Regulators hold hearing on PATH line

By Associated Press


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Developers of a proposed multi-state power transmission line are asking Virginia regulators to delay the review schedule for the line aimed at meeting the region's growing demand for energy.

American Electric Power and Allegheny Energy asked the State Corporation Commission to extend proceedings on its request for the Virginia segment of the $2.1 billion Potomac-Appalachian Transmission Highline, or PATH. Regulators indicated they plan to rule on the delay soon.

The proposed 275-mile, 765-kilovolt power line would run from AEP's John Amos plant in West Virginia, 31 miles across three counties in northern Virginia, to a substation near Kemptown, Maryland.

The companies want to update the application with new projections on increased energy demands along the East Coast by 2015 that were released in late December.

They have argued that the power line is needed to feed the Northeast's growing need for energy. The analyses found that PATH continues to be the best fix for overloading that's expected to start in 2015, the companies said.

PJM Interconnection, the transmission authority that manages the grid system for a 13-state region, said overloads and other issues could trigger blackouts and brownouts in the region by mid-2015 if the line is not built.

However, opponents of the line have argued that electrical demand projections are inaccurate and that the line would only serve to continue the use of coal for electrical generation.

Similar requests are pending in West Virginia and Maryland.

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Duke Energy will spend US$25bn to modernise its US grid

Duke Energy Clean Energy Strategy targets smart grid upgrades, wind and solar expansion, efficient gas, and high-reliability nuclear, cutting CO2, boosting decarbonization, and advancing energy efficiency and reliability for the Carolinas.

 

Key Points

A plan investing in smart grids, renewables, gas, and nuclear to cut CO2 and enhance reliability and efficiency by 2030.

✅ US$25bn smart grid upgrades; US$11bn renewables and gas

✅ 40% CO2 reduction and >80% low-/zero-carbon generation by 2030

✅ 2017 nuclear fleet 95.64% capacity factor; ~90 TWh carbon-free

 

The US power group Duke Energy plans to invest US$25bn on grid modernization over the 2017-2026 period, including the implementation of smart grid technologies to cope with the development of renewable energies, along with US$11bn on the expansion of renewable (wind and solar) and gas-fired power generation capacities.

The company will modernize its fleet and expects more than 80% of its power generation mix to come from zero and lower CO2 emitting sources, aligning with nuclear and net-zero goals, by 2030. Its current strategy focuses on cutting down CO2 emissions by 40% by 2030. Duke Energy will also promote energy efficiency and expects cumulative energy savings - based on the expansion of existing programmes - to grow to 22 TWh by 2030, i.e. the equivalent to the annual usage of 1.8 million households.

#google#

Duke Energy’s 11 nuclear generating units posted strong operating performance in 2017, as U.S. nuclear costs hit a ten-year low, providing the Carolinas with nearly 90 billion kilowatt-hours of carbon-free electricity – enough to power more than 7 million homes.

Globally, China's nuclear program remains on a steady development track, underscoring broader industry momentum.

“Much of our 2017 success is due to our focus on safety and work efficiencies identified by our nuclear employees, along with ongoing emphasis on planning and executing refueling outages to increase our fleet’s availability for producing electricity,” said Preston Gillespie, Duke Energy chief nuclear officer.

Some of the nuclear fleet’s 2017 accomplishments include, as a new U.S. reactor comes online nationally:

  • The 11 units achieved a combined capacity factor of 95.64 percent, second only to the fleet’s 2016 record of 95.72 percent, marking the 19th consecutive year of attaining a 90-plus percent capacity factor (a measure of reliability).
  • The two units at Catawba Nuclear Station produced more than 19 billion kilowatt-hours of electricity, and the single unit at Harris Nuclear Plant generated more than 8 billion kilowatt-hours, both setting 12-month records.
  • Brunswick Nuclear Plant unit 2 achieved a record operating run.
  • Both McGuire Nuclear Station units completed their shortest refueling outages ever and unit 1 recorded its longest operating run.
  • Oconee Nuclear Station unit 2 achieved a fleet record operating run.

The Robinson Nuclear Plant team completed the station’s 30th refueling outage, which included a main generator stator replacement and other life-extension activities, well ahead of schedule.

“Our nuclear employees are committed to providing reliable, clean electricity every day for our Carolinas customers,” added Gillespie. “We are very proud of our team’s 2017 accomplishments and continue to look for additional opportunities to further enhance operations.”

