Spain's oldest nuclear plant passes crucial tests

Hydro One investment risk reflects Ontario government influence, board shakeup, Avista acquisition uncertainty, regulatory hearings, dividend growth prospects, and utility M&A moves in Peterborough, with stock volatility since the 2015 IPO.

Key Points

Hydro One investment risk stems from political control, governance turnover, regulatory outcomes, and uncertain M&A.

✅ Ontario retains near-50% stake, affecting autonomy and policy risk

✅ Board overhaul and CEO exit create governance uncertainty

✅ Avista deal, OEB hearings, local utility M&A drive outcomes

Hydro One may be only half-owned by the province on Ontario but that’s enough to cause uncertainty about the company’s future, thus making for an investment risk, says Douglas Kee of Leon Frazer & Associates.

Since its IPO in November of 2015, Hydro One has seen its share of ups and downs, including a Q2 profit decline earlier this year, mostly downs at this point. Currently trading at $19.87, the stock has lost 11 per cent of its value in 2018 and 12 per cent over the last 12 months, despite a one-time gain boosting Q2 profit that followed a court ruling.

This year has been a turbulent one, to say the least, as newly elected Ontario premier Doug Ford made good this summer on his campaign promise re Hydro One by forcing the resignation of the company’s 14-person board of directors along with the retirement of its chief executive, an event that saw Hydro One shares fall amid the turmoil. An interim CEO has been found and a new 10-person board and chairman put in place, but Kee says it’s unclear what impact the shakeup will ultimately have, other than delaying a promising-looking deal to purchase US utility Avista Corp, with the companies moving to ask the U.S. regulator to reconsider the order.

Douglas Kee’s take on Hydro One stock

“We looked at Hydro One a couple of times two years ago and just decided that with the Ontario government’s still owning a big chunk of the company … there are other public companies where you get the same kind of yield, the same kind of dividend growth, so we just avoided it,” says Kee, managing director and chief investment officer with Leon Frazer & Associates, to BNN Bloomberg.

“The old board versus the new board, I’m not sure that there’s much of an improvement. It was politics more than anything,” he says. “The unfortunate part is that the acquisition they were making in the United States is kind of on hold for now. The regulatory procedures have gone ahead but they are worried, and I guess the new board has to make a decision whether to go ahead with it or not.”

“Their transmissions side is coming up for regulatory hearings next year, which could be difficult in Ontario,” says Kee. “The offset to that is that there are a lot of municipal distributions systems in Ontario that may be sold — they bought one in Peterborough recently, which was a good deal for them. There may be more of that coming too.”

Last month, Hydro One reached an agreement with the City of Peterborough to buy its Peterborough Distribution utility which serves about 37,000 customers for $105 million. Another deal to purchase Orillia Power Distribution Corp for $41 million has been cancelled after an appeal to the Ontario Energy Board was denied in late August. Hydro One’s sought-after Avista Corp acquisition is reported to be worth $7 billion.

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Texas Electric Cooperatives outperformed during Winter Storm Uri, with higher customer satisfaction, equitable rolling blackouts, and stronger grid reliability compared to deregulated markets, according to ERCOT-area survey data of regulated utilities and commercial providers.

Key Points

Member-owned utilities in Texas delivering power, noted for reliability and fair outages during Winter Storm Uri.

✅ Member-owned, regulated utilities serving local communities

✅ Rated higher for blackout management and communication

✅ Operate outside deregulated markets; align incentives with users

Winter Storm Uri began to hit parts of Texas on February 13, 2021 and its onslaught left close to 4.5 million Texas homes and businesses without power, and many faced power and water disruptions at its peak. By some accounts, the preliminary number of deaths attributed to the storm is nearly 200, and the economic toll for the Lone Star State is estimated to be as high as $295 billion. 

The more than two-thirds of Texans who lost power during this devastating storm were notably more negative than positive in their evaluation of the performance of their local electric utility, mirrored by a rise in electricity complaints statewide, with one exception. That exception are the members of the more than 60 electric cooperatives operating within the Texas Interconnection electrical grid, which, in sharp contrast to the customers of the commercial utilities that provide power to the majority of Texans, gave their local utility a positive evaluation related to its performance during the storm.

