Utility customers to benefit from tax law changes

AEMC Storage Charging Rules spark industry backlash as Tesla, Snowy Hydro, and investors warn transmission charges on batteries and pumped hydro could deter grid-scale storage, distort the National Electricity Market, and slow decarbonisation.

Key Points

AEMC Storage Charging Rules are proposals to bill grid storage for network use, shaping costs and investment.

✅ Charges apply when batteries draw power; double-charging concerns.

✅ Tesla and Snowy Hydro warn of reduced viability and delays.

✅ AEMO recommends exemptions; investors seek certainty.

Tesla, Snowy Hydro and other big suppliers of storage capacity on Australia’s main electricity grid warn proposed rule changes amount to a tax on their operations that will deter investors and slow the decarbonisation of the industry.

The Australian Energy Market Commission (AEMC) will release its final decision this Thursday on new rules for integrating batteries, pumped hydro and other forms of storage.

The AEMC’s draft decision, released in July, angered many firms because it proposed charging storage providers for drawing power, ignoring a recommendation by the Australian Electricity Market Operator (AEMO) that they be exempt.

Battery maker Tesla, which has supplied some of the largest storage to the National Electricity Market, said in a submission that the charges would “kill the commercial viability of all grid storage projects, causing inefficient investment in alternative network”, with consumers paying higher costs.

Snowy Hydro, which is building the giant Snowy 2 pumped storage project and already operates a smaller one, said in its submission the proposed changes if implemented would jeopardise investment.

“This is a major policy change, amounting to a tax on infrastructure critical to achieving a renewable future,” Snowy Hydro said.

AEMO itself argued it was important storage providers were not “disincentivised from connecting to the transmission network, as they generally provide a net benefit to the power system by charging at periods of low demand”.

Australia’s electricity grid faces economic and engineering challenges, similar to Ontario's storage push as it adjusts to the arrival of lower cost and also lower carbon alternatives to fossil fuels.

While rule changes are necessary to account for operators that can both draw from and supply power, how they are implemented can have long-lasting effects on the technologies that get encouraged or repelled, including control of EV charging issues, independent experts say.

“It doesn’t have to be this way,” said Bruce Mountain, director of the Victoria Energy Policy Centre. “In Britain, where the UK grid transformation is underway, the regulator dealing with the same issues has said that storage devices don’t pay the system charges when they withdraw electricity from the grid,” he said.

The prospect that storage operators will have to pay transmission charges could “drastically” affect their profitability since their business models rely on the difference between the price their pay for power and how much they can sell it for. Gas generators and network monopolies would benefit from the change, Mountain said.

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An AEMC spokesperson said the commission had consulted widely, including from those who objected to the payment for transmission access.

“The market is moving towards a future that will be increasingly reliant on energy storage to firm up the growing volume of renewable energy and deliver on the increasing need for critical system security services, with examples such as EVs supporting grid stability in California as the ageing fleet of thermal generators retire,” the spokesperson said, declining to elaborate on the final ruling before it is published.

“The regulatory framework needs to facilitate this transition as the energy sector continues to decarbonise,” the official said.

AusNet, which operates the Victorian energy transmission grid, said that while “technological neutrality is paramount for battery and hybrid unit connections to both the distribution and transmission networks,” it did not back charging storage access to networks in all cases.

“[Ausnet] supports a clear exemptions framework for energy storage providers,” a spokesperson said. “We recommend that batteries and other hybrid facilities should have transmission use of system charges waived if they provide a net benefit to network customers.”

We are not aware of anyone that supports the charging storage access to networks in all circumstances.

“Batteries and hybrid facilities that consume energy from the network should be provided no preferential treatment relative to other customers and generators.”

Jonathan Upson, a principal at Strategic Renewable Consulting, though, said the AEMC wants electricity flowing through batteries to be taxed twice to pay network charges – once when the electricity charges the battery and then again when the same electricity is sent out by the battery an hour or two later but this time with customers paying.

“The AEMC’s draft decision has the identical rationale for eliminating franking credits on all dividends, resulting in double taxing of company profits,” he said.

Christiaan Zuur, director of energy transformation at the Clean Energy Council, said that while much of AEMC’s draft proposal was constructive, “those benefits are either nullified or maybe even outweighed” by uncertainty over charges.

