IESO wants grid to smarten up

By Toronto Star


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The head of Ontario's electricity-system operator says that injecting "intelligence" into the provincial grid must be given higher priority if the industry is serious about accommodating renewable energy, smart appliances and emission-free electric cars.

Paul Murphy, chief executive officer of the Independent Electricity System Operator, the agency that manages the flow of megawatts in the province, is expected to announce today – on the heals of Earth Hour – the creation of an industry-led group to lay out of vision for modernizing Ontario's aging electricity system.

"We have some catching up to do," said Murphy, explaining that the deployment of smart meters across Ontario, while a pioneering move in North America, is only a first step toward creating a truly "smart grid" in the province.

"Overall the industry needs to be thinking about this, because there are some big benefits that could accrue from the more intelligent use of our delivery system.

"If we can do it in a more co-ordinated fashion, we'll be better able to take advantage of the opportunities that this developing technology presents."

A smart grid is an electricity system that uses software, two-way communications and automation to manage the flow of electricity more efficiently – from power generation, through transmission and distribution lines, and all the way into homes and businesses.

Ontario, in its 20-year power system plan, has placed high priority on building new electricity generation based on nuclear, natural gas and renewable energy, but industry experts say that making the grid smarter would let the province get by on less generation by using what we have more efficiently and better targeting conservation.

"Over the past year there's been a huge awareness of what's going on with the smart grid," said Daniel Ripchensky, vice-president of business development at Current Group LLC, a smart-grid technology supplier based in Maryland.

Ripchensky, a former resident of Toronto, attended a smart-grid conference in the city last week and was encouraged by what he considered more enlightened discussion.

"It was said many times over that the smart grid isn't smart meters, and smart meters aren't the smart grid."

In many ways a smart grid is like an Internet for energy distribution, but instead of moving data, the computers and software in the background of a smart grid manage the flow of electrons from the point of generation to the point of consumption.

A smart meter is only one piece on the edge the puzzle – like a laptop connected to a network of high-power computer servers that collectively form the Internet.

The result is a grid that can automatically heal itself, defend from outside attack, communicate with customers and appliances, and balance the flow of power coming from thousands of different generation sources – from massive nuclear and hydroelectric plants to the smallest solar or wind systems.

The industry group Murphy is assembling will at first be small, consisting of representatives from Toronto Hydro, Hydro Ottawa, Hydro One and Burlington Hydro. The plan is to expand the group to promote a collaborative dialogue across the industry.

"The small group will scope out what we're going to try to cover, who we should invite into this forum, and what we'll produce at the end of it," said Murphy, adding that one goal is to come to a common understanding of what a smart grid should be, its benefits and how to move forward.

The group will look at the need for policy changes, identify investment and technology barriers, and explore other issues likely to influence the pace of smart-grid development in Ontario, he said.

Ripchensky said his discussions with various utilities revealed how many of them have been caught off-guard by calls for a more intelligent grid.

"Investment decisions made three or five years ago wouldn't necessarily be decisions made today based on the information they now have in hand," said Ripchensky. "That's how fast things have changed."

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Two new electricity interconnectors planned for UK

Ofgem UK Electricity Interconnectors will channel subsea cables, linking Europe, enabling energy import/export, integrating offshore wind via multiple-purpose interconnectors, boosting grid stability, capacity, and investment under National Grid analysis to 2030 targets.

 

Key Points

Subsea links between the UK and Europe that trade power, integrate offshore wind, and reinforce grid capacity.

✅ Two new subsea interconnector bids open in 2025

✅ Pilot for multiple-purpose links to offshore wind clusters

✅ National Grid to assess optimal routes, capacity, and locations

 

Ofgem has opened bids to build two electricity interconnectors between the UK and continental Europe as part of the broader UK grid transformation now underway.

The energy regulator said this would “bring forward billions of pounds of investment” in the subsea cables, such as the Lake Erie Connector, which can import cheaper energy when needed and export surplus power from the UK when it is available.

Developers will be invited to submit bids to build the interconnectors next year. Ofgem will additionally run a pilot scheme for ‘multiple-purpose interconnectors’, which are used to link clusters of offshore wind farms and related innovations like an offshore vessel chargepoint to an interconnector.

This forms part of the UK Government drive to more than double capacity by 2030, and to manage rising electric-vehicle demand, as discussed in EV grid impacts, in support of its target of quadrupling offshore wind capacity by the same date.

