Utility customers to benefit from tax law changes

Goreway Power Station Overbilling exposed by Ontario Energy Board shows IESO oversight failures, GCG gaming, and $100M in inappropriate payments at the Brampton natural gas plant, penalized with fines and repayments impacting Ontario ratepayers.

Key Points

Goreway exploited IESO GCG flaws, causing about $100M in improper payouts and fines.

✅ OEB probe flagged $89M in ineligible start-up O&M charges

✅ IESO fined Goreway $10M; majority of excess costs recovered

✅ Audit found $200M in overbilling across nine generators

Hydro customers shelled out about $100 million in "inappropriate" payments to a natural gas plant that exploited flaws in how Ontario manages its private electricity generators, according to the Ontario Energy Board.

The company operating the Goreway Power Station in Brampton "gamed" the system for at least three years, according to an investigation by the provincial energy regulator. 

The investigation also delivers stinging criticism of the provincial government's Independent Electricity System Operator (IESO), slamming it for a lack of oversight. The probe by the Ontario Energy Board's market surveillance panel was completed nearly a year ago, but was only made public in November because it was buried on its website without a news release. CBC News is the first media outlet to report on the investigation.  

The excess payments to Goreway Power Station included:

• $89 million in ineligible expenses billed as the costs of firing up power production. 
• $5.6 million paid in three months from a flaw in how IESO calculated top-ups for the company committing to generate power a day in advance.   
• Of $11.2 million paid to compensate the company for IESO ordering it to start or stop generating power, the investigation concluded "a substantial portion ... was the result of gaming."  

Most privately-owned natural gas-fired plants in the province do not generate electricity constantly, but start and stop production in response to fluctuating market demand, even as the energy minister has requested an halt to natural gas generation across the grid.  IESO pays them a premium for the costs of firing up production, through what it calls "generation cost guarantee" programs. 

But the investigation found IESO did little checking into the details of Goreway Power Station's billings. 

Goreway Power Station, located near Highway 407 in Brampton, Ont., is an 875 megawatt natural gas power plant. (Goreway)

"Conservatively, at least $89 million of Goreway's submissions were clearly ineligible by any reasonable measure," concludes the report.

"Goreway routinely submitted what were obviously inappropriate expenses to be reimbursed by the IESO, and ultimately borne by Ontario ratepayers,"

The investigation panel found an "extraordinary pattern" to these billings by Goreway Power Station, suggesting the IESO should have caught on sooner. The company submitted more than $100 million in start-up operating and maintenance costs during the three-year period investigated — more than all other gas-fired generators in the province combined. The company's costs per start-up were more than double the next most expensive power generator. 

"Goreway repeatedly exploited defects in the GCG (generation cost guarantee) program, and in doing so received at least $89 million in gamed GCG payments." 

Company fined $10M

The investigation covered a three-year period from when Goreway Power Station began generating power in June 2009. Investigators said that delays in releasing documents slowed down their probe, and they only obtained all the records they needed in April 2016.

The investigating panel does not have the power to impose penalties on companies it found broke the rules. 

The IESO fined Goreway Power Station $10 million. The company has also repaid IESO "a substantial portion" of the excess payments it received during its first six years of operating, but the exact figure is blacked out in the investigation report that was made public. 

The control room from which the provincial government's Independent Electricity System Operator manages Ontario's power supply. The agency is also responsible for managing contracts with private power producers.(IESO)

"Goreway does not agree with many of the draft report's findings and conclusions, including any suggestion that Goreway engaged in gaming or that it deliberately misled the IESO," writes lawyer George Vegh on behalf of the company in a response to the investigation report, dated Aug. 1.

"Goreway has implemented initiatives designed to ensure that compliance is a chief operating principle."     

The power station, located near Highway 407 in Brampton, is a joint venture between Toyota Tsusho Corp. and JERA Co. Inc. During the period under scrutiny, the project was run by Toyota Tsusho and Chubu Electric Power Inc., both headquartered in Japan. 

Investigators fear 'same situation' exists today

The report blames the provincially-controlled IESO for creating a system with defects that allowed the over-billing. 

"Goreway was able to — and repeatedly did — exploit these defects," says the investigation report. It goes on to explain the flaws "have created opportunities for exploitation, to the serious financial disadvantage of Ontario's ratepayers," even as greening Ontario's grid could entail massive costs.

