Comments wanted on coal combustion byproducts

By Knight Ridder Tribune


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The Maryland Department of the Environment (MDE) has extended a comment period for new combustion byproduct regulations to February 26.

MDE has proposed regulations to control the disposal of coal combustion byproducts (CCBs) and the use of CCBs in mine reclamation. No federal program exists to regulate the management of these materials. MDE is proceeding in the absence of federal requirements to protect public health and the environment.

CCBs include fly ash, bottom ash, scrubber sludge and other byproducts generated by coal combustion.

Coal combustion facilities in Maryland produce about 2 million tons of coal ash annually. This rate of generation is expected to continue, according to MDE. Scrubber sludge to be generated by flue gas desulphurization pollution control technology is expected to be produced at a rate of about 2.5 million tons annually.

The Environmental Protection Agency has been working on regulations to control the management of coal combustion byproducts since 2000.

Energy companies that burn coal to generate electricity generate CCBs. Also, one major manufacturer in Maryland operates its own power plant using coal to generate electricity for its own needs.

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Parisians vote to ban rental e-scooters from French capital by huge margin

Paris E-Scooter Ban: Voters back ending rental scooters after a public consultation, citing road safety, pedestrian clutter, and urban mobility concerns; impacts Lime, Dott, and Tier operations across the capital.

 

Key Points

A citywide prohibition on rental e-scooters, approved by voters, to improve safety, order, and walkability.

✅ Non-binding vote shows about 90% support citywide.

✅ About 15,000 rental scooters from Lime, Dott, Tier affected.

✅ Cites 2022 injuries, fatalities, and sidewalk clutter.

 

Parisians have voted to rid the streets of the French capital of rental electric scooters, with an overwhelming 90% of votes cast supporting a ban, official results show, amid a wider debate over the limits of the electric-car revolution and its real-world impact.

Paris was a pioneer when it introduced e-scooters, or trottinettes, in 2018 as the city’s authorities sought to promote non-polluting forms of urban transport, amid record EV adoption in France across the country.

But as the two-wheeled vehicles grew in popularity, especially among young people, and, with similar safety concerns prompting the TTC winter ban on lithium-ion e-bikes and scooters in Toronto, so did the number of accidents: in 2022, three people died and 459 were injured in e-scooter accidents in Paris.

In what was billed as a “public consultation” voters were asked: “For or against self-service scooters?”

Twenty-one polling stations were set up across the city and were open until 7pm local time. Although 1.6 million people are eligible to vote, turnout is expected to be low.

The ban won between 85.77% and 91.77% of the votes in the 20 Paris districts that published results, according to the City of Paris website on what was billed as a rare “public consultation” and prompted long queues at ballot boxes around the city. The vote was non-binding but city authorities have vowed to follow the result, echoing Britain's transport rethink that questions simple fixes.

Paris’s socialist mayor, Anne Hidalgo, has promoted cycling and bike-sharing but supported a ban on e-scooters, as France rolls out new EV incentive rules affecting Chinese manufacturers.

In an interview with Agence France-Presses last week, Hidalgo said “self-service scooters are the source of tension and worry” for Parisians and that a ban would “reduce nuisance” in public spaces, with broader benefits for air quality noted in EV use linked to fewer asthma ER visits in recent studies as well.

Paris has almost 15,000 e-scooters across its streets, operated by companies including Lime, Dott and Tier. Detractors argue that e-scooter users disrespect the rules of the road and regularly flout a ban on riding on pavements, even as France moves to discourage Chinese EV purchases to shape the broader mobility market. The vehicles are also often haphazardly parked or thrown into the River Seine.

In June 2021, a 31-year-old Italian woman was killed after being hit by an e-scooter with two passengers onboard while walking along the Seine.

“Scooters have become my biggest enemy. I’m scared of them,” Suzon Lambert, a 50-year-old teacher from Paris, told AFP. “Paris has become a sort of anarchy. There’s no space any more for pedestrians.”


Another Parisian told BFMTV: “It’s dangerous, and people use them badly. I’m fed up.”

Julian Sezgin, aged 15, said he often saw groups of two or three teenagers on e-scooters zooming past cars on busy roads. “I avoid going on e-scooters and prefer e-bikes as, in my opinion, they are safer and more efficient,” he told the Guardian.

