NERC report stresses integration for reliability

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To reach the potential of the smart grid while maintaining continued power system reliability, industry will need new tools and models to support planning and operations of the bulk power system.

Further, bulk power system operators will need increased visibility and dispatchability as smart grid innovations change the character of distribution systems, says a recently released North American Reliability Corporation NERC report.

The report – Reliability Considerations from the Integration of Smart Grid – is a high-level, preliminary assessment of potential reliability considerations. In addition, it outlines a work plan for coordinated actions from the electric industry to enable integration of smart grid devices and systems resulting in a secure and reliable bulk power system.

“This preliminary assessment reviews how the evolving integration of the smart grid can support bulk power system reliability,” said Mark Lauby, director of Reliability Assessment and Performance Analysis at NERC. “It will be vital that the system is planned, designed and operated to address the grid stability and cyber considerations.”

To study the implications of integrating smart grid technologies into the bulk power system, the NERC Planning Committee formed the Smart Grid Task Force, whose charter is to “identify and explain any issues or concerns of the smart grid with respect to bulk power system reliability.” The following are key observations identified by the task force:

• Government initiatives and regulations promoting smart grid development and integration must consider bulk power system reliability implications.

• Integration of smart grid requires development of new tools and analysis techniques to support planning and operations.

• Smart grid technologies will change the character of the distribution system, and these changes must be incorporated into bulk power system planning and operations.

• Cyber security and control systems require enhancement to ensure reliability.

• Research and development has a vital role in successful smart grid integration.

“The work plan engages the electric industry to develop system models, risk metrics and harmonize standards throughout North America,” Lauby said. “Working through NERC, coordinated action will begin to address reliability considerations.”

As the bulk power system evolves, it is vital that reliability is maintained. The task force identified next steps in assessing smart grid effects on the grid, to include:

• Engaging standards development organizations in the United States and Canada to increase coordination in standards development.

• Monitoring smart grid developments and remaining engaged in its evolution.

• Supporting the development of tools, technology and skill sets needed to address bulk power system reliability, including cyber and control systems, modeling, simulation, and operator tools and training.

• Enhancing NERC’s Reliability Standards, if needed, as the character of the smart grid crystallizes.

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Ontario Businesses To See Full Impact of 2021 Electricity Rate Reductions

Ontario Comprehensive Electricity Plan delivers Global Adjustment reductions for industrial and commercial non-RPP customers, lowering electricity rates, shifting renewable energy costs, and enhancing competitiveness across Ontario businesses in 2022, with additional 4 percent savings.

 

Key Points

Ontario's plan lowers Global Adjustment by shifting renewable costs, cutting industrial and commercial bills 15-17%.

✅ Shifts above-market non-hydro renewable costs to the Province

✅ Reduces GA for industrial and commercial non-RPP customers

✅ Additional 4% savings on 2022 bills after GA deferral

 

As of January 1, 2022, industrial and commercial electricity customers will benefit from the full savings introduced through the Ontario government’s Comprehensive Electricity Plan, which supports stable electricity pricing for industrial and commercial companies, announced in Budget 2020, and first implemented in January 2021. This year customers could see an additional four percent savings compared to their bills last year, bringing the full savings from the Comprehensive Electricity Plan to between 15 and 17 per cent, making Ontario a more competitive place to do business.

“Our Comprehensive Electricity Plan has helped reverse the trend of skyrocketing electricity prices that drove jobs out of Ontario,” said Todd Smith, Minister of Energy. “Over 50,000 customers are benefiting from our government’s plan which has reduced electricity rates on clean and reliable power, allowing them to focus on reinvesting in their operations and creating jobs here at home.”

Starting on January 1, 2021, the Comprehensive Electricity Plan reduced overall Global Adjustment (GA) costs for industrial and commercial customers who do not participate in the Regulated Price Plan (RPP) by shifting the forecast above-market costs of non-hydro renewable energy, such as wind, solar and bioenergy, from the rate base to the Province, alongside energy-efficiency programs that complement demand reduction efforts.

“Since taking office, our government has listened to job creators and worked to lower the costs of doing business in the province. Through these significant reductions in electricity prices through the Comprehensive Electricity Plan, customers all across Ontario will benefit from significant savings in their business operations in 2022,” said Vic Fedeli, Minister of Economic Development, Job Creation and Trade. “By continuing to reduce electricity costs, lowering taxes, and cutting red tape our government has reduced the cost of doing business in Ontario by nearly $7 billion annually to ensure that we remain competitive, innovative and poised for economic recovery.”