The investigation suggests IESO hasn't made adequate changes to ensure it won't happen again, at a time when an analysis of a dirtier grid is raising concerns.   

"Goreway stands as a clear example of how generators are able to exploit the generation costs guarantee regime," says the report.

"The Panel is concerned that the same situation remains in place today." 

PC energy critic Todd Smith raised CBC News' report on the Goreway Power Station in Tuesday's question period. (Ontario Legislature)

After CBC News broke the story Tuesday, the provincial government was forced to respond in question period, amid a broader push for new gas plants to boost electricity production. 

"Here we have yet another gas plant scandal in Peel region that's costing electricity customers over $100 million," said PC energy critic Todd Smith. He slammed "the incompetence of a government that once again failed to look out for electricity customers." 

Economic Development Minister Brad Duguid said: "There is no excuse for any company in this province to ever game the system."

Nine companies overbilled $200M: audit 

The IESO found out about the overbilling "some time ago," said Duguid.

"They fully investigated, they've recovered most of the cost, they delivered a $10 million fine — the biggest fine on record."

The program that Goreway exploited became the subject of an audit that the IESO launched in 2011. The agency uncovered $200 million in ineligible billings by nine power producers, wrote the IESO vice president for policy Terry Young in an email to CBC News.

The IESO has recovered up to 85 per cent of those ineligible costs, Young noted.

Reforms to the design of the the program have removed the potential for overpayments and made it more efficient, he said, even as Ontario weighs embracing clean power more broadly. Last year, its total annual costs dropped to $23 million, down from $61 million in 2014.

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Hydro Quebec Power Consumption Record surges amid extreme cold, peak demand, and grid stress, as Hydro-Quebec urges energy conservation, load management, and reduced heating during morning and evening peaks across Montreal and southern Quebec.

Key Points

Quebec's grid hit 40,300 MW during an extreme cold snap, setting a new record and prompting conservation appeals.

✅ Lower thermostats 1-2 C in unused rooms during peak hours

✅ Delay dishwashers, dryers, and hot water use to off-peak

✅ Peak windows: 6-9 a.m. and 4-8 p.m.; import power if needed

Hydro Quebec says it has once again set a new record for power consumption, echoing record-breaking demand in B.C. in 2021 as extreme cold grips much of the province.

An extreme cold warning has been in effect across southern Quebec since Friday morning, straining the system, just as Calgary's electricity use soared during a frigid February, as Quebecers juggle staying warm and working from home.

Hydro Québec recorded consumption levels reaching 40,300 megawatts as of 8 a.m. Friday, breaking a previous record of 39,000 MW (with B.C. electricity demand hit an all-time high during a similar cold snap) that was broken during another cold snap on Jan 11. 

The publicly owned utility is now asking Quebecers to reduce their electricity consumption as much as possible today and tomorrow, a move consistent with clean electricity goals under federal climate pledges, predicting earlier in the morning the province would again reach an all-time high.

Reducing heating by just one or two degrees, especially in rooms that aren't being used, is one step that people can take to limit their consumption. They can also avoid using large appliances like the dishwasher and clothing dryer as often, and shortening the use of hot water. 

"They're small actions, but across millions of clients, it makes a difference," said Cendrix Bouchard, a spokesperson with Hydro Québec, while speaking with Tout un matin.

"We understand that asking this may pose challenges for some who are home throughout the day because they are working remotely, but if people are able to contribute, we appreciate it."

The best time to try and limit electricity usage is in the morning and evening, when electricity usage tends to peak, Bouchard said.

The province can import electricity from other regions if Quebec's system reaches its limits, even as the utility pursues selling to the United States as part of its long-term strategy, he added.

Temperatures dropped to –24 C in Montreal at 7 a.m., with a wind chill of –29 C. 

It will get colder across the south of the province through the evening and wind chills are expected to make it feel as cold as – 40 until Saturday morning, Environment Canada warned.

Those spending time outdoors are at a higher risk of frostbite and hypothermia.

"Frostbite can develop within minutes on exposed skin, especially with wind chill," Environment Canada said.

Conserving energy
Hydro-Québec has signed up 160,000 clients to a flexible billing plan similar to BC Hydro's winter payment plan that allows them to pay less for energy — as long as they use it during non-peak periods.