“Risk perception” will be important since potential newcomers won’t be sure of what charges they will pay to connect to the grid and existing operators could have their connection agreements reopened, Zuur said.

“Investors focus on the potential risk. It does factor through to the integral costs for projects,” he said.

The outcome of new charges may prompt more people to put batteries on their premises and draw power from their own solar panels, Mountain said, with rising EV adoption introducing new grid challenges, cutting their reliance on a centralised network.

“Ironically, it encourages customers to depend less and less on the grid,” he said. “It’s almost like the capture of the dominant interests playing out over time at their own expense.”

Separately, the latest edition of the Clean Energy Council Confidence Index shows leadership by state governments is helping to shore up investor appetite for investing in renewable energy amid 2021 electricity lessons even with higher 2030 emissions reduction goals from the federal government.

Overall, investor confidence increased by a point in the last six months – from 6.3 to 7.3 out of 10 – following strong commitments and policy development from state governments, particularly on the east coast, the council said.

“The results of this latest survey illustrate the economic value in policy that lowers the emissions footprint of our electricity generation, supporting regional centres and creating jobs. Investors recognise the opportunities created by limiting global temperature rise to 1.5 degrees,” said council chief executive Kane Thornton.

Among the states, NSW, Victoria and Queensland led in terms of positive investor sentiment.

Correction: this article was amended on 30 November. An earlier version stated Ausnet supported charging storage for network access. A spokesperson said it backed a waiver on charges if certain conditions are met.        

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Canada Clean Electricity Expansion is urged by the IEA to meet net-zero targets, scaling non-emitting generation, electrification, EV demand, and grid integration across provinces to decarbonize industry, buildings, and transport while ensuring reliability and affordability.

Key Points

An IEA-backed pathway for Canada to scale non-emitting power, electrification, and grid links to meet net-zero goals.

✅ Double or triple clean generation to replace fossil fuels

✅ Integrate provincial grids to decarbonize dependent regions

✅ Manage EV and heating loads with reliability and affordability

Canada will need more electricity capacity if it wants to hit its climate targets, and cleaning up Canada's electricity will be critical, according to a new report from the International Energy Agency (IEA).

The report offers mainly a rosy picture of Canada's overall federal energy policy. But, the IEA draws attention to Canada's increasing future electricity demands, and ultimately, calls on Canada to leverage its non-emitting energy potential and expand renewable energy to hit its climate targets.  

"Canada's wealth of clean electricity and its innovative spirit can help drive a secure and affordable transformation of its energy system and help realize its ambitious goals," stated Fatih Birol, the IEA executive director, in a news release.

The IEA notes that Canada has one of the cleanest energy grids globally, with 83 per cent of electricity coming from non-emitting sources in 2020. But this reflects nationwide progress in electricity to date; the report warns this is not a reason for Canada to rest on its laurels. More electricity will be needed to displace fossil fuels if Canada wants to hit its 2030 targets, the report states, and "even deeper cuts" will be required to reach net-zero by 2050.

"Perhaps more significantly, however, Canada will need to ensure sufficient new clean generation capacity to meet the sizeable levels of electrification that its net-zero targets imply."

Investing in new coal, oil and gas projects must stop to hit climate goals, global energy agency says
The Liberals have promised to create a 100 percent net-zero-emitting electricity system by 2035, with regulating oil and gas emissions and electric car sales as part of the plan; by then, every new light-duty vehicle sold in Canada will be a zero-emission vehicle. The switch from gas guzzlers to plug-in electric vehicles will create new pressures on Canada's electrical grid, as will any turn away from fossil natural gas for home heating.

To meet these challenges, the IEA warns, Canada would need to double or triple the power generated from non-emitting sources compared to today, a shift whose cost could reach $1.4 trillion according to the Canadian Gas Association. 

"Such a shift will require significant regulatory action," the report states, highlighting the need for climate policy for electricity grids to guide implementation, and that will require the federal government to work closely with provinces and territories that control power generation and distribution.

The report notes that the further integration of territorial and provincial electrical grids could allow fossil fuel-dependent provinces, like Alberta, to decarbonize and electrify their economies.

The report, entitled Canada 2022 Energy Policy Review, offers what it calls an "in-depth" look at the commitments Canada has made to transform its energy policy. Since the IEA conducted its last review in 2015, Canada has committed to cutting greenhouse gas emissions by 40 to 45 per cent from 2005 levels by 2030 and achieving net-zero by 2050 under an extended national target.