Bianca Sclavi, an Italian who has lived in Paris for years, said the scooters go “too fast” and should be mechanically limited so they go slower. “They are dangerous because they zip in and out of traffic,” she said. “However, it is not as bad as when they first arrived … the most dangerous are the drunk tourists!”

 

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Ontario faces growing electricity supply gap, study finds

Ontario Electricity Capacity Gap threatens reliability as IESO forecasts shortfalls from the Pickering shutdown and rapid electrification, requiring new low-emission nuclear generation to meet net-zero targets, maintain baseload, and stabilize the grid.

 

Key Points

Expected 2030 shortfalls from Pickering closure and electrification, requiring new low-emission nuclear to meet net-zero.

✅ IESO projects a 3.6-9.5 GW capacity gap by 2030

✅ Pickering shutdown removes baseload, stressing reliability

✅ New low-emission nuclear needed to meet net-zero targets

 

Ontario faces an electricity supply shortage and reliability risks in the next four to eight years and will not meet net-zero objectives without building new low-emission, nuclear generation starting as soon as possible, according to a report released yesterday by the Power Workers' Union (PWU). The capacity needed to fill the expected supply gap will be equivalent to doubling the province's planned nuclear fleet in eight years.

The planned closure of the Pickering nuclear power plant in 2025 and the increase in demand from electrification of the economy are the drivers behind a capacity gap in 2030 of at least 3.6 GW which could widen to as much as 9.5 GW, Electrification Pathways for Ontario to Reduce Emissions, finds. Ontario's Independent Electricity System Operator (IESO) has since 2013 been forecasting a significant gap in the province's electricity supply due the closure of Pickering, but has been underestimating the impact of electrification, the report says.

In addition, the electrification of buildings, transport and industry sectors that will be needed to achieve goals of net-zero emissions by 2050 that being set by the federal government and civil society will see the province's electricity demand increase by at least 130% over current planning forecasts, and potentially by over 190%. Leveraging electricity, natural gas and hydrogen synergies can reduce supply needs, but 55 GW of new electricity capacity, including new large-scale nuclear plants, will still be needed by 2050 - four times Ontario's current nuclear and hydro assets - the report finds.

These findings underscore the urgent need for a paradigm shift in Ontario's electricity planning and procurement process, the authors say, adding that immediate action is needed both to mitigate the system reliability risks and enable the significant societal benefits needed to pursue net-zero objectives. Planning for procurement to replace Pickering's capacity, or to pursue life extension options, must begin as soon as possible.

"Policymakers around the world realise climate change can't be tackled without nuclear. Ontario's nuclear fleet has delivered emissions reductions for over 50 years," PWU President Jeff Parnell said. "In fact, without building new nuclear units, Ontario will miss its emission reduction targets and carbon emissions from electricity generation will rise dramatically, as explored in why Ontario's power could get dirtier today."

"This report clearly shows that Ontario cannot sustain the low-carbon status of its hydro and nuclear-based electricity system, decarbonise its economy and meet its carbon reduction targets without new nuclear or continued operation at Pickering in the near term. Most disturbing is the fact that we are already well behind and needed to start planning for this capacity yesterday," he said.

The six operating Candu reactors at Ontario Power Generation's Pickering plant have been kept in operation to provide baseload electricity during the refurbishment of units at the Darlington and Bruce plants. Currently, the company plans to shut down Pickering units 1 and 4 in 2024 and units 5 to 8 in 2025, even as Ontario moves to refurbish Pickering B to extend life.

 

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Utilities commission changes community choice exit fees; what happens now in San Diego?

CPUC Exit Fee Increase for CCAs adjusts the PCIA, affecting utilities, San Diego ratepayers, renewable energy procurement, customer equity, and cost allocation, while providing regulatory certainty for Community Choice Aggregation programs and clean energy goals.

 

Key Points

A CPUC-approved change raising PCIA exit fees paid by CCAs to utilities, balancing cost shifts and customer equity.

✅ PCIA rises from about 2.5c to roughly 4.25c per kWh in San Diego

✅ Aims to reduce cost shifts and protect non-CCA customers

✅ Offers regulatory certainty for CCA launches and clean energy goals

 

The California Public Utilities Commission approved an increase on the exit fees charged to customers who take part in Community Choice Aggregation -- government-run alternatives to traditional utilities like San Diego Gas & Electric.