Interconnectors provide some 7 per cent of UK electricity demand. The UK so far has seven electricity interconnectors linked to Ireland, France, Belgium, the Netherlands and Norway, while projects like the Ireland-France connection illustrate broader European grid integration.

Balfour Beatty won a £90m contract for onshore civil engineering works on the Viking Link Norway interconnector, which is due to come into operation in 2023, while London Gateway's all-electric berth highlights related port electrification.

It said that interconnector developers have in the past been allowed to propose their preferred design, connection location and sea route to the connecting country. Ofgem has now said it may decide to consider only those projects that meet its requirements based on an analysis of location and capacity needs by National Grid.

Ofgem has not specified that the new interconnectors must link to any specific place or country, but may do so later, as priorities like the Cyprus electricity highway illustrate emerging directions.

 

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California Public Utilities Commission sides with community energy program over SDG&E

CPUC Decision on San Diego Community Power directs SDG&E to use updated forecasts, stabilizing electricity rates for CCA customers and supporting clean energy in San Diego with accurate rate forecasting and reduced volatility.

 

Key Points

A CPUC ruling directing SDG&E to use updated forecasts to ensure accurate, stable CCA rates and limit volatility.

✅ Uses 2021 sales forecasts for rate setting

✅ Aims to prevent undercollection and bill spikes

✅ Levels changes across customer classes

 

The California Public Utilities Commission on Thursday sided with the soon-to-launch San Diego community energy program in a dispute it had with San Diego Gas & Electric.

San Diego Community Power — which will begin to purchase power for customers in San Diego, Chula Vista, La Mesa, Encinitas and Imperial Beach later this year — had complained to the commission that data SDG&E intended to use to calculate rates, including community choice exit fees that could make the new energy program less attractive to prospective customers.

SDG&E argued it was using numbers it was authorized to employ as part of a general rate case amid a potential rate structure revamp that is still being considered by the commission.

But in a 4-0 vote, the commission, or CPUC, sided with San Diego Community Power and directed SDG&E to use an updated forecast for energy sales.

"This was not an easy decision," said CPUC president Marybel Batjer at the meeting, held remotely due to COVID-19 restrictions. "In my mind, this outcome best accounts for the shifting realities ... in the San Diego area while minimizing the impact on ratepayers during these difficult financial times."

In filings to the commission, SDG&E predicted a rate decrease of 12.35 percent in the coming year. While that appears to be good news for customers, Californians still face soaring electricity prices statewide, Commissioner Martha Guzman Aceves said the data set SDG&E wanted to use would lead to an undercollection of $150 million to $260 million.

That would result in rates that would be "artificially low," Guzman Aceves said, and rates "would inevitably go up quite a bit after the undercollection was addressed."

San Diego Community Power, or SDCP, said the temporary reduction would make its rates less attractive than SDG&E's, especially amid SDG&E's minimum charge proposal affecting low-usage customers, just as it is about to begin serving customers. SDCP's board members wrote an open letter last month to the commission, accusing the utility of "willful manipulation of data."

Working with an administrative law judge at the CPUC, Guzman Aceves authored a proposal requiring SDG&E to use numbers based on 2021 forecasts, as regulators simultaneously weigh whether the state needs more power plants to ensure reliability. The utility argued that could result in an increase of "roughly 40 percent" for medium and large commercial and industrial customers this year.

To help reduce potential volatility, Guzman Aceves, SDCP and other community energy supporters called for using a formula that would average out changes in rates across customer classes amid debates over income-based utility charges statewide. That's what the commissioners OK'd Thursday.

"It is essential that customer commodity rates be as accurate as we can possibly get them to avoid undercollections," said Commissioner Genevieve Shiroma.

San Diego Community Power is one of 23 community choice aggregation, or CCA, energy programs that have launched in California in the past decade.

CCAs compete with traditional power companies amid California's evolving power competition landscape, in one important role — purchasing power for a given community. They were created to boost the use of cleaner energy sources, such as wind and solar, at rates equal to or lower than investor-owned utilities.

However, CCAs do not replace utilities because the incumbent power companies still perform all of the tasks outside of power purchasing, such as transmission and distribution of energy and customer billing.

