EPA moves to regulate industrial greenhouse gases

By Associated Press


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The Environmental Protection Agency moved to more tightly control air pollution from large power plants, factories and oil refineries, a step to limit emissions widely blamed for global warming.

The EPA said it is completing a rule requiring large polluters to reduce the amounts of carbon dioxide and other greenhouse gases that they release into the air. Those emissions can boost many allergens and worsen smog, which can trigger asthma attacks and other respiratory ailments.

The rule would require companies to install better technology and improve energy efficiency whenever they build, or significantly modify, a plant.

EPA Administrator Lisa Jackson said the rule applies only to large polluters such as power plants, refineries and cement production facilities that collectively are responsible for 70 percent of greenhouse gas emissions from stationary sources in the United States.

Jackson said the rule sets commonsense standards that will clean the air and protect public health, while avoiding burdensome regulations that could harm farms and small and medium-sized businesses.

"There is no denying our responsibility to protect the planet for our children and grandchildren," she said in a statement. "It's long past time we unleashed our American ingenuity and started building the efficient, prosperous clean energy economy of the future."

The EPA announcement comes a day after an energy and climate bill was introduced in the Senate that seeks to accomplish many of the same goals. But EPA spokesman Brendan Gilfillan denied any connection, saying "rules are ready when they are ready."

The pollution rule will take effect in January, when industrial facilities that already obtain Clean Air Act permits for other pollutants will be required to obtain permits for greenhouse gases, if they increase those emissions by at least 75,000 tons per year.

Starting in July 2011, the rule would apply to any existing plant that emits at least 75,000 tons of greenhouse gases a year, or any new plant that emits 100,000 tons per year.

Emissions of 75,000 tons of carbon dioxide are equivalent to the annual emissions from 13,000 passenger vehicles, or the electricity use of about 8,200 homes per year, the EPA said.

The rule comes as Sens. John Kerry, D-Mass., and Joe Lieberman, I-Conn., made public a long-delayed bill aimed at curtailing greenhouse gas emissions. The bill would set a first-ever price on carbon dioxide emissions produced by coal-fired power plants and other large polluters.

The legislation aims to cut emissions of carbon dioxide and other heat-trapping greenhouse gases by 17 percent by 2020 and by more than 80 percent by 2050. Both targets are measured against 2005 levels and are the same as those set by a House bill approved last year.

The Obama administration has long said it would prefer that Congress pass a bill to cut greenhouse gas emissions but has used the threat of EPA regulation to push lawmakers in states heavily dependent on fossil fuels to support the climate bill.

Many large utilities and other energy companies have said they want Congress to act, believing they would be in a better bargaining position with Congress than in regulations issued by the EPA.

Even so, the energy bill faces a steep hill in the Senate. No Republican has signed on as a co-sponsor. Sen. Lindsey Graham, R-S.C., who had been working with Kerry and Lieberman, withdrew his support last week, saying it is impossible to pass the legislation in the current political climate.

The rule substantially raises the threshold amount of pollution required before greenhouse gas permits are needed. A proposal announced last September would have required permits for facilities that emit 25,000 tons per year.

Gina McCarthy, an assistant EPA administrator, said the change was made in response to complaints that the earlier proposal would have affected many small and medium-sized businesses, and even large apartment buildings. Such limits "clearly were not appropriate," she said.

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How Ukraine Unplugged from Russia and Joined Europe's Power Grid with Unprecedented Speed

Ukraine-ENTSO-E Grid Synchronization links Ukraine and Moldova to the European grid via secure interconnection, matching frequency for stability, resilience, and energy security, enabling cross-border support, islanding recovery, and coordinated load balancing during wartime disruptions.

 

Key Points

Rapid alignment of Ukraine and Moldova into the European grid to enable secure interconnection and system stability.

✅ Matches 50 Hz frequency across interconnected systems

✅ Enables cross-border support and electricity trading

✅ Improves resilience, stability, and energy security

 

On February 24 Ukraine’s electric grid operator disconnected the country’s power system from the larger Russian-operated network to which it had always been linked. The long-planned disconnection was meant to be a 72-hour trial proving that Ukraine could operate on its own and to protect electricity supply before winter as contingencies were tested. The test was a requirement for eventually linking with the European grid, which Ukraine had been working toward since 2017. But four hours after the exercise started, Russia invaded.

