Wind energy — too much of a good thing

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A surfeit of wind energy is pushing down the price of all electricity.

The real time price of electricity in West Texas, where almost all generation is wind, was negative for 23% of April. The negative prices spilled over to the rest of Texas for about 1% of the month. This may be the future of the electric industry, with negative prices for a substantial amount of time each month.

Various government programs are promoting renewable energy production schemes, such as wind machines, solar cells, and geothermal. These schemes include:

• Tax Credits — Developers receive a discount on their income taxes for investment in renewable energy projects. The tax credits can be based on the amount invested in the project or in the amount of energy produced by the project.

• Renewable Portfolio Standards (RPS) — States require their utilities to produce a stated fraction of their electricity using various types of renewable energy. The definition of utility varies, sometimes including municipally owned utilities, cooperatively owned utilities, marketers, and consumers who produce their own electricity. The definition of renewable varies, sometimes including nuclear, conventional hydro, trash burners, etc.

RPS generally includes a provision for a Renewable Energy Credit (REC) where a utility with a surplus of renewable can sell their compliance to others with a shortage. Some states value one form of renewable at multiples of other forms of renewable, such that RECs may not be fungible across state lines.

The effect of these government programs is a surfeit of renewable energy projects, especially wind projects. Since electricity is fungible, the surfeit of renewable energy projects is creating a surplus of electricity capacity, and sometimes a surplus of the actual production of electricity. Since electricity cannot be easily stored, the surplus can cause operating problems and is driving down the market price for electricity in the competitive markets such as ERCOT, the Electricity Reliability Council Of Texas, which operates the electricity facilities in most of Texas.

ERCOT has identified four different market areas based on the likelihood of transmission constraints between these market areas. The smallest market area is the West market area, which is dominated by wind generation. The capacity of wind generators in the West market area is so great that they occasionally swamp the transmission lines connecting the West market area with the rest of ERCOT. During such times, ERCOT calls upon the generators in the West market area to reduce generation, essentially to dump wind.

Until recently the ERCOT procedure was to actually tell generators in the West market area to dump wind. The wind generators apparently were unhappy with the command and control attitude of ERCOT and sought an economic approach. The current ERCOT approach allows generators in the West market area to bid for access to the transmission lines connecting the West market area to the rest of ERCOT. At least that was effectively the situation for 23% of the time in April 2009. During 664 of the quarter hour periods in April, the price for generation in the West market area was less than zero, with generators paying for the right to dump electricity into the grid. During 28 of those quarter hour periods the negative prices spilled over to other parts of ERCOT.

Renewable energy projects are able to bid negative prices due to the substantial revenue streams they obtain from sources other than ERCOT. A close analogy exists in another renewable energy market, the burning of trash in incinerators to make electricity.

Some incinerators do not have a sufficient volume of trash to produce all of the electricity for which they might be under contractual obligation to produce. The incinerators at such time will buy fossil fuels, such as coal, oil, or natural gas. As much as possible, the incinerators will instead burn trash, charging the trash hauler a tipping fee. Thus, the incinerators will see their fuel cost go from positive to negative depending upon the abundance of trash.

The trash hauler is willing to pay the tipping fee to the incinerator as opposed to the higher cost of owning a sanitary land fill or paying a higher tipping feel at an independently owned land fill. The trash hauler would prefer to be paid by the incinerator for the fuel provided by the trash hauler, but is able to afford the tipping fee because the trash hauler has other sources of revenue in the form of pickup fees. Similarly, renewable energy projects would prefer to be paid for their electricity but can afford to pay for the right to dump their electricity onto ERCOT since they have other sources of revenue.

The migration of extreme electricity prices from one region to another region has been seen in the past. While the ERCOT example is the spread of low prices from the West market area to the rest of ERCOT, the West Coast of North America provided the opposite example in 2000/2001.

The high prices faced by California were passed on by the market to Oregon, Washington, and Canada. Consumers in that area responded, most famously by shutting down aluminum smelters to sell their electrical rights into the California market. This led to higher world prices of aluminum ingots and to higher electricity prices in Venezuela. The electricity supply agreements to the smelters in Venezuela had net back pricing, with the price of electricity determined by the price the smelters received for their ingots.

