AEP responds to Ohio capacity case decision

By American Electric Power


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American Electric Power President and Chief Executive Officer Nicholas K. Akins issued the following statement in response to todayÂ’s decision from the Public Utilities Commission of Ohio PUCO in the AEP Ohio capacity charge case.

"While it is disappointing that the PUCO did not fully recognize the value of AEP Ohio's generation in this case, todayÂ’s decision is just one part of the process to determine a path to competition in Ohio. This path must provide both benefits for customers and a transition that maintains the financial integrity of AEP Ohio," Akins said. "It is clear that the PUCO recognized the relationship of this case with the pending Electric Security Plan case, and weÂ’ll look to that decision to more fully define the combined impacts of these orders."

The PUCO determined a generation capacity cost for AEP Ohio of $188.88 per megawatt-day. AEP OhioÂ’s actual cost of capacity is $355 per megawatt-day. The CommissionÂ’s order said that AEP Ohio must charge competitive retail electric service providers the Reliability Pricing Model RPM price currently $20.01 per megawatt-day, which is substantially below both AEPÂ’s actual cost of capacity and the PUCO-determined capacity cost.

Competitive retail electric service providers use AEP Ohio’s generating capacity to serve their customers. The PUCO indicated that AEP Ohio will be allowed to defer – under a method and over a period of time to be determined in AEP Ohio’s pending Electric Security Plan ESP case – the difference between the PUCO-determined capacity cost and the RPM price for recovery. An order in that case is expected in early August.

The PUCO postponed implementation of the recent order until Aug. 8 or until an order is issued in AEP OhioÂ’s pending ESP case, whichever is sooner.

AEP Ohio provides electricity to nearly 1.5 million customers of major AEP subsidiaries Ohio Power Company in Ohio and Wheeling Power Company in the northern panhandle of West Virginia. AEP Ohio is based in Gahanna, Ohio, and is a unit of American Electric Power.

American Electric Power is one of the largest electric utilities in the United States, delivering electricity to more than 5 million customers in 11 states. AEP ranks among the nationÂ’s largest generators of electricity, owning nearly 39,000 megawatts of generating capacity in the U.S. AEP also owns the nationÂ’s largest electricity transmission system, a nearly 39,000-mile network that includes more 765-kilovolt extra-high voltage transmission lines than all other U.S. transmission systems combined.

AEPÂ’s transmission system directly or indirectly serves about 10 percent of the electricity demand in the Eastern Interconnection, the interconnected transmission system that covers 38 eastern and central U.S. states and eastern Canada, and approximately 11 percent of the electricity demand in ERCOT, the transmission system that covers much of Texas.

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Electricity complaints filed by Texans reach three-year high, report says

Texas Electricity Complaints surged to a three-year high, highlighting Public Utility Commission data on billing disputes, meter problems, and service issues in the competitive retail electricity market and consumer protection process.

 

Key Points

Consumer filings to Texas PUC about billing, service, and meters, with 2018 reaching a three-year high.

✅ 5,371 complaints/inquiries in FY2018; 43.8% involved billing disputes.

✅ Service issues 15.8% and meters 12.6%; PUC publishes complaint stats.

✅ Advocates urge monitoring to keep deregulated retail market healthy.

 

The number of electricity service-related complaints and inquiries filed with the state’s Public Utility Commission reached a three-year high this past fiscal year, an advocacy group said Tuesday.

According to the Texas Coalition for Affordable Power, a nonprofit that advocates for low electricity prices, Texans filed 5,371 complaints or inquiries with the commission between September 2017 and August of this year. That’s up from the 4,175 complaints or inquiries filed during the same period in 2017 and the 4,835 filed in 2016. The complaints and inquiries included concerns with billing, meters and service.

“This stark uptick in complaints is disappointing — especially after several years of generally improving numbers,” Jay Doegey, the coalition's executive director, said in a written statement. “In percentage terms, the year-to-year rise in complaints is the greatest in a decade. Clearly, many Texans remain frustrated with aspects of their electric service.”

The utility commission did not immediately respond to a request for comment.

While complaints and inquiries increased in 2018, the number of complaints and inquiries has generally decreased since 2009, when Texans filed 15,956 with the commission. That could be because there have been lower residential electricity prices and because Texans have become more familiar with the state’s competitive retail electricity system over the last decade, the coalition's report said.