 

 

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More Polar Vortex 2021 Fallout (and Texas Two-Step): Monitor For ERCOT Identifies Improper Payments For Ancillary Services

ERCOT Ancillary Services Clawback and VOLL Pricing summarize PUCT and IMM actions on load shed, real-time pricing adders, clawbacks, and settlement corrections after the 2021 winter storm in the Texas power grid market.

 

Key Points

Policies addressing clawbacks for unprovided AS and correcting VOLL-based price adders after load shed ended in ERCOT.

✅ PUCT ordered clawbacks for ancillary services not delivered.

✅ IMM urged price correction after firm load shed ceased.

✅ ERCOT's VOLL adder raised costs by $16B during 32 hours.

 

Potomac Economics, the Independent Market Monitor (IMM) for the Electric Reliability Council of Texas (ERCOT), filed a report with the Public Utility Commission of Texas (PUCT) that certain payments were made by ERCOT for Ancillary Services (AS) that were not provided, even as ERCOT later issued a winter reliability RFP to procure capacity during subsequent seasons.

According to the IMM (emphasis added):

There were a number of instances during the operating days outlined above in which AS was not provided in real time because of forced outages or derations. For market participants that are not able to meet their AS responsibility, typically the ERCOT operator marks the short amount in the software. This causes the AS responsibility to be effectively removed and the day-ahead AS payment to be clawed back in settlement. However, the ERCOT operators did not complete this task during the winter event, echoing issues like the Ontario IESO phantom demand that cost customers millions, and therefore the "failure to provide" settlements were not invoked in real time.

Removing the operator intervention step and automating the "failure to provide" settlement was contemplated in NPRR947: Clarification to Ancillary Service Supply Responsibility Definition and Improvements to Determining and Charging for Ancillary Service Failed Quantities; however, the NPRR was withdrawn in August 2020 amid ongoing market reform discussions because of the system cost, some complexities related to AS trades, and the implementation of real-time co-optimization.

Invoking the "failure to provide" settlement for all AS that market participants failed to provide during the operating days outlined above will produce market outcomes and settlements consistent with underlying market principles. In this case, the principle is that market participants should not be paid for services that they do not provide, even as a separate ruling found power plants exempt from providing electricity in emergencies under Texas law, underscoring the distinction between obligations and settlements. Whether ERCOT marked the short amount in real-time or not should not affect the settlement of these ancillary services.

On March 3, 2021, the PUCT ordered (a related press release is here) that:

ERCOT shall claw back all payments for ancillary service that were made to an entity that did not provide its required ancillary service during real time on ERCOT operating days starting February 14, 2021 and ending on February 19,2021.

On March 4, 2021, the IMM filed another report and recommended that:

the [PUCT] direct ERCOT to correct the real-time prices from 0:00 February 18,2021, to 09:00 February 19, 2021, to remove the inappropriate pricing intervention that occurred during that time period.

The IMM approvingly noted the PUCT's February 15, 2021 order, which mandated that real-time energy prices reflect firm load shed by setting prices at the value of lost load (VOLL).1

According to the IMM (emphasis added):

This is essential in an energy-only market, like ERCOT's, where the Texas power grid faces recurring crisis risks, because it provides efficient economic signals to increase the electric generation needed to restore the load and service it reliably over the long term.

Conversely, it is equally important that prices not reflect VOLL when the system is not in shortage and load is being served, and experiences in capacity markets show auction payouts can fall sharply under different conditions. The Commission recognized this principle in its Order, expressly stating it is only ERCOT's out-of-market shedding firm load that is required to be reflected in prices. Unfortunately, ERCOT exceeded the mandate of the Commission by continuing to set process at VOLL long after it ceased the firm load shed.

ERCOT recalled the last of the firm load shed instructions at 23:55 on February 17, 2021. Therefore, in order to comply with the Commission Order, the pricing intervention that raised prices to VOLL should have ended immediately at that time. However, ERCOT continued to hold prices at VOLL by inflating the Real-Time On-Line Reliability Deployment Price Adder for an additional 32 hours through the morning of February 19. This decision resulted in $16 billion in additional costs to ERCOT's market, prompting legislative bailout proposals in Austin, of which roughly $1.5 billion was uplifted to load-serving entities to provide make-whole payments to generators for energy that was not needed or produced.

