Park service urged to reject power line

India Power Sector Crisis: a tangled market of underused plants, coal shortages, cross-subsidies, high transmission losses, and weak PPAs, requiring deregulation, power exchanges, and cost-reflective tariffs to fix insolvency and outages.

Key Points

India power market failure from subsidies, coal shortages, and losses, needing deregulation and reflective pricing.

✅ Deregulate to enable spot trading on power exchanges

✅ End cross-subsidies; charge cost-reflective tariffs

✅ Secure coal supply; cut T&D losses and theft

India's electricity industry is in a financial and political tangle.

Power producers sit on thousands of megawatts of underutilized plant, while consumers face frequent power cuts, both planned and unplanned.

Financially troubled generators struggle to escape insolvency proceedings. The state-owned banks that have mostly financed power utilities fear that debts of troubled utilities totaling 1.74 trillion rupees will soon go bad.

Aggressive bidding for supply contracts and slower-than-expected demand growth, including a recent demand slump in electricity use, is the root cause. The problems are compounded by difficulties in securing coal and other fuels, high transmission losses, electricity theft and cash-starved distribution companies.

But India's 36 state and union territory governments are contributing mightily to this financial and economic mess. They persist with populist cross-subsidies -- reducing charges for farmers and households at the cost of nonagricultural businesses, especially energy-intensive manufacturing sectors such as steel.

The states refuse to let go of their control over how electricity is produced, distributed and consumed. And they are adamant that true markets, with freedom for large industrial users to buy power at market-determined rates from whichever utility they want at power exchanges -- will not become a reality in India.

State politicians are driven mainly by the electoral need to appease farmers, India's most important vote bank, who have grown used to decades of nearly-free power.

New Delhi is therefore relying on short-term fixes instead of attempting to overhaul a defunct system. Users must pay the real cost of their electricity, as determined by a properly integrated national market free of state-level interference if India's power mess is to be really addressed.

As of Aug. 31, the country's total installed production capacity was 344,689 MW, underscoring its status as the third-largest electricity producer globally by output. Out of that, thermal power comprising coal, gas and diesel accounted for 64%, hydropower 13% and renewables accounted for 20%. Commercial and industrial users accounted for 55% of consumption followed by households on 25% and the remaining 20% by agriculture.

Coal-fired power generation, which contributes roughly 90% of thermal output and the bulk of the financially distressed generators, is the most troubled segment as it faces a secular decline in tariffs due to increasing competition from highly subsidized renewables (which also benefit from falling solar panel costs), coal shortages and weak demand.

The Central Electricity Act (CEA) 2003 opened the gates of the country's power sector for private players, who now account for 45% of generating capacity.

But easy credit, combined with an overconfident estimation of the risks involved, emboldened too many investors to pile in, without securing power purchase agreements (PPAs) with distribution companies.

As a result, power capacity grew at an annual compound rate of 11% compared to demand at 6% in the last decade leading to oversupply.

This does not mean that the electricity market is saturated. Merely that there are not enough paying customers. Distributors have plenty of consumers who will not or cannot pay, even though they have connections. There is huge unmet demand for power. There are 32 million Indian homes -- roughly 13% of the total -- mostly rural and poor with no access to electricity.

Moreover, consumption by those big commercial and industrial users which do not enjoy privileged rates is curbed by high prices, driven up by the cost of subsidizing others, extra charges on exchange-traded power and transmission and distribution losses (including theft) of 20-30%.

With renewables increasingly becoming cheaper, financially stressed distributors are avoiding long-term power purchase agreements, preferring spot markets. Meanwhile, coal shortages force generators to buy expensive imported coal supplies or cut output. The operating load for most private generators, which suffer particularly acute coal shortages in compared to state-owned utilities, has fallen from 84% in 2009-2010 to 55% now.

Smoothing coal supplies should be the top priority. Often coal is denied to power generators without long-term purchase contracts. Such discrimination in coal allocation prevails -- because the seller (state-run Coal India and its numerous subsidiaries) is an inefficient monopolist which cannot produce enough and rations coal supplies, favoring state-run generators over private.

To help power producers, New Delhi plans measures including auctioning power sales contracts with assured access to coal. However, even though coal and electricity shortages eased recently, such short-term fixes won't solve the problem. With electricity prices in secular decline, distributors are not seeking long-term supply contracts -- rather they are often looking for excuses to get out of existing agreements.

