Plant earns high-powered honor: Coal group lauds safety, efficiency

Ford Oakville EV investment secures government funding, Unifor deal, and plant retooling, channeling $500 million plus $1.98 billion for Canadian electric vehicle manufacturing, Windsor engine contracts, and 2025 production, strengthening Ontario's auto industry.

Key Points

Government and Ford will retool Oakville for EVs, creating jobs under a Unifor deal and Windsor engine work.

✅ $500M government funding for plant retooling

✅ Ford commits $1.98B; five new EVs by 2025

✅ Unifor deal adds Windsor engine work, jobs

The federal government and Ontario have pledged to spend up to $500 million to make the Ford plant in Oakville, Ont., able to build electric vehicles, aligning with efforts to capitalize on the U.S. EV pivot underway.

The future of the plant has been a key question for Canada's automotive industry, as moves like GM's Ontario EV deal point to broader changes, ever since the Unifor union started negotiating with the automaker for a new three-year pact to cover the company's Canadian workforce.

The two sides struck a deal a few hours after a midnight strike deadline on Tuesday morning, one that will see the company commit $1.98 billion to build five new electric vehicles and an engine contract that could yield new EV jobs in Windsor, Ont.

Ford has previously committed to spending $11 billion US to develop and manufacture electric vehicles, but so far all of that money was earmarked for Ford plants in Mexico and the company's home state of Michigan.

"With Oakville gaining such a substantial portion of Ford's planned investment, the assembly plant and its workers are better set for employment going forward," said Sam Fiorani, vice-president of global forecasting at AutoForecast Solutions.

Unifor's 'unique' Ford deal includes 5 new electric vehicles in Oakville, engine for Windsor plants
Currently, the plant builds the Ford Edge and Lincoln Nautilus, but concerns over the plant's future emerged earlier this year when a report suggested Ford was contemplating scrapping the Edge altogether. The new vehicles will come as welcome news for the plant, even as Fiorani says he worries that demand for the electric vehicles (EV) has so far not lived up to the hype.

"The EV market is coming, and Ford looks to be preparing for it. However, the demand is just not growing in line with the proposed investment from all vehicle manufacturers," he said.

Plant needs upgrade first
And the plant can't simply flip a switch and start building an entirely new type of vehicle. It will require a major retooling, and that will require time — and cash — to happen, which is where government cash comes in, as seen with a Niagara Region battery plant supporting the EV supply chain.

As first reported by the Toronto Star, the two branches of government have committed to spent up to $500 million combined to upgrade the plant so that it can build electric vehicles.

"The retooling will begin in 2024 with vehicles rolling off the line in 2025," Unifor president Jerry Dias said. "So we know this is a decades-long commitment."

It's not clear what portion of the cash will come from what branch of government, but CBC News has previously reported that Wednesday's throne speech is expected to contain a number of policies aimed at beefing up Canada's electric vehicle industry, as EV assembly deals are putting Canada in the race, both on the consumer side and for businesses that build them.

Ontario's minister of economic development and trade welcomed the news of a tentative deal on Tuesday and confirmed that Queen's Park legislators stand ready to do their part, as shown by Honda's Ontario battery investment moves in the province.

"Our government will always work with our federal colleagues, workers and the auto sector to ensure the right conditions are in place for the industry to remain stable today and seize the new opportunities of tomorrow," a spokesperson for Vic Fedeli told CBC News in an emailed statement Tuesday.

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Ontario Clean Grid Plan outlines emissions-free electricity growth, renewable energy procurement, nuclear expansion at Bruce and Darlington, reduced natural gas, grid reliability, and net-zero alignment to meet IESO demand forecasts and EV manufacturing loads.

Key Points

A plan to expand emissions-free power via renewables and nuclear, cut natural gas use, and meet growing demand.

✅ Targets renewables, hydro, and nuclear capacity growth

✅ Aims to reduce reliance on gas for grid reliability

✅ Aligns with IESO demand forecasts and EV manufacturing loads

Ontario is working toward filling all of the province’s quickly growing electricity needs with emissions-free sources, including a plan to secure new renewable generation and clean power options, but isn’t quite ready to commit to a moratorium on natural gas.

Energy Minister Todd Smith announced Monday a plan to address growing energy needs for 2030 to 2050 — the Independent Electricity System Operator projects Ontario’s electricity demand could double by mid-century — and next steps involve looking for new wind, solar and hydroelectric power.

