Pepco Energy saves Feds $46 million

PLREDA 2019 advances solar, wind, and geothermal on public lands, guiding DOI siting, improving transmission access, streamlining permitting, sharing revenues, and funding conservation to meet climate goals while protecting wildlife and recreation.

Key Points

A bipartisan bill to expand renewables on public lands fund conservation, speed permitting and advance U.S. climate aims.

✅ Targets 25 GW of public-land renewables by 2025

✅ Establishes wildlife conservation and recreation access funds

✅ Streamlines siting, transmission, and equitable revenue sharing

The Senate unveiled its version of a bill the House introduced in July to help the U.S. realize the extraordinary renewable energy potential of our shared public lands.

Senator Martha McSally (R-AZ) and a bipartisan coalition of western Senators introduced a Senate version of draft legislation that will help the Department of the Interior tap the renewable energy potential of our shared public lands. The western Senators represent Arizona, New Mexico, Colorado, Montana, and Idaho.

Elsewhere in the West, lawmakers have moved to modernize Oregon hydropower to streamline licensing, signaling broad regional momentum.

The Public Land Renewable Energy Development Act of 2019 (PLREDA) facilitates siting of solar, wind, and geothermal energy projects on public lands, boosts funding for conservation, and promotes ambitious renewable energy targets that will help the U.S. take action on the climate crisis.

Like the House version, the Senate bill enjoys strong bi-partisan support and industry endorsement. The Senate version makes few notable changes to the bill introduced in July by Representatives Mike Levin (D-CA) and Paul Gosar (R-AZ). It includes:

• A commitment to enhance natural resource conservation and stewardship via the establishment of a fish and wildlife conservation fund that would support conservation and restoration work and other important stewardship activities.
• An ambitious renewable energy production goal for the Department of the Interior to permit a total of 25 gigawatts of renewable energy on public lands by 2025—nearly double the current generating capacity of projects currently on our public lands.
• Establishment of criteria for identifying appropriate areas for renewable energy development using the 2012 Western Solar Plan as a model. Key criteria to be considered include access to transmission lines and likelihood of avoiding or minimizing conflict with wildlife habitat, cultural resources, and other resources and values.
• Improved public access to Federal lands for recreational uses via funds made available for preserving and improving access, including enhancing public access to places that are currently inaccessible or restricted.
• Sharing of revenues raised from renewable energy development on public lands in an equitable manner that benefits local communities near new renewable energy projects and supports the efficient administration of permitting requirements.
• Creating incentives for renewable energy development by giving Interior the authority to reduce rental rates and capacity fees to ensure new renewable energy development remains competitive in the marketplace.

NRDC strongly supports this legislation, and we will do our utmost to facilitate its passage into law. There is no question that in our era of runaway climate change, legislation that balances energy production with environmental conservation and stewardship of our public lands is critical.

PLREDA takes a balanced approach to using our public lands to help lead the U.S. toward a low-carbon future, as states pursue 100% renewable electricity goals nationwide. The bill outlines a commonsense approach for federal agencies to play a meaningful role in combatting climate change.

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Calistoga Resiliency Centre Microgrid delivers grid resilience via green hydrogen and BESS, providing island-mode backup during PSPS events, wildfire risk, and outages, with black-start and grid-forming capabilities for reliable community power.

Key Points

A hybrid green hydrogen and BESS facility ensuring resilient, islanded power for Calistoga during PSPS and outages.

✅ 293 MWh capacity with 8.5 MW peak for critical backup

✅ Hybrid lithium-ion BESS plus green hydrogen fuel cells

✅ Island mode with black-start and grid-forming support

Energy Vault, a prominent energy storage and technology company known for its gravity storage, recently secured US$28 million in project financing for its innovative Calistoga Resiliency Centre (CRC) in California. This funding will enable the development of a microgrid powered by a unique combination of green hydrogen and battery energy storage systems (BESS), marking a significant step forward in enhancing grid resilience in the face of natural disasters such as wildfires.

Located in California's fire-prone regions, the CRC is designed to provide critical backup power during Public Safety Power Shutoff (PSPS) events—periods when utility companies proactively cut power to prevent wildfires. These events can leave communities without electricity for extended periods, making the need for reliable, independent power sources more urgent as many utilities see benefits in energy storage today. The CRC, with a capacity of 293 MWh and a peak output of 8.5 MW, will ensure that the Calistoga community maintains power even when the grid is disconnected.