And complaints from 2018 are well below 2003 levels, when the number of complaints and inquiries soared to more than 17,000, a year after Texas deregulated most of its electricity market structure at the time.

But Jake Dyer, a policy analyst at the coalition, said his group is closely watching the uptick in complaints this year as the Texas power grid faces recurring strains.

“We are invested in making sure the competition works,” Dyer said. “When you see an uptick like this, you should watch very closely to make sure the market remains healthy and to make sure there is not something else going on.”

However, Dyer said that it is too early to know what that something else that is going on might be.

According to the report, concerns about billing made up most of the complaints and inquiries filed this year at 43.8 percent. That’s up from 42.5 percent in fiscal year 2017. Concerns about the provision of electrical service and about electrical meters also ranked high, constituting 15.8 percent and 12.6 percent of the complaints and inquiries, respectively.

The Public Utility Commission publishes customer complaint statistics on its website. The Texas Coalition for Affordable Power takes into account both complaints and inquiries filed with the commission for its report in order “to gauge general consumer sentiment and to maintain a uniform methodology across the study period.”

Texans can file an official complaint with the the commission's Customer Protection Division. Under the complaint process, the complaint is sent to the electric company, which has 21 days to respond.

Some providers outside the competitive market, such as electric cooperatives, drew praise for performance during the 2021 winter storm.

Following the 2021 winter storm, Texas lawmakers proposed an electricity market bailout to stabilize costs and reliability.

 

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Hydro One will keep running its U.S. coal plant indefinitely, it tells American regulators

Hydro One-Avista Merger outlines a utility acquisition shaped by Washington regulators, Colstrip coal plant depreciation, and plans for renewables, clean energy, and emissions cuts, while Montana reviews implications for jobs, ratepayers, and a 2027 closure.

 

Key Points

A utility deal setting Colstrip depreciation and renewables, without committing to an early coal plant closure.

✅ Washington sets 2027 depreciation for Colstrip units

✅ Montana reviews jobs, ratepayer impacts, community fund

✅ Avista seeks renewables; no binding shutdown commitment

 

The Washington power company Hydro One is buying will be ready to close its huge coal-fired generating station ahead of schedule, thanks to conditions put on the corporate merger by state regulators there.

Not that we actually plan to do that, the company is telling other regulators in Montana, where coal unit retirements are under debate, the huge coal-fired generating station in question employs hundreds of people. We’ll be in the coal business for a good long time yet.

Hydro One, in which the Ontario government now owns a big minority stake, is still working on its purchase of Avista, a private power utility based in Spokane. The $6.7-billion deal, which Hydro One announced in July, includes a 15 per cent share in two of the four generating units in a coal plant in Colstrip, Montana, one of the biggest in the western United States. Avista gets most of its electricity from hydro dams and gas but uses the Colstrip plant when demand for power is high and water levels at its dams are low.

#google#

Colstrip’s a town of fewer than 2,500 people whose industries are the power plant and the open-pit mines that feed it about 10 million tonnes of coal a year. Two of Colstrip’s generators, older ones Avista doesn’t have any stake in, are closing in 2022. The other two will be all that keep the town in business.

In Washington, they don’t like the coal plant and its pollution. In Montana, the future of Colstrip is a much bigger concern. The companies have to satisfy regulators in both places that letting Hydro One buy Avista is in the public interest.

Ontario proudly closed the last of our coal plants in 2014 and outlawed new ones as environmental menaces, and Alberta's coal phase-out is now slated to finish by 2023. When Hydro One said it was buying Avista, which makes about $100 million in profit a year, Premier Kathleen Wynne said she hoped Ontario’s “value system” would spread to Avista’s operations.

The settlement is “an important step towards bringing together two historic companies,” Hydro One’s chief executive Mayo Schmidt said in announcing it.

The deal has approval from the Washington Utilities and Transportation Commission staff but is subject to a vote by the group’s three commissioners. It doesn’t commit Avista to closing anything at Colstrip or selling its share. But Avista and Hydro One will budget as if the Colstrip coal burners will close in 2027, instead of running into the 2040s as their owners had once planned, a timeline that echoes debates over the San Juan Generating Station in New Mexico.