The IEA is well-known for the production of its annual World Energy Outlook. The Paris-based autonomous intergovernmental organization provides analysis, data, and policy recommendations to promote global energy security and sustainability. Canada is a part of the intergovernmental body, which also conducts peer reviews of its members' energy policy.

Oil and gas emissions rising
Natural Resources Minister Jonathan Wilkinson responded to the report in the IEA news release.

"This report acknowledges Canada's ambitious efforts and historic investments to develop pathways to achieve net-zero emissions by 2050 and ensure a transition that aligns with our shared objective of limiting global warming to 1.5 degrees Celsius," Wilkinson's statement read.

The report notes that — despite that objective — absolute emissions from Canadian oil and gas extraction went up 26 per cent between 2000 and 2019, largely from increased production.

Minister of Natural Resources Jonathan Wilkinson responds to a question at a news conference after the federal cabinet was sworn in, in Ottawa, on Oct. 26, 2021. (Justin Tang/The Canadian Press)
"Canada will need to reconcile future growth in oil sands production with increasingly strict greenhouse gas requirements," the report states.

On the plus side, the IEA found emissions per barrel of oilsands crude have decreased by 20 per cent in the last decade from technical and operational improvements.

The improving carbon efficiency of the oilsands is a "trend that is expected to continue at even higher rates," said Ben Brunnen, vice-president of oilsands, fiscal and economic policy at the Canadian Association of Petroleum Producers.

That may become important, the IEA report notes, as energy investors and buyers look for low-carbon assets and more countries adopt net-zero policies.

Further innovation, such as carbon capture and storage, could help to turn things around for Canada's oil patch, the report says. The Liberals have also said they will place a hard cap on oil and gas emissions from production, but that does not include the burning of the fossil fuels. 

In 2021, the IEA released a report that determined to achieve net-zero by 2050, among many steps, investments needed to end in coal mines, oil and gas wells. Thursday's report, however, made no mention of that, which disappointed at least one environmental group.

"A glaring omission was that this assessment says nothing about production. We know that the most important thing we can do is to stop using and producing oil and gas," said Julia Levin, a senior climate and energy program manager at Environmental Defence.

"And yet that was absent from this report, and that really is a glaring omission, which is completely out of line with their [the IEA's] own work."

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BEST vigilance raid on Wadala electricity theft uncovered a Mumbai power theft racket in Antop Hill and Sangam Nagar, with operators, illegal connections, sub-stations, meter cabins, FIRs, and Rs 72 lakh losses flagged by BEST.

Key Points

A BEST operation that nabbed operators stealing power via illegal connections in Wadala, exposing a Rs 72 lakh loss.

✅ 35 suspects booked; key operator identified as David Anthony.

✅ Illegal taps from sub-stations and meter cabins in shanties.

✅ BEST filed FIRs; Session court granted bail to accused.

In a raid conducted at Antop Hill in Wadala on Saturday, a total of 35 people were nabbed by the vigilance department for stealing electricity to the tune of Rs 72 lakh, in a case similar to a Montreal power-theft ring bust covered internationally.

It was the second such raid conducted in the past one week, where operators have been nabbed.The cash-strapped BEST is now tightening it's grasp on `operators' who steal electricity from BEST sources and provide it to their own customers on a meagre monthly rent, even as Ontario utilities warn about scams affecting customers elsewhere.

After receiving a tip-off about the theft of electricity in the Sangam Nagar area of Wadala, about 90 personnel of the BEST conducted a raid. After visiting the spots, it was found that illegal connections were made from the sub-station and other electricity boxes of the BEST in the area, underscoring how fragile networks can be amid disruptions such as major outages in London that affected thousands.

According to BEST officials, the residents from the area would come up to the accused, identified as David Anthony, and would pay a fixed amount at the end of every month for unlimited supply of power, a dynamic reminiscent of shutoff-threat scams flagged by Manitoba Hydro, though the circumstances differ. Anthony would with draw power directly from meter cabins and electricity boxes in the area. The wires he connected to these were in turn connected to households who made the arrangement with him. An official from BEST also explained that as soon they reach a location to conduct raids and vehicles of BEST officials are spotted by residents, most of the connections are cut off, which makes it difficult for them to prove the theft case However, on Saturday, BEST officials managed to conduct the raid swiftly and nab 35 people.

