Tax breaks turn solar power into cold cash

By McClatchy Tribune News


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Tax breaks and cash rebates have done what the most gung-ho green talk has not: ignited a solar power boom in Oregon.

Oregon officials expect the amount of solar power in the state to jump more than eightfold this year as businesses, nonprofits and government agencies install rooftop and ground-mounted photovoltaic systems at record rates. The surge is courtesy of the taxpayer, who foots the bill in this effort to go green.

Beefed-up state and federal incentives make building solar almost irresistible. A business can recoup an investment in a million-dollar array in five years, then post thousands of dollars annually in electricity savings. A little extra icing: The installations are exempt from property taxes through 2012.

Nonprofits and government entities are equally enthusiastic. They're allowed to transfer the incentives to investors on the hunt for tax breaks, then put up a solar array for little if any out-of-pocket expense.

"It's not just for do-gooders," said Christopher Dymond, a senior energy analyst with the Oregon Department of Energy. "There's actually a financial reward, and that's what drives industry."

The red-hot response underscores Gov. Ted Kulongoski's claims that he can strengthen the economy as he does battle with climate-warming carbon dioxide emissions. More solar installers, engineers, designers and investors, the thinking goes, fatten company payrolls just as other parts of the economy are weakening.

But the solar push highlights how crucial subsidies have become to the clean-energy calculation. Solar systems are expensive, three times the cost of wind energy, for example. A business, no matter how green its rhetoric, isn't likely to invest seriously in solar unless it can find assistance, state officials and industry leaders say.

Skeptics don't like the size of the subsidies, which are expected to reduce the state budget by almost $96 million annually by 2013 - money that otherwise would be available for schools, health care and other government-funded services. Besides, they note, even such furious development isn't going to make solar energy a significant part of the state's overall power supplies anytime soon.

"It's window dressing," said Jeff King, a senior resource analyst with the Northwest Power and Conservation Council who tracks the region's power supplies and finds solar just a blip - well under 1 percent - in the accounting. "If the objective is to reduce CO2, there are better ways to do it."

A south-facing rooftop in Northeast Portland stretches as big as two football fields. It's a perfect setup for solar, and soon it's going to get it - 4,800 solar modules with an 870-kilowatt capacity. Once the power starts flowing, the solar array will be the largest in the state - almost double the size of the current record-holder.

It will increase the state's solar capacity by 35 percent.

The modules will produce an estimated 870,000 kilowatt hours of electricity annually, despite Portland's cloudy weather. That's enough to meet all the electricity demands of the 110,000-square-foot manufacturing building or enough to light up 72 average Portland homes.

That's a lot of light bulbs. It's also a lot of intricate financing.

Portland Habilitation Center, which trains and employs individuals with disabilities, is a nonprofit that doesn't pay taxes and is hardly flush with cash. John Murphy, the organization's president, knew he wanted to go solar when he began planning for a new manufacturing facility 18 months ago.

But he quickly realized that a $7 million price tag and restrictive utility rules blocked his way. "A whole lot of laws and regulations had to change to make it happen," Murphy said. By this year, an expanded state tax credit - 50 percent of eligible costs spread over five years - had settled into place. So had utility regulations that allowed projects as big as 2 megawatts to hook into the main grid.

Energy Trust of Oregon Inc., funded by payments from Portland General Electric and Pacific Power customers, offered custom grants - more than $1 million for the habilitation center. A 30 percent federal tax credit - taken entirely in the first year - and accelerated depreciation schedules topped off the available incentives.

To tap the rich pool of tax credits, the center began looking for an outside investor, a corporate taxpayer eager to reduce its payment to the IRS. Eventually, a deal with U.S. Bank Community Development Corp., one of the largest tax credit investors in the country, began to take shape.

The nonprofit will end up putting about $556,000 into the deal. The investor will take care of the rest. It will own the project and, therefore, be able to use all the tax breaks. It expects to make 7 percent to 10 percent annually on its money. U.S. Bank Community Development will sell the power to the habilitation center for about 7 cents a kilowatt hour, but the tax breaks are what make the deal a moneymaker.

In six years, after the incentives have played out, the nonprofit can regain ownership in what has become known as the "flip" financial model. From then on, the Portland Habilitation Center gets its solar power for free, saving about $75,000 annually in electricity costs.

