Iran rejects UN criticism over nuclear program

By Associated Press


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Istanbul — Iran recently rejected criticism from the International Atomic Energy Agency that it has been delaying a probe into suspect nuclear activities.

The agency is fine-tuning a resolution that will reprimand Iran for delaying an investigation but refrain from direct threats of sanctions.

“We have no plans to produce weapons, and all of our activities are for peaceful purposes and nothing is wrong,” Iranian Foreign Minister Kamal Kharrazi told reporters in Istanbul.

“We are quite transparent and have decided to cooperate fully with IAEA and the international community,” he said.

At a meeting of the IAEA's 35-nation board of governors on Monday, agency chief Mohamed ElBaradei reflected the general frustrations with Iran, saying his agency's probe “can't go on forever.”

The agency is mainly concerned with ambiguous, missing or withheld information on the scope of Iran's enrichment program, and the source of enriched uranium found inside the country.

Asked to comment on the U.S. position in favour of a strong resolution against Iran, Mr. Kharrazi said: “That is not the first time that they are doing this. Always, they have been pushing the IAEA to act against us, but so far they have failed.”

“So far, many issues have been verified. There are minor issues that [are] still under consideration,” he said. “We don't have any concerns. Everything is transparent and we will continue our co-operation.”

Mr. Kharrazi is in Istanbul to attend a meeting of the foreign ministers of Islamic countries.

Any toughly worded IAEA document will maintain pressure on Iran to come clean on aspects of what was a covert nuclear program for nearly 20 years until discovered two years ago.

Iran has rejected U.S. allegations that its nuclear program is a smoke screen for making weapons. Instead, the country says its uranium-enrichment is geared solely toward generating electricity.

A resolution calling for increased co-operation and disclosure was likely to be presented later in the week, allowing more time for Iran to press for softer wording and the U.S.-led faction to rally for the opposite.

Under growing international pressure, Iran has suspended uranium enrichment and stopped building centrifuges. It also has allowed IAEA inspections of its nuclear facilities without notice.

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Canada Makes Historic Investments in Tidal Energy in Nova Scotia

Canada Tidal Energy Investment drives Nova Scotia's PLAT-I floating tidal array at FORCE, advancing renewable energy, clean electricity, emissions reductions, and green jobs while delivering 9 MW of predictable ocean power to the provincial grid.

 

Key Points

Federal funding for a floating tidal array delivering 9 MW of clean power in Nova Scotia, cutting annual CO2 emissions.

✅ $28.5M for Sustainable Marine's PLAT-I floating array

✅ Delivers 9 MW to Nova Scotia's grid via FORCE

✅ Cuts 17,000 tonnes CO2 yearly and creates local jobs

 

Canada has an abundance of renewable energy sources that are helping power our country's clean growth future and the Government of Canada is investing in renewable energy and grid modernization to reduce emissions, create jobs and invigorate local economies in a post COVID-19 pandemic world.

The Honourable Seamus O'Regan, Canada's Minister of Natural Resources, today announced one of Canada's largest-ever investments in tidal energy development — $28.5 million to Sustainable Marine in Nova Scotia to deliver Canada's first floating tidal energy array.

Sustainable Marine developed an innovative floating tidal energy platform called PLAT-I as part of advances in ocean and river power technologies that has undergone rigorous testing on the waters of Grand Passage for nearly two years. A second platform is currently being assembled in Meteghan, Nova Scotia and will be launched in Grand Passage later this year for testing before relocation to the Fundy Ocean Research Centre for Energy (FORCE) in 2021. These platforms will make up the tidal energy array.  

The objective of the project is to provide up to nine megawatts of predictable and clean renewable electricity to Nova Scotia's electrical grid infrastructure. This will reduce greenhouse gas emissions by 17,000 tonnes of carbon dioxide a year while creating new jobs in the province. The project will also demonstrate the ability to harness tides as a reliable source of renewable electricity to power homes, vehicles and businesses.

Tidal energy — a clean, renewable energy source generated by ocean tides and currents, alongside evolving offshore wind regulations that support marine renewables — has the potential to significantly reduce Canada's greenhouse gas emissions and improve local air quality by displacing electricity generated from fossil fuels.

Minister O'Regan made the announcement at the Marine Renewables Canada 2020 Fall Forum, which brings together its members and industry to identify opportunities and strategize a path forward for marine renewable energy sources.

Funding for the project comes from Natural Resources Canada's Emerging Renewables Power Program, part of Canada's more than $180-billion Investing in Canada infrastructure plan for public transit projects, green infrastructure, social infrastructure, trade and transportation routes and Canada's rural and northern communities, as Prairie provinces' renewable growth accelerates nationwide.