In accounting terms, they’ll depreciate the value of their share of the plant to zero over the next nine years, reflecting what they say is the end of the plant’s “useful life.” Another of Colstrip’s owners, Puget Sound Energy, has previously agreed with Washington regulators that it’ll budget for a Colstrip closure in 2027 as well.

Avista and Hydro One will look for sources of 50 megawatts of renewable electricity, including independent power projects where feasible, in the next four years and another 90 megawatts to supplement Avista’s supply once the Colstrip plant eventually closes, they promise in Washington. They’ll put $3 million into a “community transition fund” for Colstrip.

The money will come from the companies’ profits and cash, the agreement says. “Hydro One will not seek cost recovery for such funds from ratepayers in Ontario,” it says specifically.

“Ontario has always been a global leader in the transition away from dirty coal power and towards clean energy,” said Doug Howell, an anti-coal campaigner with the Sierra Club, which is a party to the agreement. “This settlement continues that tradition, paving the way for the closure of the largest single source of climate pollution in the American West by 2027, if not earlier.”

Montanans aren’t as thrilled. That state has its own public services commission, doing its own examination of the corporate merger, which has asked Hydro One and Avista to explain in detail why they want to write off the value of the Colstrip burners early. The City of Colstrip has filed a petition saying it wants in on Montana hearings because “the potential closure of (Avista’s units) would be devastating to our community.”

Don’t get too worked up, an Avista vice-president urged the Montana commission just before Easter.

“Just because an asset is depreciated does not mean that one would otherwise remove that asset from service if the asset is still performing as intended,” Jason Thackston testified in a session that dealt only with what the deal with Washington state would mean to Colstrip. We’re talking strictly about an accounting manoeuvre, not an operational commitment.

Six joint owners will have to agree to close the Colstrip generators and there’s “no other tacit understanding or unstated agreement” to do that, he said.

Besides Washington and Montana, state regulators in Idaho, including those overseeing the Idaho Power settlement process, Alaska and Oregon and multiple federal authorities have to sign off on the deal before it can happen. Hydro One hopes it’ll be done in the second half of this year.

 

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California’s Solar Power Cost Shift: A Misguided Policy Threatening Energy Equity

California Rooftop Solar Cost Shift examines PG&E rate hikes, net metering changes, and utility infrastructure spending impacts on low-income households, distributed generation, and clean energy adoption, potentially raising bills and undermining grid resilience.

 

Key Points

A claim that rooftop solar shifts fixed grid costs to others; critics cite PG&E rates, avoided costs, and impacts.

✅ PG&E rates outpace national average, underscoring cost drivers.

✅ Net metering cuts risk burdening low- and middle-income homes.

✅ Distributed generation avoids infrastructure spend and grid strain.

 

California is grappling with soaring electricity prices across the state, with Pacific Gas & Electric (PG&E) rates more than double the national average and increasing at an average of 12.5% annually over the past six years. In response, Governor Gavin Newsom issued an executive order directing state energy agencies to identify ways to reduce power costs. However, recent policy shifts targeting rooftop solar users may exacerbate the problem rather than alleviate it.

The "Cost Shift" Theory

A central justification for these pricing changes is the "cost shift" theory. This theory posits that homeowners with rooftop solar panels reduce their electricity consumption from the grid, thereby shifting the fixed costs of maintaining and operating the electrical grid onto non-solar customers. Proponents argue that this leads to higher rates for those without solar installations.

However, this theory is based on a flawed assumption: that PG&E owns 100% of the electricity generated by its customers and is entitled to full profits even for energy it does not deliver. In reality, rooftop solar users supply only about half of their energy needs and still pay for the rest. Moreover, their investments in solar infrastructure reduce grid strain and save ratepayers billions by avoiding costly infrastructure projects and reducing energy demand growth, aligning with efforts to revamp electricity rates to clean the grid as well.

Impact on Low- and Middle-Income Households

The majority of rooftop solar users are low- and middle-income households. These individuals often invest in solar panels to lower their energy bills and reduce their carbon footprint. Policy changes that undermine the financial viability of rooftop solar disproportionately affect these communities, and efforts to overturn income-based charges add uncertainty about affordability and access.

For instance, Assembly Bill 942 proposes to retroactively alter contracts for millions of solar consumers, cutting the compensation they receive from providing energy to the grid, raising questions about major changes to your electric bill that could follow if their home is sold or transferred. This would force those with solar leases—predominantly lower-income individuals—to buy out their contracts when selling their homes, potentially incurring significant financial burdens.