"We wanted to own it," Murphy said. "This is the way to make it financially viable."

Oregon is considered a testing ground for this financing technique for solar projects. But the "flip" is not the only way for nonprofits or government agencies to get a solar deal done. They can contract with companies that specialize in financing and selling renewable energy, agreeing to buy the power on a long-term, 20-year contract.

Here, too, the company gets the tax credits and the tax-exempt entity gets the solar energy. Unlike the flip model, ownership remains with the energy provider. Public officials praise this arrangement. They don't have to come up with any cash for construction; their only obligation is to buy the power at a set rate with an annual increase of between 2 percent and 4 percent.

The best part, they say, is the ability to rely on OPM - other people's money.

Honeywell Energy Services has jumped into this niche, sealing deals with Hillsboro, Medford, Pendleton and Lewis & Clark College. The solar surge has been a boon to a wide variety of companies, from the developers and consultants who package the deals to the installers who erect the modules.

"I've never seen anything like it," said Len Ralston, renewable energy project manager for Dynalectric Oregon, which will install the Portland Habilitation Center's panels.

Clean energy advocates applaud the growth, arguing that the state is on track to become a national leader in the advancement of solar energy. "Green-collar" jobs will add thousands of workers to the employment ranks, they say, and that means more taxpayers, who will more than make up for losses tied to the tax credits.

Critics counter that businesses and the industries they strengthen shouldn't have to rely on government largesse to survive, especially at the expense of state services.

State revenue officials expect the annual cost of the renewable energy credits to plateau at $95.6 million in 2013. That's about 1 percent of the total general fund projection for that year.

Put another way, it means about $50 per tax-filer will be used to pay for those tax credits.

The debate has yet another wrinkle. The federal tax credit will drop from 30 percent to 10 percent at the end of the year unless Congress passes an extension.

Advocates are confident of eventual revival, but acknowledge that delays could mean the solar boom goes bust for a while.

"We've cut back to projects we know we can absolutely finish by the end of the year," said Sandra Walden, director of Commercial Solar Ventures, which specializes in matching up tax-exempt entities and tax-paying corporations.

"Everything else is on hold or has been dropped." In short, she said, "We need government support that's consistent."

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Shell says electricity to meet 60 percent of China's energy use by 2060

China 2060 Carbon-Neutral Energy Transition projects tripled electricity, rapid electrification, wind and solar dominance, scalable hydrogen, CCUS, and higher carbon pricing to meet net-zero goals while decarbonizing heavy industry and transport.

 

Key Points

Shell's outlook for China to reach net zero by 2060 via electrification, renewables, hydrogen, CCUS, and carbon pricing.

✅ Power supply to 60% of energy; generation triples by 2060.

✅ Wind and solar reach 80% of electricity; coal declines sharply.

✅ Hydrogen scales to 17 EJ; CCUS and carbon pricing expand.

 

China may triple electricity generation to supply 60 percent of the country's total energy under Beijing's carbon-neutral goal by 2060, up from the current 23 per cent, according to Royal Dutch Shell.

Shell is one of the largest global investors in China's energy sector, with business covering gas production, petrochemicals and a retail fuel network. A leading supplier of liquefied natural gas, it has recently expanded into low-carbon business such as hydrogen power and electric vehicle charging.

In a rare assessment of the country's energy sector by an international oil major, Shell said China needed to take quick action this decade to stay on track to reach the carbon-neutrality goal.

China has mapped out plans to reach peak emissions by 2030, and aims to reduce coal power production over the coming years, but has not yet revealed any detailed carbon roadmap for 2060.

This includes investing in a reliable and renewable power system, including compressed air generation, and demonstrating technologies that transform heavy industry using hydrogen, biofuel and carbon capture and utilization.

"With early and systematic action, China can deliver better environmental and social outcomes for its citizens while being a force for good in the global fight against climate change," Mallika Ishwaran, chief economist of Shell International, told a webinar hosted by the company's China business.

Shell expects China's electricity generation to rise three-fold to more than 60 exajoules (EJ) in 2060 from 20 EJ in 2020, even amid power supply challenges reported recently.

Solar and wind power are expected to surpass coal as the largest sources of electricity by 2034 in China, reflecting projections that renewables will eclipse coal globally by mid-decade, versus the current 10 percent, rising to 80 percent by 2060, Shell said.