In order to study Winter Storm Uri’s impact on Texas, the Hobby School of Public Affairs at the University of Houston conducted an online survey during the first half of March of residents 18 and older who live in the 213 counties (91.5% of the state population) served by the Texas power grid, which is managed by the Electric Reliability Council of Texas (ERCOT). 

Three-quarters of the survey population (75%) live in areas with a deregulated utility market, where a specified transmission and delivery utility by region is responsible for delivering the electricity (purchased from one of a myriad of private companies by the consumer) to homes and businesses. The four main utility providers are Oncor, CenterPoint CNP -2.2%, American Electric Power (AEP) North, and American Electric Power (AEP) Central. 

The other 25% of the survey population live in areas with regulated markets, where a single company is responsible for both delivering the electricity to homes and businesses and serves as the only source from which electricity is purchased. Municipal-owned and operated utilities (e.g., Austin Energy, Bryan Texas Utilities, Burnet Electric Department, Denton Municipal Electric, New Braunfels Utilities, San Antonio’s CPS Energy CMS -2.1%) serve 73% of the regulated market. Electric cooperatives (e.g., Bluebonnet Electric Cooperative, Central Texas Electric Cooperative, Guadalupe Valley Cooperative, Lamb County Electric Cooperative, Pedernales Electricity Cooperative, Wood County Electric Cooperative) serve one-fifth of this market (21%), with private companies accounting for 6% of the regulated market.

The overall distribution of the survey population by electric utility providers is: Oncor (38%), CenterPoint (21%), municipal-owned utilities (18%), AEP Central & AEP North combined (12%), electric cooperatives (6%), other providers in the deregulated market (4%) and other providers in the regulated market (1%). 

There were no noteworthy differences among the 31% of Texans who did not lose power during the winter storm in regard to their evaluations of their local electricity provider or their belief that the power cuts in their locale were carried out in an equitable manner.  

However, among the 69% of Texans who lost power, those served by electric cooperatives in the regulated market and those served by private electric utilities in the deregulated market differed notably regarding their evaluation of the performance of their local electric utility, both in regard to their management of the rolling blackouts, amid debates over market reforms to avoid blackouts, and to their overall performance during the winter storm. Those Texans who lost power and are served by electric cooperatives in a regulated market had a significantly more positive evaluation of the performance of their local electric utility than did those Texans who lost power and are served by a private company in a deregulated electricity market. 

For example, only 24% of Texans served by electric cooperatives had a negative evaluation of their local electric utility’s overall performance during the winter storm, compared to 55%, 56% and 61% of those served by AEP, Oncor and CenterPoint respectively. A slightly smaller proportion of Texans served by electric cooperatives (22%) had a negative evaluation of their local electric utility’s performance managing the rolling blackouts during the winter storm, compared to 58%, 61% and 71% of Texans served by Oncor, AEP and CenterPoint, respectively.

Texans served by electric cooperatives in regulated markets were more likely to agree that the power cuts in their local area were carried out in an equitable manner compared to Texans served by commercial electricity utilities in deregulated markets. More than half (52%) of those served by an electric cooperative agreed that power cuts during the winter storm in their area were carried out in an equitable manner, compared to only 26%, 23% and 23% of those served by Oncor, AEP and CenterPoint respectively

The survey data did not allow us to provide a conclusive explanation as to why the performance during the winter storm by electric cooperatives (and to a much lesser extent municipal utilities) in the regulated markets was viewed more favorably by their customers than was the performance of the private companies in the deregulated markets viewed by their customers. Yet here are three, far from exhaustive, possible explanations.

First, electric cooperatives might have performed better (based on objective empirical metrics) during the winter storm, perhaps because they are more committed to their customers, who are effectively their bosses. .  

Second, members of electric cooperatives may believe their electric utility prioritizes their interests more than do customers of commercial electric utilities and therefore, even if equal empirical performance were the case, are more likely to rate their electric utility in a positive manner than are customers of commercial utilities.  

Third, regulated electric utilities where a single entity is responsible for the commercialization, transmission and distribution of electricity might be better able to respond to the type of challenges presented by the February 2021 winter storm than are deregulated electric utilities where one entity is responsible for commercialization and another is responsible for transmission and distribution, aligning with calls to improve electricity reliability across Texas.

