Sector leaders commit to Ontario Smart Grid Forum

By Canada News Wire


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Eleven prominent members of Ontario's electricity sector have agreed to serve on Ontario's Smart Grid Forum. Building on the investment in smart meters that is already underway, this broad-based industry dialogue aims to develop a vision for a provincial smart grid that will provide consumers with more efficient, responsive and cost-effective electricity service.

"The development of a smart grid in Ontario will foster more consumer engagement in the market and enable effective integration of distributed renewable generation," said Paul Murphy, President and CEO of the Independent Electricity System Operator (IESO), and Chair of the Ontario Smart Grid Forum. "Enabling technologies will provide consumers with the tools and information they require to actively manage their electricity consumption."

The goal of a smart grid is to use advanced information-based technologies to increase grid efficiency, reliability and flexibility. It enables the better use of the existing delivery infrastructure and offers benefits for both the consumer and the environment.

The forum will consider how a smart grid in Ontario could deliver significant operational, environmental and consumer benefits. In addition to enhancing system reliability, and supporting consumer engagement, a smart grid is likely to reduce the environmental footprint of Ontario's power system by reducing the need to expand existing infrastructure.

The Ontario Smart Grid Forum will focus on opportunities in Ontario, but will monitor developments occurring in other jurisdictions and identify potential linkages. Members include:

Paul Murphy, President and CEO, IESO, and Chair, Ontario Smart Grid Forum

David Collie, President and CEO, Burlington Hydro Inc.

Norm Fraser, Chief Operating Officer, Hydro Ottawa Limited

Anthony Haines, President, Toronto Hydro-Electric System Limited

Wayne Smith, VP, Grid Operations, Hydro One Inc.

Paul Shervill, VP, Conservation and Sector Development, Ontario Power Authority

David McFadden, Chair, Ontario Centres of Excellence

Michael Angemeer, President and CEO, Veridian Corporation

Dr. Jatin Nathwani, Professor and Ontario Research Chair in Public Policy and Sustainable Energy Management, Faculties of Engineering and Environmental Studies, University of Waterloo

Peter Wallace, Deputy Minister, Ministry of Energy

Aleck Dadson, Chief Operating Officer, Ontario Energy Board

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"Kill the viability": big batteries to lose out from electricity grid rule change

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

 

Key Points

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

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

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

✅ AEMO recommends exemptions; investors seek certainty.

 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

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How Electricity Gets Priced in Europe and How That May Change

EU Power Market Overhaul targets soaring electricity prices by decoupling gas from power, boosting renewables, refining price caps, and stabilizing grids amid inflation, supply shocks, droughts, nuclear outages, and intermittent wind and solar.

 

Key Points

EU plan to redesign electricity pricing, curb gas-driven costs, boost renewables, and protect consumers from volatility.

✅ Decouples power prices from marginal gas generation

✅ Caps non-gas revenues to fund consumer relief

✅ Supports grid stability with storage, demand response, LNG

 

While energy prices are soaring around the world, Europe is in a particularly tight spot. Its heavy dependence on Russian gas -- on top of droughts, heat waves, an unreliable fleet of French nuclear reactors and a continent-wide shift to greener but more intermittent sources like solar and wind -- has been driving electricity bills up and feeding the highest inflation in decades. As Europe stands on the brink of a recession, and with the winter heating season approaching, officials are considering a major overhaul of the region’s power market to reflect the ongoing shift from fossil fuels to renewables.

1. How is electricity priced? 
Unlike oil or natural gas, there’s no efficient way to save lots of electricity to use in the future, though projects to store electricity in gas pipes are emerging. Commercial use of large-scale batteries is still years away. So power prices have been set by the availability at any given moment. When it’s really windy or sunny, for example, then more is produced relatively cheaply and prices are lower. If that supply shrinks, then prices rise because more generators are brought online to help meet demand -- fueled by more expensive sources. The way the market has long worked is that it is that final technology, or type of plant, needed to meet the last unit of consumption that sets the price for everyone. In Europe this year, that has usually meant natural gas. 