 

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Carbon capture: How can we remove CO2 from the atmosphere?

CO2 Removal Technologies address climate change via negative emissions, including carbon capture, reforestation, soil carbon, biochar, BECCS, DAC, and mineralization, helping meet Paris Agreement targets while managing costs, land use, and infrastructure demands.

 

Key Points

Methods to extract or sequester atmospheric CO2, combining natural and engineered approaches to limit warming.

✅ Includes reforestation, soil carbon, biochar, BECCS, DAC, mineralization

✅ Balances climate goals with costs, land, energy, and infrastructure

✅ Key to Paris Agreement targets under 1.5-2.0 °C warming

 

The world is, on average, 1.1 degrees Celsius warmer today than it was in 1850. If this trend continues, our planet will be 2 – 3 degrees hotter by the end of this century, according to the Intergovernmental Panel on Climate Change (IPCC).

The main reason for this temperature rise is higher levels of atmospheric carbon dioxide, which cause the atmosphere to trap heat radiating from the Earth into space. Since 1850, the proportion of CO2 in the air has increased, with record greenhouse gas concentrations documented, from 0.029% to 0.041% (288 ppm to 414 ppm).

This is directly related to the burning of coal, oil and gas, which were created from forests, plankton and plants over millions of years. Back then, they stored CO2 and kept it out of the atmosphere, but as fossil fuels are burned, that CO2 is released. Other contributing factors include industrialized agriculture and slash-and-burn land clearing techniques, and emissions from SF6 in electrical equipment are also concerning today.

Over the past 50 years, more than 1200 billion tons of CO2 have been emitted into the planet's atmosphere — 36.6 billion tons in 2018 alone, though global emissions flatlined in 2019 before rising again. As a result, the global average temperature has risen by 0.8 degrees in just half a century.


Atmospheric CO2 should remain at a minimum
In 2015, the world came together to sign the Paris Climate Agreement which set the goal of limiting global temperature rise to well below 2 degrees — 1.5 degrees, if possible.

The agreement limits the amount of CO2 that can be released into the atmosphere, providing a benchmark for the global energy transition now underway. According to the IPCC, if a maximum of around 300 billion tons were emitted, there would be a 50% chance of limiting global temperature rise to 1.5 degrees. If CO2 emissions remain the same, however, the CO2 'budget' would be used up in just seven years.

According to the IPCC's report on the 1.5 degree target, negative emissions are also necessary to achieve the climate targets.


Using reforestation to remove CO2
One planned measure to stop too much CO2 from being released into the atmosphere is reforestation. According to studies, 3.6 billion tons of CO2 — around 10% of current CO2 emissions — could be saved every year during the growth phase. However, a study by researchers at the Swiss Federal Institute of Technology, ETH Zurich, stresses that achieving this would require the use of land areas equivalent in size to the entire US.

Young trees at a reforestation project in Africa (picture-alliance/OKAPIA KG, Germany)
Reforestation has potential to tackle the climate crisis by capturing CO2. But it would require a large amount of space


More humus in the soil
Humus in the soil stores a lot of carbon. But this is being released through the industrialization of agriculture. The amount of humus in the soil can be increased by using catch crops and plants with deep roots as well as by working harvest remnants back into the ground and avoiding deep plowing. According to a study by the German Institute for International and Security Affairs (SWP) on using targeted CO2 extraction as a part of EU climate policy, between two and five billion tons of CO2 could be saved with a global build-up of humus reserves.


Biochar shows promise
Some scientists see biochar as a promising technology for keeping CO2 out of the atmosphere. Biochar is created when organic material is heated and pressurized in a zero or very low-oxygen environment. In powdered form, the biochar is then spread on arable land where it acts as a fertilizer. This also increases the amount of carbon content in the soil. According to the same study from the SWP, global application of this technology could save between 0.5 and two billion tons of CO2 every year.


Storing CO2 in the ground
Storing CO2 deep in the Earth is already well-known and practiced on Norway's oil fields, for example. However, the process is still controversial, as storing CO2 underground can lead to earthquakes and leakage in the long-term. A different method is currently being practiced in Iceland, in which CO2 is sequestered into porous basalt rock to be mineralized into stone. Both methods still require more research, however, with new DOE funding supporting carbon capture, utilization, and storage.