Hydrogen is expected to scale up to 17 EJ, or equivalent to 580 million tonnes of coal by 2060, up from almost negligible currently, adding over 85 percent of the hydrogen will be produced through electrolysis, supported by PEM hydrogen R&D across the sector, powered by renewable and nuclear electricity, Shell said.

Hydrogen will meet 16 percent of total energy use in 2060 with heavy industry and long-distance transport as top hydrogen users, the firm added.

The firm also expects China's carbon price to rise to 1,300 yuan (CDN$256.36) per tonne in 2060 from 300 yuan in 2030.

Nuclear, on a steady development track, and biomass will have niche but important roles for power generation in the years to come, Shell said.

Electricity generated from biomass, combined with carbon, capture, utilization and storage (CCUS), provide a source of negative emissions for the rest of the energy system from 2053, it added.

 

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Planning for our electricity future should be led by an independent body

Nova Scotia Integrated Resource Plan evaluates NSPI supply options, UARB oversight, Muskrat Falls imports, coal retirements, wind and biomass expansion, transmission upgrades, storage, and least-cost pathways to decarbonize the grid for ratepayers.

 

Key Points

A 25-year roadmap assessing supply, imports, costs, and emissions to guide least-cost decarbonization for Nova Scotia.

✅ Compares wind, biomass, gas, imports, and storage costs

✅ Addresses coal retirements, emissions caps, and reliability

✅ Recommends transmission upgrades and Muskrat Falls utilization

 

Maintaining a viable electricity network requires good long-term planning and, as a recent grid operations report notes, ongoing operational improvements. The existing stock of generating assets can become obsolete through aging, changes in fuel prices or environmental considerations. Future changes in demand must be anticipated.

Periodically, an integrated resource plan is created to predict how all this will add up during the ensuing 25 years. That process is currently underway and is led by Nova Scotia Power Inc. (NSPI) and will be submitted for approval to the Utilities and Review Board (UARB).

Coal-fired plants are still the largest single source of electricity in Nova Scotia. They need to be replaced with more environmentally friendly sources when they reach the end of their useful lives. Other sources include wind, hydroelectricity from rivers, biomass, as seen in increased biomass use by NS Power, natural gas and imports from other jurisdictions.

Imports are used sparingly today but will be an important source when the electricity from Muskrat Falls comes on stream. That project has big capacity. It can produce all the power needed in Newfoundland and Labrador (NL), where Quebec's power ambitions influence regional flows, plus the amount already committed to Nova Scotia, and still have a lot left over.

Some sources of electricity are more valuable than others. The daily amount of power from wind and solar cannot be controlled. Fuel-based sources and hydro can.

Utilities make their profits by providing the capital necessary to build infrastructure. Most of the money is borrowed but a portion, typically 30 per cent, usually comes from NSPI or a sister company. On that they receive a rate of return of nine per cent. Nova Scotia can borrow money today at less than two per cent.

The largest single investment of that type is the $1.577-billion Maritime Link connecting power from Newfoundland to Nova Scotia. It continues through to the New Brunswick border to facilitate exports to the United States. NSPI’s sister company, NSP Maritime Link Inc. (NSPML), is making nine per cent on $473 million of the cost.

There is little unexploited hydro capacity in Nova Scotia and there will not be any new coal-fired plants. Large-scale solar is not competitive in Nova Scotia’s climate. Nova Scotia’s needs would not accommodate the amount of nuclear capacity needed to be cost-effective, even as New Brunswick explores small reactors in its strategy.

So the candidates for future generating resources are wind, natural gas, biomass (though biomass criticism remains) and imports from other jurisdictions. Tidal is a promising opportunity but is still searching for a commercially viable technology. 

NSPI is commendably transparent about its process (irp.nspower.ca). At this stage there is little indication of the conclusions they are reaching but that will presumably appear in due course.

The mountains of detail might obscure the fact that NSPI is not an unbiased arbiter of choices for the future.

It is reported that they want to prematurely close the Trenton 5 coal plant in 2023-25. It is valued at $88.5 million. If it is closed early, ratepayers will still have to pay off the remaining value even though the plant will be idle. NSPI wants to plan a decommissioning of five of its other seven plants. There is a federal emissions constraint but retiring coal plants earlier than needed will cost ratepayers a lot.