“While we may not need to start building today, government and those in the energy sector need to start planning immediately, so we have new clean, zero-emissions projects ready to go when we need them,” Smith said in Windsor, Ont.

The strategy also includes two nuclear projects announced last week — a new large-scale nuclear plant at Bruce Power on the shore of Lake Huron and three new small modular reactors at the site of the Darlington nuclear plant east of Toronto.

Those projects, enough to power six million homes, will help Ontario end its reliance on natural gas to generate electricity, said Smith, but committing to a natural gas moratorium in 2027 and eliminating natural gas by 2050 is contingent on the federal government helping to speed up the new nuclear facilities.

“Today’s report, the Powering Ontario’s Growth plan, commits us to working towards a 100 per cent clean grid,” Smith said in an interview.

“Hopefully the federal government can get on board with our intentions to build this clean generation as quickly as possible … That will put us in a much better position to use our natural gas facilities less in the future, if we can get those new projects online.”

The IESO has said that natural gas is required to ensure supply and stability in the short to medium term, as Ontario works on balancing demand and emissions across the grid, but that it will also increase greenhouse gas emissions from the electricity sector.

The province is expected to face increased demand for electricity from expanded electric vehicle use and manufacturing in the coming years, even as a $400-billion cost estimate for greening the grid is debated.

Keith Brooks, programs director for Environmental Defence, said the provincial plan could have been much more robust, containing firm timelines and commitments.

“This plan does not commit to getting emissions out of the system,” he said.

“It doesn’t commit to net zero, doesn’t set a timeline for a net zero goal or have any projection around emissions from Ontario’s electricity sector going forward. In fact, it’s not really a plan. It doesn’t set out any real goals and it doesn’t it doesn’t project what Ontario’s supply mix might look like.”

The Canadian Climate Institute applauded the plan’s focus on reducing reliance on gas-fired generation and emphasizing non-emitting generation, but also said there are still some question marks.

“The plan is silent on whether the province intends to construct new gas-fired generation facilities,” even as new gas plant expansions are proposed, senior research director Jason Dion wrote in a statement.

“The province should avoid building new gas plants since cost-effective alternatives are available, and such facilities are likely to end up as stranded assets. The province’s timeline for reaching net zero generation is also unclear. Canada and other G7 countries have set a target for 2035, something Ontario will need to address if it wants to remain competitive.”

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Canadian Softwood Lumber Tariffs challenge British Columbia's forestry sector, strain U.S.-Canada trade, and risk redirecting critical minerals and energy resources, threatening North American supply chains, manufacturing, and energy security across integrated markets.

Key Points

Duties imposed by the U.S. on Canadian lumber, affecting BC forestry, trade flows, and North American energy security.

✅ U.S. duties strain BC forestry and cross-border supply chains

✅ Risks redirecting critical minerals and energy exports

✅ Tariff rollback could bolster North American energy security

British Columbia Premier David Eby has raised concerns that U.S. tariffs on Canadian softwood lumber are prompting the province to redirect its critical minerals and energy resources, while B.C. challenges Alberta's electricity export restrictions domestically, away from the United States. In a recent interview, Eby emphasized the broader implications of these tariffs, suggesting they could undermine North American energy security and put electricity exports at risk across the border.

Since 2017, the U.S. Department of Commerce has imposed tariffs on Canadian softwood lumber imports, alleging that Canadian producers benefit from unfair subsidies. These duties have been a persistent source of tension between the two nations, coinciding with Canadian support for energy and mineral tariffs and significantly impacting British Columbia's forestry sector—a cornerstone of the province's economy.

Premier Eby highlighted that the financial strain imposed by these tariffs not only jeopardizes the Canadian forestry industry but also has unintended repercussions for the United States. He pointed out that the economic challenges faced by Canadian producers might lead them to seek alternative markets for their critical minerals and energy resources, as tariff threats boost support for Canadian energy projects domestically, thereby reducing the supply to the U.S. British Columbia is endowed with an abundance of critical minerals essential for various industries, including technology and defense.

The potential redirection of these resources could have significant consequences for American industries that depend on a stable and affordable supply of critical minerals and energy. Eby suggested that the tariffs might incentivize Canadian producers to explore other international markets, even as experts advise against cutting Quebec's energy exports amid the tariff dispute, diminishing the availability of these vital resources to the U.S.