2. What is the relationship between power and gas? 
Very close. Across western Europe, gas plants have been a vital part of the energy infrastructure for decades, with Irish price spikes highlighting dispatchable power risks, fed in large part by supplies piped in from Siberia. Gas-fired plants were relatively quick to build and the technology straightforward, at least compared with nuclear plants and burns cleaner than coal. About 18% of Europe’s electricity was generated at gas plants last year; in 2020 about 43% of the imported gas came from Russia. Even during the depths of the Cold War, there’d never been a serious supply problem -- until the relationship with Russia deteriorated this year after it invaded Ukraine. Diversifying away from Russia, such as by increasing imports of liquefied natural gas, requires new infrastructure that takes a lot of time and money.

3. Why does it work this way? 
In theory, the relationship isn’t different from that with coal, for example. But production hiccups and heatwave curbs on plants from nuclear in France to hydro in Spain and Norway significantly changed the generation picture this year, and power hit records as plants buckled in the heat. Since coal-fired and nuclear plants are generally running all the time anyway, gas plants were being called upon more often -- at times just to keep the lights on as summer temperatures hit records. And with the war in Ukraine resulting in record gas prices, that pushed up overall production costs. It’s that relationship that has made the surging gas price the driver for electricity prices. And since the continent is all connected, it has pushed up prices across the region. The value of the European power market jumped threefold last year, to a record 836 billion euros ($827 billion today).

4. What’s being considered? 
With large parts of European industry on its knees and households facing jumps in energy bills of several hundred percent, as record electricity prices ripple through markets, the pressure on governments and the European Union to intervene has never been higher. One major proposal is to impose a price cap on electricity from non-gas producers, with the difference between that and the market price channeled to relief for consumers. While it sounds simple, any such changes would rip up a market design that’s worked for decades and could threaten future investments because of unintended consequences.


5. How did this market evolve?
The Nordic region and the British market were front-runners in the 1990s, then Germany followed and is now the largest by far. A trader can buy and sell electricity delivered later on same day in blocks of an hour or even down to 15-minute periods, to meet sudden demand or take advantage of price differentials. The price for these contracts is decided entirely by the supply and demand, how much the wind is blowing or which coal plants are operating, for example. Demand tends to surge early in the morning and late afternoon. This system was designed when fossil fuels provided the bulk of power. Now there are more renewables, which are less predictable, with wind and solar surpassing gas in EU generation last year, and the proposed changes reflect that shift. 

6. What else have governments done?
There are also traders who focus on longer-dated contracts covering periods several years ahead, where broader factors such as expected economic output and the extent to which renewables are crowding out gas help drive prices. This year’s wild price swings have prompted countries including Germany, Sweden and Finland to earmark billions of euros in emergency liquidity loans to backstop utilities hit with sudden margin calls on their trading.

 

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Setbacks at Hinkley Point C Challenge UK's Energy Blueprint

Hinkley Point C delays highlight EDF cost overruns, energy security risks, and wholesale power prices, complicating UK net zero plans, Sizewell C financing, and small modular reactor adoption across the grid.

 

Key Points

Delays at EDF's 3.2GW Hinkley Point C push operations to 2031, lift costs to £46bn, and risk pricier UK electricity.

✅ First unit may slip to 2031; second unit date unclear.

✅ LSEG sees 6% wholesale price impact in 2029-2032.

✅ Sizewell C replicates design; SMR contracts expected soon.

 

Vincent de Rivaz, former CEO of EDF, confidently announced in 2016 the commencement of the UK's first nuclear power station since the 1990s, Hinkley Point C. However, despite milestones such as the reactor roof installation, recent developments have belied this optimism. The French state-owned utility EDF recently disclosed further delays and cost overruns for the 3.2 gigawatt plant in Somerset.

These complications at Hinkley Point C, which is expected to power 6 million homes, have sparked new concerns about the UK's energy strategy and its ambition to decarbonize the grid by 2050.

The UK government's plan to achieve net zero by 2050 includes a significant role for nuclear energy, reflecting analyses that net-zero may not be possible without nuclear and aiming to increase capacity from the current 5.88GW to 24GW by mid-century.