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California's solar energy gains go up in wildfire smoke

California Wildfire Smoke Impact on Solar reduces photovoltaic output, as particulate pollution, soot, and haze dim sunlight and foul panels, cutting utility-scale generation and grid reliability across CAISO during peak demand and heatwaves.

 

Key Points

How smoke and soot cut solar irradiance and foul panels, slashing PV generation and straining CAISO grid operations.

✅ Smoke blocks sunlight; soot deposition reduces panel efficiency.

✅ CAISO reported ~30% drop versus July during peak smoke.

✅ Longer fire seasons threaten solar reliability and capacity planning.

 

Smoke from California’s unprecedented wildfires was so bad that it cut a significant chunk of solar power production in the state, even as U.S. solar generation rose in 2022 nationwide. Solar power generation dropped off by nearly a third in early September as wildfires darkened the skies with smoke, according to the US Energy Information Administration.

Those fires create thick smoke, laden with particles that block sunlight both when they’re in the air and when they settle onto solar panels. In the first two weeks of September, soot and smoke caused solar-powered electricity generation to fall 30 percent compared to the July average, according to the California Independent System Operator (CAISO), which oversees nearly all utility-scale solar energy in California, where wind and solar curtailments have been rising amid grid constraints. It was a 13.4 percent decrease from the same period last year, even though solar capacity in the state has grown about 5 percent since September 2019.

California depends on solar installations for nearly 20 percent of its electricity generation, and has more solar capacity than the next five US states trailing it combined as it works to manage its solar boom sustainably. It will need even more renewable power to meet its goal of 100 percent clean electricity generation by 2045, building on a recent near-100% renewable milestone that underscored the transition. The state’s emphasis on solar power is part of its long-term efforts to avoid more devastating effects of climate change. But in the short term, California’s renewables are already grappling with rising temperatures.

Two records were smashed early this September that contributed to the loss of solar power. California surpassed 2 million acres burned in a single fire season for the first time (1.7 million more acres have burned since then). And on September 15th, small particle pollution reached the highest levels recorded since 2000, according to the California Air Resources Board. Winds that stoked the flames also drove pollution from the largest fires in Northern California to Southern California, where there are more solar farms.

Smaller residential and commercial solar systems were affected, too, and solar panels during grid blackouts typically shut off for safety, although smoke was the primary issue here. “A lot of my systems were producing zero power,” Steve Pariani, founder of the solar installation company Solar Pro Energy Systems, told the San Mateo Daily Journal in September.

As the planet heats up, California’s fire seasons have grown longer, and blazes are tearing through more land than ever before, while grid operators are also seeing rising curtailments as they integrate more renewables. For both utilities and smaller solar efforts, wildfire smoke will continue to darken solar energy’s otherwise bright future, even as it becomes the No. 3 renewable source in the U.S. by generation.

 

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Michigan utilities propose more than $20M in EV charging programs

Michigan EV time-of-use charging helps DTE Energy and Consumers Energy manage off-peak demand, expand smart charger rebates, and build DC fast charging infrastructure, lowering grid costs, emissions, and peak load impacts across Michigan's distribution networks.

 

Key Points

Michigan utility programs using time-based EV rates to shift charging off-peak and ease grid load via charger rebates.

✅ Off-peak rates cut peak load and distribution transformer stress.

✅ Rebates support home smart chargers and DC fast charging sites.

✅ DTE Energy and Consumers Energy invest to expand EV infrastructure.

 

The two largest utilities in the state of Michigan, DTE Energy and Consumers Energy, are looking at time-of-use charging rates in two proposed electric vehicle (EV) charging programs, aligned with broader EV charging infrastructure trends among utilities, worth a combined $20.5 million of investments.

DTE Energy last month proposed a $13 million electric vehicle (EV) charging program, which would include transformer upgrades/additions, service drops, labor and contractor costs, materials, hardware and new meters to provide time-of-use charging rates amid evolving charging control dynamics in the market. The Charging Forward program aims to address customer education and outreach, residential smart charger support and charging infrastructure enablement, DTE told regulators in its 1,100-page filing. The utility requested that rebates provided through the program be deferred as a regulatory asset.

Consumers Energy in 2017 withdrew a proposal to install 800 electric vehicle charging ports in its Michigan service territory after questions were raised over how to pay for the $15 million plan. According to Energy News Network, the utility has filed a modified proposal building on the former plan and conversations over the last year that calls for approximately half of the original investment.