All who had illegal connections were named in the complaint and an FIR was registered against them, including Anthony, who himself had illegal connections in his house. They were produced in Session court and given bail, while utilities in other regions resort to hydro disconnections during arrears season. Chief Vigilance Officer of BEST, RJ Singh said, "Most of these are commercial establishments in these shanties, which steal electricity. It is very important to catch hold of the operators as they are the providers and we need to break their backbone."

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US energy mix shows how the electric grid blends renewables, fossil fuels, nuclear, and hydro, varying by ISO/RTO markets, utilities, and state policies, affecting carbon emissions, pricing, reliability, and access.

Key Points

The US energy mix is the grid's source breakdown by region: fossil fuels, renewables, nuclear, and hydro.

✅ Check ISO or RTO dashboards for real-time generation by fuel source.

✅ Utilities may offer green power plans or RECs at modest premiums.

✅ Energy mix shifts with policy, pricing, and grid reliability needs.

There are few resources more important than energy. Sure, you may die if you don't eat for days. But your phone will die if you go too long without charging it. Energy feeds tech, the internet, city infrastructure, refrigerators, lights, and has evolved throughout U.S. history in profound ways. You get the idea. Yet unlike our other common needs, such as food, energy sources aren't exactly front of mind for most people. 

"I think a lot of people don't put a lot of bandwidth into thinking about this part of their lives," said Richard McMahon, the SVP of energy supply and finance at Edison Electric Institute, a trade group that represents investor-owned electric companies in the US. 

It makes sense. For most Americans, electricity is always there, and in many locations, there's not much of a choice involved, even as electricity demand is flat across the U.S. today. You sign up with a utility when you move into a new residence and pay your bills when they're due. 

But there's an important reality that indifference eschews: In 2018, a third of the energy-related carbon-dioxide emissions in the US came from the electric power sector, according to the US Energy Information Administration (EIA). 

A good chunk of that is from the residential sector, which consistently uses more energy than commercial customers, per EIA data.

Just as many people exercise choice when they eat, you typically also have a choice when it comes to your energy supply. That's not to say your current offering isn't what you want, or that switching will be easy or affordable, but "if you're a customer and want power with a certain attribute," McMahon said, "you can pretty much get it wherever you are." 

But first, you need to know the energy mix you have right now. As it turns out, it's not so straightforward. At all.

This brief guide may help. 

For some utility providers, you can find out if it publishes the energy mix online. Dominion Energy, which serves Idaho, North Carolina, Ohio, South Carolina, Utah, Virginia, West Virginia, and Wyoming, provides this information in a colored graphic. 

"Once you figure out who your utility is you can figure out what mix of resources they use," said Heidi Ratz, an electricity markets researcher at the World Resources Institute.

But not all utilities publish this information.

It has to do with their role in the grid and reflects utility industry trends in structure and markets. Some utility companies are vertically integrated; they generate power through nuclear plants or wind farms and distribute those electrons directly to their customers. Other utilities just distribute the power that different companies produce. 

Consider Consolidated Edison, or Con Ed, which distributes energy to parts of New York City. While reporting this story, Business Insider could not find information about the utility's energy mix online. When reached for comment, a spokesperson said, "we're indifferent to where it comes from."

That's because, in New York, distribution utilities like Con Ed often buy energy through a wholesale marketplace.

Take a look at this map. If you live in one of the colored regions, your electricity is sold on a wholesale market regulated by an organization called a regional transmission organization (RTO) or independent system operator (ISO). Distribution utilities like Con Ed often buy their energy through these markets, based on availability and cost, while raising questions about future utility revenue models as prices shift. 

Still, it's pretty easy to figure out where your energy comes from. Just look up the ISO or RTO website (such as NYISO or CAISO). Usually, these organizations will provide energy supply information in near-real time. 

That's exactly what Con Edison (which buys energy on the NYISO marketplace) suggested. As of Friday morning, roughly 40% of the energy on the market place was natural gas or other fossil fuels, 34% was nuclear, and about 22% was hydro. 

If you live in another region governed by an ISO or RTO, such as in most of California, you can do the same thing. Like NYISO, CAISO has a dashboard that shows (again, as of Friday morning) about 36% of the energy on the market comes from natural gas and more than 20% comes from renewables. 

