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EV Grid Capacity Management shows how smart charging, load balancing, and off-peak pricing align with utility demand response, DC fast charging networks, and renewable integration to keep national electricity infrastructure reliable as EV adoption scales

Key Points

EV Grid Capacity Management schedules charging and balances load to keep EV demand within utility capacity.

✅ Off-peak pricing and time-of-use tariffs shift charging demand.

✅ Smart chargers enable demand response and local load balancing.

✅ Gradual EV adoption allows utilities to plan upgrades efficiently.

One of the most frequent concerns you will see from electric vehicle haters is that the electricity grid can’t possibly cope with all cars becoming EVs, or that EVs will crash the grid entirely. However, they haven’t done the math properly. The grids in most developed nations will be just fine, so long as the demand is properly management. Here’s how.

The biggest mistake the social media keyboard warriors make is the very strange assumption that all cars could be charging at once. In the UK, there are currently 32,697,408 cars according to the UK Department of Transport. The UK national grid had a capacity of 75.8GW in 2020. If all the cars in the UK were EVs and charging at the same time at 7kW (the typical home charger rate), they would need 229GW – three times the UK grid capacity. If they were all charging at 50kW (a common public DC charger rate), they would need 1.6TW – 21.5 times the UK grid capacity. That sounds unworkable, and this is usually the kind of thinking behind those who claim the UK grid can't cope with EVs.

What they don’t seem to realize is that the chances of every single car charging all at once are infinitesimally low. Their arguments seem to assume that nobody ever drives their car, and just charges it all the time. If you look at averages, the absurdity of this position becomes particularly clear. The distance each UK car travels per year has been slowly dropping, and was 7,400 miles on average in 2019, again according to the UK Department of Transport. An EV will do somewhere between 2.5 and 4.5 miles per kWh on average, so let’s go in the middle and say 3.5 miles. In other words, each car will consume an average of 2,114kWh per year. Multiply that by the number of cars, and you get 69.1TWh. But the UK national grid produced 323TWh of power in 2019, so that is only 21.4% of the energy it produced for the year. Before you argue that’s still a problem, the UK grid produced 402TWh in 2005, which is more than the 2019 figure plus charging all the EVs in the UK put together. The capacity is there, and energy storage can help manage EV-driven peaks as well.

Let’s do the same calculation for the USA, where an EV boom is about to begin and planning matters. In 2020, there were 286.9 million cars registered in America. In 2020, while the US grid had 1,117.5TW of utility electricity capacity and 27.7GW of solar, according to the US Energy Information Administration. If all the cars were EVs charging at 7kW, they would need 2,008.3TW – nearly twice the grid capacity. If they charged at 50kW, they would need 14,345TW – 12.8 times the capacity.

However, in 2020, the US grid generated 4,007TWh of electricity. Americans drive further on average than Brits – 13,500 miles per year, according to the US Department of Transport’s Federal Highway Administration. That means an American car, if it were an EV, would need 3,857kWh per year, assuming the average efficiency figures above. If all US cars were EVs, they would need a total of 1,106.6TWh, which is 27.6% of what the American grid produced in 2020. US electricity consumption hasn’t shrunk in the same way since 2005 as it has in the UK, but it is clearly not unfeasible for all American cars to be EVs. The US grid could cope too, even as state power grids face challenges during the transition.

After all, the transition to electric isn’t going to happen overnight. The sales of EVs are growing fast, with for example more plug-ins sold in the UK in 2021 so far than the whole of the previous decade (2010-19) put together. Battery-electric vehicles are closing in on 10% of the market in the UK, and they were already 77.5% of new cars sold in Norway in September 2021. But that is new cars, leaving the vast majority of cars on the road fossil fuel powered. A gradual introduction is essential, too, because an overnight switchover would require a massive ramp up in charge point installation, particularly devices for people who don’t have the luxury of home charging. This will require considerable investment, but could be served by lots of chargers on street lamps, which allegedly only cost £1,000 ($1,300) each to install, usually with no need for extra wiring.