Utilities across the country are viewing new demand from EVs as a potential boon to their systems, a shift accelerated by the Model 3's impact on utility planning, potentially allowing greater utilization and lower costs. But that will require the vehicles to be plugged in when other demand is low, to avoid the need for extensive upgrades and more expensive power purchases. Michigan utilities' proposal focuses on off-peak EV charging, as well as on developing new EV infrastructure.

While adoption has remained relatively low nationally, last year the Edison Electric Institute and the Institute for Electric Innovation forecast 7 million EVs on United States' roads by the end of 2025. But unless those EVs can be coordinated, state power grids could face increased stress, the National Renewable Energy Laboratory has said distribution transformers may need to be replaced more frequently and peak load could push system limits — even with just one or two EVs on a neighborhood circuit. 

In its application, DTE told regulators that electrification of transportation offers a range of benefits including "reduced operating costs for EV drivers and affordability benefits for utility customers."

"Most EV charging takes place overnight at home, effectively utilizing distribution and generation capacity in the system during a low load period," the utility said. "Therefore, increased EV adoption puts downward pressure on rates by spreading fixed costs over a greater volume of electric sales."

DTE added that other benefits include reduced carbon emissions, improved air quality, increased expenditures in local economies and reduced dependency on foreign oil for the public at large.

A previous proposal from Consumers Energy included 60 fast charging DC stations along major highways in the Lower Peninsula and 750 240-volt AC stations in metropolitan areas. Consumers' new plan will offer rebates for charger installation, as U.S. charging networks jostle for position amid federal electrification efforts, including residential and DC fast-charging stations.

 

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'Unbelievably dangerous': NB Power sounds alarm on copper theft after vandalism, deaths

NB Power copper thefts highlight risks at high-voltage substations, with vandalism, fatalities, infrastructure damage, ratepayer costs, and law enforcement alerts tied to metal prices, stolen electricity, and safety concerns across New Brunswick and Nova Scotia.

 

Key Points

Substation metal thefts causing fatalities, outages, safety risks, and higher costs that impact NB ratepayers.

✅ Spike aligns with copper price near $3 per pound

✅ Fatal break-ins at high-voltage facilities in Bathurst

✅ Repairs, delays, and safety risks for crews, customers

 

New Brunswick's power utility is urging people to stay away from its substations, saying the valuable copper they contain is proving hard to resist for thieves.

NB Power has seen almost as many incidents of theft and vandalism to its property in April and May of this year, than in all of last year.

In the 2018-2019 fiscal year, the utility recorded 16 cases of theft and/or vandalism.

In April and May, there have already been 13 cases.

One of those was a fatal incident in Bathurst. On April 13, a 41-year-old man was found unresponsive and later died, after breaking into a substation. It was the second fatality linked to a break-in at an NB Power facility in 10 years.

The investigation is still ongoing, but NB Power believes the man was trying to steal copper.

The power utility has been ramping up its efforts -- finding alternate ways to secure its properties, and educate the public -- on the dangers of copper theft, as utilities work to adapt to climate change that can exacerbate severe weather.

“We really, really, really want to stress that if you’re hitting the wrong wire, cutting the wrong wire, breaking in to or cutting fences, a lot of very bad things can happen,” said NB Power spokesperson Marc Belliveau.

In the 2017-2018 fiscal year, there were 24 recorded cases of theft and/or vandalism.

It also comes at a financial cost for NB Power, and ratepayers -- on average, $330,000 a year. About two-thirds of that is copper. The rest is vehicle break-ins or stolen electricity.

“We’ve done analysis,” Belliveau said. “Often the number of break-ins correspond with the price spiking in copper. So, right now, copper’s about $3 a pound. If it was half of that, there might be half as many incidents.”

New Brunswick Public Safety Minister Carl Urquhart says he knows the utility and police are working to dissuade people from the dangers of the theft, and notes that debates around Site C dam stability issues reflect broader infrastructure safety concerns.

“We all know of incident after incident of major injuries and death caused by, simply by, copper,” he said.

Last November, a Dawson Settlement substation was targeted during a major, storm-related power outage in the province.

It meant NB Power had to divert crews to fix and secure the substation, delaying restoration times for some residents and underscoring efforts to improve local reliability across the grid.

Belliveau says that’s “most frustrating.”

