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

Key Points

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

✅ PUCT ordered clawbacks for ancillary services not delivered.

✅ IMM urged price correction after firm load shed ceased.

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

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

According to the IMM (emphasis added):

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

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Definition and Improvements to Determining and Charging for Ancillary Service Failed Quantities; however, the NPRR was withdrawn in August 2020 amid ongoing market reform discussions because of the system cost, some complexities related to AS trades, and the implementation of real-time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

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

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

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

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

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

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

According to the IMM (emphasis added):

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

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

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

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

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Germany January Power Mix shows gas-fired generation rising, coal steady, and nuclear phaseout impacts, amid cold weather, energy prices, industrial demand, and emissions targets shaping renewables, grid stability, and security of supply.

Key Points

The January electricity mix, highlighting gas, coal, renewables, and nuclear exit effects on emissions, prices, and demand.

✅ Gas output up 13% to 8.74 TWh, share at 18.6%.

✅ Coal share 23%, down year on year, steady vs late 2023.

✅ Nuclear gap filled by gas and coal; emissions below Jan 2023.

Germany's electricity generation in January presented a fascinating snapshot of its energy transition journey. As the country strives to move away from fossil fuels, with renewables overtaking coal and nuclear in its power mix, it grapples with the realities of replacing nuclear power and meeting fluctuating energy demands.

Gas Takes the Lead:

Gas-fired power plants saw their highest output in two years, generating 8.74 terawatt hours (TWh). This 13% increase compared to January 2023 compensated for the closure of nuclear reactors, which were extended during the energy crisis to shore up supply, and colder weather driving up heating needs. This reliance on gas, however, pushed its share in the electricity mix to 18.6%, highlighting Germany's continued dependence on fossil fuels.

Coal Fades, but Not Forgotten:

While gas surged, coal-fired generation remained below previous levels, dropping 29% from January 2023. However, it stayed relatively flat compared to late 2023, suggesting utilities haven't entirely eliminated it. Coal still held a 23% share, and periodic coal reliance remains evident, exceeding gas' contribution, reflecting its role as a reliable backup for intermittent renewable sources like wind.

Nuclear Void and its Fallout:

The shutdown of nuclear plants in April 2023 created a significant gap, previously accounting for an average of 12% of annual electricity output. This loss is being compensated through gas and coal, with gas currently the preferred choice, even as a nuclear option debate persists among policymakers. This strategy kept January's power sector emissions lower than the previous year, but rising demand could shift the balance.

Industry's Uncertain Impact:

Germany's industrial sector, a major energy consumer, is facing challenges like high energy prices and weak consumer demand. While the government aims to foster industrial recovery, uncertainties linger due to a shaky coalition and limited budget, and debate about a possible nuclear resurgence continues in parallel, which could reshape policy. Any future industrial revival would likely increase energy demand and potentially necessitate more gas or coal.

Cost-Driven Choices and Emission Concerns:

The choice between gas and coal depends on their relative costs, in a system pursuing a coal and nuclear phase-out under long-term policy. Currently, gas seems more favorable emission-wise, but if its price rises, coal might become more attractive, impacting overall emissions.

Looking Ahead:

Germany's energy transition faces a complex balancing act, with persistent grid expansion woes and exposure to cheap gas complicating progress. While the reliance on gas and coal highlights the difficulties in replacing nuclear, the focus on emissions reduction is encouraging. Navigating the challenges of affordability, industrial needs, and climate goals will be crucial for a successful transition to a clean and secure energy future.

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Wave Energy Converters can deliver marine power to the grid, with DOE-backed PacWave enabling offshore testing, robust designs, and renewable electricity from oscillating waves to decarbonize coastal communities and replace diesel in remote regions.

Key Points

Wave energy converters are devices that transform waves' oscillatory motion into electricity for the grid or loads.

✅ DOE's PacWave enables full-scale, grid-connected offshore testing.

✅ Multiple designs convert oscillating motion into torque and power.

✅ Ideal for islands, microgrids, and replacing diesel generation.

Waves off the coast of the U.S. could generate 2.64 trillion kilowatt hours of electricity per year — that’s about 64% of last year’s total utility-scale electricity generation in the U.S. We won’t need that much, but one day experts do hope that wave energy will comprise about 10-20% of our electricity mix, alongside other marine energy technologies under development today.