However, at its March 5, 2021, open meeting (related discussion begins around minute 20), although the PUCT acknowledged the "good points" raised by the IMM, the PUCT was not willing to retrospectively adjust its real-time pricing for this period out of concerns that some related transactions (ICE futures and others) may have already settled and for unintended consequences of such retroactive adjustments.  

 

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Alberta Electricity market needs competition

Alberta Electricity Market faces energy-only vs capacity debate as transmission, distribution, and administration fees surge; rural rates rise amid a regulated duopoly of investor-owned utilities, prompting calls for competition, innovation, and lower bills.

 

Key Points

Alberta's electricity market is an energy-only system with rising delivery charges and limited rural competition.

✅ Energy-only design; capacity market scrapped

✅ Delivery charges outpace energy on monthly bills

✅ Rural duopoly limits competition and raises rates

 

Last week, Alberta’s new Energy Minister Sonya Savage announced the government, through its new electricity rules, would be scrapping plans to shift Alberta’s electricity to a capacity market and would instead be “restoring certainty in the electricity system.”


The proposed transition from energy only to a capacity market is a contentious subject as a market reshuffle unfolds across the province that many Albertans probably don’t know much about. Our electricity market is not a particularly glamorous subject. It’s complicated and confusing and what matters most to ordinary Albertans is how it affects their monthly bills.


What they may not realize is that the cost of their actual electricity used is often just a small fraction of their bill amid rising electricity prices across the province. The majority on an average electricity bill is actually the cost of delivering that electricity from the generator to your house. Charges for transmission, distribution and franchise and administration fees are quickly pushing many Alberta households to the limit with soaring bills.


According to data from Alberta’s Utilities Consumer Advocate (UCA), and alongside policy changes, in 2004 the average monthly transmission costs for residential regulated-rate customers was below $2. In 2018 that cost was averaging nearly $27 a month. The increase is equally dramatic in distribution rates which have more than doubled across the province and range wildly, averaging from as low as $10 a month in 2004 to over $80 a month for some residential regulated-rate customers in 2018.


Where you live determines who delivers your electricity. In Alberta’s biggest cities and a handful of others the distribution systems are municipally owned and operated. Outside those select municipalities most of Alberta’s electricity is delivered by two private companies which operate as a regulated duopoly. In fact, two investor-owned utilities deliver power to over 95 per cent of rural Alberta and they continue to increase their share by purchasing the few rural electricity co-ops that remained their only competition in the market. The cost of buying out their competition is then passed on to the customers, driving rates even higher.


As the CEO of Alberta’s largest remaining electricity co-op, I know very well that as the price of materials, equipment and skilled labour increase, the cost of operating follows. If it costs more to build and maintain an electricity distribution system there will inevitably be a cost increase passed on to the consumer. The question Albertans should be asking is how much is too much and where is all that money going with these private- investor-owned utilities, as the sector faces profound change under provincial leadership?


The reforms to Alberta’s electricity system brought in by Premier Klein in the late 1900s and early 2000s contributed to a surge in investment in the sector and led to an explosion of competition in both electricity generation and retail. 


More players entered the field which put downward pressure on electricity rates, encouraged innovation and gave consumers a competitive choice, even as a Calgary electricity retailer urged the government to scrap the overhaul. But the legislation and regulations that govern rural electricity distribution in Alberta continue to facilitate and even encourage the concentration of ownership among two players which is certainly not in the interests of rural Albertans.


It is also not in the spirit of the United Conservative Party platform commitment to a “market-based” system. A market-based system suggests more competition. Instead, what we have is something approaching a monopoly for many Albertans. The UCP promised a review of the transition to a capacity market that would determine which market would be best for Alberta, and through proposed electricity market changes has decided that we will remain an energy-only market.
Consumers in rural Alberta need electricity to produce the goods that power our biggest industries. Instead of regulating and approving continued rate increases from private multinational corporations, we need to drive competition and innovation that can push rates down and encourage growth and investment in rural-based industries and communities.

 

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Nevada on track to reach RPS mandate of 50% renewable electricity by 2030: report

Nevada Renewable Portfolio Standard 2030 targets 50% clean energy, advancing solar, geothermal, and wind, cutting GHG emissions, phasing out coal, and expanding storage, EV infrastructure, and in-state renewables under PUCN oversight and tax abatements.