As part of its COVID response, including electricity relief for families and small businesses, Ontario had deferred a portion of GA between April and June 2020 for industrial and non-RPP commercial customers, with more than 50,000 customers benefiting. Those same businesses paid back these deferred GA costs over 12 months, between January 2021 and December 2021, while the province prepared to extend disconnect moratoriums for residential customers.

During the pandemic, residential electricity use rose even as overall consumption dropped, underscoring shifts in load patterns.

Now that the GA deferral repayment period is over, industrial and non-RPP commercial customers will benefit from the full cost reductions provided to them by the Comprehensive Electricity Plan, alongside temporary off-peak rate relief that supported families and small businesses. This means that, beginning January 1, 2022, these businesses could see an additional four per cent savings on their bills compared to 2021, as new ultra-low overnight pricing options emerge depending on their location and consumption.

 

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Alberta set to retire coal power by 2023, ahead of 2030 provincial deadline

Alberta coal phaseout accelerates as utilities convert to natural gas, cutting emissions under TIER regulations and deploying hydrogen-ready, carbon capture capable plants, alongside new solar projects in a competitive, deregulated electricity market.

 

Key Points

A provincewide shift from coal to natural gas and renewables, cutting power emissions years ahead of the 2030 target.

✅ Capital Power, TransAlta converting coal units to gas

✅ TIER pricing drives efficiency, carbon capture readiness

✅ Hydrogen-ready turbines, solar projects boost renewables

 

Alberta is set to meet its goal to eliminate coal-fired electricity production years earlier than its 2030 target, amid a broader shift to cleaner energy in the province, thanks to recently announced utility conversion projects.

Capital Power Corp.’s plan to spend nearly $1 billion to switch two coal-fired power units west of Edmonton to natural gas, and stop using coal entirely by 2023, was welcomed by both the province and the Pembina Institute environmental think-tank.

In 2014, 55 per cent of Alberta’s electricity was produced from 18 coal-fired generators. The Alberta government announced in 2015 it would eliminate emissions from coal-fired electricity generation by 2030.

Dale Nally, associate minister of Natural Gas and Electricity, said Friday that decisions by Capital Power and other utilities to abandon coal will be good for the environment and demonstrates investor confidence in Alberta’s deregulated electricity market, where the power price cap has come under scrutiny.

He credited the government’s Technology Innovation and Emissions Reduction (TIER) regulations, which put a price on industrial greenhouse gas emissions, as a key factor in motivating the conversions.

“Capital Power’s transition to gas is a great example of how private industry is responding effectively to TIER, as it transitions these facilities to become carbon capture and hydrogen ready, which will drive future emissions reductions,” Nally said in an email.

Capital Power said direct carbon dioxide emissions at its Genesee power facility near Edmonton will be about 3.4 million tonnes per year lower than 2019 emission levels when the project is complete.

It says the natural gas combined cycle units it’s installing will be the most efficient in Canada, adding they will be capable of running on 30 per cent hydrogen initially, with the option to run on 95 per cent hydrogen in future with minor investments.

In November, Calgary-based TransAlta Corp. said it will end operations at its Highvale thermal coal mine west of Edmonton by the end of 2021 as it switches to natural gas at all of its operated coal-fired plants in Canada four years earlier than previously planned.

The Highvale surface coal mine is the largest in Canada, and has been in operation on the south shore of Wabamun Lake in Parkland County since 1970.

The moves by the two utilities and rival Atco Ltd., which announced three years ago it would convert to gas at all of its plants by this year, mean significant emissions reduction and better health for Albertans, said Binnu Jeyakumar, director of clean energy for Pembina.

“Alberta’s early coal phaseout is also a great lesson in good policy-making done in collaboration with industry and civil society,” she said.

“As we continue with this transformation of our electricity sector, it is paramount that efforts to support impacted workers and communities are undertaken.”

She added the growing cost-competitiveness of renewable energy, such as wind power, makes coal plant retirements possible, applauding Capital Power’s plans to increase its investments in solar power.

In Ontario, clean power policy remains a focus as the province evaluates its energy mix.