In light of these concerns, Premier Eby has advocated for a reassessment of the tariffs, urging a more cooperative approach between Canada and the United States. He contends that eliminating the tariffs would be mutually beneficial, aligning with views that Biden is better for Canada's energy sector and cross-border collaboration, ensuring a consistent supply of critical resources and fostering economic growth in both countries.

The issue of U.S. tariffs on Canadian softwood lumber remains complex and contentious, with far-reaching implications for trade relations and resource distribution between the two nations. As discussions continue, stakeholders on both sides of the border are closely monitoring the situation, noting that Ford has threatened to cut U.S. electricity exports amid trade tensions, recognizing the importance of collaboration in addressing shared economic and security challenges.

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Utility Battery Storage Rankings measure grid-connected capacity, not ownership, highlighting MW, MWh, and watts per customer across PJM, MISO, and California IOUs, featuring Duke Energy, IPL, ancillary services, and frequency regulation benefits.

Key Points

Rankings that track energy storage connected to utility grids, comparing MW, MWh, and W/customer rather than ownership.

✅ Ranks by MW, MWh, and watts per customer, not asset ownership

✅ Highlights PJM, MISO cases and California IOUs' deployments

✅ Examples: Duke Energy, IPL, IID; ancillary services, frequency response

The rankings do not tally how much energy storage a utility built or owns, but how much was connected to their system. So while IPL built and owns the storage facility in its territory, Duke does not own the 16 MW of storage that connected to its system in 2016. Similarly, while California’s utilities are permitted to own some energy storage assets, they do not necessarily own all the storage facilities connected to their systems.

Measured by energy (MWh), IPL ranked fourth with 20 MWh, and Duke Energy Ohio ranked eighth with 6.1 MWh.

Ranked by energy storage watts per customer, IPL and Duke actually beat the California utilities, ranking fifth and sixth with 42 W/customer and 23 W/customer, respectively.

Duke ready for next step

Given Duke’s plans, including projects in Florida that are moving ahead, the utility is likely to stay high in the rankings and be more of a driving force in development. “Battery technology has matured, and we are ready to take the next step,” Duke spokesman Randy Wheeless told Utility Dive. “We can go to regulators and say this makes economic sense.”

Duke began exploring energy storage in 2012, and until now most of its energy storage efforts were focused on commercial projects in competitive markets where it was possible to earn revenues. Those included its 36 MW Notrees battery storage project developed in partnership with the Department of Energy in 2012 that provides frequency regulation for the Electric Reliability Council of Texas market and two 2 MW storage projects at its retired W.C. Beckjord plant in New Richmond, Ohio, that sells ancillary services into the PJM Interconnection market.

On the regulated side, most of Duke’s storage projects have had “an R&D slant to them,” Wheeless said, but “we are moving beyond the R&D concept in our regulated territory and are looking at storage more as a regulated asset.”

“We have done the demos, and they have proved out,” Wheeless said. Storage may not be ready for prime time everywhere, he said, but in certain locations, especially where it can it can be used to do more than one thing, it can make sense.

Wheeless said Duke would be making “a number of energy storage announcements in the next few months in our regulated states.” He could not provide details on those projects.

More flexible resources
Location can be a determining factor when building a storage facility. For IPL, serving the wholesale market was a driving factor in the rationale to build its 20 MW, 20 MWh storage facility in Indianapolis.

IPL built the project to address a need for more flexible resources in light of “recent changes in our resource mix,” including decreasing coal-fired generation and increasing renewables and natural gas-fired generation, as other regions plan to rely on battery storage to meet rising demand, Joan Soller, IPL’s director of resource planning, told Utility Dive in an email. The storage facility is used to provide primary frequency response necessary for grid stability.

The Harding Street storage facility in May. It was the first energy storage project in the Midcontinent ISO. But the regulatory path in MISO is not as clear as it is in PJM, whereas initiatives such as Ontario storage framework are clarifying participation. In November, IPL with the Federal Energy Regulatory Commission, asking the regulator to find that MISO’s rules for energy storage are deficient and should be revised.

Soller said IPL has “no imminent plans to install energy storage in the future but will continue to monitor battery costs and capabilities as potential resources in future Integrated Resource Plans.”