The CRC features an integrated hybrid system that combines lithium-ion batteries and green hydrogen fuel cells, even as some grid-scale projects adopt vanadium flow batteries for long-duration needs. During a PSPS event or other grid outages, the system will operate in "island mode," using hydrogen to generate electricity. This setup not only guarantees power supply but also contributes to grid stability by supporting black-start and grid-forming functions. Energy Vault's proprietary B-VAULT DC battery technology complements the hydrogen fuel cells, enhancing the overall performance and resilience of the microgrid.

One of the key aspects of the CRC project is the utilization of green hydrogen. Unlike traditional hydrogen, which is often produced using fossil fuels, green hydrogen is generated through renewable energy sources like solar or wind power, with large-scale initiatives such as British Columbia hydrogen project accelerating supply, making it a cleaner and more sustainable alternative. This aligns with California’s ambitious clean energy goals and is expected to reduce the carbon footprint of the region’s energy infrastructure.

The CRC project also sets a precedent for future hybrid microgrid deployments across California and other wildfire-prone areas, with utilities like SDG&E Emerald Storage highlighting growing adoption. Energy Vault has positioned the CRC as a model for scalable, utility-scale microgrids that can be adapted to various locations facing similar challenges. Following the success of this project, Energy Vault is expanding its portfolio with additional projects in Texas, where it anticipates securing up to US$25 million in financing.

The funding for the CRC also includes the sale of an investment tax credit (ITC), a key component of the financing structure that helps make such ambitious projects financially viable. This structure is crucial as it allows companies to leverage government incentives to offset development costs, including CEC long-duration storage funding, thus encouraging further investment in green energy infrastructure.

Despite some skepticism regarding the transportation of hydrogen rather than producing it onsite, the project has garnered strong support. California’s Public Utilities Commission (CPUC) acknowledged the potential risks of transporting green hydrogen but emphasized that it is still preferable to using more harmful fuel sources. This recognition is important as it validates Energy Vault’s approach to using hydrogen as part of a broader strategy to transition to clean, reliable energy solutions.

Energy Vault's shift from its traditional gravity-based energy storage systems to battery energy storage systems, such as BESS in New York, reflects the company's adaptation to the growing demand for versatile, efficient energy solutions. The hybrid approach of combining BESS with green hydrogen represents an innovative way to address the challenges of energy storage, especially in regions vulnerable to natural disasters and power outages.

As the CRC nears mechanical completion and aims for full commercial operations by Q2 2025, it is poised to become a critical part of California’s grid resilience strategy. The microgrid's ability to function autonomously during emergencies will provide invaluable benefits not only to Calistoga but also to other communities that may face similar grid disruptions in the future.

Energy Vault’s US$28 million financing for the Calistoga Resiliency Centre marks a significant milestone in the development of hybrid microgrids that combine the power of green hydrogen and battery energy storage. This project exemplifies the future of energy resilience, showcasing a forward-thinking approach to mitigating the impact of natural disasters and ensuring a reliable, sustainable energy future for communities at risk. With its innovative use of renewable energy sources and cutting-edge technology, the CRC sets a strong example for future energy storage projects worldwide.

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US SF6 Emissions Decline as NOAA analysis and EPA mitigation show progress, with atmospheric measurements and Greenhouse Gas Reporting verifying reductions from the electric power grid; sulfur hexafluoride's extreme global warming potential underscores inventory improvements.

Key Points

A documented drop in US sulfur hexafluoride emissions, confirmed by NOAA atmospheric data and EPA reporting reforms.

✅ NOAA towers and aircraft show 2007-2018 decline

✅ EPA reporting and utility mitigation narrowed inventory gaps

✅ Winter leaks and servicing signal further reduction options

A new NOAA analysis shows U.S. emissions of the super-potent greenhouse gas sulfur hexafluoride (SF6) have declined between 2007-2018, likely due to successful mitigation efforts by the Environmental Protection Agency (EPA) and the electric power industry, with attention to SF6 in the power industry across global markets. 

At the same time, significant disparities that existed previously between NOAA’s estimates, which are based on atmospheric measurements, and EPA’s estimates, which are based on a combination of reported emissions and industrial activity, have narrowed following the establishment of the EPA's Greenhouse Gas Reporting Program. The findings, published in the journal Atmospheric Chemistry and Physics, also suggest how additional emissions reductions might be achieved. 