Capturing CO2 to be held underground is done by using chemical processes which effectively extract the gas from the ambient air, and some researchers are exploring CO2-to-electricity concepts for utilization. This method is known as direct air capture (DAC) and is already practiced in other parts of Europe.  As there is no limit to the amount of CO2 that can be captured, it is considered to have great potential. However, the main disadvantage is the cost — currently around €550 ($650) per ton. Some scientists believe that mass production of DAC systems could bring prices down to €50 per ton by 2050. It is already considered a key technology for future climate protection.

The inside of a carbon capture facility in the Netherlands (RWE AG)
Carbon capture facilities are still very expensive and take up a huge amount of space

Another way of extracting CO2 from the air is via biomass. Plants grow and are burned in a power plant to produce electricity. CO2 is then extracted from the exhaust gas of the power plant and stored deep in the Earth, with new U.S. power plant rules poised to test such carbon capture approaches.

The big problem with this technology, known as bio-energy carbon capture and storage (BECCS) is the huge amount of space required. According to Felix Creutzig from the Mercator Institute on Global Commons and Climate Change (MCC) in Berlin, it will therefore only play "a minor role" in CO2 removal technologies.


CO2 bound by rock minerals
In this process, carbonate and silicate rocks are mined, ground and scattered on agricultural land or on the surface water of the ocean, where they collect CO2 over a period of years. According to researchers, by the middle of this century it would be possible to capture two to four billion tons of CO2 every year using this technique. The main challenges are primarily the quantities of stone required, and building the necessary infrastructure. Concrete plans have not yet been researched.


Not an option: Fertilizing the sea with iron
The idea is use iron to fertilize the ocean, thereby increasing its nuturient content, which would allow plankton to grow stronger and capture more CO2. However, both the process and possible side effects are very controversial. "This is rarely treated as a serious option in research," concludes SWP study authors Oliver Geden and Felix Schenuit.

 

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Ontario to seek new wind, solar power to help ease coming electricity supply crunch

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

 

Key Points

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

✅ Targets renewables, hydro, and nuclear capacity growth

✅ Aims to reduce reliance on gas for grid reliability

✅ Aligns with IESO demand forecasts and EV manufacturing loads

 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

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EIA: Pennsylvania exports the most electricity, California imports the most from other states

U.S. Electricity Trade by State, 2013-2017 highlights EIA grid patterns, interstate imports and exports, cross-border flows with Canada and Mexico, net exporters and importers, and market regions like ISOs and RTOs shaping consumption and generation.

 

Key Points

Brief EIA overview of interstate and cross-border power flows, ranking top net importers and exporters.

✅ Pennsylvania was the largest net exporter, averaging 59 million MWh.

✅ California was the largest net importer, averaging 77 million MWh.

✅ Top cross-border: NY, CA, VT, MN, MI imports; WA, TX, CA, NY, MT exports.

 

According to the U.S. Energy Information Administration (EIA) State Electricity Profiles, from 2013 to 2017, Pennsylvania was the largest net exporter of electricity, while California was the largest net importer.

Pennsylvania exported an annual average of 59 million megawatt-hours (MWh), while California imported an average of 77 million MWh annually.

Based on the share of total consumption in each state, the District of Columbia, Maryland, Massachusetts, Idaho and Delaware were the five largest power-importing states between 2013 and 2017, highlighting how some clean states import 'dirty' electricity as consumption outpaces local generation. Wyoming, West Virginia, North Dakota, Montana and New Hampshire were the five largest power-exporting states. Wyoming and West Virginia were net power exporting states between 2013 and 2017.

New York, California, Vermont, Minnesota and Michigan imported the most electricity from Canada or Mexico on average from 2013 to 2017, reflecting the U.S. look to Canada for green power during that period. Similarly, Washington, Texas, California, New York, and Montana exported the most electricity to Canada or Mexico, on average, during the same period.

Electricity routinely flows among the Lower 48 states and, to a lesser extent, between the United States and Canada and Mexico. From 2013 to 2017, Pennsylvania was the largest net exporter of electricity, sending an annual average of 59 million megawatthours (MWh) outside the state. California was the largest net importer, receiving an average of 77 million MWh annually.

Based on the share of total consumption within each state, the District of Columbia, Maryland, Massachusetts, Idaho, and Delaware were the five largest power-importing states between 2013 and 2017. Wyoming, West Virginia, North Dakota, Montana, and New Hampshire were the five largest power-exporting states. States with major population centers and relatively less generating capacity within their state boundaries tend to have higher ratios of net electricity imports to total electricity consumption, as utilities devote more to electricity delivery than to power production in many markets.