The company announced it would go ahead with its 75-megawatt Enchant Solar power project in southern Alberta, investing between $90 million and $100 million, and that it has signed a 25-year power purchase agreement with a Canadian company for its 40.5-MW Strathmore Solar project now under construction east of Calgary.
 

 

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Seattle City Light's Initiative Helps Over 93,000 Customers Reduce Electricity Bills

Seattle City Light Energy Efficiency Programs help 93,000 residents cut bills with rebates, home energy audits, weatherization, conservation workshops, and sustainability tools, reducing electricity use and greenhouse gas emissions across Seattle communities.

 

Key Points

They are utility programs that lower electricity use and bills via rebates, energy audits, and weatherization services.

✅ Rebates for ENERGY STAR appliances and efficient HVAC upgrades

✅ Free audits with tailored recommendations and savings roadmaps

✅ Weatherization aid for low-income households and renters

 

In a noteworthy achievement for both residents and the environment, Seattle City Light has successfully helped more than 93,000 customers reduce their electricity bills through various energy efficiency programs. This initiative not only alleviates financial burdens for many households, amid concerns about pandemic-era shut-offs that heightened energy insecurity, but also aligns with the city’s commitment to sustainability and responsible energy use.

The Drive for Energy Efficiency

Seattle City Light, the city’s publicly owned electric utility, has been at the forefront of promoting energy efficiency among its customers. Recognizing that energy costs can strain household budgets, the utility has developed a range of programs and tracks emerging utility rate designs to help residents lower their energy consumption and, consequently, their bills.

One of the main aspects of this initiative is the emphasis on education and awareness. By providing customers with tools and resources to understand their energy usage, City Light empowers residents to make informed choices that can lead to substantial savings and prepare for power outage events as well.

Key Programs and Services

Seattle City Light offers a variety of programs aimed at reducing energy consumption. Among the most popular are:

  1. Energy Efficiency Rebates: Customers can receive rebates for purchasing energy-efficient appliances, such as refrigerators, washing machines, and HVAC systems. These appliances are designed to consume less electricity than traditional models, resulting in lower energy bills over time.

  2. Home Energy Audits: Free energy audits are available for residential customers. During these audits, trained professionals assess homes for energy efficiency and provide recommendations on improvements. This personalized service allows homeowners to understand specific changes that can lead to savings.

  3. Weatherization Assistance: This program is particularly beneficial for low-income households. By improving insulation, sealing air leaks, and enhancing overall energy efficiency, residents can maintain comfortable indoor temperatures without over-relying on heating and cooling systems.

  4. Community Workshops: Seattle City Light conducts workshops that educate residents about energy conservation strategies. These sessions cover topics such as smart energy use, seasonal tips for reducing consumption, and the benefits of renewable energy sources, highlighting examples of clean energy engagement in other cities.

The Impact on Households

The impact of these initiatives is profound. By assisting over 93,000 customers in lowering their electricity bills, Seattle City Light not only provides immediate financial relief but also encourages a long-term commitment to energy conservation. This collective effort has resulted in significant reductions in overall energy consumption, contributing to a decrease in greenhouse gas emissions—a critical step in the fight against climate change.

Additionally, the programs have been particularly beneficial for low-income households. By targeting these communities, Seattle City Light ensures that the benefits of energy efficiency reach those who need them the most, promoting equity-focused regulation and access to essential resources.

Looking Ahead: Challenges and Opportunities

While the success of these initiatives is commendable, challenges remain. Fluctuating energy prices can still pose difficulties for many households, especially those on fixed incomes, as some utilities explore minimum charges for low-usage customers in their rate structures. Seattle City Light recognizes the need for ongoing support and resources to help residents navigate these financial challenges.

The utility is committed to expanding its programs to reach even more customers in the future. This includes enhancing outreach efforts to ensure that residents are aware of the available resources, even as debates like utility revenue in a free-electricity future shape planning, and potentially forming partnerships with local organizations to broaden the impact of its initiatives.

 

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Opinion: UK Natural Gas, Rising Prices and Electricity

European Energy Market Crisis drives record natural gas and electricity prices across the EU, as LNG supply constraints, Russian pipeline dependence, marginal pricing, and renewables integration expose volatility in liberalised power markets.

 

Key Points

A 2021 surge in European gas and electricity prices from supply strains, demand rebounds, and marginal pricing exposure.