California legislative and regulatory push

In California, energy storage did not have to wait for regulations to catch up with technology. With legislative and regulatory mandates, including CEC long-duration storage funding announced recently, as a push, California’s IOUs took high places in SEPA’s rankings.

Southern California Edison and San Diego Gas & Electric were first and fourth (63.2 MW and 17.2 MW), respectively, in terms of capacity. SoCal Ed and SDG&E were first and second (104 MWh and 28.4 MWh), respectively, and Pacific Gas and Electric was fifth (17 MWh) in terms of energy.

But a public power utility, the Imperial Irrigation District (IID), ended up high in the rankings – second in capacity (30 MW) and third  in energy (20 MWh) – even though as a public power entity it is not subject to the state’s energy storage mandates.

But while IID was not under state mandate, it had a compelling regulatory reason to build the storage project. It was part of a settlement reached with FERC over a September 2011 outage, IID spokeswoman Marion Champion said.

IID agreed to a $12 million fine as part of the settlement, of which $9 million was applied to physical improvements of IID’s system.

IID ended up building a 30 MW, 20 MWh lithium-ion battery storage system at its El Centro generating station. The system went into service in October 2016 and in May, IID used the system’s 44 MW combined-cycle natural gas turbine at the generating station.

Passing savings to customers
The cost of the storage system was about $31 million, and based on its experience with the El Centro project, Champion said IID plans to add to the existing batteries. “We are continuing to see real savings and are passing those savings on to our customers,” she said.

Champion said the battery system gives IID the ability to provide ancillary services without having to run its larger generation units, such as El Centro Unit 4, at its minimum output. With gas prices at $3.59 per million British thermal units, it costs about $26,880 a day to run Unit 4, she said.

IID’s territory is in southeastern California, an area with a lot of renewable resources. IID is also not part of the California ISO and acts as its own balancing authority. The battery system gives the utility greater operational flexibility, in addition to the ability to use more of the surrounding renewable resources, Champion said.

In May, IID’s board gave the utility’s staff approval to enter into contract negotiations for a 7 MW, 4 MWh expansion of its El Centro storage facility. The negotiations are ongoing, but approval could come in the next couple months, Champion said.

The heart of the issue, though, is “the ability of the battery system to lower costs for our ratepayers,” Champion said. “Our planning section will continue to utilize the battery, and we are looking forward to its expansion,” she said.” I expect it will play an even more important role as we continue to increase our percentage of renewables.”

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Energy equity in utility regulation prioritizes fair rates, clean energy access, and DERs, addressing fixed charges and energy burdens on low-income households through stakeholder engagement and public utility commission reforms.

Key Points

Fairly allocates clean energy benefits and rate burdens, ensuring access and protections for low-income households.

✅ Reduces fixed charges that burden low-income households

✅ Funds community participation in utility proceedings

✅ Prioritizes DERs, energy efficiency, and solar in impacted areas

By Kiran Julin

Pouring over the line items on your monthly electricity bill may not sound like an enticing way to spend an afternoon, but the way electricity bills are structured has a significant impact on equitable energy access and distribution. For example, fixed fees can have a disproportionate impact on low-income households. And combined with other factors, low-income households and households of color are far more likely to report losing home heating service, with evidence from pandemic power shut-offs highlighting these disparities, according to recent federal data.

Advancing Equity in Utility Regulation, a new report published by the U.S. Department of Energy’s (DOE’s) Lawrence Berkeley National Laboratory (Berkeley Lab), makes a unifying case that utilities, regulators, and stakeholders need to prioritize energy equity in the deployment of clean energy technologies and resources, aligning with a people-and-planet electricity future envisioned by advocacy groups. Equity in this context is the fair distribution of the benefits and burdens of energy production and consumption. The report outlines systemic changes needed to advance equity in electric utility regulation by providing perspectives from four organizations — Portland General Electric, a utility company; the National Consumer Law Center, a consumer advocacy organization; and the Partnership for Southern Equity and the Center for Biological Diversity, social justice and environmental organizations.
 
“While government and ratepayer-funded energy efficiency programs have made strides towards equity by enabling low-income households to access energy-efficiency measures, that has not yet extended in a major way to other clean-energy technologies,” said Lisa Schwartz, a manager and strategic advisor at Berkeley Lab and technical editor of the report. “States and utilities can take the lead to make sure the clean-energy transition does not leave behind low-income households and communities of color. Decarbonization and energy equity goals are not mutually exclusive, and in fact, they need to go hand-in-hand.”