Simon Virley, head of energy at KPMG in the UK, stressed the importance of nuclear energy in transitioning to a net zero power system, echoing industry calls for multiple new stations to meet climate goals. He pointed out that failing to build the necessary capacity could lead to increased reliance on gas.

Hinkley Point C is envisioned as the pioneer in a new wave of nuclear plants intended to augment and replace Britain's existing nuclear fleet, jointly managed by EDF and Centrica. Nuclear power contributed about 14 percent of the UK's electricity in 2022, even as Europe is losing nuclear power across the continent. However, with the planned closure of four out of five plants by March 2028 and rising electricity demand, there is concern about potential power price increases.

Rob Gross, director of the UK Energy Research Centre, emphasized the link between energy security and affordability, highlighting the risk of high electricity prices if reliance on expensive gas increases.

The first 1.6GW reactor at Hinkley Point C, initially set for operation in 2027, may now face delays until 2031, even after first reactor installation milestones were reported. The in-service date for the second unit remains uncertain, with project costs possibly reaching £46bn.

LSEG analysts predict that these delays could increase wholesale power prices by up to 6 percent between 2029 and 2032, assuming the second unit becomes operational in 2033.

Martin Young, an analyst at Investec, warned of the price implications of removing a large power station from the supply side.

In response to these delays, EDF is exploring the extension of its four oldest plants. Jerry Haller, EDF’s former decommissioning director, had previously expressed skepticism about extending the life of the advanced gas-cooled reactor fleet, but EDF has since indicated more positive inspection results. The company had already decided to keep the Heysham 1 and Hartlepool plants operational until at least 2026.

Nevertheless, the issues at Hinkley Point C raise doubts about the UK's ability to meet its 2050 nuclear build target of 24GW.

Previous delays at Hinkley were attributed to the COVID-19 pandemic, but EDF now cites engineering problems, similar to those experienced at other European power stations using the same technology.

The next major UK nuclear project, Sizewell C in Suffolk, will replicate Hinkley Point C's design, aligning with the UK's green industrial revolution agenda. EDF and the UK government are currently seeking external investment for the £20bn project.

Compared with Hinkley Point C, Sizewell C's financing model involves exposing billpayers to some risk of cost overruns. This, coupled with EDF's track record, could affect investor confidence.

Additionally, the UK government is supporting the development of small modular reactors, while China's nuclear program continues on a steady track, with contracts expected to be awarded later this year.

 

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Wind turbine firms close Spanish factories as Coronavirus restrictions tighten

Spain Wind Turbine Factory Shutdowns disrupt manufacturing as Vestas, Siemens Gamesa, and Nordex halt Spanish plants amid COVID-19 lockdowns, straining supply chains and renewables projects across Europe, with partial operations and maintenance continuing.

 

Key Points

COVID-19 lockdowns pause Spanish wind factories by Vestas, Siemens Gamesa, and Nordex, disrupting supply chains.

✅ Vestas, Siemens Gamesa, Nordex halt Spanish manufacturing

✅ Service and maintenance continue under safety protocols

✅ Supply chain and project timelines face delays in Europe

 

Europe’s largest wind turbine makers on Wednesday said they had shut down more factories in Spain, a major hub for the continent’s renewables sector, in response to an almost total lockdown in the country to contain the coronavirus outbreak as the Covid-19 crisis disrupts the sector.

Denmark’s Vestas, the world No.1, has suspended production at its two Spanish plants, a spokesman told Reuters, adding that its service and maintenance business was still working. Vestas has also paused manufacturing and construction in India, which is under a nationwide lockdown too, he said, and similar disruptions could stall U.S. utility solar projects this year.

Top rival Siemens Gamesa, known for its offshore wind turbine lineup, suspended production at six Spanish factories on Monday, bringing total closures there to eight, a spokeswoman said.

Four components factories are still partially up and running, at Reinosa on the north coast, Cuenca near Madrid, Mungia and Siguiero, she added.