Quebec's energy regulator, the Régie de l'énergie, also forces crypto-currency mining operations to shut down for some hours  on peak-demand days, a topic where BC Hydro's approach to crypto mining has also drawn attention, Bouchard said.

Hydro-Québec says the highest consumption periods are usually between 6 a.m.-9 a.m. and 4 p.m.-8 p.m.

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U.S. Utility-Scale Solar Delays driven by the coronavirus pandemic threaten construction timelines, supply chains, and financing, with interconnection and commissioning setbacks, module sourcing risks in Southeast Asia, and tax credit deadline pressures impacting project delivery.

Key Points

Setbacks to large U.S. solar builds from COVID-19 impacting construction, supply, financing, and permitting.

✅ Construction, interconnection, commissioning site visits delayed

✅ Supply chain risks for modules from Southeast Asia

✅ Tax credit deadline extensions sought by developers

About 5 gigawatts (GW) of big U.S. solar energy projects, enough to power nearly 1 million homes, could suffer delays this year if construction is halted for months due to the coronavirus pandemic, as the Covid-19 crisis hits renewables across the sector, according to a report published on Wednesday.

The forecast, a worst-case scenario laid out in an analysis by energy research firm Wood Mackenzie, would amount to about a third of the utility-scale solar capacity expected to be installed in the United States this year, even as US solar and wind growth continues under favorable plans.

The report comes two weeks after the head of the top U.S. solar trade group called the coronavirus pandemic (as solar jobs decline nationwide) "a crisis here" for the industry. Solar and wind companies are pleading with Congress to extend deadlines for projects to qualify for sunsetting federal tax credits.

Even the firm’s best-case scenario would result in substantial delays, mirroring concerns that wind investments at risk across the industry. With up to four weeks of disruption, the outbreak will push out 2 GW of projects, or enough to power about 380,000 homes. Before factoring in the impact of the coronavirus, Wood Mackenzie had forecast 14.7 GW of utility-scale solar projects would be installed this year.

In its report, the firm said the projects are unlikely to be canceled outright. Rather, they will be pushed into the second half of 2020 or 2021. The analysis assumes that virus-related disruptions subside by the end of the third quarter.

Mid-stage projects that still have to secure financing and receive supplies are at the highest risk, Wood Mackenzie analyst Colin Smith said in an interview, adding that it was too soon to know whether the pandemic would end up altering long-term electricity demand and therefore utility procurement plans, where policy shifts such as an ITC extension could reshape priorities.

Currently, restricted travel is the most likely cause of project delays, the report said. Developers expect delays in physical site visits for interconnection and commissioning, and workers have had difficulty reaching remote construction sites.

For earlier-stage projects, municipal offices that process permits are closed and in-person meetings between developers and landowners or local officials have slowed down.

Most solar construction is proceeding despite stay at home orders in many states because it is considered critical infrastructure, and long-term proposals like a tenfold increase in solar could reshape the outlook, the report said, adding that “that could change with time.”

Risks to supplies of solar modules include potential manufacturing shutdowns in key producing nations in Southeast Asia such as Malaysia, Vietnam and Thailand. Thus far, solar module production has been identified as an essential business and has been allowed to continue.

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Iran Power Outage Protests surge as electricity blackouts, drought, and a looming heat wave spark unrest in Tehran, Shiraz, and more, with chants against leadership, strikes, and sanctions-driven economic pressures mounting.

Key Points

Protests across Iran over blackouts, drought, and economic strain challenge authorities and demand accountability.

✅ Rolling blackouts blamed on drought, heat wave, and surging demand.

✅ Chants target leadership amid strikes and wage, water shortages.

✅ Legitimacy questioned after low-turnout election and sanctions.

There have been protests in a number of cities in Iran amid rising public anger over widespread electricity blackouts.

Videos on social media appeared to show crowds in Shar-e Rey near Tehran, Shiraz, Amol and elsewhere overnight.

Some people can be heard shouting "Death to the dictator" and "Death to Khamenei" - a reference to Supreme Leader Ayatollah Ali Khamenei.

The government has apologised for the blackouts, which it has blamed on a severe drought and high demand.

Elsewhere, similar outages have had political repercussions, as a widespread power outage in Taiwan prompted a minister's resignation earlier this year.