Energy bills and electricity rates are governed by state laws and utility regulators, whose mission is to ensure that utility services are reliable, safe, and fairly priced. Public utility commissions also are increasingly recognizing equity as an important goal, tool, and metric, and some customers face major changes to electric bills as reforms advance. While states can use existing authorities to advance equity in their decision-making, several, including Illinois, Maine, Oregon, and Washington, have enacted legislation over the last couple of years to more explicitly require utility regulators to consider equity.

“The infrastructure investments that utility companies make today, and regulator decisions about what goes into electricity bills, including new rate design steps that shape customer costs, will have significant impacts for decades to come,” Schwartz said.

Solutions recommended in the report include considering energy justice goals when determining the “public interest” in regulatory decisions, allocating funding for energy justice organizations to participate in utility proceedings, supporting utility programs that increase deployment of energy efficiency and solar for low-income households, and accounting for energy inequities and access in designing electricity rates, while examining future utility revenue models as technologies evolve.

The report is part of the Future of Electric Utility Regulation series that started in 2015, led by Berkeley Lab and funded by DOE, to encourage informed discussion and debate on utility trends and tackling the toughest issues related to state electric utility regulation. An advisory group of utilities, public utility commissioners, consumer advocates, environmental and social justice organizations, and other experts provides guidance.

Taking stock of past and current energy inequities

One focus of the report is electricity bills. In addition to charges based on usage, electricity bills usually also have a fixed basic customer charge, which is the minimum amount a household has to pay every month to access electricity. The fixed charge varies widely, from $5 to more than $20. In recent years, utility companies have sought sizable increases in this charge to cover more costs, amid rising electricity prices in some markets.

This fixed charge means that no matter what a household does to use energy more efficiently or to conserve energy, there is always a minimum cost. Moreover, low-income households often live in older, poorly insulated housing. Current levels of public and utility funding for energy-efficiency programs fall far short of the need. The combined result is that the energy burden – or percent of income needed to keep the lights on and their homes at a healthy temperature – is far greater for lower-income households.

“While all households require basic lighting, heating, cooling, and refrigeration, low-income households must devote a greater proportion of income to maintain basic service,” explained John Howat and Jenifer Bosco from the National Consumer Law Center and co-authors of Berkeley Lab’s report. Their analysis of data from the most recent U.S. Energy Information Administration’s Residential Energy Consumption Survey shows households with income less than $20,000 reported losing home heating service at a pace more than five times higher than households with income over $80,000. Households of color were far more likely than those with a white householder to report loss of heating service. In addition, low-income households and households of color are more likely to have to choose between paying their energy bill or paying for other necessities, such as healthcare or food.

Based on the most recent data (2015) from the U.S. Energy Information Administration (EIA), households with income less than $20,000 reported losing home heating service at a rate more than five times higher than households with income over $80,000. Households of color were far more likely than those with a white householder to report loss of heating service. Click on chart for larger view. (Credit: John Howat/National Consumer Law Center, using EIA data)

Moreover, while many of the infrastructure investment decisions that utilities make, such as whether and where to build a new power plant, often have long-term environmental and health consequences, impacted communities often are not at the table. “Despite bearing an inequitable proportion of the negative impacts of environmental injustices related to fossil fuel-based energy production and climate change, marginalized communities remain virtually unrepresented in the energy planning and decision-making processes that drive energy production, distribution, and regulation,” wrote Chandra Farley, CEO of ReSolve and a co-author of the report.

Engaging impacted communities
Each of the perspectives in the report identify a need for meaningful engagement of underrepresented and disadvantaged communities in energy planning and utility decision-making. “Connecting the dots between energy, racial injustice, economic disinvestment, health disparities, and other associated equity challenges becomes a clarion call for communities that are being completely left out of the clean energy economy,” wrote Farley, who previously served as the Just Energy Director at Partnership for Southern Equity. “We must prioritize the voices and lived experiences of residents if we are to have more equity in utility regulation and equitably transform the energy sector.”

In another essay in the report, Nidhi Thaker and Jake Wise from Portland General Electric identify the importance of collaborating directly with the communities they serve. In 2021, the Oregon Legislature passed Oregon HB 2475, which allows the Oregon Public Utility Commission to allocate ratepayer funding for organizations representing people most affected by a high energy burden, enabling them to participate in utility regulatory processes.

