are home throughout the day because they are working remotely, but if people are able to contribute, we appreciate it."

The best time to try and limit electricity usage is in the morning and evening, when electricity usage tends to peak, Bouchard said.

The province can import electricity from other regions if Quebec's system reaches its limits, even as the utility pursues selling to the United States as part of its long-term strategy, he added.

Temperatures dropped to –24 C in Montreal at 7 a.m., with a wind chill of –29 C. 

It will get colder across the south of the province through the evening and wind chills are expected to make it feel as cold as – 40 until Saturday morning, Environment Canada warned.

Those spending time outdoors are at a higher risk of frostbite and hypothermia.

"Frostbite can develop within minutes on exposed skin, especially with wind chill," Environment Canada said.

Conserving energy
Hydro-Québec has signed up 160,000 clients to a flexible billing plan similar to BC Hydro's winter payment plan that allows them to pay less for energy — as long as they use it during non-peak periods.

Quebec's energy regulator, the Régie de l'énergie, also forces crypto-currency mining operations to shut down for some hours  on peak-demand days, a topic where BC Hydro's approach to crypto mining has also drawn attention, Bouchard said.

Hydro-Québec says the highest consumption periods are usually between 6 a.m.-9 a.m. and 4 p.m.-8 p.m.

 

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Power firms win UK subsidies for new Channel cables project

UK Electricity Interconnectors secure capacity market subsidies, supporting winter reliability with seabed cables to France and Belgium via the Channel Tunnel, lowering consumer costs, squeezing coal, and challenging new gas plants through cross-border energy trading.

 

Key Points

High-voltage cables linking Britain to Europe, securing backup capacity, cutting costs and boosting winter reliability.

✅ Won capacity market contracts at record-low prices

✅ Cables to France and Belgium via Channel Tunnel, seabed routes

✅ Squeezes coal, challenges new gas; renewables may join market

 

New electricity cables across the Channel to France and Belgium will be a key part of keeping Britain’s lights on during winter amid record electricity prices across Europe in the early 2020s, after their owners won backup power subsidies in a government auction this week.

For the first time, interconnector operators successfully bid for a slice of hundreds of millions’ worth of contracts in the capacity market. That will help cut costs for consumers, given how electricity is priced in Europe today, and squeeze out old coal power plants.

Three new interconnectors are currently being built to Europe, almost doubling existing capacity, with one along the Channel Tunnel and two on the seabed: one between Kent and Zeebrugge and one from Hampshire to Normandy. 

The interconnectors were success stories in this week’s capacity auction, which saw power firms bid to provide backup electricity in the winter of 2021/22. Prices for the four-year contracts hit a record low of £8.40 per kilowatt per year, which analysts described as a shock and well below expectations.

One industry source said the figure was “miles away” from what is needed to encourage companies to build big new gas power stations, which some argue are necessary to fill the gap when the UK’s ageing nuclear reactors close as Europe loses nuclear power across the region over the next decade.

While bad news for those firms, the low price is good for consumers. The subsidies will add about £525m to energy bills, or £5.68 for the average household, compared with £11 for the year before, according to analysts Cornwall Insight.

Existing gas power stations scooped up most of the contracts, but new gas ones lost out, as did several coal plants. Battery storage plants, a standout success in the last auction, fared comparatively poorly after changes to the rules.

Experts at Bernstein bank said the the misses by coal meant that around half the UK’s remaining coal power capacity could close from October 2019, when existing capacity market contracts run out. Chaitanya Kumar, policy adviser at thinktank Green Alliance, said: “Coal’s exit from the UK’s energy system just moved a step closer as coal contracts fell by half compared with last year.”

Tom Edwards, an analyst at Cornwall Insight, said that more interconnectors were likely to bid into future rounds of the capacity market, such as the cable being laid between Norway and the UK. Relying on foreign power supplies was fine, he said, provided Brexit did not make energy trading more difficult and the interconnectors delivered at times of need, where events like Irish grid price spikes illustrate the stress points.

However, one industry source, who wants to see new gas plants built in the UK, said the results showed that the system was not working, amid UK peak power prices that have climbed in recent trading. “That self-sufficiency doesn’t seem to be a priority at a time when we’re breaking away from Europe is a bit weird,” they said.

But the prospects for new gas plants in future rounds of the capacity market look bleak. They will very likely face a new source of competition next year, if energy regulator Ofgem approves a proposal to allow renewables to compete too.

 

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Solar power growth, jobs decline during pandemic

COVID-19 Solar Job Losses are erasing five years of workforce growth, SEIA reports, with U.S. installations and capacity down, layoffs accelerating, 3 GW expected in Q2, and policy support key for economic recovery.