 

Key Points

A state mandate requiring 50% of electricity from renewables by 2030, driving solar, geothermal, wind, and storage.

✅ 50% clean power by 2030; 100% carbon-free target by 2050

✅ Growth in solar, geothermal, wind; coal phase-out; natural gas remains

✅ RETA incentives spur 6.1 GW capacity, jobs, and in-state investment

 

Nevada is on track to meet its Renewable Portfolio Standard of 50% of electricity generated by renewable energy sources by 2030, according to the Governor's Office of Energy's annual Status of Energy Report.

Based on compliance reports the Public Utilities Commission of Nevada has received, across all providers, about 20% of power is currently generated by renewable resources, and, nationally, renewables ranked second in 2020 as filings show Nevada's investor-owned utility and other power providers have plans to reach the state's ambitious RPS of 50% by 2030, according to the report released Jan. 28.

"Because transportation and electricity generation are Nevada's two largest contributors to greenhouse gas emissions, GOE's program work in 2021 underscored our focus on transportation electrification and reaching the state's legislatively required renewable portfolio standard," GOE Director David Bobzien said in a statement Jan. 28. "While electricity generated from renewable resources currently accounts for about 25% of the state's electricity, a share similar to projections that renewables will soon provide about one-fourth of U.S. electricity overall, we continue to collaborate with the Public Utilities Commission of Nevada, electricity providers, the renewable energy industry and conservation organizations to ensure Nevada reaches our target of 50% clean energy by 2030."

The state's RPS, enacted in 1997 and last modified in 2019, requires an increase in renewable energy, starting with 22% in 2020 and increasing to 50% by 2030. The increase in renewables will reduce GHG emissions and help the state reach its goal of 100% carbon-free power by 2050, while states like Rhode Island have a 100% by 2030 plan, highlighting varying timelines.

Renewable additions
The state added 1.332 GW of renewable capacity in 2021 as part of the Renewable Energy Tax Abatement program, at a time when U.S. renewable energy hit a record 28% in April, for a total renewable capacity of 6.117 GW, according to the report.

The RETA program awards partial sales and use tax and partial property-tax abatements to eligible renewable energy facilities, which increase Nevada's tax revenue and create jobs in a growing industry. Eligible projects must employ at least 50% Nevada workers, pay 175% of Nevada's average wage during construction, and offer health care benefits to workers and their dependents.

Since its adoption in 2010, the GOE has approved 60 projects, including large-scale solar PV, solar thermal, biomass, geothermal and wind projects throughout the state, according to the report. Projects granted abatements in 2021 include:

  • 100-MW Citadel Solar Project
  • 150-MW Dry Lake Solar + Storage Project
  • 714-MW Gemini Solar Project
  • 55-MW North Valley Power Geothermal Project
  • 113-MW Boulder Flats Solar Project
  • 200-MW Arrow Canyon Solar Project

"Nevada does not produce fossil fuels of any significant amount, and gasoline, jet fuel and natural gas for electricity or direct use must be imported," according to the report. "Transitioning to domestically produced renewable resources and electrified transportation can provide cost savings to Nevada residents and businesses, as seen in Idaho's largely renewable mix today, while reducing GHG emissions. About 86% of the fuel for energy that Nevada consumes comes from outside the state."

Phasing out coal plants
Currently, more than two-thirds of the state's electricity is produced by natural gas-fired power plants, with renewables covering most of the remaining generation, according to the report. Nevada continues to phase out its remaining coal power plants, as renewables surpassed coal nationwide in 2022, which provide less than 10% of produced electricity.

"Nevada has seen a significant increase in capturing its abundant renewable energy resources such as solar and geothermal," according to the report. "Renewable energy production continues to grow, powering Nevada homes and business and serves to diversify the state's economy by exporting solar and geothermal to neighboring states, as California neared 100% renewable electricity for the first time. Nevada has more than tripled its renewable energy production since 2011."

 

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Yukon eyes connection to B.C. electricity grid

Yukon-BC Electricity Intertie could link Yukon to BC's hydroelectric power, enabling renewable energy integration, net-zero grid goals by 2035, transmission expansion for mining, and stronger Arctic energy security through a coast-to-coast network.