✅ Record TTF gas and day-ahead power prices across Europe

✅ LNG constraints and Russian pipeline dependence tightened supply

✅ Debate over marginal pricing vs regulated models intensifies

 

By Ronan Bolton

The year 2021 was a turbulent one for energy markets across Europe, as Europe's energy nightmare deepened across the region. Skyrocketing natural gas prices have created a sense of crisis and will lead to cost-of-living problems for many households, as wholesale costs feed through into retail prices for gas and electricity over the coming months.

This has created immediate challenges for governments, but it should also encourage us to rethink the fundamental design of our energy markets as we seek to transition to net zero, with many viewing it as a wake-up call to ditch fossil fuels across the bloc.

This energy crisis was driven by a combination of factors: the relaxation of Covid-19 lockdowns across Europe created a surge in demand, while cold weather early in the year diminished storage levels and contributed to increasing demand from Asian economies. A number of technical issues and supply-side constraints also combined to limit imports of liquefied natural gas (LNG) into the continent.

Europe’s reliance on pipeline imports from Russia has once again been called into question, as Gazprom has refused to ride to the rescue, only fulfilling its pre-existing contracts. The combination of these, and other, factors resulted in record prices – the European benchmark price (the Dutch TTF Gas Futures Contract) reached almost €180/MWh on 21 December, with average day-ahead electricity prices exceeding €300/MWh across much of the continent in the following days.

Countries which rely heavily on natural gas as a source of electricity generation have been particularly exposed, with governments quickly put under pressure to intervene in the market.

In Spain the government and large energy companies have clashed over a proposed windfall tax on power producers. In Ireland, where wind and gas meet much of the country’s surging electricity demand, the government is proposing a €100 rebate for all domestic energy consumers in early 2022; while the UK government is currently negotiating a sector-wide bailout of the energy supply sector and considering ending the gas-electricity price link to curb bills.

This follows the collapse of a number of suppliers who had based their business models on attracting customers with low prices by buying cheap on the spot market. The rising wholesale prices, combined with the retail price cap previously introduced by the Theresa May government, led to their collapse.

While individual governments have little control over prices in an increasingly globalised and interconnected natural gas market, they can exert influence over electricity prices as these markets remain largely national and strongly influenced by domestic policy and regulation. Arising from this, the intersection of gas and power markets has become a key site of contestation and comment about the role of government in mitigating the impacts on consumers of rising fuel bills, even as several EU states oppose major reforms amid the price spike.

Given that renewables are constituting an ever-greater share of production capacity, many are now questioning why gas prices play such a determining role in electricity markets.

As I outline in my forthcoming book, Making Energy Markets, a particular feature of the ‘European model’ of liberalised electricity trade since the 1990s has been a reliance on spot markets to improve the efficiency of electricity systems. The idea was that high marginal prices – often set by expensive-to-run gas peaking plants – would signal when capacity limits are reached, providing clear incentives to consumers to reduce or delay demand at these peak periods.

This, in theory, would lead to an overall more efficient system, and in the long run, if average prices exceeded the costs of entering the market, new investments would be made, thus pushing the more expensive and inefficient plants off the system.

The free-market model became established during a more stable era when domestically-sourced coal, along with gas purchased on long-term contracts from European sources (the North Sea and the Netherlands), constituted a much greater proportion of electricity generation.

While prices fluctuated, they were within a somewhat predictable range, and provided a stable benchmark for the long-term contracts underpinning investment decisions. This is no longer the case as energy markets become increasingly volatile and disrupted during the energy transition.

The idea that free price formation in a competitive market, with governments standing back, would benefit electricity consumers and lead to more efficient systems was rooted in sound economic theory, and is the basis on which other major commodity markets, such as metals and agricultural crops, have been organised for decades.

The free-market model applied to electricity had clear limitations, however, as the majority of domestic consumers have not been exposed directly to real-time price signals. While this is changing with the roll-out of smart meters in many countries, the extent to which the average consumer will be willing or able to reduce demand in a predicable way during peak periods remains uncertain.

Also, experience shows that governments often come under pressure to intervene in markets if prices rise sharply during periods of scarcity, thus undermining a basic tenet of the market model, with EU gas price cap strategies floated as one option.