Whenever those plants are closed, there will be a need for new sources of power. NSPI is proposing to plan for new investments in new transmission infrastructure to facilitate imports. Other possibilities would be additional wind farms, consistent with the shift to more wind and solar projects, thermal plants that burn natural gas or biomass, or storage for excess wind power that arrives before it can be used. The investment in storage could be anywhere from $20 million to $200 million.

These will add to the asset burden funded by ratepayers, even as industrial customers seek discounts while still paying for shuttered coal infrastructure.

External sources of new power will not provide NSPI the same opportunity: wind power by independent producers might be less expensive because they are willing to settle for less than nine per cent or because they are more efficient. Buying more power from Muskrat Falls will use transmission infrastructure we are already paying for. If a successful tidal technology is found, it will not be owned by NSPI or a sister company, which are no longer trying to perfect the technology.

This is not to suggest that NSPI would misrepresent the alternatives. But they can tilt the discussion in their favour. How tough will they be negotiating for additional Muskrat Falls power when it hurts their profits? Arguing for premature coal retirement on environmental grounds is fair game but whether the cost should be accepted is a political choice. 

NSPI is in a conflict of interest. We need a different process. An independent body should author the integrated resource plan. They should be fully informed about NSPI’s views.

They should communicate directly with Newfoundland and Labrador for Muskrat power, with independent wind producers, and with tidal power companies. The UARB cannot do any of these things.

The resulting plan should undergo the same UARB review that NSPI’s version would. This enhances the likelihood that Nova Scotians will get the least-cost alternative.

 

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This kite could harness more of the world's wind energy

Autonomous Energy Kites harness offshore wind on floating platforms, using carbon fiber wings, tethers, and rotors to generate grid electricity; an airborne wind energy solution backed by Alphabet's Makani to cut turbine costs.

 

Key Points

Autonomous Energy Kites are tethered craft that capture winds with rotors, generating grid power from floating platforms.

✅ Flies circles on tethers; rotors drive generators to feed the grid.

✅ Operates over deep-sea winds where fixed turbines are impractical.

✅ Lighter, less visual impact, and lower installation costs offshore.

 

One company's self-flying energy kite may be the answer to increasing wind power around the world, alongside emerging wave power solutions as well.

California-based Makani -- which is owned by Google's parent company, Alphabet -- is using power from the strongest winds found out in the middle of the ocean, where the offshore wind sector has huge potential, typically in spots where it's a challenge to install traditional wind turbines. Makani hopes to create electricity to power communities across the world.

Despite a growing number of wind farms in the United States and the potential of this energy source, lessons from the U.K. underscore how to scale, yet only 6% of the world's electricity comes from wind due to the the difficulty of setting up and maintaining turbines, according to the World Wind Energy Association.

When the company's co-founders, who were fond of kiteboarding, realized deep-sea winds were largely untapped, they sought to make that energy more accessible. So they built an autonomous kite, which looks like an airplane tethered to a base, to install on a floating platform in water, as part of broader efforts to harness oceans and rivers for power across regions. Tests are currently underway off the coast of Norway.

"There are many areas around the world that really don't have a good resource for renewable power but do have offshore wind resources," Makani CEO Fort Felker told Rachel Crane, CNN's innovation correspondent. "Our lightweight kites create the possibility that we could tap that resource very economically and bring renewable power to hundreds of millions of people."

This technology is more cost-efficient than a traditional wind turbine, which is a lot more labor intensive and would require lots of machinery and installation.

The lightweight kite, which is made of carbon fiber, has an 85-foot wingspan. The kite launches from a base station and is constrained by a 1,400-foot tether as it flies autonomously in circles with guidance from computers. Crosswinds spin the kite's eight rotors to move a generator that produces electricity that's sent back to the grid through the tether.

The kites are still in the prototype phase and aren't flown constantly right now as researchers continue to develop the technology. But Makani hopes the kites will one day fly 24/7 all year round. When the wind is down, the kite will return to the platform and automatically pick back up when it resumes.

Chief engineer Dr. Paula Echeverri said the computer system is key for understanding the state of the kite in real time, from collecting data about how fast it's moving to charting its trajectory.

Echeverri said tests have been helpful in establishing what some of the challenges of the system are, and the team has made adjustments to get it ready for commercial use. Earlier this year, the team successfully completed a first round of autonomous flights.