Ukraine’s connection to Europe—which was not supposed to occur until 2023—became urgent, and engineers aimed to safely achieve it in just a matter of weeks. On March 16 they reached the key milestone of synchronizing the two systems. It was “a year’s work in two weeks,” according to a statement by Kadri Simson, the European Union commissioner for energy. That is unusual in this field. “For [power grid operators] to move this quickly and with such agility is unprecedented,” says Paul Deane, an energy policy researcher at the University College Cork in Ireland. “No power system has ever synchronized this quickly before.”

Ukraine initiated the process of joining Europe’s grid in 2005 and began working toward that goal in earnest in 2017, as did Moldova. It was part of an ongoing effort to align with Europe, as seen in the Baltic states’ disconnection from the Russian grid, and decrease reliance on Russia, which had repeatedly threatened Ukraine’s sovereignty. “Ukraine simply wanted to decouple from Russian dominance in every sense of the word, and the grid is part of that,” says Suriya Jayanti, an Eastern European policy expert and former U.S. diplomat who served as energy chief at the U.S. embassy in Kyiv from 2018 to 2020.

After the late February trial period, Ukrenergo, the Ukrainian grid operator, had intended to temporarily rejoin the system that powers Russia and Belarus. But the Russian invasion made that untenable. “That left Ukraine in isolation mode, which would be incredibly dangerous from a power supply perspective,” Jayanti says. “It means that there’s nowhere for Ukraine to import electricity from. It’s an orphan.” That was a particularly precarious situation given Russian attacks on key energy infrastructure such as the Zaporizhzhia nuclear power plant and ongoing strikes on Ukraine’s power grid that posed continuing risks. (According to Jayanti, Ukraine’s grid was ultimately able to run alone for as long as it did because power demand dropped by about a third as Ukrainians fled the country.)

Three days after the invasion, Ukrenergo sent a letter to the European Network of Transmission System Operators for Electricity (ENTSO-E) requesting authorization to connect to the European grid early. Moldelectrica, the Moldovan operator, made the same request the following day. While European operators wanted to support Ukraine, they had to protect their own grids, amid renewed focus on protecting the U.S. power grid from Russian hacking, so the emergency connection process had to be done carefully. “Utilities and system operators are notoriously risk-averse because the job is to keep the lights on, to keep everyone safe,” says Laura Mehigan, an energy researcher at University College Cork.

An electric grid is a network of power-generating sources and transmission infrastructure that produces electricity and carries it from places such as power plants, wind farms and solar arrays to houses, hospitals and public transit systems. “You can’t just experiment with a power system and hope that it works,” Deane says. Getting power where it is it needed when it is needed is an intricate process, and there is little room for error, as incidents involving Russian hackers targeting U.S. utilities have highlighted for operators worldwide.

Crucial to this mission is grid interconnection. Linked systems can share electricity across vast areas, often using HVDC technology, so that a surplus of energy generated in one location can meet demand in another. “More interconnection means we can move power around more quickly, more efficiently, more cost effectively and take advantage of low-carbon or zero-carbon power sources,” says James Glynn, a senior research scholar at the Center on Global Energy Policy at Columbia University. But connecting these massive networks with many moving parts is no small order.

One of the primary challenges of interconnecting grids is synchronizing them, which is what Ukrenergo, Moldelectrica and ENTSO-E accomplished last week. Synchronization is essential for sharing electricity. The task involves aligning the frequencies of every energy-generation facility in the connecting systems. Frequency is like the heartbeat of the electric grid. Across Europe, energy-generating turbines spin 50 times per second in near-perfect unison, and when disputes disrupt that balance, slow clocks across Europe can result, reminding operators of the stakes. For Ukraine and Moldova to join in, their systems had to be adjusted to match that rhythm. “We can’t stop the power system for an hour and then try to synchronize,” Deane says. “This has to be done while the system is operating.” It is like jumping onto a moving train or a spinning ride at the playground: the train or ride is not stopping, so you had better time the jump perfectly.

 

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Tunisia moves ahead with smart electricity grid

Tunisia Smart Grid Project advances with an AFD loan as STEG deploys smart meters in Sfax, upgrades grid infrastructure, boosts energy efficiency, curbs losses, and integrates renewable energy through digitalization and advanced communication systems.