“Wave power is really the last missing piece to help us to transition to 100% renewables, ” said Marcus Lehmann, co-founder and CEO of CalWave Power Technologies, one of a number of promising startups focused on building wave energy converters.

But while scientists have long understood the power of waves, it’s proven difficult to build machines that can harness that energy, due to the violent movement and corrosive nature of the ocean, combined with the complex motion of waves themselves, even as a recent wave and tidal market analysis highlights steady advances.

″Winds and currents, they go in one direction. It’s very easy to spin a turbine or a windmill when you’ve got linear movement. The waves really aren’t linear. They’re oscillating. And so we have to be able to turn this oscillatory energy into some sort of catchable form,” said Burke Hales, professor of cceanography at Oregon State University and chief scientist at PacWave, a Department of Energy-funded wave energy test site off the Oregon Coast. Currently under construction, PacWave is set to become the nation’s first full-scale, grid-connected test facility for these technologies, a milestone that parallels U.K. wind power lessons on scaling new industries, when it comes online in the next few years.

“PacWave really represents for us an opportunity to address one of the most critical barriers to enabling wave energy, and that’s getting devices into the open ocean,” said Jennifer Garson, Director of the Water Power Technologies Office at the U.S. Department of Energy.

At the beginning of the year, the DOE announced $25 million in funding for eight wave energy projects to test their technology at PacWave, as offshore wind forecasts underscore the growing investor interest in ocean-based energy. We spoke with a number of these companies, which all have different approaches to turning the oscillatory motion of the waves into electrical power.

Different approaches
Of the eight projects, Bay Area-based CalWave received the largest amount, $7.5 million. 

″The device we’re testing at PacWave will be a larger version of this,” said Lehmann. The x800, our megawatt-class system, produces enough power to power about 3,000 households.”

CalWave’s device operates completely below the surface of the water, and as waves rise and fall, surge forward and backward, and the water moves in a circular motion, the device moves too. Dampers inside the device slow down that motion and convert it into torque, which drives a generator to produce electricity, a principle mirrored in some wind energy kite systems as they harvest aerodynamic forces.

“And so the waves move the system up and down. And every time it moves down, we can generate power, and then the waves bring it back up. And so that oscillating motion, we can turn into electricity just like a wind turbine,” said Lehmann.

Another approach is being piloted by Seattle-based Oscilla Power, which was awarded $1.8 million from the DOE, and is getting ready to deploy its wave energy converter off the coast of Hawaii, at the U.S. Navy Wave Energy Test site.

Oscilla Power’s device is composed of two parts. One part floats on the surface and moves with the waves in all directions — up and down, side to side and rotationally. This float is connected to a large, ring-shaped structure which hangs below the surface, and is designed to stay relatively steady, much like how underwater kites leverage a stable reference to generate power. The difference in motion between the float and the ring generates force on the connecting lines, which is used to rotate a gearbox to drive a generator.

″The system that we’re deploying in Hawaii is what we call the Triton-C. This is a community-scale system,” said Balky Nair, CEO of Oscilla Power. “It’s about a third of the size of our flagship product. It’s designed to be 100 kilowatt rated, and it’s designed for islands and small communities.”

Nair is excited by wave energy’s potential to generate electricity in remote regions, which currently rely on expensive and polluting diesel imports to meet their energy needs when other renewables aren’t available, and similar tidal energy for remote communities efforts in Canada point to viable models. Before wave energy is adopted at-scale, many believe we’ll see wave energy replacing diesel generators in off-the-grid communities.

A third company, C-Power, based in Charlottesville, Virginia, was awarded more than $4 million to test its grid-scale wave energy converter at PacWave. But first, the company wants to commercialize its smaller scale system, the SeaRAY, which is designed for lower-power applications. 

″Think about sensors in the ocean, research, metocean data gathering, maybe it’s monitoring or inspection,” said C-Power CEO Reenst Lesemann on the initial applications of his device.

The SeaRAY consists of two floats and a central body, the nacelle, which contains the drivetrain. As waves pass by, the floats bob up and down, rotating about the nacelle and turning their own respective gearboxes which power the electric generators.

Eventually, C-Power plans to scale up its SeaRAY so that it’s capable of satellite communications and deep water deployments, before building a larger system, called the StingRAY, for terrestrial electricity generation.

Meanwhile, one Swedish company, Eco Wave Power, is taking another approach completely, eschewing offshore technologies in favor of simpler wave power devices that can be installed on breakwaters, piers, and jetties.