President Hassan Rouhani explained in televised remarks on Tuesday morning that the drought meant most of the country's hydroelectric power plants were not operating, placing more pressure on thermal power plants, and that electricity consumption had surged as people used air conditioning to cope with the intense summer heat.

"I apologise to our dear people who have faced problems and suffering in the past few days and I urge them to co-operate [by cutting their electricity use]. People complain about power outages and they are right," Mr Rouhani said.

A video that has gone viral in recent days shows a woman complaining about the blackouts and corruption at a government office in the northern city of Gorgan and demanding that her comments be conveyed to "higher-ups like Mr Rouhani". "The only thing you have done is forcing hijab on us," she shouts.

The president has promised that the government will seek to resolve the problems within the next two or three weeks.

However, a power sector spokesman warned on Monday that consumption was exceeding the production capacity of Iran's power plants by 11GW, and said a "looming heat wave" could make the situation worse, as seen in Iraq's summer electricity crunch this year.

Iranians have also been complaining about water shortages and the non-payment of wages by some local authorities, while thousands of people working in Iran's oil industry have been on strike over pay and conditions, as officials discuss further energy cooperation with Iraq to ease supply pressures.

There was already widespread discontent at government corruption and the economic hardship caused by sanctions that were reinstated when the US abandoned a nuclear deal with Iran three years ago, even as Iran supplies about 40% of Iraq's electricity through cross-border sales.

Analysts say that after the historically low turnout in last month's presidential election, when more than half of the eligible voters stayed at home, the government is facing a serious challenge to its legitimacy.

Mr Rouhani will be succeeded next month by Ebrahim Raisi, a hard-line cleric close to Ayatollah Khamenei who won 62% of the vote after several prominent contenders were disqualified, while Iran finalizes power grid deals with Iraq to bolster regional ties.

The 60-year-old former judiciary chief has presented himself as the best person to combat corruption and solve Iran's economic problems, including ambitions to transmit electricity to Europe as a regional power hub.

But many Iranians and human rights activists have pointed to his human rights record, accusing him of playing a role in the executions of thousands of political prisoners in the 1980s and in the deadly crackdowns on mass anti-government protests in 2009 and 2019.

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California Grid Transition drives decarbonization with renewable energy, EV charging, microgrids, and energy storage, while tackling wildfire risk, aging infrastructure, and cybersecurity threats to build grid resilience and reliability across a rapidly electrifying economy.

Key Points

California Grid Transition is the statewide shift to renewables, storage, EVs, and resilient, secure infrastructure.

✅ Integrates solar, wind, storage, and demand response at scale

✅ Expands microgrids and DERs to enhance reliability and resilience

✅ Addresses wildfire, aging assets, and cybersecurity risks

Gretchen Bakke thinks a lot about power—the kind that sizzles through a complex grid of electrical stations, poles, lines and transformers, keeping the lights on for tens of millions of Californians who mostly take it for granted.

They shouldn’t, says Bakke, who grew up in a rural California town regularly darkened by outages. A cultural anthropologist who studies the consequences of institutional failures, she says it’s unclear whether the state’s aging electricity network and its managers can handle what’s about to hit it, as U.S. blackout risks continue to mount.

California is casting off fossil fuels to become something that doesn’t yet exist: a fully electrified state of 40 million people. Policies are in place requiring a rush of energy from renewable sources such as the sun and wind and calling for millions of electric cars that will need charging—changes that will tax a system already fragile, unstable and increasingly vulnerable to outside forces.

“There is so much happening, so fast—the grid and nearly everything about energy is in real transition, and there’s so much at stake,” said Bakke, who explores these issues in a book titled simply, “The Grid.”

The state’s task grew more complicated with this week’s announcement that Pacific Gas and Electric, which provides electricity for more than 5 million customer accounts, intends to file for bankruptcy in the face of potentially crippling liabilities from wildfires. But the reshaping of California’s energy future goes far beyond the woes of a single company.

The 19th-century model of one-way power delivery from utility companies to customers is being reimagined. Major utilities—and the grid itself—are being disrupted by rooftops paved with solar panels and the rise of self-sufficient neighborhood mini-grids. Whole cities and counties are abandoning big utilities and buying power from wholesalers and others of their choosing.

With California at the forefront of a new energy landscape, officials are racing to design a future that will not just reshape power production and delivery but also dictate how we get around and how our goods are made. They’re debating how to manage grid defectors, weighing the feasibility of an energy network that would expand to connect and serve much of the West and pondering how to appropriately regulate small power producers.