Working in deeper water provides an additional benefit over traditional wind turbines, according to Felker. By being farther offshore, the technology is less visible from land, and the growth of offshore wind in the U.K. shows how coastal communities can adapt. Wind turbines can be obtrusive and impact natural life in the surrounding area. These kites may be more attractive to areas that wish to preserve their scenic coastlines and views.

It's also desirable for regions that face constraints related to installing conventional turbines -- such as island nations, where World Bank support is helping developing countries accelerate wind adoption, which have extremely high prices for electricity because they have to import expensive fossil fuels that they then burn to generate electricity.

Makani isn't alone in trying to bring novelty to wind energy. Several others companies such as Altaeros Energies and Vortex Bladeless are experimenting with kites of their own or other types of wind-capture methods, such as underwater kites that generate electricity, a huge oscillating pole that generates energy and a blimp tethered to the ground that gathers winds at higher altitudes.

 

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US NRC streamlines licensing for advanced reactors

NRC Advanced Reactor Licensing streamlines a risk-informed, performance-based, technology-inclusive pathway for advanced non-light water reactors, aligning with NEIMA to enable predictable regulatory reviews, inherent safety, clean energy deployment, and industrial heat, hydrogen, and desalination applications.

 

Key Points

A risk-informed, performance-based NRC pathway streamlining licensing for advanced non-light water reactors.

✅ Aligned with NEIMA: risk-informed, performance-based, tech-inclusive

✅ Predictable licensing for advanced non-light water reactor designs

✅ Enables clean heat, hydrogen, desalination beyond electricity

 

The US Nuclear Regulatory Commission (NRC) voted 4-0 to approve the implementation of a more streamlined and predictable licensing pathway for advanced non-light water reactors, aligning with nuclear innovation priorities identified by industry advocates, the Nuclear Energy Institute (NEI) announced, and amid regional reliability measures such as New England emergency fuel stock plans that have drawn cost scrutiny.

This approach is consistent with the Nuclear Energy Innovation and Modernisation Act (NEIMA), a nuclear innovation act passed in 2019 by the US Congress calling for the development of a risk-informed, performance-based and technology inclusive licensing process for advanced reactor developers.

NEI Chief Nuclear Officer Doug True said: “A modernised regulatory framework is a key enabler of next-generation nuclear technologies that, amid ACORE’s challenge to DOE subsidy proposals in energy market proceedings, can help us meet our energy needs while protecting the climate. The Commission’s unanimous approval of a risk-informed and performance-based licensing framework paves the way for regulatory reviews to be aligned with the inherent safety characteristics, smaller reactor cores and simplified designs of advanced reactors.”

Over the last several years the industry’s Licensing Modernisation Project, sponsored by US Department of Energy, led by Southern Nuclear, and supported by NEI’s Advanced Reactor Regulatory Task Force, and influenced by a presidential order to bolster uranium and nuclear energy, developed the guidance for this new framework. Amid shifts in the fuel supply chain, including the U.S. ban on Russian uranium, this approach will inform the development of a new rule for licensing advanced reactors, which NEIMA requires.

“A well-defined licensing path will benefit the next generation of nuclear plants, especially as regions consider New England market overhaul efforts, which could meet a wide range of applications beyond generating electricity such as producing heat for industry, desalinating water, and making hydrogen – all without carbon emissions,” True noted.

 

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Ontario Energy Board prohibiting electricity shutoffs during latest stay-at-home order

OEB Disconnection Ban shields Ontario residential customers under the stay-at-home order, pausing electricity distributor shutoffs for non-payment and linking COVID-19 Energy Assistance Program credits for small businesses, charities, and overdue utility bills.

 

Key Points

A pause on electricity shutoff notices during Ontario's stay-at-home order, with COVID-19 bill credits for customers.

✅ Distributors cannot issue residential disconnection notices.

✅ Applies through the stay-at-home order timeline.

✅ CEAP credits: $750 residential; $1,500 small biz and charities.

 

With Ontario now into the third province-wide lockdown, the Ontario Energy Board (OEB) has promised residents won't have to worry about their power being shut off.

On April 8, the Province issued the third stay-at-home order in the last 13 months which is scheduled to last for 28 days until at least May 6, as electricity rates and policies continue to shift.