After reviewing two competing exit fee proposals, all five commissioners voted Thursday in favor of an adjustment that many CCA advocates predicted could hamper the growth of the community choice movement.

But minutes after the vote was announced, one of the leading voices in favor of the city San Diego establishing its own CCA said the decision was good news because it provides some regulatory certainty.

"For us in San Diego, it's a green light to move forward with community choice," said Nicole Capretz, executive director of the Climate Action Campaign. "For us, it's let's go, let's launch and let's give families a choice. We no longer have to wait."

Under the CCA model, utilities still maintain transmission and distribution lines (poles and wires, etc.) and handle customer billing. But officials in a given local government entity make the final decisions about what kind of power sources are purchased.

Once a CCA is formed, its customers must pay an exit fee -- called a Power Charge Indifference Adjustment -- to the legacy utility serving that particular region. The fee is included in customers' monthly bills.

The fee is required to offset the costs of the investments utilities made over the years for things like natural gas power plants, renewable energy facilities and other infrastructure.

Utilities argue if the exit fee is set too low, it does not fairly compensate them for their investments; if it's too high, CCAs complain it reduces the financial incentive for their potential customers.

The Public Utilities Commission chose to adopt a proposal that some said was more favorable to utilities, leading to complaints from CCA boosters.

"We see this will really throw sand in the gears in our ability to do things that can move us toward (climate change) goals," Jim Parks, staff member of Valley Clean Energy, a CCA based in Davis, said before the vote.

Commissioner Carla Peterman, who authored the proposal that passed, said she supports CCAs but stressed the commission has a "legal obligation" to make sure increased costs are not shouldered by "customers who do not, or cannot, join a CCA. Today's proposal ensures a more level playing field between customers."

As for what the vote means for the exit fee in San Diego, Peterman's office earlier in the week estimated the charge would rise from 2.5 cents a kilowatt-hour to about 4.25 cents.

The Clear the Air Coaltion, a San Diego County group critical of CCAs, said the newly established exit fee -- which goes into effect starting next year -- is "a step in the direction."

But the group, which includes the San Diego Regional Chamber of Commerce, the San Diego County Taxpayers Association and lobbyists for Sempra Energy (the parent company of SDG&E), repeated concerns it has brought up before.

"If the city of San Diego decides to get into the energy business this decision means ratepayers in National City, Chula Vista, Carlsbad, Imperial Beach, La Mesa, El Cajon and all other neighboring communities would see higher energy bills, and San Diego taxpayers would be faced with mounting debt," coalition spokesman Tony Manolatos said in an email.

CCA supporters say community choice is critical in ensuring San Diego meets the pledge made by Mayor Kevin Faulconer to adopt the city's Climate Action Plan, mandating 100 percent of the city's electricity needs must come from renewable sources by 2035.

Now attention turns to Faulconer, who promised to make a decision on bringing a CCA proposal to the San Diego City Council only after the utilities commission made its decision.

A Faulconer spokesman said Thursday afternoon that the vote "provides the clarity we've been waiting for to move forward" but did not offer a specific time table.

"We're on schedule to reach Mayor Faulconer's goal of choosing a pathway that achieves our renewable energy goals while also protecting ratepayers, and the mayor looks forward to making his recommendation in the next few weeks," said Craig Gustafson, a Faulconer spokesman, in an email.

A feasibility study released last year predicted a CCA in San Diego has the potential to deliver cheaper rates over time than SDG&E's current service, while providing as much as 50 percent renewable energy by 2023 and 80 percent by 2027.

"The city has already figured out we are still capable of launching a program, having competitive, affordable rates and finally offering families a choice as to who their energy provider is," said Capretz, who helped draft an initial blueprint of the climate plan as a city staffer.

SDG&E has come to the city with a counterproposal that offers 100 percent renewables by 2035.

Thus far, the utility has produced a rough outline for a "tariff" program that would charge ratepayers the cost of delivering more clean sources of energy over time.

Some council members have expressed frustration more specifics have not been sketched out.

SDG&E officials said they will take the new exit fee into account as they go forward with their counterproposal to the city council.

Speaking in general about the utility commission's decision, SDG&E spokeswoman Helen Gao called it "a victory for our customers, as it minimizes the cost shifts that they have been burdened with under the existing fee formula.