When a CCA is formed, California rules stipulate the utility customers in that area are automatically enrolled in the CCA. If customers prefer to stay with their previous power company, they can opt out of joining the CCA.

The shift of customers from SDG&E to San Diego Community Power is expected to be large. The total number of accounts for SDCP is expected to be 770,000, which would make it the second-largest CCA in the state. That's why SDCP considered Thursday's CPUC decision to be so important.

"At a time when customers are choosing between sticking with San Diego Gas & Electric and migrating to a CCA, we want them to have accurate bill information," said Commissioner Clifford Rechtschaffen.

"SDCP is very happy with today's CPUC decision, and that the commissioners shared our goal of limiting rate volatility for businesses and families in the region," said SDCP interim CEO Bill Carnahan. "This is definitely a win for accurate rate forecasting, and our mutual customers, and we look forward to working with SDG&E on next steps."

In an email, SDG&E spokeswoman Helen Gao said, "We are committed to continuing to work collaboratively with local Community Choice Aggregation programs to support their successful launch in 2021 and ensure that our mutual customers receive excellent customer service."

San Diego Community Power's case before the CPUC was joined by the California Community Choice Association, a trade group advocating for CCAs, and the Clean Energy Alliance — the North County-based CCA representing Del Mar, Solana Beach and Carlsbad that is scheduled to launch this summer.

SDCP will begin its rollout this year, folding in about 71,000 municipal, commercial and industrial accounts. The bulk of its roughly 700,000 residential accounts is expected to come in January 2022.

 

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Ireland: We are the global leaders in taking renewables onto the grid

Ireland 65% Renewable Grid Capability showcases world leading integration of intermittent wind and solar, smart grid flexibility, EU-SysFlex learnings, and the Celtic Interconnector to enhance stability, exports, and energy security across the European grid.

 

Key Points

Ireland can run its isolated power system with 65% variable wind and solar, informing EU grid integration and scaling.

✅ 65% system non-synchronous penetration on an isolated grid

✅ EU-SysFlex roadmap supports large-scale renewables integration

✅ Celtic Interconnector adds 700MW capacity and stability

 

Ireland is now able to cope with 65% of its electricity coming from intermittent electricity sources like wind and solar, as highlighted by Ireland's green electricity outlook today – an expertise Energy Minister Denish Naugthen believes can be replicated on a larger scale as Europe moves towards 50% renewable power by 2030.

Denis Naughten is an Irish politician who serves as Minister for Communications, Climate Action and Environment since May 2016.

Naughten spoke to editor Frédéric Simon on the sidelines of a EURACTIV event in the European  Parliament to mark the launch of EU-SysFlex, an EU-funded project, which aims to create a long-term roadmap for the large-scale integration of renewable energy on electricity grids.

What is the reason for your presence in Brussels today and the main message that you came to deliver?

The reason that I’m here today is that we’re going to share the knowledge what we have developed in Ireland, right across Europe. We are now the global leaders in taking variable renewable electricity like wind and solar onto our grid.

We can take a 65% loading on to the grid today – there is no other isolated grid in the world that can do that. We’re going to get up to 75% by 2020. This is a huge technical challenge for any electricity grid and it’s going to be a problem that is going to grow and grow across Europe, even as Europe's electricity demand rises in the coming years, as we move to 50% renewables onto our grid by 2030.

And our knowledge and understanding can be used to help solve the problems right across Europe. And the sharing of technology can mean that we can make our own grid in Ireland far more robust.

What is the contribution of Ireland when it comes to the debate which is currently taking place in Europe about raising the ambition on renewable energy and make the grid fit for that? What are the main milestones that you see looking ahead for Europe and Ireland?

It is a challenge for Europe to do this, but we’ve done it Ireland. We have been able to take a 65% loading of wind power on our grid, with Irish wind generation hitting records recently, so we can replicate that across Europe.

Yes it is about a much larger scale and yes, we need to work collaboratively together, reflecting common goals for electricity networks worldwide – not just in dealing with the technical solutions that we have in Ireland at the fore of this technology, but also replicating them on a larger scale across Europe.

And I believe we can do that, I believe we can use the learnings that we have developed in Ireland and amplify those to deal with far bigger challenges that we have on the European electricity grid.

Trialogue talks have started at European level about the reform of the electricity market. There is talk about decentralised energy generation coming from small-scale producers. Do you see support from all the member states in doing that? And how do you see the challenges ahead on a political level to get everyone on board on such a vision?