 

Key Points

A national program funded by an AFD $131.7M loan to modernize STEG, deploy smart meters, and integrate renewable energy.

✅ 430,000 smart meters in Sfax during phase one

✅ 20-year AFD loan with 7-year grace period

✅ Cuts losses, improves efficiency, enables renewables

 

The Tunisian parliament has approved taking a $131.7 million loan from the French Development Agency for the implementation of a smart grid project.

Parliament passed legislation regarding the 400 million dinar ($131.7 million) loan plus a grant of $1.1 million.

The loan, to be repaid over 20 years with a grace period of up to 7 years, is part of the Tunisian government’s efforts to establish a strategy of energy switching aimed at reducing costs and enhancing operational efficiency.

The move to the smart grid had been postponed after the Tunisian Company of Electricity and Gas (STEG) announced in March 2017 that implementation of the first phase of the project would begin in early 2018 and cover the entire country by 2023.

STEG was to have received funding some time ago. Last year at the Africa Smart Grid Summit in Tunis, the company said it would initiate an international tender during the first quarter of 2019 to start the project.

The French funding is to be allocated to implementation of the first phase only, which will involve development of control and communication stations and the improvement of infrastructure, where regulatory outcomes such as the Hydro One T&D rates decision can influence investment planning in comparable markets.

It includes installation of 430,000 “intelligent” metres over three years in Sfax governorate in southern Tunisia. The second phase of the project is planned to extend the programme to the rest of the country.

Smart metres to be installed in homes and businesses in Sfax account for about 10% of the total number of metres to be deployed in Tunisia.

At the beginning of 2017, the Industrial Company of Metallic Articles (SIAM), a Tunisian industrial electrical equipment and machinery company, signed an agreement with Huawei for the Chinese company to supply smart electricity metres. The value of the deal was not disclosed.

The smart grid is designed to reduce power waste, reduce the number of unpaid bills, prevent consumer fraud such as power theft in India across distribution networks, improve the ecosystem and increase competitiveness in the electricity sector.

Experts said the main difference between the traditional and smart grids is the adoption of advanced infrastructure for measuring electricity consumption and for communication between the power plant and consumers. The data exchange allows power plants to coordinate electricity production with actual demand.

STEG previously indicated that it had implemented measures to ensure the transition to the smart grid, especially since digitalisation is playing an important role in the energy sector.

The project, which translates Tunisia’s energy plans in the form of a partnership between the public and private sectors, aims at reaching 30% of the country’s electricity need from renewable sources by 2025, even as entities like the TVA face climate goals scrutiny that can affect electricity rates in other markets.

The development of the smart grid will allow STEG to monitor consumption patterns, detect abuses and remotely monitor the grid’s power supply, at a time when regulators have questioned UK network profits to spur efficiency, underscoring the value of transparency.

“The smart grid will change the face of the energy system towards the use of renewable energies,” said Tunisian Industry Minister Slim Feriani. At the forum on alternative energies, he pointed out that energy sector digitisation requires investments in technology and a change in the consumption mentality, as new entrants consider roles like Tesla electricity retailer plans in advanced markets.

Official data indicate that Tunisia’s energy deficit accounts for one-third of the country’s annual trade deficit, which reached record levels of more than $6 billion last year.

STEG, whose debts have reached $329 million over the past eight years, a situation resembling Manitoba Hydro debt pressures in Canada, has not disclosed when and how funding would be secured for the completion of the second phase. The company insists it is working to prevent further losses and to collect its unpaid bills.

STEG CEO Moncef Harrabi, earlier this year, said: “The current situation of the company has forced us to take immediate action to reduce the worsening of the crisis and stop the financial bleeding caused by losses.”

He said the company had repeatedly asked the government to pay subsidy instalments due to the company and to enact binding decisions to force government institutions and departments to pay electricity bills, while elsewhere measures like Thailand power bill cuts have been used to support consumers.

The Tunisian government has yet to disburse the subsidy instalments due STEG for 2018 and 2019, which amount to $658 million. STEG also imports natural gas from Algeria for its power plants at a cost of $1.1 billion a year.

 

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New Mexico Could Reap $30 Billion Driving on Electricity

New Mexico EV Benefits highlight cheaper fuel, lower maintenance, cleaner air, and smarter charging, cutting utility bills, reducing NOx and carbon emissions, and leveraging incentives and renewable energy to accelerate EV adoption statewide.