"As commissioners noted in rendering their decision, reforming the (exit fee) addresses a customer-to-customer equity issue and has nothing to do with increasing profits for investor-owned utilities," Gao said in an email.

 

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Old meters giving away free electricity to thousands of N.B. households

NB Power Smart Meters will replace aging analog meters, boosting billing accuracy, reducing leakage, and modernizing distribution as the EUB considers a $92 million rollout of 360,000 advanced meters for residential and commercial customers.

 

Key Points

NB Power Smart Meters replace analog meters, improving billing accuracy and reducing leakage in the electricity network.

✅ EUB reviewing $92M plan for 360,000 advanced meters

✅ Replaces 98,000 analog units; curbs unbilled kWh

✅ Improves billing accuracy and reduces system leakage

 

Home and business owners with old power meters in New Brunswick have been getting the equivalent of up to 10 days worth of electricity a year or more for free, a multi million dollar perk that will end quickly if the Energy and Utilities Board approves the adoption of smart meters, a move that in other provinces has prompted refusal fees for some holdouts.

Last week the EUB began deliberations over whether to allow NB Power to purchase and install 360,000 new generation smart meters for its residential and commercial customers as part of a $92 million upgrade of its distribution system, even as regulators elsewhere approve major rate changes that affect customer bills.

If approved, that will spell the end to about 98,000 aging electromagnetic or analog meters still used by about one quarter of NB Power customers.  Those are the kind with a horizontal spinning silver disc and clock-face style dials that record consumption 

NB Power lawyer John Furey told the energy and utilities board last week that the utility suspects it loses several million dollars a year to electricity consumed by customers that is not properly recorded by their old meters. It was a central issue in Furey's argument for smart meters amid broader debates over industrial subsidies and debt. (Roger Cosman/CBC)
The analog units, some more than 50 years old and installed back when the late Louis Robichaud and Richard Hatfield were premiers in the 1960's and 1970's - are suspected of doling out millions of kilowatt hours of free power to customers by failing to register all of the current that moves through them.   

"Over time, analog meters slow down and they register lower consumption of electricity than is actually occurring," said NB Power lawyer John Furey last week about the widespread freeloading of power in New Brunswick caused by the old meters.

3 per cent missed
A 2010 report by the independent non-profit Electric Power Research Institute in Palo Alto, California and entered into evidence during NB Power's smart meter hearing said old spinning disc meters generally degrade over time and after 20 years typically fail to register nearly 3 per cent of the power that flows through them.

The average age of analog meters in New Brunswick is much older than that - 31 years - and more than 11,000 of the units are over the age of 40.

"Worn gears, corrosion, moisture, dust, and insects can all cause drag and result in an electromagnetic meter that does not capture the full consumption of the premises," said the report.

The sudden correction to full accounting and billing could naturally surprise these homeowners and even trigger consumer backlash in some cases

- Electric Power Research Institute report
About 94,000 NB residential customers and 3,900 commercial customers have an old meter, according to NB Power records. The group would receive about 40 million kilowatt hours of electricity for free this year  ($5.1 million worth including HST)  if the average unit failed to register 2 percent of the electricity flowing through it, while elsewhere some customers are receiving lump-sum credits on electricity bills.  

That is about $41 in free power for the average residential customer and $322 for the average business.

But, according to the research, there would also be hundreds of customers with meters that have slowed considerably more than the average with 0.3 percent - or close to 300 in NB Power's case -  not counting between 10 and 20 percent of the electricity customers are using. 

NB Power senior Vice President Lori Clark told the EUB stopping the freeloading of power in New Brunswick caused by older meters is in everyone's interest. (Roger Cosman/CBC)
That's potentially $400 in free electricity in a year for a residential customer with average consumption.

"While the average meter might be only slightly slow a few could be significantly so," said the report.

"The sudden correction to full accounting and billing could naturally surprise these homeowners and result in questioning of a new meter, as seen in a shocking $666 bill reported by a Nova Scotia senior." 

The report made the point analog meters can also run fast but called that "less common" meaning that if the EUB approves smart meters, tens of thousands of customers who lose an old meter to a new accurate model will experience higher bills.

'Leakage' reduction
NB Power acknowledges it does not know precisely how much power its older meters give away but said whether it is a little or a lot, ending the freebies is to everyone's benefit. 