The Real Drivers of Rising Energy Costs

While rooftop solar users are being blamed for rising electricity rates, calls for action have mounted as the true culprits lie elsewhere. Unchecked utility infrastructure spending has been a significant factor in escalating costs. For example, PG&E's rates have increased rapidly, yet the utility's spending on infrastructure projects has often been criticized for inefficiency and lack of accountability. Instead of targeting solar users, policymakers should scrutinize utility profit motives and infrastructure investments to identify areas where costs can be reduced without sacrificing service quality.

California's approach to addressing rising electricity costs by targeting rooftop solar users is misguided. The "cost shift" theory is based on flawed assumptions and overlooks the substantial benefits that rooftop solar provides to the grid and ratepayers. To achieve a sustainable and equitable energy future, the state must focus on controlling utility spending, promoting clean energy access for all, especially as it exports its energy policies across the West, and ensuring that policies support—not undermine—the adoption of renewable energy technologies.

 

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Thermal power plants’ PLF up on rising demand, lower hydro generation

India Coal Power PLF rose as capacity utilisation improved on rising peak demand and hydropower shortfall; thermal plants lifted plant load factor, IPPs lagged, and generation beat program targets amid weak rainfall and slower snowmelt.

 

Key Points

Coal plant load factor in India rose in May on higher demand and weak hydropower, with generation beating targets.

✅ PLF rose to 65.3% as demand climbed

✅ Hydel generation fell 14% YoY on poor rainfall

✅ IPP PLF at 57.8%, below 60% debt comfort

 

Capacity utilisation levels of coal-based power plants improved in May because of a surge in electricity demand and lower generation from hydroelectric sources. The plant load factor (PLF) of thermal power plants went up to 65.3% in the month, 1.7 percentage points higher than the year-ago period.

While PLFs of central and state government-owned plants were 75.5% and 64.5%, respectively, the same for independent power producers (IPPs) stood at 57.8%, even as coal and electricity shortages eased across the market. Though PLFs of IPPs were higher than May 2017 levels, it failed to cross the 60% mark, which eases debt servicing capabilities of power generation assets.

Thermal power plants generated 96,580 million units (MU) in May, 4% more than the programme set for the month and 5.2% higher than last year, partly supported by higher imported coal volumes in the market. On the other hand, hydel plants produced 10,638 MU, 10% lower than the target, reflecting a 14% decline from last year.

#google#

Peak demand of power on the last day of the month was 1,62,132 MW, 4.3% higher than the demand registered in the same day a year ago, underscoring India's position as the third-largest electricity producer globally.

According to sources, hydropower plants have been generating lesser than expected electricity due to inadequate rainfall and snow melting at a slower pace than previous years, even as the US reported a power generation jump year on year. Data for power generation from renewable sources have not been made available yet.

 

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Warren Buffett’s Secret To Cheap Electricity: Wind

Berkshire Hathaway Energy Wind Power drives cheap electricity rates in Iowa via utility-scale wind turbines, integrated transmission, battery storage, and grid management, delivering renewable energy, stable pricing, and long-term rate freezes through 2028.

 

Key Points

A vertically integrated wind utility lowering Iowa rates via owned generation, transmission, and advanced grid control.

✅ Owned wind assets meet Iowa residential demand

✅ Integrated transmission lowers costs and losses

✅ Rate freeze through 2028 sustains cheap power

 

In his latest letter to Berkshire Hathaway shareholders, Warren Buffett used the 20th anniversary of Berkshire Hathaway Energy to tout its cheap electricity bills for customers.

When Berkshire purchased the majority share of BHE in 2000, the cost of electricity for its residential customers in Iowa was 8.8 cents per kilowatt-hour (kWh) on average. Since then, these electricity rates have risen at a paltry <1% per year, with a freeze on rate hikes through 2028. As anyone who pays an electricity bill knows, that is an incredible deal.  

As Buffett himself notes with alacrity, “Last year, the rates [BHE’s competitor in Iowa] charged its residential customers were 61% higher than BHE’s. Recently, that utility received a rate increase that will widen the gap to 70%.”

 

The Winning Strategy

So, what’s Buffett’s secret to cheap electricity? Wind power.