Wyoming and West Virginia were net power exporting states (they exported more power to other states than they consumed) between 2013 and 2017. Customers residing in these two states are not necessarily at an economic disadvantage or advantage compared with customers in neighboring states when considering their electricity bills and fees and market dynamics. However, large amounts of power trading may affect a state’s revenue derived from power generation.

Some states also import and export electricity outside the United States to Canada or Mexico, even as Canada's electricity exports face trade tensions today. New York, California, Vermont, Minnesota, and Michigan are the five states that imported the most electricity from Canada or Mexico on average from 2013 through 2017. Similarly, Washington, Texas (where electricity production and consumption lead the nation), California, New York, and Montana are the five states that exported the most electricity to Canada or Mexico, on average, for the same period.

Many states within the continental United States fall within integrated market regions, referred to as independent system operators or regional transmission organizations. These integrated market regions allow electricity to flow freely between states or parts of states within their boundaries.

EIA’s State Electricity Profiles provide details about the supply and disposition of electricity for each state, including net trade with other states and international imports and exports, and help you understand where your electricity comes from more clearly.

 

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A New Electric Boat Club Launches in Seattle

Aurelia Boat Club delivers electric boat membership in Seattle, featuring zero-emission propulsion, quiet cruising, sustainable recreation, and a managed fleet with maintenance, insurance, moorage, and charging handled for members seeking hassle-free, eco-friendly boating.

 

Key Points

Aurelia Boat Club is a Seattle membership offering all-electric boats, with maintenance, insurance, and moorage included.

✅ Unlimited access to an all-electric fleet

✅ Maintenance, insurance, moorage, and charging included

✅ Quiet, zero-emission cruising on Seattle waters

 

Seattle's maritime scene has welcomed a new player: Aurelia Boat Club. Founded by former Pure Watercraft employees, Aurelia is poised to redefine electric boating in the city, where initiatives like Washington State Ferries hybrid-electric upgrade are underway. The club's inception follows the unexpected closure of Pure Watercraft, a Seattle-based startup that aimed to revolutionize the pleasure boating industry before its financial troubles led to its downfall.

From Pure Watercraft to Aurelia Boat Club

Pure Watercraft, established in 2011, garnered attention for its innovative electric propulsion systems designed to replace traditional gas-powered motors in boats, while efforts to build the first commercial electric speedboats also advanced. The company attracted significant investment, including a notable partnership with General Motors in 2021, which acquired a 25% stake in Pure Watercraft. Despite these efforts, Pure Watercraft faced financial difficulties and entered receivership in 2024, leading to the liquidation of its assets. 

Amidst this transition, Danylo Kurgan and Mrugesh Desai saw an opportunity to continue the vision of electric boating. Kurgan, formerly a financial analyst at Pure Watercraft and involved in the company's boat club operations, teamed up with Desai, a technology executive and startup investor. Together, they acquired key assets from Pure Watercraft's receivership, including electric outboard motors, pontoon boats, inflatable crafts, battery systems, spare parts, and digital infrastructure. 

Aurelia Boat Club's Offerings

Aurelia Boat Club aims to provide a sustainable and accessible alternative to traditional gas-powered boat clubs in Seattle. Members can enjoy unlimited access to a fleet of all-electric boats without the responsibilities of ownership. The club's boats are equipped with electric motors, offering a quiet and environmentally friendly boating experience, similar to how electric ships are clearing the air on the B.C. coast. Additionally, Aurelia handles maintenance, repairs, insurance, and moorage, allowing members to focus solely on enjoying their time on the water. 

The Future of Electric Boating in Seattle

Aurelia Boat Club's launch signifies a growing interest in sustainable boating practices in Seattle. The club's founders are committed to scaling the business and expanding their fleet to meet the increasing demand for eco-friendly recreational activities, as projects like battery-electric high-speed ferries indicate. By leveraging the assets and knowledge gained from Pure Watercraft, Aurelia aims to continue the legacy of innovation in the electric boating industry.

As the boating community becomes more environmentally conscious, initiatives like Aurelia Boat Club play a crucial role in promoting sustainable practices, and examples such as Harbour Air's electric aircraft highlight the momentum. The club's success could serve as a model for other cities, demonstrating that with the right vision and resources, the transition to electric boating is not only feasible but also desirable.

While the closure of Pure Watercraft marked the end of one chapter, it also paved the way for new ventures like Aurelia Boat Club to carry forward the mission of transforming the boating industry, with regional moves like the Kootenay Lake electric-ready ferry and international innovations such as Berlin electric flying ferry showing what's possible. With a strong foundation and a clear vision, Aurelia is set to make significant waves in Seattle's electric boating scene.