Other explanations for these findings may exist, which in addition to the three posited above, await future empirical verification via new and more comprehensive studies designed specifically to study electric cooperatives, large commercial utilities, and the incentives that these entities face under the regulatory system governing production, commercialization and distribution of electricity, including rulings that some plants are exempt from providing electricity in emergencies under state law. 

Still, opinion about electricity providers during Winter Storm Uri is clear: Texans served by regulated electricity markets, especially by electric cooperatives, were much more satisfied with their providers’ performance than were those in deregulated markets. Throughout its history, Texas has staunchly supported the free market. Could Winter Storm Uri change this propensity, or will attempts to regulate electricity lessen as the memories of the storm’s havoc fades? With a hotter summer predicted to be on the horizon in 2021 and growing awareness of severe heat blackout risks, we may soon get an answer.   

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Space solar power promises wireless energy from orbital solar satellites via microwave or laser power beaming, using photovoltaics and rectennas. NRL and AFRL advances hint at 24-7 renewable power delivery to Earth and airborne drones.

Key Points

Space solar power beams orbital solar energy to Earth via microwaves or lasers, enabling continuous wireless electricity.

✅ Harvests sunlight in orbit and transmits via microwaves or lasers

✅ Provides 24-7 renewable power, independent of weather or night

✅ Enables wireless power for remote sites, grids, and drones

Earlier this year, a small group of spectators gathered in David Taylor Model Basin, the Navy’s cavernous indoor wave pool in Maryland, to watch something they couldn’t see. At each end of the facility there was a 13-foot pole with a small cube perched on top. A powerful infrared laser beam shot out of one of the cubes, striking an array of photovoltaic cells inside the opposite cube. To the naked eye, however, it looked like a whole lot of nothing. The only evidence that anything was happening came from a small coffee maker nearby, which was churning out “laser lattes” using only the power generated by the system as ambitions for cheap abundant electricity gain momentum worldwide.

The laser setup managed to transmit 400 watts of power—enough for several small household appliances—through hundreds of meters of air without moving any mass. The Naval Research Lab, which ran the project, hopes to use the system to send power to drones during flight. But NRL electronics engineer Paul Jaffe has his sights set on an even more ambitious problem: beaming solar power to Earth from space. For decades the idea had been reserved for The Future, but a series of technological breakthroughs and a massive new government research program suggest that faraway day may have finally arrived as interest in space-based solar broadens across industry and government.

Since the idea for space solar power first cropped up in Isaac Asimov’s science fiction in the early 1940s, scientists and engineers have floated dozens of proposals to bring the concept to life, including inflatable solar arrays and robotic self-assembly. But the basic idea is always the same: A giant satellite in orbit harvests energy from the sun and converts it to microwaves or lasers for transmission to Earth, where it is converted into electricity. The sun never sets in space, so a space solar power system could supply renewable power to anywhere on the planet, day or night, as recent tests show we can generate electricity from the night sky as well, rain or shine.

Like fusion energy, space-based solar power seemed doomed to become a technology that was always 30 years away. Technical problems kept cropping up, cost estimates remained stratospheric, and as solar cells became cheaper and more efficient, and storage improved with cheap batteries, the case for space-based solar seemed to be shrinking.

That didn’t stop government research agencies from trying. In 1975, after partnering with the Department of Energy on a series of space solar power feasibility studies, NASA beamed 30 kilowatts of power over a mile using a giant microwave dish. Beamed energy is a crucial aspect of space solar power, but this test remains the most powerful demonstration of the technology to date. “The fact that it’s been almost 45 years since NASA’s demonstration, and it remains the high-water mark, speaks for itself,” Jaffe says. “Space solar wasn’t a national imperative, and so a lot of this technology didn’t meaningfully progress.”

John Mankins, a former physicist at NASA and director of Solar Space Technologies, witnessed how government bureaucracy killed space solar power development firsthand. In the late 1990s, Mankins authored a report for NASA that concluded it was again time to take space solar power seriously and led a project to do design studies on a satellite system. Despite some promising results, the agency ended up abandoning it.

In 2005, Mankins left NASA to work as a consultant, but he couldn’t shake the idea of space solar power. He did some modest space solar power experiments himself and even got a grant from NASA’s Innovative Advanced Concepts program in 2011. The result was SPS-ALPHA, which Mankins called “the first practical solar power satellite.” The idea, says Mankins, was “to build a large solar-powered satellite out of thousands of small pieces.” His modular design brought the cost of hardware down significantly, at least in principle.