SF6 is most commonly used as an electrical insulator in high-voltage equipment that transmits and distributes electricity, and its emissions have been increasing worldwide as electric power systems expand, even as regions hit milestones like California clean energy surpluses in recent years. Smaller amounts of SF6 are used in semiconductor manufacturing and in magnesium production. 

SF6 traps 25,000 times more heat than carbon dioxide over a 100-year time scale for equal amounts of emissions, and while CO2 emissions flatlined in 2019 globally, that comparison underscores the potency of SF6. That means a relatively small amount of the gas can have a significant impact on climate warming. Because of its extremely large global warming potential and long atmospheric lifetime, SF6 emissions will influence Earth’s climate for thousands of years.

In this study, researchers from NOAA’s Global Monitoring Laboratory, as record greenhouse gas concentrations drive demand for better data, working with colleagues at EPA, CIRES, and the University of Maryland, estimated U.S. SF6 emissions for the first time from atmospheric measurements collected at a network of tall towers and aircraft in NOAA’s Global Greenhouse Gas Reference Network. The researchers provided an estimate of SF6 emissions independent from the EPA’s estimate, which is based on reported SF6 emissions for some industrial facilities and on estimated SF6 emissions for others.

“We observed differences between our atmospheric estimates and the EPA’s activity-based estimates,” said study lead author Lei Hu, a Global Monitoring Laboratory researcher who was a CIRES scientist at the time of the study. “But by closely collaborating with the EPA, we were able to identify processes potentially responsible for a significant portion of this difference, highlighting ways to improve emission inventories and suggesting additional emission mitigation opportunities, such as forthcoming EPA carbon capture rules for power plants, in the future.” 

In the 1990s, the EPA launched voluntary partnerships with the electric power, where power-sector carbon emissions are falling as generation shifts, magnesium, and semiconductor industries to reduce SF6 emissions after the United States recognized that its emissions were significant. In 2011, large SF6 -emitting facilities were required to begin tracking and reporting their emissions under the EPA Greenhouse Gas Reporting Program. 

Hu and her colleagues documented a decline of about 60 percent in U.S. SF6 emissions between 2007-2018, amid global declines in coal-fired power in some years—equivalent to a reduction of between 6 and 20 million metric tons of CO2 emissions during that time period—likely due in part to the voluntary emission reduction partnerships and the EPA reporting requirement. A more modest declining trend has also been reported in the EPA’s national inventories submitted annually under the United Nations Framework Convention on Climate Change. 

Examining the differences between the NOAA and EPA independent estimates, the researchers found that the EPA’s past inventory analyses likely underestimated SF6 emissions from electrical power transmission and distribution facilities, and from a single SF6 production plant in Illinois. According to Hu, the research collaboration has likely improved the accuracy of the EPA inventories. The 2023 draft of the EPA’s U.S. Greenhouse Gas Emissions and Sinks: 1990-2021 used the results of this study to support revisions to its estimates of SF6 emissions from electrical transmission and distribution. 

The collaboration may also lead to improvements in the atmosphere-based estimates, helping NOAA identify how to expand or rework its network to better capture emitting industries or areas with significant emissions, according to Steve Montzka, senior scientist at GML and one of the paper’s authors.

Hu and her colleagues also found a seasonal variation in SF6 emissions from the atmosphere-based analysis, with higher emissions in winter than in summer. Industry representatives identified increased servicing of electrical power equipment in the southern states and leakage from aging brittle sealing materials in the equipment in northern states during winter as likely explanations for the enhanced wintertime emissions—findings that suggest opportunities for further emissions reductions.

“This is a great example of the future of greenhouse gas emission tracking, where inventory compilers and atmospheric scientists work together to better understand emissions and shed light on ways to further reduce them,” said Montzka.

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Iceland Bitcoin Mining Energy Shortage highlights surging cryptocurrency and blockchain data center electricity demand, as hydroelectric and geothermal power strain to cool servers, stabilize grid, and meet rapid mining farm growth amid Arctic-friendly conditions.

Key Points

Crypto mining data centers in Iceland are outpacing renewable power, straining the grid and exceeding residential electricity demand.