 

Key Points

New Mexico EV Benefits are the cost, grid, and emissions gains from EV adoption and optimized off-peak charging.

✅ Electricity near $1.11 per gallon equivalent cuts fueling costs

✅ Fewer moving parts mean less maintenance and lifecycle costs

✅ Off-peak charging reduces utility bills and grid emissions

 

What would happen if New Mexicans ditched gasoline and started to drive on cleaner, cheaper electricity? A new report from MJ Bradley & Associates, commissioned by NRDC and Southwest Energy Efficiency Project, answers that question, demonstrating that New Mexico could realize $30 billion in avoided expenditures on gasoline and maintenance, reduced utility bills, and environmental benefits by 2050. The state is currently considering legislation to jump-start that transition by providing consumers incentives to support electric vehicle (EV) purchases and the installation of charging stations, drawing on examples like Nevada's clean-vehicle push to accelerate deployment, a policy that would require a few million dollars in lost tax revenue. The report shows an investment of this kind could yield tens of billions of dollars in net benefits.


$20 Billion in Driver Savings

EVs save families money because driving on electricity in New Mexico is the cost-equivalent of driving on $1.11 per gallon gasoline. Furthermore, EVs have fewer moving parts and less required maintenance—no oil changes, no transmissions, no mufflers, no timing belts, etc. That means that tackling the nation’s largest source of carbon pollution, transportation, could save New Mexicans over $20 billion by 2050 because EVs are cheaper to charge and maintain than gas powered cars, and an EV boom benefits all customers through lower rates.

Those are savings New Mexico can bank on because the price of electricity is significantly cheaper than the price of gasoline and also inherently more stable. Electricity is made from a diverse supply of domestic and increasingly clean resources, and 2021 electricity lessons continue to inform grid planning today. Unlike the volatile world oil market, New Mexico’s electric sector is regulated by the state’s utility commission. Adjusted for inflation, the price of electricity has been steady around the dollar-a-gallon equivalent mark in New Mexico for the last 20 years, while gas prices jump up or down radically and unpredictably.

$4.8 Billion in Reduced Electric Bills

While some warn that electric cars will challenge state power grids, New Mexico can charge millions of EVs without the need to make significant investments in the electric grid. This is because EVs can be charged when the grid is underutilized and renewable energy is abundant, like when people are sleeping overnight when wind energy generation often peaks. And the billions of dollars in new utility revenue from EV charging in excess of associated costs will be automatically returned to utility customers per an accounting mechanism that is already in state law that requires downward adjustment of rates when sales increase. Accordingly, widespread EV adoption could reduce every utility customer’s electric bill.

Thankfully, New Mexico’s electric industry is already acting to ensure utility customers in the state realize those benefits sooner rather than later. The state’s rural electric cooperatives have proposed an ambitious plan to leverage funds available as a result of the Volkswagen diesel scandal to build a state-wide public fast charging network that mirrors progress as Arizona goes EV across the Southwest. Additionally, New Mexico’s investor-owned utilities will soon propose transportation electrification investments as required by legislation NRDC supported last year that Governor Lujan Grisham signed into law.

$4.8 Billion in Societal Benefits from Reduced Pollution

The report estimates that widespread EV adoption would dramatically reduce emissions of greenhouse gases from passenger vehicles in New Mexico, and also cut emissions of NOx, a local pollutant that threatens the health off all New Mexicans, especially children and people with respiratory conditions. The report finds growing the state’s EV market to meet New Mexico’s long-term environmental goals would yield $4.8 billion in societal benefits.

The Bottom Line: New Mexico Should Act Now to Accelerate its EV Market

Adding it all up, that’s more than $30 billion in potential benefits to New Mexico by 2050. Here’s the catch: as of June 2019, there were only 2,500 EVs registered in New Mexico, which means the state needs to accelerate the EV market, as the American EV boom ramps up nationally, to capture those billions of dollars in potential benefits. Thankfully, with second generation, longer range, affordable EVs now available, the market is well positioned to expand rapidly as the state moves to adopt Clean Car Standards that will ensure EVs are available for purchase in the state.