“The extraordinary differential between our rates and theirs is largely the result of our huge accomplishments in converting wind into electricity,” Buffett explains. 

Wind turbines in Iowa that BHE owns and operates are expected to generate about 25.2 million megawatt-hours (MWh) of electricity for its customers, as projects like Building Energy operations begin to contribute. By Buffett’s estimations, that will be enough to power all of its residential customers’ electricity needs in Iowa.  


The company has plans to increase its renewable energy generation in other regions as well. This year, BHE Canada is expected to start construction on a 117.6MW wind farm in Alberta, Canada with its partner, Renewable Energy Systems, that will provide electricity to 79,000 homes in Canada’s oil country.

Observers note that Alberta is a powerhouse for both green energy and fossil fuels, underscoring the region's unique transition.

But I would argue that the secret to BHE’s success perhaps goes deeper than transitioning to sources of renewable energy. There are plenty of other utility companies that have adopted wind and solar power as an energy source. In the U.S., where renewable electricity surpassed coal in 2022, at least 50% of electricity customers have the option to buy renewable electricity from their power supplier, according to the Department of Energy. And some states, such as New York, have gone so far as to allow customers to pick from providers who generate their electricity.

What differentiates BHE from a lot of the competition in the utility space is that it owns the means to generate, store, transmit and supply renewable power to its customers across the U.S., U.K. and Canada, with lessons from the U.K. about wind power informing policy.

In its financial filings for 2019, the company reported that it owns 33,600MW of generation capacity and has 33,400 miles of transmission lines, as well as a 50% interest in Electric Transmission Texas (ETT) that has approximately 1,200 miles of transmission lines. This scale and integration enables BHE to be efficient in the distribution and sale of electricity, including selling renewable energy across regions.

BHE is certainly not alone in building renewable-energy fueled electricity dominions. Its largest competitor, NextEra, built 15GW of wind capacity and has started to expand its utility-scale solar installations. Duke Energy owns and operates 2,900 MW of renewable energy, including wind and solar. Exelon operates 40 wind turbine sites across the U.S. that generate 1,500 MW.

 

Integrated Utilities Power Ahead

It’s easy to see why utility companies see wind as a competitive source of electricity compared to fossil fuels. As I explained in my previous post, Trump’s Wrong About Wind, the cost of building and generating wind energy have fallen significantly over the past decade. Meanwhile, improvements in battery storage and power management through new technological advancements have made it more reliable (Warren Buffett bet on that one too).

But what is also striking is that integrated power and transmission enables these utility companies to make those decisions; both in terms of sourcing power from renewable energy, as well as the pricing of the final product. Until wind and solar power are widespread, these utility companies are going to have an edge of the more fragmented ends of the industry who can’t make these purchasing or pricing decisions independently. 

Warren Buffett very rarely misses a beat. He’s not the Oracle of Omaha for nothing. Berkshire Hathaway’s ownership of BHE has been immensely profitable for its shareholders. In the year ended December 31, 2019, BHE and its subsidiaries reported net income attributable to BHE shareholders of $2.95 billion.

There’s no question that renewable energy will transform the utility industry over the next decade. That change will be led by the likes of BHE, who have the power to invest, control and manage their own energy generation assets.

 

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Nonstop Records For U.S. Natural-Gas-Based Electricity

U.S. Natural Gas Power Demand is surging for electricity generation amid summer heat, with ERCOT, Texas grid reserves tight, EIA reporting coal and nuclear retirements, renewables intermittency, and pipeline expansions supporting combined-cycle capacity and prices.

 

Key Points

It is rising use of natural gas for power, driven by summer heat, plant retirements, and new combined-cycle capacity.

✅ ERCOT reserve margin 9%, below 14% target in Texas

✅ Gas share of U.S. power near 40-43% this summer

✅ Coal and nuclear retirements shift capacity to combined cycle

 

As the hot months linger, it will be natural gas that is leaned on most to supply the electricity that we need to run our air conditioning loads on the grid and keep us cool.

And this is surely a great and important thing: "Heat causes most weather-related deaths, National Weather Service says."

Generally, U.S. gas demand for power in summer is 35-40% higher than what it was five years ago, with so much more coming (see Figure).

The good news is regions across the country are expected to have plenty of reserves to keep up with power demand.