India needs a fundamental two-step reform. First, the market must be deregulated to allow most bulk suppliers and users to move to power trading exchanges, which currently account for just 10% of the market.

This would lead to genuine price discovery in a spot market and, in time, lead to the trading of electricity futures contracts. That would help in consumers and producers hedge their respective costs and revenues and safeguard their economic positions without any need for government intervention.

The second step to a healthy electricity industry is for consumers to pay the real cost of power. Cross-subsidization must end. That would promote optimal electricity use, innovation and environmental protection. Farmers enjoying nearly-free power create ecological problems by investing in water-guzzling crops such as rice and sugar cane.

Most industrial consumers, who do not have power supply privileges, have their businesses distorted and delayed by high prices. Lowering their costs would encourage power-intensive manufacturing to expand, and in the process, boost electricity demand and improve capacity utilization.

Of course, cutting theft is central to making consumers pay their way. Government officials must stop turning a blind eye to theft, especially when such transmission and distribution losses average 20%.

Politicians who want to continue subsidizing farmers or assist the poor can do so by paying cash out directly to their bank accounts, instead of wrongly relying on the power sector.

Such market-oriented reforms have long been blocked by state-level politicians, who now enjoy the influence born of operating subsidies and interfering in the sector. New Delhi must address this opposition. Narendra Modi, as a self-styled reforming prime minister, should have the courage to bite this bullet and convince state governments (starting with those ruled by his Bharatiya Janata Party) to reform. To encourage cooperation, he could offer states securing real improvements an increased share of centrally collected taxes.

Ritesh Kumar Singh is to be the chief economist of the new policy research and advocacy company Indonomics Consulting. He is former assistant director of the Finance Commission of India.

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Toyota and Honda Moving e delivers hydrogen backup power via a fuel cell bus, portable batteries, and power exporters for disaster relief, emergency electricity, and grid outage support near charging stations and microgrids.

Key Points

A hydrogen mobile power system using a fuel cell bus and batteries to supply emergency electricity during disasters.

✅ Fuel cell bus outputs up to 18 kW, 454 kWh capacity

✅ Portable batteries and power exporter deliver site power

✅ Supports disaster relief near hydrogen charging stations

Without the uninterrupted supply of power and electricity, modern economies would be unable to function. A blackout can impact everything from transport to health care, communication, and even water supplies, as seen in a near-blackout in Japan that strained the grid. It is one of the key security concerns for every government on earth, a point underscored by Fatih Birol on electricity options during the pandemic, and the growth in the market for backup power reflects that fact. In 2018, the global Backup Power market was $14.9 billion and is expected to reach $22 billion by the end of 2025, growing at a CAGR of 5.0 percent between 2019 and 2025.

It is against this backdrop that Toyota and Honda have come up with a new and innovative solution to providing electricity during disasters. The two transport giants have launched a mobile power generation system that consists of a fuel cell bus that can carry a large amount of hydrogen, aligned with Japan's hydrogen energy system efforts underway, portable external power output devices, and portable batteries to disaster zones. The system, which is called ‘Moving e’ includes Toyota’s charging station fuel cell bus, Honda’s power exporter 9000 portable external power output device, two types of Honda’s portable batteries, and a Honda Mobile Power Pack Charge & Supply Concept charger/discharger for MPP. 

In simple terms, the bus would drive to a disaster zone, and while other approaches such as gravity energy storage are advancing, the portable batteries and power output devices would be used to extract electricity from the fuel cell bus and provide it wherever it is needed. The bus itself can generate 454kWh and has a maximum output of 18kW. That is more than enough energy to supply electricity for large indoor areas such as an evacuation area. The bus is also fitted with space for people to nap or rest during a disaster.

The two companies plan to test the effectiveness of the Moving e at multiple municipalities and businesses. These locations will have to be within 100km of a hydrogen station that is capable of refueling the bus. If the bus has to drive 200km, then its electricity supply to the disaster zone would drop from 490kwh to 240kWh. While there aren’t currently enough hydrogen stations to make this a realistic scenario for all disaster zones, especially as countries push for hydrogen-ready power plants in Germany and related infrastructure, hydrogen is growing increasingly competitive with gasoline and diesel.