 

Key Points

A link connecting Yukon's grid to BC hydro to import renewables, cut emissions, and strengthen northern energy security.

✅ Enables renewable imports to meet 2035 net-zero electricity target

✅ Supports mining growth with reliable, low-carbon power

✅ Enhances Arctic energy security via national grid integration

 

Yukon's energy minister says Canada's push for more green energy and a net-zero electricity grid should spark renewed interest in connecting the territory's power to British Columbia, home to the Electric Highway network.

Minister of Energy, Mines and Resources John Streicker says linking the territory's power grid to the south would help with the national move to renewable energy, including new wind turbines being added in the Yukon, support the mineral extraction required for green projects, and improve northern energy and Arctic security.

"We're getting to the moment in time when we will want an electricity grid which stretches from coast to coast to coast. … I think that the moment is coming for this — it's sort of a nation-building moment. And I think that from the Yukon's perspective, we're very interested," Streicker said in an interview.

The idea of a link, originally proposed to span 763 kilometres between Whitehorse and Iskut, B.C., was first floated in 2016 but sat on the shelf after a viability study put the price tag at as much as $1.7 billion, even as a study indicates B.C. may need to double its power output to electrify all road vehicles.


Two years later, Yukon's then-energy-minister Ranj Pillai — now premier — mused again about the possibility of connecting to power from B.C., where green energy ambitions include the Site C hydro dam.

The idea appeared to have been resurrected at this year's Western Premiers' Conference in June, with both Pillai and B.C. Premier David Eby publicly mentioning early conversations about grid development and interties.

At the conference, Eby said British Columbia was fortunate to have the ability to support other jurisdictions with its hydro electricity.

"So certainly part of the conversation was how do we support each other in sharing our strength, including emerging hydrogen projects across the province?" he said.

"And one of those that British Columbia was able to put on the table is if we can find ways to enter ties with, for example, with the Yukon, to support them in their efforts to access more electricity to grow their economy and decarbonize their electrical grid, then that's very good news for everybody."

The federal government has set a target of making the country's electricity grid net-zero by 2035, while jurisdictions like the N.W.T. plan for more residents to drive electric vehicles as part of the transition.

 

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How Canada can capitalize on U.S. auto sector's abrupt pivot to electric vehicles

Canadian EV Manufacturing is accelerating with GM, Ford, and Project Arrow, integrating cross-border supply chains, battery production, rare-earths like lithium and cobalt, autonomous tech, and home charging to drive clean mobility and decarbonization.

 

Key Points

Canadian EV manufacturing spans electric and autonomous vehicles, domestic batteries, and integrated US-Canada trade.

✅ GM and Ford retool plants for EVs and autonomous production

✅ Project Arrow showcases Canadian zero-emission supply capabilities

✅ Lithium, cobalt, and battery hubs target cross-border resilience

 

The storied North American automotive industry, the ultimate showcase of Canada’s high-tensile trade ties with the United States and emerging Canada-U.S. collaboration on EVs momentum, is about to navigate a dramatic hairpin turn.

But as the Big Three veer into the all-electric, autonomous era, some Canadians want to seize the moment and take the wheel.

“There’s a long shadow between the promise and the execution, but all the pieces are there,” says Flavio Volpe, president of the Automotive Parts Manufacturers’ Association.

“We went from a marriage on the rocks to one that both partners are committed to. It could be the best second chapter ever.”

Volpe is referring specifically to GM, which announced late last month an ambitious plan to convert its entire portfolio of vehicles to an all-electric platform by 2035.

But that decision is just part of a cascading transformation across the industry, marking an EV inflection point with existential ramifications for one of the most tightly integrated cross-border manufacturing and supply-chain relationships in the world.

China is already working hard to become the “source of a new way” to power vehicles, President Joe Biden warned last week.

“We just have to step up.”

Canada has both the resources and expertise to do the same, says Volpe, whose ambitious Project Arrow concept — a homegrown zero-emissions vehicle named for the 1950s-era Avro interceptor jet — is designed to showcase exactly that, as recent EV assembly deals in Canada underscore.

“We’re going to prove to the market, we’re going to prove to the (manufacturers) around the planet, that everything that goes into your zero-emission vehicle can be made or sourced here in Canada,” he says.

“If somebody wants to bring what we did over the line and make 100,000 of them a year, I’ll hand it to them.”