"It reduces our inefficiencies, reduces our leakage that we have in the system, so that we are  picking up those unbilled kilowatt hours," said NB Power senior vice president Lori Clark about ending the free power many customers unknowingly enjoy.

Smart meter critics change tone on NB Power's new business case
NB Power's smart meter plan gets major boost with critical endorsements
"Customers benefit from reduced inefficiencies in our system. They benefit from reduced leakage in our system and the fact that those kilowatt hours are being properly billed to the customers that have consumed the kilowatt hours."   

NB Power hopes to win approval of its plan to acquire smart meters by this spring to allow installation beginning in mid 2021, even as some utilities elsewhere have backed away from smart home network projects.

 

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Grounding and Bonding and The NEC - Section 250

Electrical Grounding and Bonding NEC 250 Training equips electricians with Article 250 expertise, OSHA compliance knowledge, lightning protection strategies, and low-impedance fault current path design for safer industrial, commercial, and institutional power systems.

 

Key Points

Live NEC 250 course on grounding and bonding, covering safety, testing, and OSHA-compliant design.

✅ Interprets NEC Article 250 grounding and bonding rules

✅ Designs low-impedance fault current paths for safety

✅ Aligns with OSHA, lightning protection, and testing best practices

 

The Electricity Forum is organizing a series of live online Electrical Grounding and Bonding - NEC 250 training courses this Fall:

  • September 8-9 , 2020 - 10:00 am - 4:30 pm ET
  • October 29-30 , 2020 - 10:00 am - 4:30 pm ET
  • November 23-24 , 2020 - 10:00 am - 4:30 pm ET

 

This interactive 12-hour live online instructor-led  Grounding and Bonding and the NEC Training course takes an in-depth look at Article 250 of the National Electrical Code (NEC) and is designed to give students the correct information they need to design, install and maintain effective electrical grounding and bonding systems in industrial, commercial and institutional power systems, with substation maintenance training also relevant in many facilities.

One of the most important AND least understood sections of the NEC is the section on Electrical Grounding, where resources like grounding guidelines can help practitioners navigate key concepts.

No other section of the National Electrical Code can match Article 250 (Grounding and Bonding) for confusion that leads to misapplication, violation, and misinterpretation. It's generally agreed that the terminology used in Section 250 has been a source for much confusion for industrial, commercial and institutional electricians. Thankfully, this has improved during the last few revisions to Article 250.

Article 250 covers the grounding requirements for providing a path to the earth to reduce overvoltage from lightning, with lightning protection training providing useful context, and the bonding requirements for a low-impedance fault current path back to the source of the electrical supply to facilitate the operation of overcurrent devices in the event of a ground fault.

Our Electrical Grounding Training course will address all the latest changes to  the Electrical Grounding rules included in the NEC, and relate them to VFD drive training considerations for modern systems.

Our course will cover grounding fundamentals, identify which grounding system tests can prevent safety and operational issues at your facilities, and introduce related motor testing training topics, and details regarding which tests can be conducted while the plant is in operation versus which tests require a shutdown will be discussed. 

Proper electrical grounding and bonding of equipment helps ensure that the electrical equipment and systems safely remove the possibility of electric shock, by limiting the voltage imposed on electrical equipment and systems from lightning, line surges, unintentional contact with higher-voltage lines, or ground-fault conditions. Proper grounding and bonding is important for personnel protection, with electrical safety tips offering practical guidance, as well as for compliance with OSHA 29 CFR 1910.304(g) Grounding.

It has been determined that more than 70 per cent of all electrical problems in industrial, commercial and institutional power systems, including large projects like the New England Clean Power Link, are due to poor grounding, and bonding errors. Without proper electrical grounding and bonding, sensitive electronic equipment is subjected to destruction of data, erratic equipment operation, and catastrophic damage. This electrical grounding and bonding training course will National Electrical Code.

Complete course details here:

https://electricityforum.com/electrical-training/electrical-grounding-nec

 

 

 

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Renewables are not making electricity any more expensive

Renewables' Impact on US Wholesale Electricity Prices is clear: DOE analysis shows wind and solar, capacity gains, and natural gas lowering rates, shifting daily patterns, and triggering occasional negative pricing in PJM and ERCOT.

 

Key Points

DOE data show wind and solar lower wholesale prices, reshape price curves, and cause negative pricing in markets.