This would be a perfectly viable way to provide charging for most people. For example, as I write this article, my own EV is attached to a lamppost down the street from my house. It is receiving 5.5kW costing 24p (32 cents) per kWh through SimpleSocket, a service run by Ubitricity (now owned by Shell) and installed by my local London council, Barnet. I plugged in at 11am and by 7.30pm, my car (which was on about 28% when I started) will have around 275 miles of range – enough for a couple more weeks. It will have cost me around £12 ($16) – way less than a tank of fossil fuel. It was a super-easy process involving the scanning of a QR code and entering of a credit card, very similar to many parking systems nowadays. If most lampposts had one of these charging plugs, not having off-street parking would be no problem at all for owning an EV.

With most EVs having a range of at least 200 miles these days, and the average mileage per day being 20 miles in the UK (the 7,400-mile annual figure divided by 365 days) or 37 miles in the USA, EVs won’t need charging more than once a week or even every week or two. On average, therefore, the grids in most developed nations will be fine. The important consideration is to balance the load, because if too many EVs are charging at once, there could be a problem, and some regions like California are looking to EVs for grid stability as part of the solution. This will be a matter of incentivizing charging during off-peak times such as at night, or making peak charging more expensive. It might also be necessary to have the option to reduce charging power rates locally, while providing the ability to prioritize where necessary – such as emergency services workers. But the problem is one of logistics, not impossibility.

There will be grids around the world that are not in such a good place for an EV revolution, at least not yet, and some critics argue that policies like Canada's 2035 EV mandate are unrealistic. But to argue that widespread EV adoption will be an insurmountable catastrophe for electricity supply in developed nations is just plain wrong. So long as the supply is managed correctly to make use of spare capacity when it’s available as much as possible, the grids will cope just fine.

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Canada Manufacturing Policy prioritizes affordable energy, trims carbon taxes, aligns with Buy America, and supports the resource sector, PPE and plastics supply, nearshoring, and resilient supply chains amid COVID-19, correcting costly green energy policies.

Key Points

A policy to boost industry with affordable energy, lower carbon taxes, resource ties, and aligned U.S. trade.

✅ Cuts energy costs and carbon tax burdens for competitiveness

✅ Rebuilds resource-sector linkages and domestic supply chains

✅ Seeks Buy America relief and clarity on plastics regulation

By Jocelyn Bamford

Since its inception in 2017, the Coalition of Concerned Manufacturers and Businesses has warned all levels of government that there would be catastrophic effects if policies that drove both the manufacturing and natural resources sectors out of the country were adopted.

The very origins of our coalition was in the fight for a competitive landscape in Ontario, a cornerstone of which is affordable energy and sounding the alarm that the Green Energy Policy in Ontario pushed many manufacturers out of the province.

The Green Energy Policy made electricity in Ontario four times the average North American rate. These unjust prices were largely there to subsidize the construction of expensive and inefficient wind and solar energy infrastructure, even as cleaning up Canada's grid is cited as critical to meeting climate pledges.

My company’s November hydro bill was $55,000 and $36,500 of that was the so-called global adjustment charge, the name given to these green energy costs.

Unaffordable electricity, illustrated by higher Alberta power costs in recent years, coupled with ever-more burdensome carbon taxes, have pushed Canadian manufacturing into the open arms of other countries that see the importance of affordable energy to attract business.

One can’t help but ask the question: If Canada had policies that attracted and maintained a robust manufacturing sector, would we be in the same situation with a lack of personal protective equipment and medical supplies for our front-line medical workers and our patients during this pandemic?  If our manufacturing sector wasn’t crippled by taxes and regulation, would it be more nimble and able to respond to a national emergency?

It seems that the federal government’s policies are designed to push manufacturing out, stifle our resource sector, and kill the very plastics industry that is so essential to keeping our front-line medical staff, patients, and citizens safe, even as the net-zero race accelerates federally.

As the federal government chased its obsession with a new green economy – a strange obsession given our country’s small contribution to global GHGs – including proposals for a fully renewable grid by 2030 advocated by some leaders, it has been blinded from the real threats to our country, threats that became very, very real with COVID-19.

After the pandemic has passed, the federal government must work to make Canada manufacturing and resource friendly again, recognizing that the IEA net-zero electricity report projects the need for more power. COVID-19 proves that Canada relies on a robust resource economy and manufacturing sector to survive. We need to ensure that we are prepared for future crises like the one we are facing now.