“All the expensive conversion machinery, instead of being inside the floaters like in the competing technologies, is on land just like a regular power station. So basically this enables a very low installation, operation, and maintenance cost,” explained CEO Inna Braverman.

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Ukraine Electricity Exports resume as the EU grid links stabilize; ENTSO-E caps, megawatt capacity, renewables, and infrastructure repairs enable power flows to Moldova, Poland, Slovakia, and Romania despite ongoing Russian strikes.

Key Points

Resumed cross-border power sales showing grid stability under ENTSO-E limits and surplus generation.

✅ Exports restart to Moldova; Poland, Slovakia, Romania next.

✅ ENTSO-E cap limits to 400 MW; more capacity under negotiation.

✅ Revenues fund grid repairs after Russian strikes.

Ukraine began resuming electricity exports to European countries on Tuesday, its energy minister said, a dramatic turnaround from six months ago when fierce Russian bombardment of power stations plunged much of the country into darkness in a bid to demoralize the population.

The announcement by Energy Minister Herman Halushchenko that Ukraine was not only meeting domestic consumption demands but also ready to restart exports to its neighbors was a clear message that Moscow’s attempt to weaken Ukraine by targeting its infrastructure did not work.

Ukraine’s domestic energy demand is “100%” supplied, he told The Associated Press in an interview, and it has reserves to export due to the “titanic work” of its engineers and international partners.

Russia ramped up infrastructure attacks in September, when waves of missiles and exploding drones destroyed about half of Ukraine's energy system, even as it built lines to reactivate the Zaporizhzhia plant in occupied territory. Power cuts were common across the country as temperatures dropped below freezing and tens of millions struggled to keep warm.

Moscow said the strikes were aimed at weakening Ukraine’s ability to defend itself, and both sides have floated a possible agreement on power plant attacks amid mounting civilian harm, while Western officials said the blackouts that caused civilians to suffer amounted to war crimes. Ukrainians said the timing was designed to destroy their morale as the war marked its first anniversary.

Ukraine had to stop exporting electricity in October to meet domestic needs.

Engineers worked around the clock, often risking their lives to come into work at power plants and keep the electricity flowing. Kyiv’s allies also provided help. In December, U.S. Secretary of State Antony Blinken announced $53 million in bilateral aid to help the country acquire electricity grid equipment, on top of $55 million for energy sector support.

Much more work remains to be done, Halushchenko said. Ukraine needs funding to repair damaged generation and transmission lines, and revenue from electricity exports would be one way to do that.

The first country to receive Ukraine’s energy exports will be Moldova, he said.

Besides the heroic work by engineers and Western aid, warmer temperatures are enabling the resumption of exports by making domestic demand lower, and across Europe initiatives like virtual power plants for homes are helping balance grids. Nationwide consumption was already down at least 30% due to the war, Halushchenko said, with many industries having to operate with less power.

Renewables like solar and wind power also come into play as temperatures rise, taking some pressure off nuclear and coal-fired power plants.

But it’s unclear if Ukraine can keep up exports amid the constant threat of Russian bombardment.

“Unfortunately now a lot of things depend on the war,” Halushchenko said. “I would say we feel quite confident now until the next winter.”

Exports to Poland, Slovakia and Romania are also on schedule to resume, he said.

“Today we are starting with Moldova, and we are talking about Poland, we are talking about Slovakia and Romania,” Halushchenko added, noting that how much will depend on their needs.

“For Poland, we have only one line that allows us to export 200 megawatts, but I think this month we will finish another line which will increase this to an additional 400 MW, so these figures could change,” he said.

Export revenue will depend on fluctuating electricity prices in Europe, where stunted hydro and nuclear output may hobble recovery efforts. In 2022, while Ukraine was still able to export energy, Ukrainian companies averaged 40 million to 70 million euros a month depending on prices, Halushchenko said.

“Even if it’s 20 (million euros) it’s still good money. We need financial resources now to restore generation and transmission lines,” he said.

Ukraine has the ability to export more than the 400 megawatt capacity limit imposed by the European Network of Transmission System Operators for Electricity, or ENTSO-E, and rising EU wind and solar output is reshaping cross-border flows. “We are in negotiations to increase this cap because today we can export even more, we have the necessary reserves in the system,” the minister said.

The current capacity limit is in line with what Ukraine was exporting in September 2022 before Ukraine diverted resources to meet domestic needs amid the Russian onslaught.