Germany’s Nordex, the No.8 globally which is 36% owned by Spain’s Acciona, has now shuttered all of its production in Spain, even as new projects like Enel’s 90MW build move ahead, including two nacelle casing factories in Barasoain and Vall d’Uixo, as well as a rotor blade site in Lumbier.

“Production is no longer active,” a spokeswoman said in response to a Reuters query.

The new closures take the number of idled wind power factories on the continent to 19, all in Spain and Italy, the European countries worst hit by the pandemic, with investments at risk across the sector.

Spain is second only to Italy in terms of numbers of coronavirus-related fatalities and restrictions have become even stricter in the country’s third week of lockdown at a time when renewables surpassed fossil fuels for the first time in Europe.

“Some factories have temporarily paused activity as a precautionary step to strengthen sanitary measures within the sites and guarantee full compliance with government recommendations,” industry association WindEurope said, noting that wind power grows in some markets despite the pandemic.

 

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DBRS Confirms Ontario Power Generation Inc. at A (low)/R-1 (low), Stable Trends

OPG Credit Rating affirmed by DBRS at A (low) issuer and unsecured debt, R-1 (low) CP, Stable trends, backed by a supportive regulatory regime, strong leverage metrics, and provincial support; monitor Darlington Refurbishment costs.

 

Key Points

It is DBRS's confirmation of OPG at A (low) issuer and unsecured, R-1 (low) CP, with Stable outlooks.

✅ Stable trends; strong cash flow-to-debt and capital ratios

✅ Provincial financing via OEFC; Fair Hydro Trust ring-fenced

✅ Darlington Refurbishment on budget; cost overruns remain risk

 

DBRS Limited (DBRS) confirmed the Issuer Rating and the Unsecured Debt rating of Ontario Power Generation Inc. (OPG or the Company) at A (low) and the Commercial Paper (CP) rating at R-1 (low), amid sector developments such as Hydro One leadership efforts to repair government relations and measures like staff lockdowns at critical sites.

All trends are Stable. The ratings of OPG continue to be supported by (1) the reasonable regulatory regime in place for the Company's regulated generation facilities, including stable pricing signals for large users, (2) strong cash flow-to-debt and debt-to-capital ratios and (3) continuing financial support from its shareholder, the Province of Ontario (the Province; rated AA (low) with a Stable trend by DBRS). The Province, through its agent, the Ontario Electricity Financial Corporation (rated AA (low) with a Stable trend by DBRS), provides most of OPG's financing (approximately 43% of consolidated debt). The Company's remaining debt includes project financing (31%), including projects such as a battery energy storage system proposed near Woodstock, non-recourse debt issued by Fair Hydro Trust (Senior Notes rated AAA (sf), Under Review with Negative Implications by DBRS; 11%), CP (2%) and Senior Notes issued under the Medium Term Note Program (12%).

In March 2019, the Province introduced 'Bill 87, Fixing the Hydro Mess Act, 2019' which includes winding down the Fair Hydro Plan, and later introduced electricity relief to mitigate customer bills during the COVID-19 pandemic. OPG will remain as the Financial Services Manager for the outstanding Fair Hydro Trust debt, which will become obligations of the Province. DBRS does not expect this development to have a material impact on the Company as (1) the Fair Hydro Trust debt will continue to be bankruptcy-remote and ring-fenced from OPG (all debt is non-recourse to the Company) and (2) the credit rating on the Company's investment in the Subordinated Notes (rated AA (sf), Under Review with Negative Implications by DBRS) will likely remain investment grade while the Junior Subordinated Notes (rated A (sf), Under Review with Developing Implications by DBRS) will not necessarily be negatively affected by this change (see the DBRS press release, 'DBRS Maintains Fair Hydro Trust, Series 2018-1 and Series 2018-2 Notes Under Review,' dated March 26, 2019, for more details).