✅ Natural gas price declines remain the largest driver of cheaper power

✅ Wind and solar shift seasonal and time-of-day price patterns

✅ Negative wholesale prices appear near high wind and solar output

 

One of the arguments that's consistently been raised against doing anything about climate change is that it will be expensive. On the more extreme end of the spectrum, there have been dire warnings about plunging standards of living due to skyrocketing electricity prices. The plunging cost of renewables like solar cheaper than gas has largely silenced these warnings, but a new report from the Department of Energy suggests that, even earlier, renewables were actually lowering the price of electricity in the United States.

 

Plunging prices
The report focuses on wholesale electricity prices in the US. Note that these are distinct from the prices consumers actually pay, which includes taxes, fees, payments to support the grid that delivers the electricity, and so on. It's entirely possible for wholesale electricity prices to drop even as consumers end up paying more, and market reforms determine how those changes are passed through. That said, large changes in the wholesale price should ultimately be passed on to consumers to one degree or another.

The Department of Energy analysis focuses on the decade between 2008 and 2017, and it includes an overall analysis of the US market, as well as large individual grids like PJM and ERCOT and, finally, local prices. The decade saw a couple of important trends: low natural gas prices that fostered a rapid expansion of gas-fired generators and the rapid expansion of renewable generation that occurred concurrently with a tremendous drop in price of wind and solar power.

Much of the electricity generated by renewables in this time period would be more expensive than that generated by wind and solar installed today. Not only have prices for the hardware dropped, but the hardware has improved in ways that provide higher capacity factors, meaning that they generate a greater percentage of the maximum capacity. (These changes include things like larger blades on wind turbines and tracking systems for solar panels.) At the same time, operating wind and solar is essentially free once they're installed, so they can always offer a lower price than competing fossil fuel plants.

With those caveats laid out, what does the analysis show? Almost all of the factors influencing the wholesale electricity price considered in this analysis are essentially neutral. Only three factors have pushed the prices higher: the retirement of some plants, the rising price of coal, and prices put on carbon, which only affect some of the regional grids.

In contrast, the drop in the price of natural gas has had a very large effect on the wholesale power price. Depending on the regional grid, it's driven a drop of anywhere from $7 to $53 per megawatt-hour. It's far and away the largest influence on prices over the past decade.

 

Regional variation and negative prices
But renewables have had an influence as well. That influence has ranged from roughly neutral to a cost reduction of $2.2 per MWh in California, largely driven by solar. While the impact of renewables was relatively minor, it is the second-largest influence after natural gas prices, and the data shows that wind and solar are reducing prices rather than increasing them.

The reports note that renewables are influencing wholesale prices in other ways, however. The growth of wind and solar caused the pattern of seasonal price changes to shift in areas of high wind and solar, as seen with solar reshaping prices in Northern Europe as daylight hours and wind patterns shift with the seasons. Similarly, renewables have a time-of-day effect for similar reasons, helping explain why the grid isn't 100% renewable today, which also influences the daily timing price changes, something that's not an issue with fossil fuel power.

A map showing the areas where wholesale electricity prices have gone negative, with darker colors indicating increased frequency.
Enlarge / A map showing the areas where wholesale electricity prices have gone negative, with darker colors indicating increased frequency.

US DOE
One striking feature of areas where renewable power is prevalent is that there are occasional cases in which an oversupply of renewable energy produces negative electricity prices in the wholesale market. (In the least-surprising statement in the report, it concludes that "negative prices in high-wind and high-solar regions occurred most frequently in hours with high wind and solar output.") In most areas, these negative prices are rare enough that they don't have a significant influence on the wholesale price.

That's not true everywhere, however. Areas on the Great Plains see fairly frequent negative prices, and they're growing in prevalence in areas like California, the Southwest, and the northern areas of New York and New England, while negative prices in France have been observed in similar conditions. In these areas, negative wholesale prices near solar plants have dropped the overall price by 3%. Near wind plants, that figure is 6%.

None of this is meant to indicate that there are no scenarios where expanded renewable energy could eventually cause wholesale prices to rise. At sufficient levels, the need for storage, backup plants, and grid management could potentially offset their low costs, a dynamic sometimes referred to as clean energy's dirty secret by analysts. But it's clear we have not yet reached that point. And if the prices of renewables continue to drop, then that point could potentially recede fast enough not to matter.

 

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