I don’t believe there is a political problem here in relation to this. I think there is unanimity across Europe that we need to support consumers in producing electricity for self-consumption and to be able to either store or put that back into the grid.

The issues here are more technical in nature. And how you support a grid to do that. And who actually pays for that. Ireland is very much a microcosm of the pan-European grid and how we can deal with those challenges.

What we’re doing at the moment in Ireland is looking at a pilot scheme to support consumers to generate their own electricity to meet their own needs and to be able to store that on site.

I think in the years to come a lot of that will be actually done with more battery storage in the form of electric vehicles and people would be able to transport that energy from one location to another as and when it’s needed. In the short term, we’re looking at some novel solutions to support consumers producing their own electricity and meeting their own needs.

So I think this is complex from a technical point of view at the moment, I don’t think there is an unwillingness from a political perspective to do it, and I think working with this particular initiative and other initiatives across Europe, we can crack those technical challenges.

To conclude, last year, the European Commission allocated €4 million to a project to link up the Irish electricity grid to France. How is that going to benefit Ireland? And is that related to worries that you may have over Brexit?

The plan, which is called the Celtic Interconnector, is to link France with the Irish electricity grid. It’s going to have a capacity of about 700MW. It allows us to provide additional stability on our grid and enables us to take more renewables onto the grid. It also allows us to export renewable electricity onto the main European grid as well, and provide stability to the French network.

So it’s a benefit to both individual networks as well as allowing far more renewables onto the grid. We’ve been working quite closely with RTE in France and with both regulators. We’re hoping to get the support of the European Commission to move it now from the design stage onto the construction stage. And I understand discussions are ongoing with the Commission at present with regard to that.

And that is going to diversify potential sources of electricity coming in for Ireland in a situation which is pretty uncertain because of Brexit, correct?

Well, I don’t think there is uncertainty because of Brexit in that we have agreements with the United Kingdom, we’re still going to be part of the broader energy family in relation to back-and-forth supply across the Irish Sea, with grid reinforcements in Scotland underscoring reliability needs.  But I think it is important in terms of meeting the 15% interconnectivity that the EU has set in relation to electricity.

And also in relation of providing us with an alternative support in relation to electricity supply outside of Britain. Because Britain is now leaving the European Union and I think this is important from a political point of view, and from a broader energy security point of view. But we don’t see it in the short term as causing threats in relation to security of supply.

 

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U.S. Residents Averaged Fewer Power Outages in 2022

2022 U.S. Power Outage Statistics show lower SAIDI as fewer major events hit, with SAIFI trends, electric reliability, outage duration and frequency shaped by hurricanes, winter storms, vegetation, and utility practices across states.

 

Key Points

They report SAIDI and SAIFI for 2022, showing outage duration, frequency, and impacts of major weather events.

✅ 2022 SAIDI averaged 5.6 hours; SAIFI averaged 1.4 interruptions.

✅ Fewer major events lowered outage duration versus 2021.

✅ Hurricanes and winter storms drove long outages in several states.

 

In 2022, U.S. electricity consumers on average experienced about 5.5 hours of power disruptions, a decrease from nearly two hours compared to 2021. This information comes from the latest Annual Electric Power Industry Report. The reduction in yearly power interruptions primarily resulted from fewer significant events in 2022 compared to the previous year, and utility disaster planning continues to support grid resilience as severe weather persists.

Since 2013, excluding major events, the annual average duration of power interruptions has consistently hovered around two hours. Factors contributing to major power disruptions include weather-related incidents, vegetation interference near power lines, and specific utility practices, while pandemic-related grid operations influenced workforce planning more than outage frequency. To assess the reliability of U.S. electric utilities, two key indexes are utilized:

  • The System Average Interruption Duration Index (SAIDI) calculates the total length (in hours) an average customer endures non-brief power interruptions over a year.
  • The System Average Interruption Frequency Index (SAIFI) tracks the number of times interruptions occur.