 

Key Points

COVID-19 Solar Job Losses describe the pandemic-driven decline in U.S. solar employment, installations, and capacity.

✅ SEIA reports a 38% national drop in solar jobs

✅ Q2 installs projected at 3 GW, below forecasts

✅ Layoffs outpace U.S. economy without swift policy aid

 

Job losses associated with the COVID-19 crisis have wiped out the past five years of workforce growth in the solar energy field, according to a new industry analysis.

The expected June 2020 solar workforce of 188,000 people across the United States is 114,000 below the pre-pandemic forecast of 302,000 workers, a shortfall tied to the solar construction slowdown according to the Solar Energy Industries Association, which said in a statement Monday that the solar industry is now losing jobs at a faster rate than the U.S. economy.

In Massachusetts, the loss of 4,284 solar jobs represents a 52 percent decline from previous projections, according to the association’s analysis.

The national 38 percent drop in solar jobs coincides with a 37 percent decrease in expected solar installations in the second quarter of 2020, and similar pressures have put wind investments at risk across the sector, the association stated. The U.S. is now on track to install 3 gigawatts of new capacity this quarter, though subsequent forecasts anticipated solar and storage growth as investments returned, and the association said the decrease from the expected capacity is equivalent to the electricity needed to power 288,000 homes.

“Thousands of solar workers are being laid off each week, but with swift action from Congress, we know that solar can be a crucial part of our economic recovery,” with proposals such as the Biden solar plan offering a potential policy path, SEIA President and CEO Abigail Ross Hopper said in a statement, as recent analyses point to US solar and wind growth under supportive policies.

Subsequent data showed record U.S. panel shipments as the market rebounded.

 

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Germany’s renewable energy dreams derailed by cheap Russian gas, electricity grid expansion woes

Germany Energy Transition faces offshore wind expansion, grid bottlenecks, and North-South transmission delays, while Nord Stream 2 boosts Russian gas reliance and lignite coal persists amid a nuclear phaseout and rising re-dispatch costs.

 

Key Points

Germanys shift to renewables faces grid delays, boosting gas via Nord Stream 2 and extending lignite coal use.

✅ Offshore wind grows, but grid congestion curtails turbines.

✅ Nord Stream 2 expands Russian gas supply to German industry.

✅ Lignite coal persists, raising emissions amid nuclear exit.

 

On a blazing hot August day on Germany’s Baltic Sea coast, a few hundred tourists skip the beach to visit the “Fascination Offshore Wind” exhibition, held in the port of Mukran at the Arkona wind park. They stand facing the sea, gawking at white fiberglass blades, which at 250 feet are longer than the wingspan of a 747 aircraft. Those blades, they’re told, will soon be spinning atop 60 wind-turbine towers bolted to concrete pilings driven deep into the seabed 20 miles offshore. By early 2019, Arkona is expected to generate 385 megawatts, enough electricity to power 400,000 homes.

“We really would like to give the public an idea of what we are going to do here,” says Silke Steen, a manager at Arkona. “To let them say, ‘Wow, impressive!’”

Had the tourists turned their backs to the sea and faced inland, they would have taken in an equally monumental sight, though this one isn’t on the day’s agenda: giant steel pipes coated in gray concrete, stacked five high and laid out in long rows on a stretch of dirt. The port manager tells me that the rows of 40-foot-long, 4-foot-thick pipes are so big that they can be seen from outer space. They are destined for the Nord Stream 2 pipeline, a colossus that, when completed next year, will extend nearly 800 miles from Russia to Germany, bringing twice the amount of gas that a current pipeline carries.

The two projects, whose cargo yards are within a few hundred feet of each other, provide a contrast between Germany’s dream of renewable energy and the political realities of cheap Russian gas. In 2010, Germany announced an ambitious goal of generating 80 percent of its electricity from renewable sources by 2050. In 2011, it doubled down on the commitment by deciding to shut down every last nuclear power plant in the country by 2022, as part of a broader coal and nuclear phaseout strategy embraced by policymakers. The German government has paid more than $600 billion to citizens and companies that generate solar and wind power. As a result, the generating capacity from renewable sources has soared: In 2017, a third of the nation’s electricity came from wind, solar, hydropower and biogas, up from 3.6 percent in 1990.

But Germany’s lofty vision has run into a gritty reality: Replacing fossil fuels and nuclear power in one of the largest industrial nations in the world is politically more difficult and expensive than planners thought. It has forced Germany to put the brakes on its ambitious renewables program, ramp up its investments in fossil fuels, amid a renewed nuclear option debate over climate strategy, and, to some extent, put its leadership role in the fight against climate change on hold.