While gas generators are still considered more reliable and generally cheaper than backup batteries for home use, cleaner backup power is growing increasingly popular, and novel storage like power-to-gas in Europe is also advancing across grids. This latest development by Toyota and Honda is another step forward for the battery and fuel cell industry, with initiatives like PEM hydrogen R&D in China accelerating progress, – especially considering the meteoric rise of hydrogen energy in recent years.
 

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Enbridge Alberta CCS Project targets carbon capture and storage in Alberta, capturing emissions from industrial emitters to advance net-zero goals, leveraging carbon pricing, regulatory support, and a hub model despite a key partner's exit.

Key Points

A proposed Alberta carbon capture hub by Enbridge to store industrial emissions and support net-zero targets.

✅ Seeks emitters across power, oil and gas, and heavy industry

✅ Backed by carbon pricing, regulation, and net-zero mandates

✅ Faces high capex, storage risk, and anchor-tenant uncertainty

Enbridge Inc., a Canadian energy giant, is digging its heels in on its proposed carbon capture and storage (CCS) project in Alberta. This comes despite the recent withdrawal of Capital Power, a major potential emitter that was expected to utilize the CCS technology. Enbridge maintains the project remains viable, but questions linger about its future viability without a cornerstone anchor.

The CCS project, envisioned as a major carbon capture hub in Alberta, aimed to capture emissions from industrial facilities and permanently store them underground. This technology has the potential to play a significant role in reducing greenhouse gas emissions and mitigating the effects of climate change, alongside grid solutions like bridging the Alberta-B.C. electricity gap that can complement decarbonization efforts.

Capital Power's decision to shelve its $2.4 billion Genesee Generating Station project, which was designed to integrate with the CCS hub, threw a wrench into Enbridge's plans. The Genesee project was expected to be a key source of emissions for capture and storage, and its status is being weighed as Ottawa advances the federal coal plan to phase out unabated coal.

Enbridge, however, remains optimistic. The company cites ongoing discussions with other potential emitters interested in utilizing the CCS technology, amid new funding signals such as the U.S. DOE's $110M for CCUS that highlight momentum. They believe the project holds significant value despite Capital Power's departure.

"We are confident in the long-term viability of the project and continue to actively engage with potential customers," said Enbridge spokesperson Rachel Giroux. "Carbon capture and storage is a critical technology for achieving net-zero emissions, and we believe there is a strong business case for our CCS project."

Enbridge's confidence hinges on several factors. Firstly, they believe there is a growing appetite for CCS technology amongst industrial facilities facing increasing pressure to reduce their carbon footprint. Regulations and carbon pricing mechanisms, including new U.S. EPA power plant rules that test CCS readiness, could further incentivize companies to adopt CCS solutions.

Secondly, Enbridge highlights the potential for capturing emissions from not just power plants but also from other industrial sectors like oil and gas production and clean hydrogen projects in Canada, where reforming processes can generate CO2. This broader application could significantly increase the captured carbon volume and strengthen the project's economic viability.

However, skepticism remains. Critics point to the high upfront costs associated with CCS development and the nascent stage of the technology. They argue that without a guaranteed stream of captured emissions, the project might not be financially sound. Additionally, the long-term safety and effectiveness of large-scale carbon storage solutions remain under scrutiny.

The success of Enbridge's CCS project hinges on attracting new emitters. Replacing Capital Power's contribution will be a significant challenge. Enbridge will need to demonstrate the project's economic viability and navigate the complex regulatory landscape surrounding CCS technology.

The Alberta government's position on CCS is crucial. While the government has expressed support for the technology, the level of financial and regulatory incentives offered will significantly impact investor confidence, especially as the IEA net-zero outlook underscores Canada's need for much more electricity. A clear and stable policy framework will be essential for attracting emitters to the project.

The future of Enbridge's CCS project remains uncertain. Capital Power's withdrawal is a setback, but Enbridge's continued commitment suggests they believe the technology holds promise. Whether they can find enough emitters to justify the project's development will be a critical test. The outcome will have significant implications for the future of CCS technology in Alberta and Canada's broader efforts to achieve net-zero emissions, including Canada-Germany clean energy cooperation that seeks to scale low-carbon fuels.

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ADNOC Hydrogen Export Projects target global energy transition, courting investors and equity stakes for blue and green hydrogen, ammonia shipping, CCS at Ruwais, and long-term supply contracts across power, transport, and industrial sectors.