On April 30, the annual winter disconnection ban is set to expire, meaning electricity distributors like Hydro One would normally be permitted to issue disconnection notices for non-payment as early as 14 days before the end of the ban.

However, the OEB has announced changes for electricity consumers that prohibit electricity distributors from issuing disconnection notices to residential customers for the entirety of the stay-at-home order.

Additionally, the COVID-19 Energy Assistance Program is available for residential, small business, and registered charity customers who have overdue amounts on their electricity or gas bills as a result of the pandemic, complementing support for electric bills introduced during COVID-19, and the fixed COVID-19 hydro rate that helped stabilize costs.

Those who meet these criteria are eligible for credits up to a maximum of $750 for residential customers and $1,500 for small businesses and charities, alongside earlier moves to set an off-peak price to ease costs.

 

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P.E.I. government exploring ways for communities to generate their own electricity

P.E.I. Community Energy Independence empowers local microgrids through renewable generation, battery storage, and legislative reform, enabling community-owned power, stable electricity rates, and grid-friendly distributed generation across Island communities with wind, biomass, and net metering models.

 

Key Points

A program enabling communities to generate and store renewable power under supportive laws and grid-friendly models.

✅ Legislative review of Electric Power and Renewable Energy Acts

✅ Community microgrids with wind, biomass, and battery storage

✅ Grid integration without raising rates via Maritime Electric

 

The P.E.I. government is taking steps to review energy legislation and explore new options when it comes to generating power across Island communities.

Energy Minister Steven Myers said one of those options will be identifying ways for Island communities to generate their own energy, aligning with a federal electrification study now examining how electricity can reduce or eliminate fossil fuels. 

He said the move would provide energy independence, create jobs and economic development, and save the communities on their energy bills, as seen with an electricity bill credit in Newfoundland that eased costs for consumers.

But the move will require sweeping legislative changes, that may include the merging of the Electric Power Act and the Renewable Energy Act, similar to an electricity market overhaul in Connecticut seen in other jurisdictions.  

Myers said creating energy independence should ensure a steady supply of electricity while also ensuring costs remain reasonable for P.E.I. residents, even as a Nova Scotia electricity rate hike highlights regional cost pressures.   

"We have communities that are looking to generate their own electricity for their own needs," said Myers, adding the province will not dictate what energy sources communities can invest in. 

He also said the province wants to find new community-based models that will complement existing services.

"How do we do that in a way that we don't impact the grid, that we don't impact the service that Maritime Electric is delivering, mindful of a seasonal rate backlash in New Brunswick that illustrates consumer concerns, that we don't drive up the rates for all other Islanders."

Last fall, a group of P.E.I. MLAs traveled to Samsø, a small Danish island, where they learned about renewable and sustainable energy systems being used there.

The province is looking at storage options so it can store power generated during the day to be used in the evening when electricity use is at its highest. (CBC)
Samsø produces 100 per cent of its electricity from wind and biomass, and utilities like HECO meeting renewable goals early show how quickly transitions can occur. The P.E.I. government said the Island produces 25 per cent of its electricity from wind. 

Following the trip, Myers said he was impressed by the control the island had over its energy production and would like to see if a similar model could work on P.E.I. 

Myers said the legislative review will also look at different ways to store energy on the Island. 

He said that will allow communities to sell that excess energy into the provincial electricity grid, and those revenues could be redirected into that community's priorities. 

'For the survival and the future of their community'
"This is kind of a model that we had suggested that would be in place that would allow people in their own community to produce a revenue stream for themselves that they could then turn into projects like rinks, or parks, or tennis courts or whatever it is that community thinks is the most important thing for the survival and the future of their community," said Myers. 

Energy Minister Steven Myers says creating energy independence could create a steady supply of electricity while also ensuring costs remain reasonable for P.E.I. residents. (Randy McAndrew/CBC)
The province said Maritime Electric, Summerside Electric and the P.E.I. Energy Corporation will be involved in the review, recognizing that a Nova Scotia ruling on rate-setting powers underscores regulatory limits 

Government also wants to hear from Islanders and will be accepting written submissions beginning Monday. Myers said the province is also planning to host public consultations, but because of COVID-19, those will be held virtually in mid-June.

Myers calls this a major move, one that will take time. He said he doesn't expect the legislation to be made public until the spring of 2021.

"I want to make sure we take our time and do the proper consultation."

 

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