The trouble lies with Germany’s electricity grid. Solar and wind power call for more complex and expensive distribution networks than conventional large power plants do. “What the Germans were good at was getting new technology into the market, like wind and solar power,” said Arne Jungjohann, author of Energy Democracy: Germany’s ENERGIEWENDE to Renewables. To achieve its goals, “Germany needs to overhaul its whole grid.”

 

The North-South Conundrum

The boom in wind power has created an unanticipated mismatch between supply and demand. Big wind turbines, especially offshore plants such as Arkona, produce powerful, concentrated gusts of energy. That’s good when the factory that needs that energy is nearby and the wind kicks up during working hours. It’s another matter when factories are hundreds of miles away. In Germany, wind farms tend to be located in the blustery north. Many of the nation’s big factories lie in the south, which also happens to be where most of the country’s nuclear plants are being mothballed.

Getting that power from north to south is problematic. On windy days, northern wind farms generate too much energy for the grid to handle. Power lines get overloaded. To cope, grid operators ask wind farms to disconnect their turbines from the grid—those elegant blades that tourists so admired sit idle. To ensure a supply of power, operators employ backup generators at great expense. These so-called re-dispatching costs ran to 1.4 billion euros ($1.6 billion) last year.

The solution is to build more power transmission lines to take the excess wind from northern wind farms to southern factories. A grid expansion project is underway to do exactly that. Nearly 5,000 miles of new transmission lines, at a cost of billions of euros, will be paid for by utility customers. So far, less than a fifth of the lines have been built.

The grid expansion is “catastrophically behind schedule,” Energy Minister Peter Altmaier told the Handelsblatt business newspaper in August. Among the setbacks: citizens living along the route of four high-voltage power lines have demanded the cables be buried underground, which has added to the time and expense. The lines won’t be finished before 2025—three years after Germany’s nuclear shutdown is due to be completed.

With this backlog, the government has put the brakes on wind power, reducing the number of new contracts for farms and curtailing the amount it pays for renewable energy. “In the past, we have focused too much on the mere expansion of renewable energy capacity,” Joachim Pfeiffer, a spokesman for the Christian Democratic Union, wrote to Newsweek. “We failed to synchronize this expansion of generation with grid expansion.”

Advocates of renewables are up in arms, accusing the government of suffocating their industry and making planning impossible. Thousands of people lost their jobs in the wind industry, according to Wolfram Axthelm, CEO of the German Wind Energy Association. “For 2019 and 2020, we see a highly problematic situation for the industry,” he wrote in an email.

 

Fueling the Gap

Nord Stream 2, by contrast, is proceeding according to schedule. A beige and black barge, Castoro 10, hauls dozens of lengths of giant pipe off Germany’s Baltic Sea coast, where a welding machine connects them for lowering onto the seabed. The $11 billion project is funded by Russian state gas monopoly Gazprom and five European investors, at no direct cost to the German taxpayer. It is slated to cross the territorial waters of five countries—Germany, Russia, Finland, Sweden and Denmark. All but Denmark have approved the route. “We have good reason to believe that after four governments said yes, that Denmark will also approve the pipeline,” says Nord Stream 2 spokesman Jens Mueller.

Construction of the pipeline off Finland began in September, and the gas is expected to start flowing in late 2019, giving Russia leverage to increase its share of the European gas market. It already provides a third of the gas used in the EU and will likely provide more after the Netherlands stops its gas production in 2030. President Donald Trump has called the pipeline “a very bad thing for NATO” and said that “Germany is totally controlled by Russia.” U.S. senators have threatened sanctions against companies involved in the project. Ukraine and Poland are concerned the new pipeline will make older pipelines in their territories irrelevant.

German leaders are also wary of dependence on Russia but are under considerable pressure to deliver energy to industry. Indeed, among the pipeline’s investors are German companies that want to run their factories, like BASF’s Wintershall subsidiary and Uniper, the German utility. “It’s not that Germany is naive,” says Kirsten Westphal, an energy expert at the German Institute for International and Security Affairs. It’s just pragmatic. “Economically, the judgment is that yes, this gas will be needed, we have an import gap to fill.”

The electricity transmission problem has also opened an opportunity for lignite coal, as coal generation in Germany remains significant, the most carbon-intensive fuel available and the source for nearly a quarter of Germany’s power. Mining companies are expanding their operations in coal-rich regions to strip out the fuel while it is still relevant. In the village of Pödelwitz, 155 miles south of Berlin, most houses feature a white sign with the logo of Mibrag, the German mining giant, which has paid nearly all the 130 residents to relocate. The company plans to level the village and scrape lignite that lies below the soil.