 

 

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BC Hydro cryptic about crypto mining electricity use

BC Hydro Crypto Mining Moratorium pauses high-load connection requests, as BCUC reviews electricity demand, gigawatt-hours and megawatt load forecasts, data center growth, and potential rate impacts on the power grid and industrial customers.

 

Key Points

A BC order pausing crypto mining connections while BC Hydro and BCUC assess load, grid impacts, and ratepayer risks.

✅ 18-month pause on new high-load crypto connections

✅ 1,403 MW in requests suspended; 273 MW existing or pending

✅ Seeks to manage demand, rates, and grid reliability

 

In its Nov. 1, 2022 load update briefing note to senior executives of the Crown corporation, BC Hydro shows that the entire large industrial sector accounted for 6,591 gigawatt-hours during the period – one percent less than forecast in the service plan.

BC Hydro censored load statistics about crypto mining, coal mining and chemicals from the briefing note, which was obtained under the freedom of information law and came amid scrutiny over B.C. electricity imports because it feared that disclosure would harm Crown corporation finances and third-party business interests.

Crypto mining requires high-powered computers to run and be cooled around the clock constantly. So much so that cabinet ordered the BC Utilities Commission (BCUC) last December to place an 18-month moratorium on crypto mining connection requests, while other jurisdictions, such as the N.B. Power crypto review, undertook similar pauses to assess impacts.


In a news release, the government said 21 projects seeking 1,403 megawatts were temporarily suspended. The government said that would be enough to power 570,000 homes or 2.1 million electric vehicles for a year.

A report issued by BC Hydro before Christmas said there were already 166 megawatts of power from operational projects at seven sites. Another six projects with 107 megawatts were nearing connection, bringing its total load to 273 megawatts.

Richard McCandless, a retired assistant deputy minister who analyzes the performance of BC Hydro and the Insurance Corp of British Columbia, said China's May 2021 ban on crypto mining had a major ripple effect on those seeking cheap and reliable power.

"When China cracked down, these guys fled to different areas," McCandless said in an interview. "So they took their computers and went somewhere else. Some wound up in B.C."

He said BC Hydro's secrecy about crypto loads appears rooted in the Crown corporation underestimating load demand, even as new generating stations were commissioned to bolster capacity.

"Crypto is up so dramatically; they didn't want to show that," McCandless said. "Maybe they didn't want to be seen as being asleep at the switch."

Indeed, BCUC's April 21 decision on BC Hydro's 2021 revenue forecasts through the 2025 fiscal year included BC Hydro's forecast increase for crypto and data centres of about 100 gigawatt-hours through fiscal 2024 before returning to 2021 levels by 2025. In addition, the BCUC document said that BC Hydro's December 2020 load forecast was lower than the previous one because of project cancellations and updated load requests, amid ongoing nuclear power debate in B.C.

"Given the segment's continued uncertainty and volatility, the forecast assumes these facilities are not long-lived," the BC Hydro application said.

A September 2022 report to the White House titled "Crypto-Assets in the United States" said increased electricity demand from crypto-asset mining could lead to rate increases.

"Crypto-asset mining in upstate New York increased annual household electric bills by [US]$82 and annual small business electric bills by [US]$164, with total net losses from local consumers and businesses estimated to be [US]$179 million from 2016-2018," the report said. The information mentioned Plattsburgh, New York's 18-month moratorium in 2018. Manitoba announced a similar suspension almost a month before B.C.

B.C.'s total core domestic load of 23,666 gigawatt-hours was two percent higher than the service plan amid BC Hydro call for power planning, with commercial and light industrial (9,198 gigawatt-hours) and residential (7,877 gigawatt-hours) being the top two customer segments.

"A cooler spring and warmer summer supported increased loads, as the Western Canada drought strained hydropower production regionally. However, warmer daytime temperatures in September impacted heating more than cooling," said the briefing note.

"Commercial and light industrial consumption benefited from warmer temperatures in August but has also been impacted to a lesser degree by the reduced heating load in the first three weeks of October."

Loads improved relative to 2021, but offices, retail businesses and restaurants remained below pre-pandemic levels. Education, recreation and hotel sectors were in line with pre-pandemic levels. Light industrial sector growth offset the declines.

For heavy industry, pulp and paper electricity use was 15 percent ahead of forecast, but wood manufacturing was 16 percent below forecast. The briefing note said oil and gas grew nine percent relative to the previous year but, alongside ongoing LNG power demand, fell nine percent below the service plan.

 

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