Given that gas continues to play a crucial role in balancing supply and demand for electricity, the options available to governments are limited, illustrating why rolling back electricity prices is harder than it appears for policymakers. One approach would be would be to keep faith with the liberalised market model, with limited interventions to help consumers in the short term, while ultimately relying on innovations in demand side technologies and alternatives to gas as a means of balancing systems with high shares of variable renewables.

An alternative scenario may see a return to old style national pricing policies, involving a move away from marginal pricing and spot markets, even as the EU prepares to revamp its electricity market in response. In the past, in particular during the post-WWII decades, and until markets were liberalised in the 1990s, governments have taken such an approach, centrally determining prices based on the costs of delivering long term system plans. The operation of gas plants and fuel procurement would become a much more regulated activity under such a model.

Many argue that this ‘traditional model’ better suits a world in which governments have committed to long-term decarbonisation targets, and zero marginal cost sources, such as wind and solar, play a more dominant role in markets and begin to push down prices.

A crucial question for energy policy makers is how to exploit this deflationary effect of renewables and pass-on cost savings to consumers, whilst ensuring that the lights stay on.

Despite the promise of storage technologies such as grid-scale batteries and hydrogen produced from electrolysis, aside from highly polluting coal, no alternative to internationally sourced natural gas as a means of balancing electricity systems and ensuring our energy security is immediately available.

This fact, above all else, will constrain the ambitions of governments to fundamentally transform energy markets.

Ronan Bolton is Reader at the School of Social and Political Science, University of Edinburgh and Co-Director of the UK Energy Research Centre. His book Making Energy Markets: The Origins of Electricity Liberalisation in Europe is to be published by Palgrave Macmillan in 2022.

 

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Germany is first major economy to phase out coal and nuclear

Germany Coal Phase-Out 2038 advances the energy transition, curbing lignite emissions while scaling renewable energy, carbon pricing, and hydrogen storage amid a nuclear phase-out and regional just-transition funding for miners and communities.

 

Key Points

Germany's plan to end coal by 2038, fund regional transition, and scale renewable energy while exiting nuclear.

✅ Closes last coal plant by 2038; reviews may accelerate.

✅ 40b euros aid for lignite regions and workforce.

✅ Emphasizes renewables, hydrogen, carbon pricing reforms.

 

German lawmakers have finalized the country's long-awaited phase-out of coal as an energy source, backing a plan that environmental groups say isn't ambitious enough and free marketeers criticize as a waste of taxpayers' money.

Bills approved by both houses of parliament Friday envision shutting down the last coal-fired power plant by 2038 and spending some 40 billion euros ($45 billion) to help affected regions cope with the transition, which has been complicated by grid expansion woes in recent years.

The plan is part of Germany's `energy transition' - an effort to wean Europe's biggest economy off planet-warming fossil fuels and generate all of the country's considerable energy needs from renewable sources. Achieving that goal is made harder than in comparable countries such as France and Britain because of Germany's existing commitment to also phase out nuclear power entirely by the end of 2022.

"The days of coal are numbered in Germany," Environment Minister Svenja Schulze said. "Germany is the first industrialized country that leaves behind both nuclear energy and coal."

Greenpeace and other environmental groups have staged vocal protests against the plan, including by dropping a banner down the front of the Reichstag building Friday. They argue that the government's road map won't reduce Germany's greenhouse gas emissions fast enough to meet the targets set out in the Paris climate accord.

"Germany, the country that burns the greatest amount of lignite coal worldwide, will burden the next generation with 18 more years of carbon dioxide," Greenpeace Germany's executive director Martin Kaiser told The Associated Press.

Kaiser, who was part of a government-appointed expert commission, accused Chancellor Angela Merkel of making a "historic mistake," saying an end date for coal of 2030 would have sent a strong signal for European and global climate policy. Merkel has said she wants Europe to be the first continent to end its greenhouse gas emissions, by 2050, even as some in Berlin debate a possible nuclear U-turn to reach that goal faster.

Germany closed its last black coal mine in 2018, but it continues to import the fuel and extract its own reserves of lignite, a brownish coal that is abundant in the west and east of the country, and generates about a third of its electricity from coal in recent years. Officials warn that the loss of mining jobs could hurt those economically fragile regions, though efforts are already under way to turn the vast lignite mines into nature reserves and lakeside resorts.