In the map linked above, you'll notice that some of the ISOs and RTOs like MISO encompass enormous regions. That means that even if you figure out where the energy in your market comes from, it's not going to be geographically specific. But there are a couple of ways to drill down even further. 

The Environmental Protection Agency has a straightforward tool called Power Profiler. You can enter your zip code to see the fuel mix in your area. But it's not perfect. The data are from 2016 and, in some regions of the country like the upper Midwest, they aren't much more localized, and some import dirty electricity due to regional trading. 

The World Resources Institute also has a tool that allows you to see the electricity mix by state, based on 2017 data from EIA. These numbers represent power generation, not the electricity actually flowing into your sockets, but they offer a rough idea of what energy resources are operating in your state. 

One option is to check with your utility to see if it has a "green power" offering. Over 600 utilities across the country have one, according to the Climate Reality Project, though they often come at a slightly higher cost. It's typically on the scale of just a few more cents per kilowatt-hour. 

There are also independent, consumer-facing companies like Arcadia and Green Mountain Energy that allow you to source renewable energy, by virtually connecting you to community solar projects or purchasing Renewable Energy Certificates, or RECs, on your behalf, as America goes electric and more options emerge. 

"RECs measure an investment in a clean energy resource," Ratz said, in an email. "The goal of putting that resource on the grid is to push out the need for dirtier resources."

The good news: Even if you do nothing, your energy mix will get cleaner. Coal production has fallen to lows not seen since the 1980s, amid disruptions in coal and nuclear sectors that affect reliability and costs, while renewable electricity generation has doubled since 2008. So whether you like it or not, you'll be roped into the clean energy boom one way or another. 

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Florida Solar for All Opt-Out highlights Gov. DeSantis rejecting EPA grant funds under the Inflation Reduction Act, limiting low-income households' access to solar panels, clean energy programs, and promised electricity savings across disadvantaged communities.

Key Points

Florida Solar for All Opt-Out is the state declining EPA grants, restricting low-income access to solar energy savings.

✅ EPA grant under IRA aimed at low-income solar

✅ Estimated 20% electricity bill savings missed

✅ Florida lacks PPAs and renewable standards

Florida has passed up on up to $400 million in federal money that would have helped low-income households install solar panels.

A $7 billion grant “competition” to promote clean energy in disadvantaged communities by providing low-income households with access to affordable solar energy was introduced by President Joe Biden earlier this year, and despite his climate law's mixed results in practice, none of that money will reach Florida households.

The Environmental Protection Agency announced the competition in June as part of Biden’s Inflation Reduction Act. However, Florida Gov. Ron DeSantis has decided to pass on the $400 million up for grabs by choosing to opt out of the opportunity.

Inflation Reduction Act:What is the Inflation Reduction Act? Everything to know about one of Biden's big laws

The program would have helped Florida households reduce their electricity costs by a minimum of 20% during a key time when Floridians are leaving in droves due to a rising cost of living associated with soaring insurance costs, inflation, and proposed FPL rate hikes statewide.

Florida was one of six other states that chose not to apply for the money.

President Joe Biden announced a $7 billion “competition” to promote clean energy in disadvantaged communities.

The opportunity, named “Solar for All,” was announced by the EPA in June and promised to provide up to $7 billion in grants to states, territories, tribal governments, municipalities, and nonprofits to expand the number of low-income and disadvantaged communities primed for residential solar investment — enabling millions of low-income households to access affordable, resilient and clean solar energy.

The grant is intended to help lower energy costs for families, create jobs and help reduce greenhouse effects that accelerate global climate change by providing financial support and incentives to communities that were previously locked out of investments.

How much money would Floridians save under the ‘Solar for All’ solar panel grant?

The program aims to reduce household electricity costs by at least 20%. Florida households paid an average of $154.51 per month for electricity in 2022, just over 14% of the national average of $135.25, and debates over hurricane rate surcharges continue to shape customer bills, according to the U.S. Energy Information Administration. A 20% savings would drop those bills down to around $123 per month.

On the campaign trail, DeSantis has pledged to unravel Biden’s green energy agenda if elected president, amid escalating solar policy battles nationwide, slamming the Inflation Reduction Act and what he called “a concerted effort to ramp up the fear when it comes to things like global warming and climate change.”