✅ Hydroelectric and geothermal capacity nearing allocation limits

✅ Cooling-friendly climate draws energy-hungry mining farms

✅ Grid planning and regulation lag rapid data center growth

The value of bitcoin may have stumbled in recent months, but in Iceland it has known only one direction so far: upward. The stunning success of cryptocurrencies around the globe has had a more unexpected repercussion on the island of 340,000 people: It could soon result in an energy shortage in the middle of the Atlantic Ocean.

As Iceland has become one of the world's prime locations for energy-hungry cryptocurrency servers — something analysts describe as a 21st-century gold-rush equivalent — the industry’s electricity demands have skyrocketed, too. For the first time, they now exceed Icelanders’ own private energy consumption, and energy producers fear that they won’t be able to keep up with rising demand if Iceland continues to attract new companies bidding on the success of cryptocurrencies, a concern echoed by policy moves like Russia's proposed mining ban amid electricity deficits.

Companies have flooded Iceland with requests to open new data centers to “mine” cryptocurrencies in recent months, even as concerns mount that the country may have to slow down investments amid an increasingly stretched electricity generation capacity, a dynamic seen in BC Hydro's suspension of new crypto connections in Canada.

“There was a lot of talk about data centers in Iceland about five years ago, but it was a slow start,” Johann Snorri Sigurbergsson, a spokesman for Icelandic energy producer HS Orka, told The Washington Post. “But six months ago, interest suddenly began to spike. And over the last three months, we have received about one call per day from foreign companies interested in setting up projects here.”

“If all these projects are realized, we won’t have enough energy for it,” Sigurbergsson said.

Every cryptocurrency in the world relies on a “blockchain” platform, which is needed to trade with digital currencies. Tracking and verifying a transaction on such a platform is like solving a puzzle because networks are often decentralized, and there is no single authority in charge of monitoring payments. As a result, a transaction involves an immense number of mathematical calculations, which in turn occupy vast computer server capacity. And that requires a lot of electricity, as analyses of bitcoin's energy use indicate worldwide.

The bitcoin rush may have come as a surprise to locals in sleepy Icelandic towns that are suddenly bustling with cryptocurrency technicians, but there’s a simple explanation. “The economics of bitcoin mining mean that most miners need access to reliable and very cheap power on the order of 2 or 3 cents per kilowatt hour. As a result, a lot are located near sources of hydro power, where it’s cheap,” Sam Hartnett, an associate at the nonprofit energy research and consulting group Rocky Mountain Institute, told the Washington Post.

Top financial regulators briefed a Senate panel on Feb. 6 about their work with cryptocurrencies like Bitcoin, and the risks to potential investors. (Reuters)

Located in the middle of the Atlantic Ocean and famous for its hot springs and mighty rivers, Iceland produces about 80 percent of its energy in hydroelectric power stations, compared with about 6 percent in the United States, and innovations such as underwater kites illustrate novel ways to harness marine energy. That and the cold climate make it a perfect location for new data-mining centers filled with servers in danger of overheating.

Those conditions have attracted scores of foreign companies to the remote location, including Germany's Genesis Mining, which moved to Iceland about three years ago. More have followed suit since then or are in the process of moving. 

While some analysts are already sensing a possible new revenue source for the country that is so far mostly known abroad as a tourist haven and low-budget airline hub, others are more concerned by a phenomenon that has so far mostly alarmed analysts because of its possible financial unsustainability, alongside issues such as clean energy's dirty secret that complicate the picture. Some predictions have concluded that cryptocurrency computer operations may account for “all of the world’s energy by 2020” or may already account for the equivalent of Denmark's energy needs. Those predictions are probably too alarmist, though. 

Most analysts agree that the real energy-consumption figure is likely smaller, and several experts recently told the Washington Post that bitcoin — currently the world's biggest cryptocurrency — used no more than 0.14 percent of the world’s generated electricity, as of last December. Even though global consumption may not be as significant as some have claimed, it still presents a worrisome drain for a tiny country such as Iceland, where consumption suddenly began to spike with almost no warning — and continues to grow fast.

Some networks are considering or have already pushed through changes to their protocols, designed to reduce energy use. But implementing such changes for the leading currency, bitcoin, won't be as easy because it is inherently decentralized. The companies that provide the vast amounts of computing power needed for these transactions earn a small share, comparable to a processing fee or a reward.