OPG's key credit metrics improved in 2018, following the approval of its 2017-2021 rates application by the Ontario Energy Board in December 2017, alongside the Province's energy-efficiency programs that shape demand. The Company's profitability strengthened significantly, with corporate return on equity (ROE) of 7.8% (adjusted for a $205 million gain on sale of property; 5.1% in 2017) closer to the regulatory allowed ROE of 8.78%. However, DBRS continues to view a positive rating action as unlikely in the short term because of the ongoing large capital expenditures program, including the $12.8 billion Darlington Refurbishment project, amid ongoing oversight following the nuclear alert investigation in Ontario. However, a downgrade could occur should there be significant cost overruns with the Darlington Refurbishment project that result in stranded costs. DBRS notes that the Darlington Refurbishment project is currently on budget and on schedule.

 

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How vehicle-to-building charging can save costs, reduce GHGs and help balance the grid: study

Ontario EV Battery Storage ROI leverages V2B, V2G, two-way charging, demand response, and second-life batteries to monetize peak pricing, cut GHG emissions, and unlock up to $38,000 in lifetime value for commuters and buildings.

 

Key Points

The economic return from V2B/V2G two-way charging and second-life storage using EV batteries within Ontario's grid.

✅ Monetize peak pricing via workplace V2B discharging

✅ Earn up to $8,400 per EV over vehicle life

✅ Reduce gas generation and GHGs with demand response

 

The payback that usually comes to mind when people buy an electric vehicle is to drive an emissions-free, low-maintenance, better-performing mode of transportation.

On top of that, you can now add $38,000.

That, according to a new report from Ontario electric vehicle education and advocacy nonprofit, Plug‘n Drive, is the potential lifetime return for an electric car driven as a commuter vehicle while also being used as an electricity storage option amid an energy storage crunch in Ontario’s electricity system.

“EVs contain large batteries that store electric energy,” says the report. “Besides driving the car, [those] batteries have two other potentially useful applications: mobile storage via vehicle-to-grid while they are installed in the vehicle, and second-life storage after the vehicle batteries are retired.”

Pricing and demand differentials
The study, prepared by the research firm Strategic Policy Economics, modeled a two-stage scenario calculating the total benefits from both mobile and second-life storage when taking advantage of differences in daytime and nighttime electricity pricing and demand.


If done systematically and at scale, the combined benefits to EV owners, building operators and the electricity system in Ontario could reach $129 million per year by 2035, according to the report. Along with the financial gains, the province would also cut GHG emissions by up to 67.2 kilotons annually.

The math might sound complicated, but the concepts are simple. All it requires is for drivers to charge their batteries with low-cost electricity overnight at home, then plug them into two-way EV charging stations at work and discharge their stored electricity for use by the building by day when buying power from the grid is more expensive.

“Workplace buildings could avoid high daytime prices by purchasing electricity from EVs parked onsite and enjoy savings as a result,” says the report.

Based on average commuting distances, EVs in this scenario could make half their storage capacity available for discharge. Drivers would be paid out of the building’s savings, effectively selling electricity back to the grid and earning up to $8,400 over the life of their vehicle.

According to the report, Ontario could have as many as 18,555 vehicles participating in mobile storage by 2030. At this level, the daily electricity demand would be reduced by 565 MWh. This, in turn, would reduce demand for natural gas-fired electricity generation, a fossil-fuel electricity source, avoiding the expense of gas purchases while reducing GHG emissions.

The second-life storage opportunity begins when the vehicle lifespan ends. “EV batteries will still have over 80% of their storage capacity after being driven for 13 years and providing mobile storage,” the report states. “Those-second life batteries could provide a low-cost energy storage solution for the electricity grid and enhance grid stability over time.”

Some of the savings could be shared with EV owners in the form of a rebate worth up to 20 per cent of the batteries’ initial cost.

Call to action
The report concludes with a call to action for EV advocates to press policy makers and other stakeholders to take actions on building codes, the federal Clean Fuel Standard and other business models in order to maximize the benefits of using EV batteries for the electricity system in this way, even as growing adoption could challenge power grids in some regions.

“EVs are often approached as an environmental solution to climate change,” says Cara Clairman, Plug’n Drive president and CEO. “While this is true, there are significant economic opportunities that are often overlooked.”

 

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