The report explains why energy equity requires correcting inequities resulting from past and present failures as well as rethinking how we achieve future energy and decarbonization goals. “Equity in energy requires adopting an expansive definition of the ‘public interest’ that encompasses energy, climate, and environmental justice. Energy equity also means prioritizing the deployment of distributed energy resources and clean energy technologies in areas that have been hit first and worst by the existing fossil fuel economy,” wrote Jean Su, energy justice director and senior attorney at the Center for Biological Diversity.

This report was supported by DOE’s Grid Modernization Laboratory Consortium, with funding from the Office of Energy Efficiency and Renewable Energy and the Office of Electricity.

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California Governor Gavin Newsom vetoed a bill aimed at expanding load flexibility in state grid planning, citing conflicts with California’s resource adequacy framework and concerns over grid reliability and energy planning uncertainty.

Why has Newsom vetoed the Bill to Codify Load Flexibility?

Governor Gavin Newsom’s veto blocks legislation that would have required the California Energy Commission to incorporate load flexibility into the state’s energy planning and policy framework, a move that has stirred debate across the clean energy sector.

✅ Argues the bill conflicts with California’s existing Resource Adequacy system

✅ Draws backlash from clean energy and grid modernization advocates

✅ Exposes ongoing tension over how to manage renewable integration and demand response

California Governor Gavin Newsom has vetoed Assembly Bill 44, which would have required the California Energy Commission to evaluate and incorporate load management mechanisms into the state’s energy planning process. The move drew criticism from clean energy advocates who say it undermines efforts to strengthen grid reliability and reduce costs.

The bill directed the commission to adopt “upfront technical requirements and load modification protocols” that would allow load-serving entities to adjust their electrical demand forecasts. Proponents viewed this as a way to modernize California’s grid management, and to explore a revamp of electricity rates to help clean the grid, making it more responsive to demand fluctuations and renewable energy variability.

In his veto statement, Newsom said the bill was incompatible with existing energy planning frameworks, even as a looming electricity shortage remains a concern. “While I support expanding electric load flexibility, this bill does not align with the California Public Utility Commission’s Resource Adequacy framework,” he said. “As a result, the requirements of this bill would not improve electric grid reliability planning and could create uncertainty around energy resource planning and procurement processes.”

Newsom’s decision comes shortly after he signed a broad package of energy legislation that set the stage for a regional Western electricity market and extended the state’s cap-and-trade program. However, that legislative package did not include continued funding for several key grid reliability programs — including what advocates have called the world’s largest virtual power plant, a distributed network of connected devices that can balance electricity demand in real time.

Clean energy supporters saw AB 44 as a crucial step toward integrating these distributed energy resources into long-term grid planning. “With Assembly Bill 44 being vetoed, the state has missed a huge opportunity to advance common-sense policy that would have lowered costs, strengthened the grid, and unlocked the full potential of advanced energy,” said Edson Perez, California lead at Advanced Energy United.

Perez added that the setback increases pressure on lawmakers to take stronger action in the next legislative session. “The pressure is on next session to ensure that California is using all tools in its policy toolbox to build critically needed infrastructure, strengthen the grid, and bring costs down,” he said.

California’s growing use of demand response programs and virtual power plants has been central to its strategy for managing grid stress during heat waves and wildfire seasons. These systems allow utilities and customers to temporarily reduce or shift energy use, helping to prevent blackouts and reduce the need for fossil-fuel peaker plants during peak demand.

A recent report by the Brattle Group found that California’s taxpayer-funded virtual power plant could save ratepayers $206 million between 2025 and 2028 while reducing reliance on gas generation. The study, commissioned by Sunrun and Tesla Energy, highlighted the potential for flexible load management to improve both grid reliability and reduce costs, even as regulators weigh whether the state needs more power plants to ensure reliability.

Despite these findings, Newsom’s veto signals continued tension between state policymakers and clean energy advocates over how best to modernize California’s power grid. While the governor has prioritized large-scale renewable development and regional market integration, critics argue that California’s climate policy choices risk exacerbating reliability challenges and that failing to codify load flexibility could slow progress toward a more adaptive, resilient, and affordable clean energy future.

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