“We’re really trying to take a more proactive approach. And certainly, we encourage people that if you know somebody who’s thinking of doing something like that, to really try and talk them out of it because it’s unbelievably dangerous to break in to a substation,” he said.

Nova Scotia Power, connected through the Maritime Link, was not able to provide details on thefts at their substations, but spokesman David Rodenhiser said "the value of the stolen copper is minor in comparison to the risk that’s created when thieves break into our high-voltage electrical substations."

It's not just risky for the people breaking in, and public opposition to projects like Site C underscores broader community safety concerns.

"It also puts the safety of the workers who maintain our substations at risk, because when thieves steal copper, the protective safety devices in the substations don’t work properly," Rodenhiser said.

Additionally, in Nova Scotia, projects like the Maritime Link have advanced regional transmission, and Nova Scotia Power’s copper components have identifying markers, which make that copper difficult to fence. Anyone who buys or sells stolen propery is at risk of criminal charges.

 

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Nuclear plants produce over half of Illinois electricity, almost faced retirement

Illinois Zero Emission Credits support nuclear plants via tradable credits tied to wholesale electricity prices, carbon costs, created by the Future Energy Jobs Bill to avert Exelon closures and sustain low-carbon power.

 

Key Points

State credits that value nuclear power's zero-carbon output, priced by market and carbon metrics to keep plants running.

✅ Pegged to wholesale prices, carbon costs, and state averages.

✅ Created by Future Energy Jobs Bill to prevent plant retirements.

✅ Supports Exelon Quad Cities and Clinton nuclear facilities.

 

Nuclear plants have produced over half of Illinois electricity generation since 2010, but the states two largest plants would have been retired amid the debate over saving nuclear plants if the state had not created a zero emission credit (ZEC) mechanism to support the facilities.

The two plants, Quad Cities and Clinton, collectively delivered more than 12 percent of the states electricity generation over the past several years. In May 2016, however, Exelon, the owner of the plants, announced that they had together lost over $800 million dollars over the previous six years and revealed plans to retire them in 2017 and 2018, similar to the Three Mile Island closure later announced for 2019 by its owner.

In December 2016, Illinois passed the Future Energy Jobs Bill, which established a zero emission credit (ZEC) mechanism

to support the plants financially. Exelon then cancelled its plans to retire the two facilities.

The ZEC is a tradable credit that represents the environmental attributes of one megawatt-hour of energy produced from the states nuclear plants. Its price is based on a number of factors that include wholesale electricity market prices, nuclear generation costs, state average market prices, and estimated costs of the long-term effects of carbon dioxide emissions.

The bill is set to take effect in June, but faces multiple court challenges as some utilities have expressed concerns that the ZEC violates the commerce clause and affects federal authority to regulate wholesale energy prices, amid gas-fired competition in nearby markets that shapes the revenue outlook.

Illinois ranks first in the United States for both generating capacity and net electricity generation from nuclear power, a resource many see as essential for net-zero emissions goals, and accounts for approximately one-eighth of the nuclear power generation in the nation.

 

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More Polar Vortex 2021 Fallout (and Texas Two-Step): Monitor For ERCOT Identifies Improper Payments For Ancillary Services

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

 

Key Points

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

✅ PUCT ordered clawbacks for ancillary services not delivered.

✅ IMM urged price correction after firm load shed ceased.

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

 

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

According to the IMM (emphasis added):

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

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

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

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

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

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

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

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

According to the IMM (emphasis added):

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

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

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

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

 

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Analysis: Why is Ontario’s electricity about to get dirtier?

Ontario electricity emissions forecast highlights rising grid CO2 as nuclear refurbishments and the Pickering closure drive more natural gas, limited renewables, and delayed Quebec hydro imports, pending advances in storage and transmission upgrades.

 

Key Points

A projection that Ontario's grid CO2 will rise as nuclear units refurbish or retire, increasing natural gas use.

✅ Nuclear refurbs and Pickering shutdown cut zero-carbon baseload

✅ Gas plants fill capacity gaps, boosting GHG emissions

✅ Quebec hydro imports face cost, transmission, and timing limits

 

Ontario's energy grid is among the cleanest in North America — but the province’s nuclear plans mean that some of our progress will be reversed over the next decade.