GM earned the ire of Canadian auto workers in 2018 by announcing the closure of its assembly plant in Oshawa, Ont. It later resurrected the facility with a $170-million investment to retool it for autonomous vehicles.

“It was, ‘You closed Oshawa, how dare you?’ And I was one of the ‘How dare you’ people,” Volpe says.

“Well, now that they’ve reopened Oshawa, you sit there and you open your eyes to the commitment that General Motors made.”

Ford, too, has entered the fray, promising $1.8 billion to retool its sprawling landmark facility in Oakville, Ont., to build EVs.

It’s a leap of faith of sorts, considering what market experts say is ongoing consumer doubt about EVs and EV supply shortages that drive wait times.

“Range anxiety” — the persistent fear of a depleted battery at the side of the road — remains a major concern, even though it’s less of a problem than most people think.

Consulting firm Deloitte Canada, which has been tracking automotive consumer trends for more than a decade, found three-quarters of future EV buyers it surveyed planned to charge their vehicles at home overnight.

“The difference between what is a perceived issue in a consumer’s mind and what is an actual issue is actually quite negligible,” Ryan Robinson, Deloitte’s automotive research leader, says in an interview.

“It’s still an issue, full stop, and that’s something that the industry is going to have to contend with.”

So, too, is price, especially with the end of the COVID-19 pandemic still a long way off. Deloitte’s latest survey, released last month, found 45 per cent of future buyers in Canada hope to spend less than $35,000 — a tall order when most base electric-vehicle models hover between $40,000 and $45,000.

“You put all of that together and there’s still, despite the electric-car revolution hype, some major challenges that a lot of stakeholders that touch the automotive industry face,” Robinson says.

“It’s not just government, it’s not just automakers, but there are a variety of stakeholders that have a role to play in making sure that Canadians are ready to make the transition over to electric mobility.”

With protectionism no longer a dirty word in the United States and Biden promising to prioritize American workers and suppliers, the Canadian government’s job remains the same as it ever was: making sure the U.S. understands Canada’s mission-critical role in its own economic priorities.

“We’re both going to be better off on both sides of the border, as we have been in the past, if we orient ourselves toward this global competition as one force,” says Gerald Butts, vice-chairman of the political-risk consultancy Eurasia Group and a former principal secretary to Prime Minister Justin Trudeau.

“It served us extraordinarily well in the past … and I have no reason to believe it won’t serve us well in the future.”

Last month, GM announced a billion-dollar plan to build its new all-electric BrightDrop EV600 van in Ingersoll, Ont., at Canada’s first large-scale EV manufacturing plant for delivery vehicles.

That investment, Volpe says, assumes Canada will take the steps necessary to help build a homegrown battery industry — with projects such as a new Niagara-region battery plant pointing the way — drawing on the country’s rare-earth resources like lithium and cobalt that are waiting to be extracted in northern Ontario, Quebec and elsewhere.

Given that the EV industry is still in his infancy, the free market alone won’t be enough to ensure those resources can be extracted and developed, he says.

“General Motors made a billion-dollar bet on Canada because it’s going to assume that the Canadian government — this one or the next one — is going to commit” to building that business.

Such an investment would pay dividends well beyond the auto sector, considering the federal Liberal government’s commitment to lowering greenhouse gas-emissions, including a 2035 EV mandate, and meeting targets set out in the Paris climate accord.

“If you make investments in renewable energy and utility storage using battery technology, you can build an industry at scale that the auto industry can borrow,” Volpe says.

Major manufacturing, retail and office facilities would be able to use that technology to help “shave the peak” off Canada’s GHG emissions and achieve those targets, all the while paving the way for a self-sufficient electric-vehicle industry.

“You’d be investing in the exact same technology you’d use in a car.”

There’s one problem, says Robinson: the lithium-ion batteries on roads right now might not be where the industry ultimately lands.

“We’re not done with with battery technology,” Robinson says. “What you don’t want to do is invest in a technology that is that is rapidly evolving, and could potentially become obsolete going forward.”

Fuel cells — energy-efficient, hydrogen-powered units that work like batteries, but without the need for constant recharging — continue to be part of the conversation, he adds.

“The amount of investment is huge, and you want to be sure that you’re making the right decision, so you don’t find yourself behind the curve just as all that capacity is coming online.”

 

 

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