Jaffe, who was just starting to work on hardware for space solar power at the Naval Research Lab, got excited about Mankins’ concept. At the time he was developing a “sandwich module” consisting of a small solar panel on one side and a microwave transmitter on the other. His electronic sandwich demonstrated all the elements of an actual space solar power system and, perhaps most important, it was modular. It could work beautifully with something like Mankins' concept, he figured. All they were missing was the financial support to bring the idea from the laboratory into space.

Jaffe invited Mankins to join a small team of researchers entering a Defense Department competition, in which they were planning to pitch a space solar power concept based on SPS-ALPHA. In 2016, the team presented the idea to top Defense officials and ended up winning four out of the seven award categories. Both Jaffe and Mankins described it as a crucial moment for reviving the US government’s interest in space solar power.

They might be right. In October, the Air Force Research Lab announced a $100 million program to develop hardware for a solar power satellite. It’s an important first step toward the first demonstration of space solar power in orbit, and Mankins says it could help solve what he sees as space solar power’s biggest problem: public perception. The technology has always seemed like a pie-in-the-sky idea, and the cost of setting up a solar array on Earth is plummeting, as proposals like a tenfold U.S. solar expansion signal rapid growth; but space solar power has unique benefits, chief among them the availability of solar energy around the clock regardless of the weather or time of day.

It can also provide renewable energy to remote locations, such as forward operating bases for the military, which has deployed its first floating solar array to bolster resilience. And at a time when wildfires have forced the utility PG&E to kill power for thousands of California residents on multiple occasions, having a way to provide renewable energy through the clouds and smoke doesn’t seem like such a bad idea. (Ironically enough, PG&E entered a first-of-its-kind agreement to buy space solar power from a company called Solaren back in 2009; the system was supposed to start operating in 2016 but never came to fruition.)

“If space solar power does work, it is hard to overstate what the geopolitical implications would be,” Jaffe says. “With GPS, we sort of take it for granted that no matter where we are on this planet, we can get precise navigation information. If the same thing could be done for energy, especially as peer-to-peer energy sharing matures, it would be revolutionary.”

Indeed, there seems to be an emerging race to become the first to harness this technology. Earlier this year China announced its intention to become the first country to build a solar power station in space, and for more than a decade Japan has considered the development of a space solar power station to be a national priority. Now that the US military has joined in with a $100 million hardware development program, it may only be a matter of time before there’s a solar farm in the solar system.

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Germany Energy Price Defensive Shield counters soaring gas and electricity costs with a gas price brake, VAT cut, subsidies for households and SMEs, LNG terminals, renewables, temporary nuclear extension, and targeted borrowing to curb inflation.

Key Points

A 200 billion euro package to cap energy costs, subsidize basics, and stabilize inflation for firms and households.

✅ Gas price brake and VAT cut reduce consumer and SME energy bills.

✅ Temporary electricity subsidies and nuclear extension aid winter supply.

✅ Funded via new borrowing; supports LNG and renewable expansion.

German Chancellor Olaf Scholz set out a 200 billion euro ($194 billion) "defensive shield", including a gas price brake and a cut in sales tax for the fuel, to protect companies and households from the impact of soaring energy prices in Germany.

Europe's biggest economy is trying to cope with surging gas and electricity costs, with local utilities seeking help, caused largely by a collapse in Russian gas supplies to Europe, which Moscow has blamed on Western sanctions following its invasion of Ukraine in February.

3 minute readSeptember 29, 202211:35 AM PDTLast Updated 6 days ago
Germany agrees 200 bln euro package to shield against surging energy prices
By Holger Hansen and Kirsti Knolle

"Prices have to come down, so the government will do everything it can. To this end, we are setting up a large defensive shield," said Scholz.

Under the plans, to run until spring 2024, the government will introduce an emergency price brake on gas, the details of which will be announced next month, while Europe weighs emergency measures to limit electricity prices across the bloc. It is scrapping a planned gas levy meant to help firms struggling with high spot market prices. 

A temporary electricity price brake will subsidise basic consumption for consumers and small and medium-sized companies, and complements an electricity subsidy for industries under discussion. Sales tax on gas will fall to 7% from 19%.

In its efforts to cut its dependence on Russian energy, Germany is also promoting the expansion of renewable energy and developing liquefied gas terminals, but rolling back European electricity prices remains complex.