They are the source of the Icelandic bitcoin miners’ income — a revenue source that many Icelanders are still not quite sure what to make of, especially if the lights start flickering.

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U.S. Power Grid D+ Rating underscores aging infrastructure, rising outages, cyber threats, EMP and solar flare risks, strained transmission lines, vulnerable transformers, and slow permitting, amplifying reliability concerns and resilience needs across national energy systems.

Key Points

ASCE's D+ grade flags aging infrastructure, rising outages, and cyber, EMP, and weather risks needing investment.

✅ Major outages rising; weather remains top disruption driver.

✅ Aging transformers, transmission lines, limited maintenance.

✅ Cybersecurity gaps via smart grid, EV charging, SCADA.

The U.S. power grid just received its “grade card” from the American Society of Civil Engineers (ASCE) and it barely passed.

The overall rating of our antiquated electrical system was a D+. Major power outages in the United States, including widespread blackouts, have grown from 76 in 2007 to 307 in 2011, according to the latest available statistics. The major outage figures do not take into account all of the smaller outages which routinely occur due to seasonal storms.

The American Society of Civil Engineers power grid grade card rating means the energy infrastructure is in “poor to fair condition and mostly below standard, with many elements approaching the end of their service life.” It further means a “large portion of the system exhibits significant deterioration” with a “strong risk of failure.”

Such a designation is not reassuring and validates those who purchased solar generators over the past several years.

#google#

The vulnerable state of the power grid gets very little play by mainstream media outlets. Concerns about a solar flare or an electromagnetic pulse (EMP) attack instantly sending us back to an 1800s existence are legitimate, but it may not take such an extreme act to render the power grid a useless tangle of wires. The majority of the United States’ infrastructure and public systems evaluated by the ASCE earned a “D” rating. A “C” ranking (public parks, rail and bridges) was the highest grade earned. It would take a total of $3.6 trillion in investments by 2020 to fix everything, the report card stated. To put that number in perspective, the federal government’s budget for all of 2012 was slightly more, $3.7 trillion.

“America relies on an aging electrical grid and pipeline distribution systems, some of which originated in the 1880s,” the report read. “Investment in power transmission has increased since 2005, but ongoing permitting issues, weather events, including summer blackouts that strain local systems, and limited maintenance have contributed to an increasing number of failures and power interruptions. While demand for electricity has remained level, the availability of energy in the form of electricity, natural gas, and oil will become a greater challenge after 2020 as the population increases. Although about 17,000 miles of additional high-voltage transmission lines and significant oil and gas pipelines are planned over the next five years, permitting and siting issues threaten their completion. The electric grid in the United States consists of a system of interconnected power generation, transmission facilities, and distribution facilities.”

Harness the power of the sun when the power goes out…

There are approximately 400,000 miles of electrical transmission lines throughout the United States, and thousands of power generating plants dot the landscape. The ASCE report card also stated that new gas-fired and renewable generation issues increase the need to add new transmission lines. Antiquated power grid equipment has reportedly prompted even more “intermittent” power outages in recent years.

The American Society of Civil Engineers accurately notes that the power grid is more vulnerable to cyber attacks than ever before, including Russian intrusions documented in recent years, and it cites the aging electrical system as the primary culprit. Although the decades-old transformers and other equipment necessary to keep power flowing around America are a major factor in the enhanced vulnerability of the power grid, moving towards a “smart grid” system is not the answer. As previously reported by Off The Grid News, smart grid systems and even electric car charging stations make the power grid more accessible to cyber hackers. During the Hack in the Box Conference in Amsterdam, HP ArcSight Product Manager Ofer Sheaf stated that electric car charging stations are in essence a computer on the street. The roadway fueling stations are linked to the power grid electrical system. If cyber hackers garner access to the power grid via the charging stations, they could stop the flow of power to a specific area or alter energy distribution levels and overload the system.

While a relatively small number of electric car charging stations exist in America now, that soon will change. Ongoing efforts by both federal and state governments to reduce our reliance on fossil fuels have resulted in grants and privately funded vehicle charging station projects. New York Governor Andrew Cuomo in April announced plans to build 360 such electrical stations in his state. A total of 3,000 car charging stations are in the works statewide and are slated for completion over the next five years.