“We are in the depths of the conversation,” said Michael Picker, president of the state Public Utilities Commission, who cautions that even as the system is being rebooted, like repairing a car while driving in practice, there’s no real plan for making it all work.

Such transformation is exceedingly risky and potentially costly. California still bears the scars of having dropped its regulatory reins some 20 years ago, leaving power companies to bilk the state of billions of dollars it has yet to completely recover. And utility companies will undoubtedly pass on to their customers the costs of grid upgrades to defend against natural and man-made threats.

Some weaknesses are well known—rodents and tree limbs, for example, are common culprits in power outages, even as longer, more frequent outages afflict other parts of the U.S. A gnawing squirrel squeezed into a transformer on Thanksgiving Day three years ago, shutting off power to parts of Los Angeles International Airport. The airport plans to spend $120 million to upgrade its power plant.

But the harsh effects of climate change expose new vulnerabilities. Rising seas imperil coastal power plants. Electricity infrastructure is both threatened by and implicated in wildfires. Picker estimates that utility operations are related to one in 10 wildland fires in California, which can be sparked by aging equipment and winds that send tree branches crashing into power lines, showering flammable landscapes with sparks.

California utilities have been ordered to make their lines and equipment more fire-resistant as they’re increasingly held accountable for blazes they cause. Pacific Gas and Electric reported problems with some of its equipment at a starting point of California’s deadliest wildfire, which killed at least 86 people in November in the town of Paradise. The cause of the fire is under investigation.

New and complex cyber threats are more difficult to anticipate and even more dangerous. Computer hackers, operating a world away, can—and have—shut down electricity systems, toggling power on and off at will, and even hijacked the computers of special teams dispatched to restore control.

Thomas Fanning, CEO of Southern Co., one of the country’s largest utilities, recently disclosed that his teams have fended off multiple attempts to hack a nuclear power plant the firm operates. He called grid hacking “the most important under-reported war in American history.”

However, if you’ve got what seems like an insoluble problem requiring a to-the-studs teardown and innovative rebuild, California is a good place to start. After all, the first electricity grid was built in San Francisco in 1879, three years before Thomas Edison’s power station in New York City. (Edison’s plant burned to the ground a decade later.)

California’s energy-efficiency regulations have helped reduce statewide energy use, which peaked a decade ago and is on the decline, somewhat easing pressure on the grid. The major utilities are ahead of schedule in meeting their obligation to obtain power from renewable sources.

California’s universities are teaming with national research labs to develop cutting-edge solutions for storing energy produced by clean sources. California is fortunate in the diversity of its energy choices: hydroelectric dams in the north, large-scale solar operations in the Mojave Desert to the east, sprawling windmill farms in mountain passes and heat bubbling in the Geysers, the world’s largest geothermal field north of San Francisco. A single nuclear-power plant clings to the coast near San Luis Obispo, but it will be shuttered in 2025.

But more renewable energy, accessible at the whims of weather, can throw the grid off balance. Renewables lack the characteristic that power planners most prize: dispatchability, ready when called on and turned off when not immediately needed. Wind and sun don’t behave that way; their power is often available in great hunks—or not at all, as when clouds cover solar panels or winds drop.

In the case of solar power, it is plentiful in the middle of the day, at a time of low demand. There’s so much in California that most days the state pays its neighbors to siphon some off,  lest the excess impede the grid’s constant need for balance—for a supply that consistently equals demand.

So getting to California’s new goals of operating on 100 percent clean energy by 2045 and having 5 million electric vehicles within 12 years will require a shift in how power is acquired and managed. Consumers will rely more heavily on battery storage, whose efficiency must improve to meet that demand.

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SunCrate Solar Microgrid delivers resilient, plug-and-play renewable power to Puerto Rico schools, combining Canadian Solar PV, Tesla Powerwall battery storage, and Black & Veatch engineering to ensure off-grid continuity during outages and disasters.

Key Points

A compact PV-and-battery system for resilient, diesel-free power and microgrid backup at schools and clinics.