To help households and companies weather any winter supply disruption, amid rising heating and electricity costs this winter, especially in southern Germany, two nuclear plants previously due to close by the end of this year will be able to keep running until spring 2023.

The package will be financed with new borrowing this year, as Berlin makes use of the suspension of a constitutionally enshrined limit on new debt of 0.35% of gross domestic product.

Finance Minister Christian Lindner has said he wants to comply with the limit again next year, even as the EU outlines gas price cap strategies for the market.

Lindner, of the pro-business Free Democrats (FDP) who share power with Scholz's Social Democrats and the Greens, said on Thursday the country's public finances were stable.

"We can put it no other way: we find ourselves in an energy war," said Lindner. "We want to clearly separate crisis expenditure from our regular budget management, we want to send a very clear signal to the capital markets."

He also said the steps would act as a brake on inflation, which hit its highest level in more than a quarter of century in September.

Opposition conservative Markus Soeder, premier of the southern state of Bavaria, said the steps gave the right signal.

"It gives industry and citizens confidence that we can get through the winter," he said.

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China Industrial Power Demand 2020 highlights COVID-19 disruption to electricity consumption as factory output stalls; IHS Markit estimates losses equal to Chile's usage, impacting thermal coal, LNG, and Hubei's industrial load.

Key Points

An analysis of COVID-19's hit to China's electricity use, cutting industry demand and fuel needs for coal and LNG.

✅ 73 billion kWh loss equals Chile's annual power use

✅ Cuts translate to 30m tonnes coal or 9m tonnes LNG

✅ Hubei peak load 21 percent below plan amid shutdowns

China’s industrial power demand in 2020 may decline by as much as 73 billion kilowatt hours (kWh), according to IHS Markit, as the outbreak of the coronavirus has curtailed factory output and prevented some workers from returning to their jobs.

FILE PHOTO: Smoke is seen from a cooling tower of a China Energy ultra-low emission coal-fired power plant during a media tour, in Sanhe, Hebei province, China July 18, 2019. REUTERS/Shivani Singh
The cut represents about 1.5% of industrial power consumption in China. But, as the country is the world’s biggest electricity consumer and analyses of China's electricity appetite routinely underscore its scale, the loss is equal to the power used in the whole of Chile and it illustrates the scope of the disruption caused by the outbreak.

The reduction is the energy equivalent of about 30 million tonnes of thermal coal, at a time when China aims to reduce coal power production, or about 9 million tonnes of liquefied natural gas (LNG), IHS said. The coal figure is more than China’s average monthly imports last year while the LNG figure is a little more than one month of imports, based on customs data.

China has tried to curtail the spread of the coronavirus that has killed more than 1,400 and infected over 60,000 by extending the Lunar New Year holiday for an extra week and encouraging people to work from home, measures that contributed to a global dip in electricity demand as well.

Last year, industrial users consumed 4.85 trillion kWh electricity, accounting for 67% of the country’s total, even as India's electricity demand showed sharp declines in the region.

Xizhou Zhou, the global head of power and Renewables at IHS Markit, said that in a severe case where the epidemic goes on past March, China’s economic growth will be only 4.2% during 2020, down from an initial forecast of 5.8%, while power consumption will climb by only 3.1%, down from 4.1% initially, even as power cuts and blackouts raise concerns.

“The main uncertainty is still how fast the virus will be brought under control,” said Zhou, adding that the impact on the power sector will be relatively modest from a full-year picture in 2020, even though China's electric power woes are already clouding solar markets.

In Hubei province, the epicenter of the virus outbreak, the peak power load at the end of January was 21% less than planned, mirroring how Japan's power demand was hit during the outbreak, data from Wood Mackenzie showed.

Industrial operating rates point to a firm reduction in power consumption in China.

Utilization rates at plastic processors are between 30% and 60% and the low levels are expected to last for another two week, according to ICIS China.

Weaving machines at textile plants are operating at below 10% of capacity, the lowest in five years, ICIS data showed. China is the world’s biggest textile and garment exporter.

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Nova Scotia Cap-and-Trade Program joins Western Climate Initiative to leverage emissions trading IT systems, track allowances, and manage compliance, while setting in-province caps, carbon pricing signals, and third-party verified reporting for industrial and fuel suppliers.