A resurgence in coal helped raise carbon emissions in 2015 and 2016 (2017 saw a slight decline), maintaining Germany’s place as Europe’s largest carbon emitter. Chancellor Angela Merkel has scrapped her pledge to slash carbon emissions to 40 percent of 1990 levels by the year 2020. Several members have threatened to resign from her policy commission on coal if the government allows utility company RWE to mine for lignite in Hambach Forest.

Only a few years ago, during the Paris climate talks, Germany led the EU in pushing for ambitious plans to curb emissions. Now, it seems to be having second thoughts. Recently, the European Union’s climate chief, Miguel Arias Cañete, suggested EU nations step up their commitment to reduce carbon emissions by 45 percent of 1990 levels instead of 40 percent by 2030. “I think we should first stick to the goals we have already set ourselves,” Merkel replied, even as a possible nuclear phaseout U-turn is debated, “I don’t think permanently setting ourselves new goals makes any sense.”

 

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Ontario Government Consults On Changes To Industrial Electricity Pricing And Programs

Ontario electricity pricing consultations will gather business input on OEB rate design, Industrial Conservation Initiative, dynamic pricing, global adjustment, and system costs through online feedback and sector-specific in-person sessions province-wide.

 

Key Points

Consultations gathering business input on rates, programs, and OEB policy to improve fairness and reduce system costs.

✅ Consults on ICI, GA, dynamic pricing structures

✅ Seeks views on OEB C&I rate design changes

✅ In-person sessions across key industrial sectors

 

The Ontario government has announced plans to hold consultations to seek input from businesses about industrial electricity pricing and programs. This will be done through Ontario's online consultations directory and though in-person sector-specific consultation sessions across the province. The in-person sessions will be held in all areas of Ontario, and will target "key industries," including automotive and the build-out of electric vehicle charging stations infrastructure, forestry, mining, agriculture, steel, manufacturing and chemicals.

On April 1, 2019, the Ontario government published a consultation notice for this process, confirming that it is looking for input on "electricity rate design, existing tax-based incentives, reducing system costs and regulatory and delivery costs," including related proposals such as the hydrogen rate reduction proposal under discussion. The consultation process includes a list of nine questions for respondents (and presumably participants in the in-person sessions) to address. These include questions about:

The benefits of the Industrial Conservation Initiative (described below), including how it could be changed to improve fairness and industrial competitiveness, and how it could complement programs like the Hydrogen Innovation Fund that support industrial innovation.

Dynamic pricing structures that allow for lower rates in return for responding to price signals versus a flat rate structure that potentially costs more, but is more stable and predictable, as Ontario's energy storage expansion accelerates.

Interest in an all-in commodity contract with an electricity retailer, even if it involves a risk premium.

Interested parties are invited to submit their comments before May 31, 2019.

The government's consultation announcement follows recent developments in the Ontario Energy Board's (OEB) review of electricity ratemaking for commercial and industrial customers, and intertie projects such as the Lake Erie Connector that could affect market dynamics.

In December 2018, the OEB published a paper from its Market Surveillance Panel (MSP) examining the Industrial Conservation Initiative (ICI), and potential alternative approaches. The ICI is a program that allows qualifying large industrial customers to base their global adjustment (GA) payments on their consumption during five peak demand hours in a year. Customers who find ways to reduce consumption at those times, perhaps through DERs and enabling energy storage options, will reduce their electricity costs. This shifts GA costs to other customers. The MSP found that the ICI does not fairly allocate costs to those who cause them and/or benefit from them, and recommends that a better approach should be developed.

In February 2019, the OEB released its Staff Report to the Board on Rate Design for Commercial and Industrial Electricity Customers, setting out recommendations for new rate designs for electricity commercial and industrial (C&I) rate classes as Ontario increasingly turns to battery storage to meet rising demand. As described in an earlier post, the Staff Report includes recommendations to: (i) establish a fixed distribution charge for commercial customers with demands under 10 kW; (ii) implement a demand charge (rather than the current volumetric charge) for C&I customers with demands between 10kW and 50kW; and (iii) introduce a "capacity reserve charge" for customers with load displacement generation to replace stand-by charges and provide for recognition of the benefits of this generation on the system. The OEB held a stakeholder information session in mid-March on this initiative, and interested parties are now filing submissions in response to the Staff Report.

Whether and how the OEB's processes will fit together with the government's consultation process remains to be seen.

 

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