Here are five things our government can do now to meet that end:

1. End all carbon taxes immediately.

2. Create a mandate to bring manufacturing back to Canada through competitive offerings and favourable tax regimes.

3. Recognize the interconnections between the resource sector and manufacturing, including how fossil-fuel workers support the transition across supply chains. Many manufacturers supply parts and pieces to the resource sector, and they rely on affordable energy to compete globally.

4. Stop the current federal government initiative to label plastic as toxic. At a time when the government is appealing to manufacturers to re-tool and produce needed plastic products for the health care sector, labelling plastics as toxic is counterproductive.

5. Work to secure a Canadian exemption to Buy America. This crisis has clearly shown us that dependency on China is dangerous. We must forge closer ties with America and work as a trading block in order to be more self-sufficient.

These are troubling times. Many businesses will not survive.

We need to take back our manufacturing sector.  We need to take back our resource sector.

We need to understand the interconnected nature of these two important segments of our gross domestic production, and opportunities like an Alberta–B.C. grid link to strengthen reliability.
If we do not, in the next pandemic we may find ourselves not only without ventilators, masks and gowns but also without energy to operate our hospitals.

Jocelyn Bamford is a Toronto business executive and President of the Coalition of Concerned Manufacturers and Businesses of Canada

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American-Made Solar Prize Round 3 accelerates DOE-backed solar innovation, empowering entrepreneurs and domestic manufacturing with photovoltaics and grid integration support via National Laboratories, incubators, and investors to validate products, secure funding, and deploy backup power.

Key Points

A DOE challenge fast-tracking solar innovation to market readiness, boosting US manufacturing and grid integration.

✅ $50,000 awards to 20 teams for prototype validation

✅ Access to National Labs, incubators, investors, and mentors

✅ Focus on PV advances and grid integration solutions

The U.S. Department of Energy (DOE) announced the 20 competitors who have been invited to advance to the next phase of the American-Made Solar Prize Round 3, a competition designed to incentivize the nation’s entrepreneurs to strengthen American leadership in solar energy innovation and domestic manufacturing, a key front in the clean energy race today.

The American-Made Solar Prize is designed to help more American entrepreneurs thrive in the competitive global energy market. Each round of the prize brings new technologies to pre-commercial readiness in less than a year, ensuring new ideas enter the marketplace. As part of the competition, teams will have access to a network of DOE National Laboratories, technology incubators and accelerators, and related DOE efforts like next-generation building upgrades, venture capital firms, angel investors, and industry. This American-Made Network will help these competitors raise private funding, validate early-stage products, or test technologies in the field.

Each team will receive a $50,000 cash prize and become eligible to compete in the next phase of the competition. Through a rigorous evaluation process, teams were chosen based on the novelty of their ideas and how their solutions address a critical need of the solar industry. The teams were selected from 120 submissions and represent 11 states. These projects will tackle challenges related to new solar applications, like farming, as well as show how solar can be used to provide backup power when the grid goes down, aided by increasingly affordable batteries now reaching scale. Nine teams will advance solar photovoltaic technologies, and 11 will address challenges related to how solar integrates with the grid. The projects are as follows:

Photovoltaics:

• Durable Antireflective and Self-Cleaning Glass (Pittsburgh, PA)
• Pursuit Solar - More Power, Less Hassle (Denver, NC)
• PV WaRD (San Diego, CA)
• Remotely Deployed Solar Arrays (Charlottesville, VA)
• Robotics Changing the Landscape for Solar Farms (San Antonio, TX)
• TrackerSled (Chicago, IL)
• Transparent Polymer Barrier Films for PV (Bristol, PA)
• Solar for Snow (Duluth, MN)
• SolarWall Power Tower (Buffalo, NY)

Systems Integration:

• Affordable Local Solar Storage via Utility Virtual Power Plants (Parker, TX)
• Allbrand Solar Monitor (Detroit, MI)
• Beyond Monitoring – Next Gen Software and Hardware (Atlanta, GA)
• Democratizing Solar with Artificial Intelligence Energy Management (Houston, TX)
• Embedded, Multi-Function Maximum Power Point Tracker for Smart Modules (Las Vegas, NV)
• Evergrid: Keep Solar Flowing When the Grid Is Down (Livermore, CA)
• Inverter Health Scan (San Jose, CA)
• JuiceBox: Integrated Solar Electricity for Americans Transitioning out of Homelessness and Recovering from Natural Disasters (Claremont, CA)
• Low-Cost Parallel-Connected DC Power Optimizer (Blacksburg, VA)
• Powerfly: A Plug-and-Play Solar Monitoring Device (Berkeley, CA)
• Simple-Assembly Storage Kit (San Antonio, TX)

Read the descriptions of the projects to see how they contribute to efforts to improve solar and wind power worldwide.