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Minnesota Electric Cooperatives are driving grid innovation with smart meters, time-of-use pricing, demand response, and energy storage, including iron-air batteries, to manage peak loads, integrate wind and solar, and cut costs for rural members.

Key Points

Member-owned utilities piloting load management, meters, and storage to integrate wind and solar, cutting peak demand.

✅ Time-of-use pricing pilots lower bills and shift peak load.

✅ Iron-air battery tests add multi-day, low-cost energy storage.

✅ Smart meters enable demand response across rural co-ops.

Minnesota electric cooperatives have quietly emerged as laboratories for clean grid innovation, outpacing investor-owned utilities on smart meter installations, time-based pricing pilots, and experimental battery storage solutions.

“Co-ops have innovation in their DNA,” said David Ranallo, a spokesperson for Great River Energy, a generation and distribution cooperative that supplies power to 28 member utilities — making it one of the state’s largest co-op players.

Minnesota farmers helped pioneer the electric co-op model more than a century ago, similar to modern community-generated green electricity initiatives, pooling resources to build power lines, transformers and other equipment to deliver power to rural parts of the state. Today, 44 member-owned electric co-ops serve about 1.7 million rural and suburban customers and supply almost a quarter of the state’s electricity.

Co-op utilities have by many measures lagged on clean energy. Many still rely on electricity from coal-fired power plants. They’ve used political clout with rural lawmakers to oppose new pollution regulations and climate legislation, and some have tried to levy steep fees on customers who install solar panels.

Where they are emerging as innovators is with new models and technology for managing electric grid loads — from load-shifting water heaters to a giant experimental battery made of iron. The programs are saving customers money by delaying the need for expensive new infrastructure, and also showing ways to unlock more value from cheap but variable wind and solar power.

Unlike investor-owned utilities, “we have no incentive to invest in new generation,” said Darrick Moe, executive director of the Minnesota Rural Electric Association. Curbing peak energy demand has a direct financial benefit for members.

Minnesota electric cooperatives have launched dozens of programs, such as the South Metro solar project, in recent years aimed at reducing energy use and peak loads, in particular. They include:

Cost calculations are the primary driver for electric cooperatives’ recent experimentation, and a lighter regulatory structure and evolving electricity market reforms have allowed them to act more quickly than for-profit utilities.

“Co-ops and [municipal utilities] can act a lot more nimbly compared to investor-owned utilities … which have to go through years of proceedings and discussions about cost-recovery,” said Gabe Chan, a University of Minnesota associate professor who has researched electric co-ops extensively. Often, approval from a local board is all that’s required to launch a venture.

Great River Energy’s programs, which are rebranded and sold through member co-ops, yielded more than 101 million kilowatt-hours of savings last year — enough to power 9,500 homes for a year.

Beyond lowering costs for participants and customers at large, the energy-saving and behavior-changing programs sometimes end up being cited as case studies by larger utilities considering similar offerings. Advocates supporting a proposal by the city of Minneapolis and CenterPoint Energy to allow residents to pay for energy efficiency improvements on their utility bills through distributed energy rebates used several examples from cooperatives.

Despite the pace of innovation on load management, electric cooperatives have been relatively slow to transition from coal-fired power. More than half of Great River Energy’s electricity came from coal last year, and Dairyland Power, another major power wholesaler for Minnesota co-ops, generated 70% of its energy from coal. Meanwhile, Xcel Energy, the state’s largest investor-owned utility, has already reduced coal to about 20% of its energy mix.

The transition to cleaner power for some co-ops has been slowed by long-term contracts with power suppliers that have locked them into dirty power. Others have also been stalled by management or boards that have been resistant to change. John Farrell, director of the Institute for Local Self-Reliance’s Energy Democracy program, said generalizing co-ops is difficult. 

“We’ve seen some co-ops that have got 75-year contracts for coal, that are invested in coal mines and using their newsletter to deny climate change,” he said. “Then you see a lot of them doing really amazing things like creating energy storage systems … and load balancing [programs], because they are unique and locally managed and can have that freedom to experiment without having to go through a regulatory process.”

Great River Energy, for its part, says it intends to reach 54% renewable generation by 2025, while some communities, like Frisco, Colorado, are targeting 100% clean electricity by specific dates. Its members recently voted to sell North Dakota’s largest coal plant, but the arrangement involves members continuing to buy power from the new owners for another decade.