The influence of major events on electrical reliability is gauged by comparing affected states' SAIDI and SAIFI values against the U.S. average, which was 5.6 hours of outages and 1.4 outages per customer in 2022. The year witnessed 18 weather-related disasters in the U.S., each resulting in over $1 billion in damages, and COVID-19 grid assessments indicated the electricity system was largely safe from pandemic impacts. Noteworthy major events include:

  • Hurricane Ian in September 2022, leaving over 2.6 million Floridian customers without electricity, with restoration in some areas taking weeks rather than days.
  • Hurricane Nicole in November 2022, causing over 300,000 Florida customers to lose power.
  • Winter Storm Elliott in December 2022, affecting over 1.5 million customers in multiple states including Texas where utilities struggled after Hurricane Harvey to restore service, and Florida, and bringing up to four feet of snow in parts of New York.

In 2022, states like Florida, West Virginia, Maine, Vermont, and New Hampshire experienced the most prolonged power interruptions, with New Hampshire averaging 10.3 hours and Florida 19.1 hours, and FPL's Irma storm response illustrates how restoration can take days or weeks in severe cases. Conversely, the District of Columbia, Delaware, Rhode Island, Nebraska, and Iowa had the shortest total interruptions, with the District of Columbia averaging just 34 minutes and Iowa 85 minutes.

The frequency of outages, unlike their duration, is more often linked to non-major events. Across the nation, Alaska recorded the highest number of power disruptions per customer (averaging 3.5), followed by several heavily forested states like Tennessee and Maine. Power outages due to falling tree branches are common, particularly during winter storms that burden tree limbs and power lines, as seen in a North Seattle outage affecting 13,000 customers. The District of Columbia stood out with the shortest and fewest outages per customer.

 

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Overturning statewide vote, Maine court energizes Hydro-Quebec's bid to export power

Maine Hydropower Transmission Line revived by high court after referendum challenge, advancing NECEC, Hydro-Quebec supply, Central Maine Power partnership, clean energy integration, grid reliability, and lower rates across New England pending land-lease ruling.

 

Key Points

A court-revived NECEC line delivering 1,200 MW of Hydro-Quebec hydropower via CMP to strengthen the New England grid.

✅ Maine high court deems retroactive referendum unconstitutional

✅ Pending state land lease case may affect final route

✅ Project could lower rates and cut emissions in New England

 

Maine's highest court on Tuesday breathed new life into a $1-billion US transmission line that aims to serve as conduit for Canadian hydropower, after construction starts drew scrutiny, ruling that a statewide vote rebuking the project was unconstitutional.

The Supreme Judicial Court ruled that the retroactive nature of the referendum last year violated the project developer's constitutional rights, sending it back to a lower court for further proceedings.

The court did not rule in a separate case that focuses on a lease for a 1.6-kilometre portion of the proposed power line that crosses state land.

Central Maine Power's parent company and Hydro-Québec teamed up on the project that would supply up to 1,200 megawatts of Canadian hydropower, amid the ongoing Maine-Quebec corridor debate in the region. That's enough electricity for one million homes.

Most of the proposed 233-kilometre power transmission line would be built along existing corridors, but a new 85-kilometre section was needed to reach the Canadian border, echoing debates around the Northern Pass clash in New Hampshire.

Workers were already clearing trees and setting poles when the governor asked for work to be suspended after the referendum in November 2021, mirroring New Hampshire's earlier rejection of a Quebec-Massachusetts proposal that rerouted regional plans. The Maine Department of Environmental Protection later suspended its permit, but that could be reversed depending on the outcome of legal proceedings.

The high court was asked to weigh in on two separate lawsuits. Developers sought to declare the referendum unconstitutional while another lawsuit focused on a lease allowing transmission lines to cross a short segment of state-owned land.

Supporters say bold projects such as this one, funded by ratepayers in Massachusetts, are necessary to battle climate change and introduce additional electricity into a region that's heavily reliant on natural gas, which can cause spikes in energy costs, as seen with Nova Scotia rate increases recently across the Atlantic region.

Critics say the project's environmental benefits are overstated — and that it would harm the woodlands in western Maine.

It was the second time the Supreme Judicial Court was asked to weigh in on a referendum aimed at killing the project. The first referendum proposal never made it onto the ballot after the court raised constitutional concerns.

Although the project is funded by Massachusetts ratepayers, the introduction of so much electricity to the grid would serve to stabilize or reduce electricity rates for all consumers, proponents contend, even as Manitoba Hydro rate hikes face opposition elsewhere.

The referendum on the project was the costliest in Maine history, topping $90 million US and underscoring deep divisions.

