Regulators challenge electric credit elimination

FERC Grid Resiliency Pricing Opposition underscores industry groups, RTOs, and ISOs rejecting DOE's NOPR, warning against out-of-market subsidies for coal and nuclear, favoring competitive markets, reliability, and true grid resilience.

Key Points

Coalition urging FERC to reject DOE's NOPR subsidies, protecting reliability and competitive power markets.

✅ Industry groups, RTOs, ISOs oppose DOE NOPR

✅ PJM reports sufficient reliability and resilience

✅ Reject out-of-market aid to coal, nuclear

A diverse group of a dozen energy industry associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies today submitted reply comments to the Federal Energy Regulatory Commission (FERC) continuing their opposition to the Department of Energy's (DOE) proposed rulemaking on grid resiliency pricing and electricity pricing changes within competitive markets, in the next step in this FERC proceeding.

Action by FERC, as lawmakers urge movement on aggregated DERs to modernize markets, is expected by December 11.

In these comments, this broad group of energy industry associations notes that most of the comments submitted initially by an unprecedented volume of filers, including grid operators whose markets would be impacted by the proposed rule, urged FERC not to adopt DOE'sproposed rule to provide out-of-market financial support to uneconomic coal and nuclear power plants in the wholesale electricity markets overseen by FERC.

Just a small set of interests - those that would benefit financially from discriminatory pricing that favors coal and nuclear plants - argued in favor of the rule put forward by DOE in its Notice of Proposed Rulemaking, or NOPR, as did coal and business interests in related regulatory debates. But even those interests - termed 'NOPR Beneficiaries' by the energy associations - failed to provide adequate justification for FERC to approve the rule, and their specific alternative proposals for implementing the bailout of these plants were just as flawed as the DOE plan, according to the energy industry associations.

'The joint comments filed today with partners across the energy spectrum reflect the overwhelming majority view that this proposed rulemaking by FERC is unprecedented and unwarranted, said Todd Foley, Senior Vice President, Policy & Government Affairs, American Council on Renewable Energy.

We're hopeful that FERC will rule against an anti-competitive distortion of the electricity marketplace and avoid new unnecessary initiatives that increase power prices for American consumers and businesses.'

In the new reply comments submitted in response to the initial comments filed by hundreds of stakeholders on or before October 23 - the energy industry associations made the following points: Despite hundreds of comments filed, no new information was brought forth to validate the assertion - by DOE or the NOPR Beneficiaries - that an emergency exists that requires accelerated action to prop up certain power plants that are failing in competitive electricity markets: 'The record in this proceeding, including the initial comments, does not support the discriminatory payments proposed' by DOE, state the industry groups.

Nearly all of the initial comments filed in the matter take issue with the DOE NOPR and its claim of imminent threats to the reliability and resilience of the electric power system, despite reports of coal and nuclear disruptions cited by some advocates: 'Of the hundreds of comments filed in response to the DOE NOPR, only a handful purported to provide substantive evidence in support of the proposal. In contrast, an overwhelming majority of initial comments agree that the DOE NOPR fails to substantiate its assertions of an immediate reliability or resiliency need related to the retirement of merchant coal-fired and nuclear generation.'

Grid operators filed comments refuting claims that the potential retirement of coal and nuclear plants which could not compete for economically present immediate or near-term challenges to grid management, even as a coal CEO criticism targeted federal decisions: 'Even the RTOs and ISOs themselves filed comments opposing the DOE NOPR, noting that the proposed cost-of-service payments to preferred generation would disrupt the competitive markets and are neither warranted nor justified.... Most notably, this includes PJM Interconnection, ... the RTO in which most of the units potentially eligible for payments under the DOE NOPR are located. PJM states that its region 'unquestionably is reliable, and its competitive markets have for years secured commitments from capacity resources that well exceed the target reserve margin established to meet [North American Electric Reliability Corp.] requirements.' And PJM analysis has confirmed that the region's generation portfolio is not only reliable, but also resilient.'

The need for NOPR Beneficiaries to offer alternative proposals reflects the weakness of DOE'srule as drafted, but their options for propping up uneconomic power plants are no better, practically or legally: 'Plans put forward by supporters of the power plant bailout 'acknowledge, at least implicitly, that the preferential payment structure proposed in the DOE NOPR is unclear, unworkable, or both. However, the alternatives offered by the NOPR Beneficiaries, are equally flawed both substantively and procedurally, extending well beyond the scope of the DOE NOPR.'

Citing one example, the energy groups note that the detailed plan put forward by utility FirstEnergy Service Co. would provide preferential payments far more costly than those now provided to individual power plants needed for immediate reasons (and given a 'reliability must run' contract, or RMR): 'Compensation provided under [FirstEnergy's proposal] would be significantly expanded beyond RMR precedent, going so far as to include bailing [a qualifying] unit out of debt based on an unsupported assertion that revenues are needed to ensure long-term operation.'

Calling the action FERC would be required to take in adopting the DOE proposal 'unprecedented,' the energy industry associations reiterate their opposition: 'While the undersigned support the goals of a reliable and resilient grid, adoption of ill-considered discriminatory payments contemplated in the DOE NOPR is not supportable - or even appropriate - from a legal or policy perspective.

About ACORE

The American Council on Renewable Energy (ACORE) is a national non-profit organization leading the transition to a renewable energy economy. With hundreds of member companies from across the spectrum of renewable energy technologies, consumers and investors, ACORE is uniquely positioned to promote the policies and financial structures essential to growth in the renewable energy sector. Our annual forums in Washington, D.C., New York and San Franciscoset the industry standard in providing important venues for key leaders to meet, discuss recent developments, and hear the latest from senior government officials and seasoned experts.