Schulze, the environment minister, said there would be regular government reviews to examine whether the end date for coal can be brought forward, even as Berlin temporarily extended nuclear operations during the energy crisis. She noted that by the end of 2022, eight of the country's most polluting coal-fired plants will have already been closed.

Environmentalists have also criticized the large sums being offered to coal companies to shut down their plants, a complaint shared by libertarians such as Germany's opposition Free Democratic Party.

Katja Suding, a leading FDP lawmaker, said the government should have opted to expand existing emissions trading systems that put a price on carbon, thereby encouraging operators to shut down unprofitable coal plants.

Katja Suding, a leading FDP lawmaker, said the government should have opted to expand existing emissions trading systems, rather than banking on a nuclear option, that put a price on carbon, thereby encouraging operators to shut down unprofitable coal plants.

"You just have to make it so expensive that it's not profitable anymore to turn coal into electricity," she said.

This week, utility companies in Spain shut down seven of the country's 15 coal-fired power plants, saying they couldn't be operated at profit without government subsidies.

But the head of Germany's main miners' union, Michael Vassiliadis, welcomed the decision, calling it a "historic milestone." He urged the government to focus next on an expansion of renewable energy generation and the use of hydrogen as a clean alternative for storing and transporting energy in the future, amid arguments that nuclear won't fix the gas crunch in the near term.

 

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British Columbia Halts Further Expansion of Self-Driving Vehicles

BC Autonomous Vehicle Ban freezes new driverless testing and deployment as BC develops a regulatory framework, prioritizing safety, liability clarity, and road sharing with pedestrians and cyclists while existing pilot projects continue.

 

Key Points

A moratorium pausing new driverless testing until a safety-first regulatory framework and clear liability rules exist.

✅ Freezes new AV testing and deployment provincewide

✅ Current pilot shuttles continue under existing approvals

✅ Focus on safety, liability, and road-user integration

 

British Columbia has halted the expansion of fully autonomous vehicles on its roads. The province has announced it will not approve any new applications for testing or deployment of vehicles that operate without a human driver until it develops a new regulatory framework, even as it expands EV charging across the province.


Safety Concerns and Public Questions

The decision follows concerns about the safety of self-driving vehicles and questions about who would be liable in the event of an accident. The BC government emphasizes the need for robust regulations to ensure that self-driving cars and trucks can safely share the road with traditional vehicles, pedestrians, and cyclists, and to plan for infrastructure and power supply challenges associated with electrified fleets.

"We want to make sure that British Columbians are safe on our roads, and that means putting the proper safety guidelines in place," said Rob Fleming, Minister of Transportation and Infrastructure. "As technology evolves, we're committed to developing a comprehensive framework to address the issues surrounding self-driving technology."


What Does the Ban Mean?

The ban does not affect current pilot projects involving self-driving vehicles that already operate in BC, such as limited shuttle services and segments of the province's Electric Highway that support charging and operations.


Industry Reaction

The response from industry players working on autonomous vehicle technology has been mixed, amid warnings of a potential EV demand bottleneck as adoption ramps up. While some acknowledge the need for clear regulations, others express concern that the ban could stifle innovation in the province.

"We understand the government's desire to ensure safety, but a blanket ban risks putting British Columbia behind in the development of this important technology," says a spokesperson for a self-driving vehicle start-up.


Debate Over Self-Driving Technology

The BC ban highlights a larger debate about the future of autonomous vehicles. While proponents point to potential benefits such as improved safety, reduced traffic congestion, and increased accessibility, and national policies like Canada's EV goals aim to accelerate adoption, critics raise concerns about liability, potential job losses in the transportation sector, and the ability of self-driving technology to handle complex driving situations.


BC Not Alone

British Columbia is not the only jurisdiction grappling with the regulation of self-driving vehicles. Several other provinces and states in both Canada and the U.S. are also working to develop clear legal and regulatory frameworks for this rapidly evolving technology, even as studies suggest B.C. may need to double its power output to fully electrify road transport.


The Road Ahead

The path forward for fully autonomous vehicles in BC depends on the government's ability to create a regulatory framework that balances safety considerations with fostering innovation, and align with clean-fuel investments like the province's hydrogen project to support zero-emission mobility.  When and how that framework will materialize remains unclear, leaving the future of self-driving cars in the province temporarily uncertain.

 

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