The high-stakes campaign put environmental and conservation groups at odds, and pitted utilities backing the project, amid the Hydro One-Avista backlash, against operators of fossil fuel-powered plants that stand to lose money.

 

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New England Is Burning the Most Oil for Electricity Since 2018

New England oil-fired generation surges as ISO New England manages a cold snap, dual-fuel switching, and a natural gas price spike, highlighting winter reliability challenges, LNG and pipeline limits, and rising CO2 emissions.

 

Key Points

Reliance on oil-burning power plants during winter demand spikes when natural gas is costly or constrained.

✅ Driven by dual-fuel switching amid high natural gas prices

✅ ISO-NE winter reliability rules encourage oil stockpiles

✅ Raises CO2 emissions despite coal retirements and renewables growth

 

New England is relying on oil-fired generators for the most electricity since 2018 as a frigid blast boosts demand for power and natural gas prices soar across markets. 

Oil generators were producing more than 4,200 megawatts early Thursday, accounting for about a quarter of the grid’s power supply, according to ISO New England. That was the most since Jan. 6, 2018, when oil plants produced as much as 6.4 gigawatts, or 32% of the grid’s output, said Wood Mackenzie analyst Margaret Cashman.  

Oil is typically used only when demand spikes, because of higher costs and emissions concerns. Consumption has been consistently high over the past three weeks as some generators switch from gas, which has surged in price in recent months. New England generators are producing power from oil at an average rate of almost 1.8 gigawatts so far this month, the highest for January in at least five years. 

Oil’s share declined to 16% Friday morning ahead of an expected snowstorm, which was “a surprise,” Cashman said. 

“It makes me wonder if some of those generators are aiming to reserve their fuel for this weekend,” she said.

During the recent cold snap, more than a tenth of the electricity generated in New England has been produced by power plants that haven’t happened for at least 15 years.

Burning oil for electricity was standard practice throughout the region for decades. It was once our most common fuel for power and as recently as 2000, fully 19% of the six-state region’s electricity came from burning oil, according to ISO-New England, more than any other source except nuclear power at the time.

Since then, however, natural gas has gotten so cheap that most oil-fired plants have been shut or converted to burn gas, to the point that just 1% of New England’s electricity came from oil in 2018, whereas about half our power came from natural gas generation regionally during that period. This is good because natural gas produces less pollution, both particulates and greenhouse gasses, although exactly how much less is a matter of debate.

But as you probably know, there’s a problem: Natural gas is also used for heating, which gets first dibs. Prolonged cold snaps require so much gas to keep us warm, a challenge echoed in Ontario’s electricity system as supply tightens, that there might not be enough for power plants – at least, not at prices they’re willing to pay.

After we came close to rolling brownouts during the polar vortex in the 2017-18 winter because gas-fired power plants cut back so much, ISO-NE, which has oversight of the power grid, established “winter reliability” rules. The most important change was to pay power plants to become dual-fuel, meaning they can switch quickly between natural gas and oil, and to stockpile oil for winter cold snaps.

We’re seeing that practice in action right now, as many dual-fuel plants have switched away from gas to oil, just as was intended.

That switch is part of the reason EPA says the region’s carbon emissions have gone up in the pandemic, from 22 million tons of CO2 in 2019 to 24 million tons in 2021. That reverses a long trend caused partly by closing of coal plants and partly by growing solar and offshore wind capacity: New England power generation produced 36 million tons of CO2 a decade ago.

So if we admit that a return to oil burning is bad, and it is, what can we do in future winters? There are many possibilities, including tapping more clean imports such as Canadian hydropower to diversify supply.

The most obvious solution is to import more natural gas, especially from fracked fields in New York state and Pennsylvania. But efforts to build pipelines to do that have been shot down a couple of times and seem unlikely to go forward and importing more gas via ocean tanker in the form of liquefied natural gas (LNG) is also an option, but hits limits in terms of port facilities.

Aside from NIMBY concerns, the problem with building pipelines or ports to import more gas is that pipelines and ports are very expensive. Once they’re built they create a financial incentive to keep using natural gas for decades to justify the expense, similar to moves such as Ontario’s new gas plants that lock in generation. That makes it much harder for New England to decarbonize and potentially leaves ratepayers on the hook for a boatload of stranded costs.

 

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