Key Points

ADNOC plans blue and green hydrogen exports, leveraging Ruwais, CCS, and ammonia to secure long-term supply.

✅ Blue hydrogen via gas reforming with CCS; ammonia for shipping.

✅ Green hydrogen from solar-powered electrolysis under development.

✅ Ruwais expansions and Fertiglobe ammonia tie-up target long-term supply.

Abu Dhabi is seeking investors to help build hydrogen-export facilities, as Middle Eastern oil producers plan to adopt cleaner energy solutions, sources told Bloomberg.

Abu Dhabi National Oil Company (ADNOC) is holding talks with energy companies for them to purchase equity stakes in the hydrogen projects, the sources referred, as Germany's hydrogen strategy signals rising import demand.

ADNOC, which already produces hydrogen for its refineries, also aims to enter into long-term supply contracts, as Canada-Germany clean energy cooperation illustrates growing cross-border demand, before making any progress with these investments.

Amid a global push to reduce greenhouse-gas emissions, the state-owned oil companies in the Gulf region seek to turn their expertise in exporting liquid fuel into shipping hydrogen or ammonia across the world for clean and universal electricity needs, transport, and industrial use.

Most of the ADNOC exports are expected to be blue hydrogen, created by converting natural gas and capturing the carbon dioxide by-product that can enable using CO2 to generate electricity approaches, according to Bloomberg.

The sources said that the Abu Dhabi-based company will raise its production of hydrogen by expanding an oil-processing plant and the Borouge petrochemical facility at the Ruwais industrial hub, supporting a sustainable electric planet vision, as the extra hydrogen will be used for an ammonia facility planned with Fertiglobe.

Abu Dhabi also plans to develop green hydrogen, similar to clean hydrogen in Canada initiatives, which is generated from renewable energy such as solar power.

Noteworthy to mention, in May 2021, ADNOC announced that it will construct a world-scale blue ammonia production facility in Ruwais in Abu Dhabi to contribute to the UAE's efforts to create local and international hydrogen value chains.

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Champlain Hudson Power Express connects Hydro-Québec hydropower to the New York grid via a 1.25 GW high voltage transmission line, enabling renewable energy imports, grid decarbonization, storage synergy, and reduced fossil fuel generation.

Key Points

A 1.25 GW cross-border transmission project delivering Hydro-Québec hydropower to New York City to displace fossil power.

✅ 1.25 GW buried HV line from Quebec to Astoria, Queens

✅ Supports renewable imports and grid decarbonization in NYC

✅ Enables two-way trade and reservoir storage synergy

Last week, Quebec Premier François Legault took to Twitter to celebrate after New York State authorities tentatively approved the first new transmission line in three decades, the Champlain Hudson Power Express, that would connect Quebec’s vast hydroelectric network to the northeastern U.S. grid.

“C’est une immense nouvelle pour l’environnement. De l’énergie fossile sera remplacée par de l’énergie renouvelable,” he tweeted, or translated to English: “This is huge news for the environment. Fossil fuels will be replaced by renewable energy.”

The proposed construction of a 1.25 gigawatt transmission line from southern Quebec to Astoria, Queens, known as the Champlain Hudson Power Express, ties into a longer term strategy by Hydro Québec: in the coming decade, as cities such as New York and Boston look to transition away from fossil fuel-generated electricity and decarbonize their grids, Hydro-Québec sees opportunities to supply them with energy from its vast network of 61 hydroelectric generating stations and other renewable power, as Quebec has closed the door on nuclear power in recent years.

Already, the provincial utility is one of North America’s largest energy producers, generating $2.3 billion in net income in 2020, and planning to increase hydropower capacity over the near term. Hydro-Quebec has said it intends to increase exports and had set a goal of reaching $5.2 billion in net income by 2030, though its forecasts are currently under review.

But just as oil and gas companies have encountered opposition to nearly every new pipeline, Hydro-Québec is finding resistance as it seeks to expand its pathways into major export markets, which are all in the U.S. northeast. Indeed, some fossil fuel companies that would be displaced by Hydro-Québec are fighting to block the construction of its new transmission lines.

“Linear projects — be it a transmission line or a pipeline or highway or whatever — there’s always a certain amount of public opposition,” Gary Sutherland, director of strategic affairs and stakeholder relations for Hydro-Québec, told the Financial Post, “which is a good thing because it makes the project developer ask the right questions.”