✅ Plug-and-play, modular PV, inverter, and battery architecture

✅ Tesla Powerwall storage; Canadian Solar 325 W panels

✅ Scales via daisy-chain for higher loads and microgrids

Eleven months since their three-building school was first plunged into darkness by Hurricane Maria, 140 students in Puerto Rico’s picturesque Yabucoa district have reliable power. Resilient electricity service was provided Saturday to the SU Manuel Ortiz school through an innovative scalable, plug-and-play solar system pioneered by SunCrate Energy with Black & Veatch support. Known as a “SunCrate,” the unit is an effective mitigation measure to back up the traditional power supply from the grid. The SunCrate can also provide sustainable power in the face of ongoing system outages and future natural disasters without requiring diesel fuel.

The humanitarian effort to return sustainable electricity to the K-8 school, found along the island’s hard-hit southeastern coast, drew donated equipment and expertise from a collection of North American companies. Additional support for the Yabucoa project came from Tesla, Canadian Solar and Lloyd Electric, reflecting broader efforts to build a solar-powered grid in Puerto Rico after Hurricane Maria.

“We are grateful for this initiative, which will equip this school with the technology needed to become a resilient campus and not dependent on the status of the power grid. This means that if we are hit with future harmful weather events, the school will be able to open more quickly and continue providing services to students,” Puerto Rico Secretary of Education Julia Keleher said.

The SunCrate harnesses a scalable rapid-response design developed by Black & Veatch and manufactured by SunCrate Energy. Electricity will be generated by an array of 325-W CS6U-Poly modules from Canadian Solar. California-based Tesla contributed advanced battery energy storage through various Powerwall units capable of storing excess solar power and delivering it outside peak generation periods, with related experience from a virtual power plant in Texas informing deployment.  Lloyd Electric Co. of Wichita Falls, Texas, partnered to support delivery and installation of the SunCrate.

“As families in the region begin to prepare for the school year, this community is still impacted by the longest U.S. power outage in history,” said Dolf Ivener, a Midwestern entrepreneur who owns King of Trails Construction and SunCrate Energy, which is donating the SunCrate. “SunCrate, with its rapid deployment and use of renewable energy, should give this school peace of mind and hopefully returns a touch of long-overdue normalcy to students and their parents. When it comes to consistent power, SunCrate is on duty.”

The SunCrate is a portable renewable energy system conceived by Ivener and designed and tested by Black & Veatch. Its modular design uses solar PV panels, inverters and batteries to store and provide electric power in support of critical services such as police, fire, schools, clinics and other community level facilities.

A SunCrate can generate 23 to 156 kWh per day, and store 10 kWh to 135 kWh depending on configuration. A SunCrate’s power generation and storage capacity can be easily scaled through daisy-chained configurations to accommodate larger buildings and loads. Leveraging resources from Tesla, Canadian Solar, Lloyd Electric and Lord Electric, the unit in Yabucoa will provide an estimated 52 kWh of storable power without requiring use of costlier diesel-powered generators and cutting greenhouse gas emissions. Its capabilities allow the school to strengthen its function as a designated Community Emergency Response Center in the event of future natural disasters.

“Canadian Solar has a long history of using solar power to support humanitarian efforts aiding victims of social injustice and natural disasters, including previous donations to Puerto Rico after Hurricane Maria,” said Dr. Shawn Qu, Chairman and Chief Executive Officer of Canadian Solar. “We are pleased to make the difference for these schoolchildren in Yabucoa who have been without reliable power for too long.”

The SunCrate will also substantially lower the school’s ongoing electricity costs by providing a reliable source of renewable energy on site, as falling costs of solar batteries improve project economics overall.

“Through our experience providing engineering services in Puerto Rico for nearly 50 years, including dozens of specialized projects for local government and industrial clients, we see great potential for SunCrate as a source of resilient power for the Commonwealth’s remote schools and communities at large, underscoring the importance of electricity resilience across critical infrastructure,” said Charles Moseley, a Program Director in Black & Veatch’s water business. “We hope that the deployment of the SunCrate in Yabucoa sets a precedent for facility and municipal level migro-grid efforts on the island and beyond.”

SunCrate also has broad potential applications in conflict/post-conflict environments and in rural electrification efforts in the developing world, serving as a resilient source of electricity within hours of its arrival on site and could enable peer-to-peer energy within communities. Of particular benefit, the system’s flexibility cuts fuel costs to a fraction of a generator’s typical consumption when they are used around the clock with maintenance requirements.

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