SHIELD ActWeather-related events were the primary cause of power outages from 2007 to 2012, according to the infrastructure report card. Power grid reliability issues are emerging as the greatest threat to the electrical system, with rising attacks on substations compounding the risks. The ASCE grade card also notes that retiring and rotating in “new energy sources” is a “complex” process. Like most items we routinely purchase in our daily lives, many of the components needed to make the power grid functional are not manufactured in the United States.

The SHIELD Act is the first real piece of federal legislation in years drafted to address power grid vulnerabilities. While the single bill will not fix all of the electrical system issues, it is a big step in the right direction – if it ever makes it out of committee. Replacing aging transformers, encasing them in a high-tech version of a Faraday cage, and stockpiling extra units so instant repairs are possible would help preserve one of the nation’s most critical and life-saving pieces of infrastructure after a weather-related incident or man-made disaster.

“Geomagnetic storm environments can develop instantaneously over large geographic footprints,” solar geomagnetic researcher John Kappenman said about the fragile state of the power grid. He was quoted in an Oak Ridge National Laboratory report. “They have the ability to essentially blanket the continent with an intense threat environment and … produce significant collateral damage to critical infrastructures. In contrast to well-conceived design standards that have been successfully applied for more conventional threats, no comprehensive design criteria have ever been considered to check the impact of the geomagnetic storm environments. The design actions that have occurred over many decades have greatly escalated the dangers posed by these storm threats for this critical infrastructure.”

The power grid has morphed in size tenfold during the past 50 years. While solar flares, cyber attacks, and an EMP are perhaps the most extensive and frightening threats to the electrical system, the infrastructure could just as easily fail in large portions due to weather-related events exacerbated by climate change across regions. The power grid is basically a ticking time bomb which will spawn civil unrest, lack of food, clean water, and a multitude of fires if it does go down.

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Cape Town Renewable Energy Plan targets 450+ MW via solar, wind, and battery storage, cutting Eskom reliance, lowering greenhouse gas emissions, stabilizing electricity prices, and boosting grid resilience through municipal procurement, PPAs, and city-owned plants.

Key Points

A municipal plan to procure over 450 MW, cut Eskom reliance, stabilize prices, and reduce Cape Town emissions.

✅ Up to 150 MW from private plants within the city

✅ 300 MW to be purchased from outside Cape Town later

✅ City financing 100-200 MW of its own generation

Cape Town is seeking to secure more than 450 megawatts of power from renewable sources to cut reliance on state power utility Eskom Holdings SOC Ltd., where wind procurement cuts were considered during lockdown, and reduce greenhouse gas emissions.

South Africa’s second-biggest city is looking at a range of options, including geothermal exploration in comparable markets, and expects the bulk of the electricity to be generated from solar plants, Kadri Nassiep, the city’s executive director of energy and climate change, said in an interview.

On July 14 the city of 4.6 million people released a request for information to seek funding to build its own plants. This month or next it will seek proposals for the provision of as much as 150 megawatts from privately owned plants, largely solar additions, to be built and operated within the city, he said. As much as 300 megawatts may also be purchased at a later stage from plants outside of Cape Town, according to Nassiep.

The city could secure finance to build 100 to 200 megawatts of its own generation capacity, Nassiep said. “We realized that it is important for the city to be more in control around the pricing of the power,” he added.

Power Outages

Cape Town’s foray into the securing of power from sources other than Eskom comes after more than a decade of intermittent electricity outages, while elsewhere in Africa coal projects face scrutiny from lenders, because the utility can’t meet national demand. The government last year said municipalities could find alternative suppliers.

Earlier this month Ethekwini, the municipal area that includes the city of Durban, issued a request for information for the provision of 400 megawatts of power, similar to BC Hydro’s call for power driven by EV uptake.

The City of Johannesburg will in September seek information and proposals for the construction of a 150-megawatt solar plant, reflecting moves like Ontario’s new wind and solar procurements to tackle supply gaps, 50 megawatts of rooftop solar panels and the refurbishment of an idle gas-fired plant that could generate 20 megawatts, it said in June. It will also seek information for the installation of 100 megawatts of battery storage.

Cape Town, which uses a peak of 1,800 megawatts of electricity in winter, hopes to start generating some of its own power next year, aligning with SaskPower’s 2030 renewables plan seen in Canada, according to a statement that accompanied its request for financing proposals.
 

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