While Sutherland said he isn’t expecting opposition to the line into New York, he acknowledged Hydro-Québec also didn’t fully anticipate the opposition encountered with the New England Clean Energy Connect, a 1.2 gigawatt transmission line that would cost an estimated US$950 million and run from Quebec through Maine, eventually connecting to Massachusetts’ grid.

In Maine, natural gas and nuclear energy companies, which stand to lose market share, and also environmentalists, who oppose logging through sensitive habitat, both oppose the project.

In August, Maine’s highest court invalidated a lease for the land where the lines were slated to be built, throwing permits into question. Meanwhile, Calpine Corporation and Vistra Energy Corp., both Texas-based companies that operate natural gas plants in Maine, formed a political action committee called Mainers for Local Power. It has raised nearly US$8 million to fight the transmission line, according to filings with the Maine Ethics Commission.

Neither Calpine nor Vistra could be reached for comment by the time of publication.

“It’s been 30 years since we built a transmission line into the U.S. northeast,” said Sutherland. “In that time we have increased our exports significantly … but we haven’t been able to build out the corresponding transmission to get that energy from point A to point B.”

Indeed, since 2003, Hydro-Québec’s exports outside the province have grown from roughly two terrawatts per year to more than 30 terrawatts, including recent deals with NB Power to move more electricity into New Brunswick. The provincial utility produces around 210 terrawatts annually, but uses less than 178 terrawatts in Quebec.

Linear projects — be it a transmission line or a pipeline or highway or whatever — there’s always a certain amount of public opposition

In Massachusetts, it has signed contracts to supply 9.4 terrawatts annually — an amount roughly equivalent to 8 per cent of the New England region’s total consumption. Meanwhile, in New York, Hydro-Québec is in the final stages of negotiating a 25-year contract to sell 10.4 terawatts — about 20 per cent of New York City’s annual consumption.

In his tweets, Legault described the New York contract as being worth more than $20 billion over 25 years, although Hydro Québec declined to comment on the value because the contract is still under negotiation and needs approval by New York’s Public Services Commission — expected by mid-December.

Both regions are planning to build out solar and wind power to meet their growing clean energy needs and reach ambitious 2030 decarbonization targets. New York has legislated a goal of 70 per cent renewable power by that time, while Massachusetts has called for a 50 per cent reduction in emissions in the same period.

Hydro-Quebec signage is displayed on a manhole cover in Montreal. PHOTO BY BRENT LEWIN/BLOOMBERG FILES
According to a 2020 paper titled “Two Way Trade in Green Electrons,” written by three researchers at the Center for Energy and Environmental Policy Research at the Massachusetts’ Institute for Technology, Quebec’s hydropower, which like fossil fuels can be dispatched, will help cheaply and efficiently decarbonize these grids.

“Today transmission capacity is used to deliver energy south, from Quebec to the northeast,” the researchers wrote, adding, “…in a future low-carbon grid, it is economically optimal to use the transmission to send energy in both directions.”

That is, once new transmission lines and wind and solar power are built, New York and Massachusetts could send excess energy into Quebec where it could be stored in hydroelectric reservoirs until needed.

“This is the future of this northeast region, as New York state and New England are decarbonizing,” said Sutherland. “The only renewable energies they can put on the grid are intermittent, so they’re going to need this backup and right to the north of them, they’ve got Hydro-Québec as backup.”

Hydro-Québec already sells roughly 7 terrawatts of electricity per year into New York on the spot market, but Sutherland says it is constrained by transmission constraints that limit additional deliveries.

And because transmission lines can cost billions of dollars to build, he said Hydro-Québec needs the security of long-term contracts that ensure it will be paid back over time, aligning with its broader $185-billion transition strategy to reduce reliance on fossil fuels.

Sutherland expressed confidence that the Champlain Hudson Power Express project would be constructed by 2025. He noted its partners, Blackstone-backed Transmission Developers, have been working on the project for more than a decade, and have already won support from labour unions, some environmental groups and industry.

The project calls for a barge to move through Lake Champlain and the Hudson River, and dig a trench while unspooling and burying two high voltage cables, each about 10-12 centimetres in diameter. In certain sections of the Hudson River, known to have high concentrations of PCP pollutants, the cable would be buried underground alongside the river.