His energy agenda includes ending Biden’s subsidies for electric cars while pushing policies that he says would ramp up domestic oil production.

“The subsidies are going to drive inflation higher,” DeSantis said at an event in September. “It’s not going to help with interest rates, and it is certainly not going to help with our unsustainable debt levels.”

DeSantis heading to third debate:As he enters third debate, Ron DeSantis has a big Nikki Haley problem

DeSantis’ plan to curb clean energy usage in Florida seems to be at odds with the state as a whole, and the region's evolving strategy for the South underscores why it has been ranked among the top three states to go solar since 2019, according to the Solar Energy Industries Association (SEIA).

SEIA also shows, however, that Florida lags behind many other states when it comes to solar policies, as utilities tilt the solar market in ways that influence policy outcomes statewide. Florida, for instance, has no renewable energy standards, which are used to increase the use of renewable energy sources for electricity by requiring or encouraging suppliers to provide customers with a stated minimum share of electricity from eligible renewable resources, according to the EIA.

Power purchase agreements, which can help lower the cost of going solar through third-party financing, are also not allowed in Florida, with court rulings on monopolies reinforcing the existing market structure. And there have been other policies implemented that drove other potential solar investments to other states.

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BC Hydro Trespassing Surge highlights risky social media stunts at dams and power stations, with restricted areas breached for selfies, electrocution hazards ignored, and safety signage violated across Buntzen Lake, Jones Lake, and Jordan River.

Key Points

A spike in illegal entries at BC Hydro sites for social media, increasing electrocution and drowning risks.

✅ 200% rise in trespassing over five years

✅ Risks: electrocution, drowning, deadly falls

✅ Obey signage; avoid restricted dam and substation areas

More and more daredevils are climbing onto dangerous dams and power stations to gain likes and social media followers, according to a new report from BC Hydro.

The power provider says it's seen a 200 per cent uptick in trespassing into restricted areas over the past five years, with many of the incidents posted onto sites like YouTube, Facebook and Instagram.

"It's concerning for us because our infrastructure has risk with it," said David Conway, a community relations manager for BC Hydro.

"There's a risk of electrocution in regards to our transmission towers and our substations ... and people can be severely injured, as seen in serious injuries cases, or killed," he said.

The company released a report Tuesday, noting specific incidents of users trespassing onto sites at Buntzen Lake in Anmore, Jones Lake in the Fraser Valley and Jordan River near Victoria; it has also been issuing Site C updates during the pandemic. The incidents ranged from climbing transmission towers to swimming in restricted areas at dam sites.

In a separate matter, an external investigation at Manitoba Hydro has examined alleged assaults by workers.

Conway says annual incidents climbed from a handful to about one dozen, but BC Hydro expects the figures to be even higher. He says many more events likely go unreported.

The report ties the increase in incidents to the pursuit of "social media glory." Between 2011 and 2017, at least 259 people were killed worldwide in selfie-related incidents, according to the Journal of Family Medicine and Primary Care, and a knowledge gap in electrical safety remains a factor. Many of the incidents involved water, electrical equipment or dangerous heights.

In 2018, three social media personalities died after falling off a cliff at Shannon Falls near Squamish, B.C.

North Shore Rescue attributes about 30 per cent of its calls to outdoor users attempting to capture content for social media.

Survey results highlighted in the BC Hydro report show that 15 per cent of British Columbians admit to putting themselves in a dangerous position "to achieve the 'perfect' shot."

Awareness also influences careers, as many young Canadians say they would work in electricity if they knew more.

The survey was conducted online by 800 B.C. residents. For comparison purposes, a probability sample of the same size would yield a margin of error of plus or minus 3.5 per cent, 19 times out of 20.

During the pandemic, the U.S. grid overseer issued a coronavirus warning to highlight operational risks.

Risky activities include standing at the edge of a cliff, knowingly disobeying safety signage or trespassing, or taking a selfie from a dangerous height.

Two per cent of British Columbians admit to injuring themselves in the name of a selfie.

"We want people to stay safe. We want to remind the public to stay a safe distance away from our infrastructure, and follow safety guidance near downed lines, as electricity and generating facilities can be dangerous," said Conway.

BC Hydro is urging all visitors to obey signage, steer clear of power-generating equipment and to stay on designated trails.

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