Getting it right

New Mexico has enormous amounts to gain from a small investment in incentives that support EV adoption now. For that investment to pay off, it needs to send a clear and unambiguous signal. Unfortunately, the same legislation that would establish tax credits to increase consumer access to electric vehicles in New Mexico was recently amended so it would not be helpful for 80 percent of consumers who lease, instead of buying EVs. And it would penalize EV drivers at the same time—with a $100 annual increase in registration fees, even as Texas adds a $200 EV fee under a similar rationale, to make up for lost gas tax revenue. That’s significantly more than what drivers of new gasoline vehicles pay annually in gas taxes in the state. Consumer Reports recently analyzed the growing trend to unfairly penalize electric cars via disproportionately high registration fees. In doing so, it estimated that the “maximum justifiable fee” to replace gas tax revenue in New Mexico would be $53. Anything higher will only slow or stop benefits New Mexico can attain from moving to cleaner cars.

To be clear, everyone should pay their fair share to maintain the transportation system, but EVs are not the problem when it comes to lost gas tax revenue. We need a comprehensive solution that addresses the real sources of transportation revenue loss while not undermining efforts to reduce dependence on gasoline. Thankfully, that can be done. For more, see A Simple Way to Fix the Gas Tax Forever.

 

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Working From Home Will Drive Up Electricity Bills for Consumers

Remote Work Energy Costs are rising as home offices and telecommuting boost electricity bills; utilities, broadband usage, and COVID-19-driven stay-at-home policies affect productivity, consumption patterns, and household budgets across the U.K. and Europe.

 

Key Points

Remote Work Energy Costs are increased household electricity and utility expenses from telecommuting and home office use.

✅ WFH shifts energy load from offices to households.

✅ Higher device, lighting, and heating/cooling usage drives bills.

✅ Broadband access gaps limit remote work equity.

 

Household electricity bills are set to soar, with rising residential electricity use tied to the millions of people now working at home to avoid catching the coronavirus.

Running laptops and other home appliances will cost consumers an extra 52 million pounds ($60 million) each week in the U.K., according to a study from Uswitch, a website that helps consumers compare the energy prices that utilities charge.

For each home-bound household, the pain to the pocketbook may be about 195 pounds per year extra, even as some utilities pursue pandemic cost-cutting to manage financial pressures.

The rise in price for households comes even as overall demand is falling rapidly in Europe, with wide swaths of the economy shut down to keep workers from gathering in one place, and the U.S. grid overseer issuing warnings about potential pandemic impacts on operations.

People stuck at home will plug in computers, lights and appliances when they’d normally be at the office, increasing their consumption.

With the Canadian government declaring a state of emergency due to the coronavirus, companies are enabling work-from-home structures to keep business running and help employees follow social distancing guidelines, and some utilities have even considered housing critical staff on site to maintain operations. However, working remotely has been on the rise for a while.

“The coronavirus is going to be a tipping point. We plodded along at about 10% growth a year for the last 10 years, but I foresee that this is going to really accelerate the trend,” Kate Lister, president of Global Workplace Analytics.

Gallup’s State of the Workplace 2017 study found that 43% of employees work remotely with some frequency. Research indicates that in a five-day workweek, working remotely for two to three days is the most productive. That gives the employee two to three days of meetings, collaboration and interaction, with the opportunity to just focus on the work for the other half of the week.

Remote work seems like a logical precaution for many companies that employ people in the digital economy, even as some federal agencies sparked debate with an EPA telework policy during the pandemic. However, not all Americans have access to the internet at home, and many work in industries that require in-person work.

According to the Pew Research Center, roughly three-quarters of American adults have broadband internet service at home. However, the study found that racial minorities, older adults, rural residents and people with lower levels of education and income are less likely to have broadband service at home. In addition, 1 in 5 American adults access the internet only through their smartphone and do not have traditional broadband access. 

Full-time employees are four times more likely to have remote work options than part-time employees. A typical remote worker is college-educated, at least 45 years old and earns an annual salary of $58,000 while working for a company with more than 100 employees, according to Global Workplace Analytics, and in Canada there is growing interest in electricity-sector careers among younger workers. 

New York, California and other states have enacted strict policies for people to remain at home during the coronavirus pandemic, which could change the future of work, and Canadian provinces such as Saskatchewan have documented how the crisis has reshaped local economies across sectors.

“I don’t think we’ll go back to the same way we used to operate,” Jennifer Christie, chief HR officer at Twitter, told CNBC. “I really don’t.”