Over the next six months, these teams will fast-track their efforts to identify, develop, and test disruptive solutions amid record solar and storage growth projected nationwide. During a national demonstration day at Solar Power International in September 2020, a panel of judges will select two final winners who will receive a $500,000 prize. Learn more at the American-Made Solar Prize webpage.

The American-Made Challenges incentivize the nation's entrepreneurs to strengthen American leadership in energy innovation and domestic manufacturing. These new challenges seek to lower the barriers U.S.-based innovators face in reaching manufacturing scale by accelerating the cycles of learning from years to weeks while helping to create partnerships that connect entrepreneurs to the private sector and the network of DOE’s National Laboratories across the nation, alongside recent wind energy awards that complement solar innovation.

Go here to learn how this work aligns with a tenfold solar expansion being discussed nationally.

https://www.energy.gov/eere/solar/solar-energy-technologies-office

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Ontario electricity pricing consultations will gather business input on OEB rate design, Industrial Conservation Initiative, dynamic pricing, global adjustment, and system costs through online feedback and sector-specific in-person sessions province-wide.

Key Points

Consultations gathering business input on rates, programs, and OEB policy to improve fairness and reduce system costs.

✅ Consults on ICI, GA, dynamic pricing structures

✅ Seeks views on OEB C&I rate design changes

✅ In-person sessions across key industrial sectors

The Ontario government has announced plans to hold consultations to seek input from businesses about industrial electricity pricing and programs. This will be done through Ontario's online consultations directory and though in-person sector-specific consultation sessions across the province. The in-person sessions will be held in all areas of Ontario, and will target "key industries," including automotive and the build-out of electric vehicle charging stations infrastructure, forestry, mining, agriculture, steel, manufacturing and chemicals.

On April 1, 2019, the Ontario government published a consultation notice for this process, confirming that it is looking for input on "electricity rate design, existing tax-based incentives, reducing system costs and regulatory and delivery costs," including related proposals such as the hydrogen rate reduction proposal under discussion. The consultation process includes a list of nine questions for respondents (and presumably participants in the in-person sessions) to address. These include questions about:

The benefits of the Industrial Conservation Initiative (described below), including how it could be changed to improve fairness and industrial competitiveness, and how it could complement programs like the Hydrogen Innovation Fund that support industrial innovation.

Dynamic pricing structures that allow for lower rates in return for responding to price signals versus a flat rate structure that potentially costs more, but is more stable and predictable, as Ontario's energy storage expansion accelerates.

Interest in an all-in commodity contract with an electricity retailer, even if it involves a risk premium.

Interested parties are invited to submit their comments before May 31, 2019.

The government's consultation announcement follows recent developments in the Ontario Energy Board's (OEB) review of electricity ratemaking for commercial and industrial customers, and intertie projects such as the Lake Erie Connector that could affect market dynamics.

In December 2018, the OEB published a paper from its Market Surveillance Panel (MSP) examining the Industrial Conservation Initiative (ICI), and potential alternative approaches. The ICI is a program that allows qualifying large industrial customers to base their global adjustment (GA) payments on their consumption during five peak demand hours in a year. Customers who find ways to reduce consumption at those times, perhaps through DERs and enabling energy storage options, will reduce their electricity costs. This shifts GA costs to other customers. The MSP found that the ICI does not fairly allocate costs to those who cause them and/or benefit from them, and recommends that a better approach should be developed.

In February 2019, the OEB released its Staff Report to the Board on Rate Design for Commercial and Industrial Electricity Customers, setting out recommendations for new rate designs for electricity commercial and industrial (C&I) rate classes as Ontario increasingly turns to battery storage to meet rising demand. As described in an earlier post, the Staff Report includes recommendations to: (i) establish a fixed distribution charge for commercial customers with demands under 10 kW; (ii) implement a demand charge (rather than the current volumetric charge) for C&I customers with demands between 10kW and 50kW; and (iii) introduce a "capacity reserve charge" for customers with load displacement generation to replace stand-by charges and provide for recognition of the benefits of this generation on the system. The OEB held a stakeholder information session in mid-March on this initiative, and interested parties are now filing submissions in response to the Staff Report.