The cooperative’s path to clean power could become clearer if its experimental iron-air battery project is successful. The project, the first of its kind in the country, is expected to be completed by 2023.

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Muskrat Falls rate mitigation offsets Newfoundland Power's rate stabilization decrease as NL Hydro begins cost recovery; Public Utilities Board approval enables collections while Labrador-Island Link nears commissioning, stabilizing electricity rates despite megaproject delays, overruns.

Key Points

Muskrat Falls rate mitigation is NL Hydro's cost recovery via power rates to stabilize bills as commissioning nears.

✅ Offsets 6.4% decrease with a 6.1% rate increase

✅ About 6% now funds NL Hydro's rate mitigation

✅ Collections begin as Labrador-Island Link nears commissioning

With their July electricity bill, Newfoundland Power customers have begun paying for Muskrat Falls, though a lump-sum credit was also announced to offset costs and bills haven't significantly increased — yet.

In a July newsletter, Newfoundland Power said electricity bills were set to decrease by 6.4 per cent as part of the annual rate stabilization adjustment, which reflects the cost of electricity generation.

Instead, that decrease has been offset by a 6.1 increase in electricity rates so Newfoundland and Labrador Hydro can begin recovering the cost of Muskrat Falls, with a $5.2-billion federal package also underpinning the project, the $13-billion hydroelectric megaproject that is billions over budget and years behind schedule.

That means for residential customers, electricity rates will decrease to 12.346 cents per kilowatt, though the basic customer charge will go up slightly from $15.81 to $15.83. According to an N.L. Hydro spokesperson, about six per cent of electricity bills will now go toward what it calls a "rate mitigation fund." 

N.L. Hydro claims victory in Muskrat Falls arbitration dispute with Astaldi
Software troubles blamed for $260M Muskrat Falls cost increase, with N.L. power rates stable for now
The spokesperson said N.L. Hydro is expecting the rate increase to result in $43 million this year, according to a recent financial update from the energy corporation — a tiny fraction of the project's cost. 

N.L. Hydro asked the Public Utilities Board to approve the rate increase, a process similar to Nova Scotia's recent 14% approval by its regulator, in May. In a letter, Energy, Industry and Technology Minister Andrew Parsons supported the increase, though he asked N.L. Hydro to keep electricity rates "as close to current levels as possible. 

Province modifies order in council
Muskrat Falls is not yet fully online — largely due to software problems with the Labrador-Island Link transmission line — and an order in council dictated that ratepayers on the island of Newfoundland would not begin paying for the project until the project was fully commissioned. 

The provincial government modified that order in council so N.L. Hydro can begin collecting costs associated with Muskrat Falls once the project is "nearing" commissioning.

In June, N.L. Hydro said the project was expected to finally be completed by the end of the year.

In an interview with CBC News, Progressive Conservative interim leader David Brazil said the decision to begin recovering the cost of Muskrat Falls from consumers should have been delayed.

"There was an opportunity here for people to get some reprieve when it came to their electricity bills and this administration chose not to do that, not to help the people while they're struggling," he said.

In a statement, Parsons said reducing the rate was not an option, and would have resulted in increased borrowing costs for Muskrat Falls.

"Reducing the rate for one year to have it increase significantly the following year is not consistent with rate mitigation and also places an increased financial burden on taxpayers one year from now," Parsons said.

Decision 'reasonable': Consumer advocate
Brazil said his party didn't know the payments from Muskrat Falls would start in July, and criticized the government for not being more transparent.

A person wearing a blue shirt and black blazer stands outside on a lawn.
N.L. consumer advocate Dennis Browne says it makes sense to begin recouping the cost of Muskrat Falls. (Garrett Barry/CBC)
Newfoundland and Labrador consumer advocate Dennis Browne said the decision to begin collecting costs from consumers was "reasonable."

"We're into a financial hole due to Muskrat Falls, and what has happened is in order to stabilize rates, we have gone into rate stabilization efforts," he said.

In February, the provincial and federal governments signed a complex agreement to shield ratepayers aimed at softening the worst of the financial impact from Muskrat Falls. Browne noted even with the agreement, the provincial government will have to pay hundreds of millions in order to stabilize electricity rates.

"Muskrat Falls would cost us $0.23 a kilowatt, and that is out of the range of affordability for most people, and that's why we're into rate mitigation," he said. "This was part of a rate mitigation effort, and I accepted it as part of that."

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