 

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Solar power growth, jobs decline during pandemic

COVID-19 Solar Job Losses are erasing five years of workforce growth, SEIA reports, with U.S. installations and capacity down, layoffs accelerating, 3 GW expected in Q2, and policy support key for economic recovery.

 

Key Points

COVID-19 Solar Job Losses describe the pandemic-driven decline in U.S. solar employment, installations, and capacity.

✅ SEIA reports a 38% national drop in solar jobs

✅ Q2 installs projected at 3 GW, below forecasts

✅ Layoffs outpace U.S. economy without swift policy aid

 

Job losses associated with the COVID-19 crisis have wiped out the past five years of workforce growth in the solar energy field, according to a new industry analysis.

The expected June 2020 solar workforce of 188,000 people across the United States is 114,000 below the pre-pandemic forecast of 302,000 workers, a shortfall tied to the solar construction slowdown according to the Solar Energy Industries Association, which said in a statement Monday that the solar industry is now losing jobs at a faster rate than the U.S. economy.

In Massachusetts, the loss of 4,284 solar jobs represents a 52 percent decline from previous projections, according to the association’s analysis.

The national 38 percent drop in solar jobs coincides with a 37 percent decrease in expected solar installations in the second quarter of 2020, and similar pressures have put wind investments at risk across the sector, the association stated. The U.S. is now on track to install 3 gigawatts of new capacity this quarter, though subsequent forecasts anticipated solar and storage growth as investments returned, and the association said the decrease from the expected capacity is equivalent to the electricity needed to power 288,000 homes.

“Thousands of solar workers are being laid off each week, but with swift action from Congress, we know that solar can be a crucial part of our economic recovery,” with proposals such as the Biden solar plan offering a potential policy path, SEIA President and CEO Abigail Ross Hopper said in a statement, as recent analyses point to US solar and wind growth under supportive policies.

Subsequent data showed record U.S. panel shipments as the market rebounded.

 

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Egypt Plans Power Link to Saudis in $1.6 Billion Project

Egypt-Saudi Electricity Interconnection enables cross-border power trading, 3,000 MW capacity, and peak-demand balancing across the Middle East, boosting grid stability, reliability, and energy security through an advanced electricity network, interconnector infrastructure, and GCC grid integration.

 

Key Points

A 3,000 MW grid link letting Egypt and Saudi Arabia trade power, balance peak demand, and boost regional reliability.

✅ $1.6B project; Egypt invests ~$600M; 2-year construction timeline

✅ 3,000 MW capacity; peak-load shifting; cross-border reliability

✅ Links GCC grid; complements Jordan and Libya interconnectors

 

Egypt will connect its electricity network to Saudi Arabia, joining a system in the Middle East that has allowed neighbors to share power, similar to the Scotland-England subsea project that will bring renewable power south.

The link will cost about $1.6 billion, with Egypt paying about $600 million, Egypt’s Electricity Minister Mohamed Shaker said Monday at a conference in Cairo, as the country pursues a smart grid transformation to modernize its network. Contracts to build the network will be signed in March or April, and construction is expected to take about two years, he said. In times of surplus, Egypt can export electricity and then import power during shortages.

"It will enable us to benefit from the difference in peak consumption,” Shaker said. “The reliability of the network will also increase.”

Transmissions of electricity across borders in the Gulf became possible in 2009, when a power grid connected Qatar, Kuwait, Saudi Arabia and Bahrain, a dynamic also seen when Ukraine joined Europe's grid under emergency conditions. The aim of the grid is to ensure that member countries of the Gulf Cooperation Council can import power in an emergency. Egypt, which is not in the GCC, may have been able to avert an electricity shortage it suffered in 2014 if the link with Saudi Arabia existed at the time, Shaker said.

The link with Saudi Arabia should have a capacity of 3,000 megawatts, he said. Egypt has a 450-megawatt link with Jordan and one with Libya at 200 megawatts, the minister said. Egypt will seek to use its strategic location to connect power grids in Asia, where the Philippines power grid efforts are raising standards, and elsewhere in Africa, he said.

In 2009, a power grid linked Qatar, Kuwait, Saudi Arabia and Bahrain, allowing the GCC states to transmit electricity across borders, much like proposals for a western Canadian grid that aim to improve regional reliability. 

 

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