Whether and how the OEB's processes will fit together with the government's consultation process remains to be seen.

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Ontario Ultra-Low Overnight Electricity Rates cut costs for shift workers and EV charging, with time-of-use pricing, off-peak savings, on-peak premiums, kilowatt-hour details, and Ontario Energy Board guidance for homes and businesses across participating utilities.

Key Points

Ontario's ultra-low overnight plan: 2.4c/kWh 11pm-7am for EVs, shift workers; higher daytime on-peak pricing.

✅ 2.4c/kWh 11pm-7am; 24c/kWh on-peak 4pm-9pm

✅ Best for EV charging, shift work, night usage

✅ Available provincewide by Nov 1 via local utilities

The Ontario government is introducing a new ultra-low overnight price plan that can benefit shift workers and individuals who charge electric vehicles while they sleep.

Speaking at a news conference on Tuesday, Energy Minister Todd Smith said the new plan could save customers up to $90 a year.

“Consumer preferences are still changing and our government realized there was more we could do, especially as the province continues to have an excess supply of clean electricity at night when province-wide electricity demand is lower,” Smith said, noting a trend underscored by Ottawa's demand decline during the pandemic.

The new rate, which will be available as an opt-in option as of May 1, will be 2.4 cents per kilowatt-hour from 11 p.m. to 7 a.m. Officials say this is 67 per cent lower than the current off-peak rate, which saw a off-peak relief extension during the pandemic.

However, customers should be aware that this plan will mean a higher on-peak rate, as unlike earlier calls to cut peak rates, Hydro One peak charges remained unchanged for self-isolating customers.

The new plan will be offered by Toronto Hydro, London Hydro, Centre Wellington Hydro, Hearst Power, Renfrew Hydro, Wasaga Distribution, and Sioux Lookout Hydro by May. Officials have said this will be expanded to all local distribution companies by Nov. 1.

With the new addition of the “ultra low” pricing, there are now three different electricity plans that Ontarians can choose from. Here is what you have to know about the new hydro options:

TIME OF USE:
Most residential customers, businesses and farms are eligible for these rates, similar to BC Hydro time-of-use proposals in another province, which are divided into off-peak, mid-peak and on-peak hours.

This is what customers will pay as of May 1 according to the Ontario Energy Board, following earlier COVID-19 electricity relief measures that temporarily adjusted rates:

 Off-peak (Weekdays between 7 p.m. and 7 a.m. and on weekends/holidays): 7.4 cents per kilowatt-hour
 Mid-Peak (Weekdays between 7 a.m. and 11 a.m., and between 5 p.m. and 7 p.m.): 10.2 cents per kilowatt-hour
 On-Peak ( Weekdays 11 a.m. to 5 p.m.): 15.1 cents per kilowatt-hour

TIERED RATES
This plan allows customers to get a standard rate depending on how much electricity is used. There are various thresholds per tier, and once a household exceeds that threshold, a higher price applies. Officials say this option may be beneficial for retirees who are home often during the day or those who use less electricity overall.

The tiers change depending on the season. This is what customers will pay as of May 1:

 Residential households that use 600 kilowatts of electricity per month and non-residential businesses that use 750 kilowatts per month: 8.7 cents per kilowatt-hour.
 Residences and businesses that use more than that will pay a flat rate of 10.3 cents per kilowatt-hour

ULTRA-LOW OVERNIGHT RATES
Customers can opt-in to this plan if they use most of their electricity overnight.

This is what customers will pay as of May 1:

•  Between 11 p.m. and 7 a.m.: 2.4 cents per kilowatt-hour
•  Weekends and holidays between 7 a.m. and 11 p.m.: 7.4 cents per kilowatt-hour
•  Mid-Peak (Weekdays between 7 a.m. and 4 p.m., and between 9 p.m. and 11 p.m.): 10.2 cents per kilowatt-hour
•  On-Peak (weekdays between 4 p.m. and 9 p.m.): 24 cents per kilowatt-hour

More information on these plans can be found on the Ontario Energy Board website, alongside stable pricing for industrial and commercial updates from the province.