The only exception is ERCOT, covering 90% of the electric load in Texas, where a 9% reserve margin is expected, below the desired 14%.

Last summer, however, ERCOT’s reserve margin also was below the desired level, yet the grid operator maintained system reliability with no load curtailments.

Simply put, other states are very lucky that Texas has been able to maintain gas at 50% of its generation, despite being more than justified to drastically increase that.

At about 1,600 Bcf per year, the flatness of gas for power demand in Texas since 2000 has been truly remarkable, especially since Lone Star State production is up 50% since then.

Increasingly, other U.S. states (and even countries) are wanting to import huge amounts of gas from Texas, a state that yields over 25% of all U.S. output.

Yet if Texas justifiably ever wants to utilize more of its own gas, others would be significantly impacted.

At ~480 TWh per year, if Texas was a country, it would be 9th globally for power use, even ahead of Brazil, a fast growing economy with 212 million people, and France, a developed economy with 68 million people.

In the near-term, this explains why a sweltering prolonged heat wave in July in Texas, with a hot Houston summer setting new electricity records, is the critical factor that could push up still very low gas prices.

But for California, our second highest gas using state, above-average snowpack should provide a stronger hydropower for this summer season relative to 2018.

Combined, Texas and California consume about 25% of U.S. gas, with Texas' use double that of California.

 

Across the U.S., gas could supply a record 40-43% of U.S. electricity this summer even as the EIA expects solar and wind to be larger sources of generation across the mix

Our gas used for power has increased 35-40% over the past five years, and January power generation also jumped on the year, highlighting broad momentum.

Our gas used for power has increased 35-40% over the past five years. DATA SOURCE: EIA; JTC

Indeed, U.S. natural gas for electricity has continued to soar, even as overall electricity consumption has trended lower in some years, at nearly 10,700 Bcf last year, a 16% rise from 2017 and easily the highest ever.

Gas is expected to supply 37% of U.S. power this year, even as coal-fired generation saw a brief uptick in 2021 in EIA data, versus 27% just five years ago (see Figure).

Capacity wise, gas is sure to continue to surge its share 45% share of the U.S. power system.

"More than 60% of electric generating capacity installed in 2018 was fueled by natural gas."

We know that natural gas will continue to be the go-to power source: coal and nuclear plants are retiring, and while growing, wind and solar are too intermittent, geography limited, and transmission short to compensate like natural gas can.

"U.S. coal power capacity has fallen by a third since 2010," and last year "16 gigawatts (16,000 MW) of U.S. coal-fired power plants retired."

This year, some 2,000 MW of coal was retired in February alone, with 7,420 MW expected to be closed in 2019.

Ditto for nuclear.

Nuclear retirements this year include Pilgrim, Massachusetts’s only nuclear plant, and Three Mile Island in Pennsylvania.

This will take a combined ~1,600 MW of nuclear capacity offline.

Another 2,500 MW and 4,300 MW of nuclear are expected to be leaving the U.S. power system in 2020 and 2021, respectively.

As more nuclear plants close, EIA projects that net electricity generation from U.S. nuclear power reactors will fall by 17% by 2025.

From 2019-2025 alone, EIA expects U.S. coal capacity to plummet nearly 25% to 176,000 MW, with nuclear falling 15% to 83,000 MW.

In contrast, new combined cycle gas plants will grow capacity almost 30% to around 310,000 MW.

Lower and lower projected commodity prices for gas encourage this immense gas build-out, not to mention non-stop increases in efficiency for gas-based units.

Remember that these are official U.S. Department of Energy estimates, not coming from the industry itself.

In other words, our Department of Energy concludes that gas is the future.

Our hotter and hotter summers are therefore more and more becoming: "summers for natural gas"

Ultimately, this shows why the anti-pipeline movement is so dangerous.

"Affordable Energy Coalition Highlights Ripple Effect of Natural Gas Moratorium."

In April, President Trump signed two executive orders to promote energy infrastructure by directing federal agencies to remove bottlenecks for gas transport into the Northeast in particular, where New England oil-fired generation has spiked, and to streamline federal reviews of border-crossing pipelines and other infrastructure.

Builders, however, are not relying on outside help: all they know is that more U.S. gas demand is a constant, so more infrastructure is mandatory.

They are moving forward diligently: for example, there are now some 27 pipelines worth $33 billion already in the works in Appalachia.

 

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