What was once Canada’s largest single source of greenhouse-gas emissions is now a solar-power plant. The Nanticoke Generating Station, a coal-fired power plant in Haldimand County, was decommissioned in stages from 2010 to 2013 — and even before the last remaining structures were demolished earlier this year, Ontario Power Generation had replaced its nearly 4,000 megawatts with a 44-megawatt solar project in partnership with the Six Nations of the Grand River Development Corporation and the Mississaugas of the Credit First Nation.

But neither wind nor solar has done much to replace coal in Ontario’s hydro sector, a sign of how slowly Ontario is embracing clean power in practice across the province. At Nanticoke, the solar panels make up less than 2 per cent of the capacity that once flowed out to southern Ontario over high-voltage transmission lines. In cleaning up its electricity system, the province relied primarily on nuclear power — but the need to extend the nuclear system’s lifespan will end up making our electricity dirtier again.

“We’ve made some pretty great strides since 2005 with the fuel mix,” says Terry Young, vice-president of corporate communications at the Independent Electricity System Operator, the provincial agency whose job it is to balance supply and demand in Ontario’s electricity sector. “There have been big changes since 2005, but, yes, we will see an increase because of the closure of Pickering and the refurbs coming.”

“The refurbs” is industry-speak for the major rebuilds of both the Darlington and Bruce nuclear-power stations. The two are both in the early stages of major overhauls intended to extend their operating lives into the 2060s: in the coming years, they’ll be taken offline and rebuilt. (The Pickering nuclear plant will not be refurbished and will shut down in 2024.)

The catch is that, as the province loses its nuclear capacity in increments, Ontario will be short of electricity in the coming years and the IESO will need to find capacity elsewhere to make sure the lights stay on. And that could mean burning a lot more natural gas — and creating more greenhouse-gas emissions.

According to the IESO’s planning assumptions, electricity will be responsible for 11 megatonnes of greenhouse-gas emissions annually by 2035 (last year, it was three megatonnes). That’s the “reference case” scenario: if conservation and efficiency policies shave off some electricity demand, we could get it down to something like nine megatonnes. But if demand is higher than expected, it could be as high as 13 megatonnes — more than quadruple Ontario’s 2018 emissions.

Even in the worst-case scenario, the province’s emissions from electricity would still be less than half of what they were in 2005, before the province began phasing out its coal generation. But it’s still a reversal of a trend that both Liberals and Progressive Conservatives have boasted about — the Liberals to justify their energy policies, the PCs to justify their hostility to a federal carbon tax.

Young emphasized that technology can change and that the IESO’s planning assumptions are just that: projections based on the information available today. A revolution in electricity storage could make it possible to store the province’s cleaner power sources overnight for use during the day, but that’s still only in the realm of speculation — and the natural-gas infrastructure exists in the real world, today.

Ontario Power Generation — the Crown corporation that operates many of the province’s power plants, including Pickering and Darlington — recently bought four gas plants, two of them outright (two it already owned in part). All were nearly complete or already operational, so the purchase itself won’t change the province’s emissions prospects. Rather, OPG is simply looking to maintain its share of the electricity market after the Pickering shutdown.

“It will allow us to maintain our scale, with the upcoming end of Pickering’s commercial operations, so that we can continue our role as the driver of Ontario’s lower carbon future,” Neal Kelly, OPG’s director of media, issues, and management, told TVO.org via email. “Further, there is a growing need for flexible gas fired generation to support intermittent wind and solar generation.”

The shift to more gas-fired generation has been coming for a while, and critics say that Ontario has missed an opportunity to replace the lost Pickering capacity with something cleaner. MPP Mike Schreiner, leader of the Green party, has argued for years that Ontario should have pursued an agreement with Quebec to import clean hydroelectricity.

“To me, it’s a cost-effective solution, and it’s a zero-emissions solution,” Schreiner says. “Regardless of your position on sources of electricity, I think everyone could agree that waterpower from Quebec is going to be less expensive.”

Quebec is eager to sell Ontario its surplus hydro power, but not everyone agrees that importing power would be cheaper. A study published by the Ontario Chamber of Commerce (and commissioned by Ontario Power Generation) calls the claim a “myth” and states that upgrading electric-transmission wires between Ontario and Quebec would cost $1.2 billion and take 10 years, while some estimates suggest fully greening Ontario's grid would cost far more overall.

With Quebec imports seemingly a non-starter and major changes to Ontario’s nuclear fleet already underway, there’s only one path left for this province’s greenhouse-gas emissions: upwards.

 

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