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BC Hydro Crypto Mining Moratorium pauses high-load connection requests, as BCUC reviews electricity demand, gigawatt-hours and megawatt load forecasts, data center growth, and potential rate impacts on the power grid and industrial customers.

Key Points

A BC order pausing crypto mining connections while BC Hydro and BCUC assess load, grid impacts, and ratepayer risks.

✅ 18-month pause on new high-load crypto connections

✅ 1,403 MW in requests suspended; 273 MW existing or pending

✅ Seeks to manage demand, rates, and grid reliability

In its Nov. 1, 2022 load update briefing note to senior executives of the Crown corporation, BC Hydro shows that the entire large industrial sector accounted for 6,591 gigawatt-hours during the period – one percent less than forecast in the service plan.

BC Hydro censored load statistics about crypto mining, coal mining and chemicals from the briefing note, which was obtained under the freedom of information law and came amid scrutiny over B.C. electricity imports because it feared that disclosure would harm Crown corporation finances and third-party business interests.

Crypto mining requires high-powered computers to run and be cooled around the clock constantly. So much so that cabinet ordered the BC Utilities Commission (BCUC) last December to place an 18-month moratorium on crypto mining connection requests, while other jurisdictions, such as the N.B. Power crypto review, undertook similar pauses to assess impacts.

In a news release, the government said 21 projects seeking 1,403 megawatts were temporarily suspended. The government said that would be enough to power 570,000 homes or 2.1 million electric vehicles for a year.

A report issued by BC Hydro before Christmas said there were already 166 megawatts of power from operational projects at seven sites. Another six projects with 107 megawatts were nearing connection, bringing its total load to 273 megawatts.

Richard McCandless, a retired assistant deputy minister who analyzes the performance of BC Hydro and the Insurance Corp of British Columbia, said China's May 2021 ban on crypto mining had a major ripple effect on those seeking cheap and reliable power.

"When China cracked down, these guys fled to different areas," McCandless said in an interview. "So they took their computers and went somewhere else. Some wound up in B.C."

He said BC Hydro's secrecy about crypto loads appears rooted in the Crown corporation underestimating load demand, even as new generating stations were commissioned to bolster capacity.

"Crypto is up so dramatically; they didn't want to show that," McCandless said. "Maybe they didn't want to be seen as being asleep at the switch."

Indeed, BCUC's April 21 decision on BC Hydro's 2021 revenue forecasts through the 2025 fiscal year included BC Hydro's forecast increase for crypto and data centres of about 100 gigawatt-hours through fiscal 2024 before returning to 2021 levels by 2025. In addition, the BCUC document said that BC Hydro's December 2020 load forecast was lower than the previous one because of project cancellations and updated load requests, amid ongoing nuclear power debate in B.C.

"Given the segment's continued uncertainty and volatility, the forecast assumes these facilities are not long-lived," the BC Hydro application said.

A September 2022 report to the White House titled "Crypto-Assets in the United States" said increased electricity demand from crypto-asset mining could lead to rate increases.

"Crypto-asset mining in upstate New York increased annual household electric bills by [US]$82 and annual small business electric bills by [US]$164, with total net losses from local consumers and businesses estimated to be [US]$179 million from 2016-2018," the report said. The information mentioned Plattsburgh, New York's 18-month moratorium in 2018. Manitoba announced a similar suspension almost a month before B.C.

B.C.'s total core domestic load of 23,666 gigawatt-hours was two percent higher than the service plan amid BC Hydro call for power planning, with commercial and light industrial (9,198 gigawatt-hours) and residential (7,877 gigawatt-hours) being the top two customer segments.

"A cooler spring and warmer summer supported increased loads, as the Western Canada drought strained hydropower production regionally. However, warmer daytime temperatures in September impacted heating more than cooling," said the briefing note.

"Commercial and light industrial consumption benefited from warmer temperatures in August but has also been impacted to a lesser degree by the reduced heating load in the first three weeks of October."

Loads improved relative to 2021, but offices, retail businesses and restaurants remained below pre-pandemic levels. Education, recreation and hotel sectors were in line with pre-pandemic levels. Light industrial sector growth offset the declines.

For heavy industry, pulp and paper electricity use was 15 percent ahead of forecast, but wood manufacturing was 16 percent below forecast. The briefing note said oil and gas grew nine percent relative to the previous year but, alongside ongoing LNG power demand, fell nine percent below the service plan.

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