Key Points

A provincial emissions trading system using WCI services to cap GHGs, track allowances, and enforce verified compliance.

✅ Uses WCI IT system to manage allowances and registry

✅ Initial trading limited to in-province participants

✅ Third-party verification and annual reporting deadlines

Nova Scotia is yet to set targets for its new cap and trade regime to reduce greenhouse gases, but the province announced Monday that it has joined the Western Climate Initiative Inc. -- a non-profit corporation formed to provide administrative and technical services to states and provinces with emissions trading programs.

Environment Minister Iain Rankin said joining the initiative would allow the province to use its IT system to manage and track its new cap and trade program.

Rankin said the province can join without trading greenhouse gas emission allowances with other jurisdictions -- California, Quebec, and Ontario are currently linked through the program, with Hydro-Québec's U.S. sales highlighting cross-border dynamics. Nova Scotia currently has no plans to trade outside the province as it works on emissions caps Rankin said will be ready sometime in June.

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Nova Scotia is yet to set targets for its new cap and trade regime to reduce greenhouse gases, but the province announced Monday that it has joined the Western Climate Initiative Inc. -- a non-profit corporation formed to provide administrative and technical services to states and provinces with emissions trading programs.

Environment Minister Iain Rankin said joining the initiative would allow the province to use its IT system to manage and track its new cap and trade program.

Rankin said the province can join without trading greenhouse gas emission allowances with other jurisdictions -- California, Quebec, and Ontario are currently linked through the program. Nova Scotia currently has no plans to trade outside the province as it works on emissions caps Rankin said will be ready sometime in June.

"By keeping our system internal it ensures that our greenhouse gas reductions are happening within our province," said Rankin. "But we do have that opportunity (to join) and if there are new entrants or we need more access to credits then that may shift our strategy."

The use of the system will cost Nova Scotia about US$314,000 for 2018-19, with an annual cost in subsequent years of about US$228,000 or more, if the province requests modifications.

"If we were to do something like that internally we would have to build a full database and hire more people, so this was an obvious choice for us," said Rankin.

Nova Scotia has already met the national reduction target of 30 per cent below 2005 levels and says it's on track to have 40 per cent of electricity generation from renewables by 2020, underscoring how cleaning up Canada's electricity supports climate pledges.

Stephen Thomas, energy campaign coordinator for the Ecology Action Centre, called the province's move an "important small step," stressing the importance of using the same administrative rules as the other jurisdictions involved.

But Thomas said Nova Scotia should go further and trade emissions with California, Quebec, and Ontario, and also put a price on carbon by auctioning credits as they do.

Thomas said Nova Scotia's system stands to be volatile because of the smaller number of participants -- about 20 including Nova Scotia Power, Northern Pulp, Lafarge, and large oil and gasoline companies such as ExxonMobil, Imperial and Irving.

"It's very likely to favour Nova Scotia Power as the largest single emitter with the most credits to sell here, and that would change if we had a linked system, at a time when Canada will need more electricity to hit net-zero according to the IEA," Thomas said.

He said it's important to have a linked system and a regional approach in Atlantic Canada, which has more emissions per person and more emissions per GDP than places like Ontario, Quebec and California, and where policies like Newfoundland's rate reduction plan can influence electricity strategy.

"Reducing emissions, because we are so emissions-intensive here, is a little bit cheaper," said Thomas. "So it's possible that Ontario, Quebec and California could pay Nova Scotia to reduce its emissions."

Under its program, Nova Scotia requires industrial facilities generating 50,000 tonnes or more of greenhouse gas emissions per year to report emissions.

Regulations also cover petroleum product suppliers that import or produce 200 litres of fuel or more per year for consumption and natural gas distributors whose products produce at least 10,000 tonnes of greenhouse gas emissions a year.

Companies were to have reported to the Environment Department by May 1 but Rankin said the deadline has been pushed back to June 1, a deadline that was to be followed in subsequent years in any event. Reports must be verified by a third party by Sept. 1 every year.

The Liberal government passed enabling legislation for cap and trade last fall.

As for the upcoming emissions caps, Rankin isn't tipping the province's hand yet, even as B.C.'s 2050 targets face a shortfall in some forecasts.

"Those caps will recognize the investments that have already been made and therefore will be the most cost-effective program that we can put together to meet the federal requirement," he said.

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