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Hinkley Point C dome lift marks a nuclear reactor milestone in Somerset, as EDF used Big Carl crane to place a 245-tonne steel roof, enabling 2027 startup amid costs, delays, and precision indoor welding.

Key Points

A 245-tonne dome lifted onto Hinkley Point C's first reactor, finishing the roof and enabling fit-out for a 2027 startup.

✅ 245-tonne steel dome lifted by Big Carl onto 44m-high reactor

✅ Indoor welding avoided weather defects seen at Flamanville

✅ Cost now £33bn; first power targeted by end of 2027

Engineers have lifted a steel roof onto a building which will house the first of two nuclear reactors at Hinkley Point in Somerset.

Hundreds of people helped with the delicate operation to get the 245-tonne steel dome into position.

It means the first reactor can be installed next year, ready to be switched on in June 2027.

Engineers at EDF said the "challenging job" was completed in just over an hour.

They first broke the ground on the new nuclear station in March 2017. Now, some 10,000 people work on what is Europe's largest building site.

Yet many analysts note that Europe is losing nuclear power even as demand for reliable energy grows.

They have faced delays from Covid restrictions and other recent setbacks, and the budget has doubled to £33bn, so getting the roof on the first of the two reactor buildings is a big deal.

EDF's nuclear island director Simon Parsons said it was a "fantastic night".

"Lifting the dome into place is a celebration of all the work done by a fantastic team. The smiles on people's faces this morning were something else.

"Now we can get on with the fitting of equipment, pipes and cables, including the first reactor which is on site and ready to be installed next year."

Nuclear minister Andrew Bowie hailed the "major milestone" in the building project, citing its role in the UK's green industrial revolution ambitions.

He said: "This is a key part of the UK Government's plans to revitalise nuclear."

But many still question whether Hinkley Point C will be worth all the money, especially after Hitachi's project freeze in Britain, with Roy Pumfrey of the Stop Hinkley campaign describing the project as "shockingly bad value".

Why lift the roof on?

The steel dome is bigger than the one on St Paul's Cathedral in London.

To lift it onto the 44-metre-high reactor building, they needed the world's largest land-based crane, dubbed Big Carl by engineers.

So why not just build the roof on top of the building?

The answer lies in a remote corner of Normandy in France, near a village called Flamanville.

EDF has been building a nuclear reactor there since 2007, ten years before they started in west Somerset.

The project is now a decade behind schedule and has still not been approved by French regulators.

Why? Because of cracks found in the precision welding on the roof of the reactor building.

In nuclear-powered France, they built the roof in situ, out in the open. 

Engineers have decided welding outside, exposed to wind and rain, compromised the high standards needed for a nuclear reactor.

So in Somerset they built a temporary workshop, which looks like a fair sized building itself. All the welding has been done inside, and then the completed roof was lifted into place.

Is it on time or on budget?

No, neither. When Hinkley C was first approved a decade ago, EDF said it would cost £14bn.

Four years later, in 2017, they finally started construction. By now the cost had risen to £19.5bn, and EDF said the plant would be finished by the end of 2025.

Today, the cost has risen to £33bn, and it is now hoped Hinkley C will produce electricity by the end of 2027.

"Nobody believes it will be done by 2027," said campaigner Roy Pumfrey.

"The costs keep rising, and the price of Hinkley's electricity will only get dearer," they added.

On the other hand, the increase in costs is not a problem for British energy bill payers, or the UK government.

EDF agreed to pay the full cost of construction, including any increases.

When I met Grant Shapps, then the UK Energy Secretary, at the site in April, he shrugged off the cost increases.

He said: "I think we should all be rather pleased it is not the British tax payer - it is France and EDF who are paying."

In return, the UK government agreed a set rate for Hinkley's power, called the Strike Price, back in 2013. The idea was this would guarantee the income from Hinkley Point for 35 years, allowing investors to get their money back.

Will it be worth the money?

Back in 2013, the Strike Price was set at £92.50 for each megawatt hour of power. At the time, the wholesale price of electricity was around £50/MWh, so Hinkley C looked expensive.

But since then, global shocks like the war in Ukraine have increased the cost of power substantially, and advocates argue next-gen nuclear could deliver smaller, cheaper, safer designs.

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