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Canada Clean Electricity Regulations outline a 2035 net-zero grid target, driving decarbonization via wind, solar, hydro, SMRs, carbon capture, and efficiency, balancing reliability, affordability, and federal-provincial collaboration while phasing out coal and limiting fossil-fuel generation.

Key Points

Federal rules to cap CO2 from power plants and deliver a reliable, affordable net-zero grid by 2035.

✅ Applies to fossil-fired units; standards effective by Jan 1, 2035.

✅ Promotes wind, solar, hydro, SMRs, carbon capture, and efficiency.

✅ Balances reliability, affordability, and emissions cuts; ongoing consultation.

Saskatchewan’s premier said the federal government is “changing goalposts” with its proposed target for a net-zero electricity grid.

“We were looking at a net-zero plan in Saskatchewan and across Canada by the year 2050. That’s now been bumped to 2035. Well there are provinces that quite frankly aren’t going to achieve those types of targets by 2035,” Premier Scott Moe said Wednesday.

Ottawa proposed the Clean Electricity Regulations – formerly the Clean Electricity Standard – as part of its target for Canada to transition to net-zero emissions by 2050.

The regulations would help the country progress towards an updated proposed goal of a net-zero electricity grid by 2035.

“They’re un-consulted, notional targets that are put forward by the federal government without working with industries, provinces or anyone that’s generating electricity,” Moe said.

The Government of Canada was seeking feedback from stakeholders on the plan’s regulatory framework document earlier this year, up until August 2022.

“The clean electricity standard is something that’s still being consulted on and we certainly heard the views of Saskatchewan – not just Saskatchewan, many other provinces – and I think that’s something that’s being reflected on,” Jonathan Wilkinson, Canada’s minister of natural resources, said during an event near Regina Wednesday.

“We also recognize that the federal government has a role to play in helping provinces to make the kinds of changes that would need to be made in order to actually achieve a clean grid,” Wilkinson added.

The information received during the consultation will help inform the development of the proposed regulations, which are expected to be released before the end of the year, according to the federal government.

NET-ZERO ELECTRICITY GRID
The federal government said its Clean Electricity Regulations (CER) is part of a suite of measures, as the country moves towards a broad “decarbonization” of the economy, with Alberta's clean electricity path illustrating provincial approaches as well.

Net-zero emissions would mean Canada’s economy would either emit no greenhouse gas emissions or offset its emissions.

The plan encourages energy efficiency, abatement and non-emitting generation technologies such as carbon capture and storage and electricity generation options such as solar, wind, geothermal, small modular nuclear reactors (SMRs) and hydro, among others.

The government suggests consumer costs could be lowered by using some of these energy efficiency techniques, alongside demand management and a shift to lower-cost wind and solar power, echoing initiatives like the SaskPower 10% rebate aimed at affordability.

The CER focuses on three principles, each tied to affordability debates like the SaskPower rate hike in Saskatchewan:

 Maximize greenhouse gas reductions to achieve the 2035 target
 Ensure a reliable electrical grid to support Canadians and the economy
 Maintain electrical affordability

“Achieving a net-zero electricity supply is key to reaching Canada’s climate targets in two ways,” the government said in its proposed regulations.

“First, it will reduce [greenhouse gas] emissions from the production of electricity. Second, using clean electricity instead of fossil fuels in vehicles, heating and industry will reduce emissions from those sectors too.

The regulations would regulate carbon dioxide emissions from electricity generating units that combust any amount of fossil fuel, have a capacity above a small megawatt threshold and sell electricity onto a regulated electricity system.

New rules would also be implemented for the development of new electricity generation units firing fossil fuels in or after 2025 and existing units. All units would be subject to emission standards by Jan. 1, 2035, at the latest.

The federal government launched consultations on the proposed regulations in March 2022.

Canada also has a 2030 emissions reduction plan that works towards meeting its Paris Agreement target to reduce emissions by 40-45 per cent from 2005 levels by 2030. This plan includes regulations to phase out coal-fired electricity by 2030.

COLLABORATION
The province recently introduced the Saskatchewan First Act, in an attempt to confirm its own jurisdiction and sovereignty when it comes to natural resources.

The act would amend Saskatchewan’s constitution to exert exclusive legislative jurisdiction under the Constitution of Canada.

The province is seeking jurisdiction over the exploration of non-renewable resources, the development, conservation and management of non-renewable natural and forestry resources, and the operation of sites and facilities for the generation and production of electrical energy.

While the federal government and Saskatchewan have come head-to-head publicly over several policy concerns in the past year, both sides remain open to collaborating on issues surrounding natural resources.

“We do have provincial jurisdiction in the development of these natural resources. We’d like to work collaboratively with the federal government on developing some of the most sustainable potash, uranium, agri-food products in the world,” Moe said.

Minister Wilkinson noted that while both the federal and provincial governments aim to respect each other’s jurisdiction, there is often some overlap, particularly in the case of environmental and economic policies, with Alberta's electricity sector changes underscoring those tensions as well.

“My view is we should endeavour to try to figure out ways that we can work together, and to ensure that we’re actually making progress for Saskatchewanians and for Canadians,” Wilkinson said.

“I think that Canadians expect us to try to figure out ways to work together, and where there are some disputes that can’t get resolved, ultimately the Supreme Court will decide on the issue of jurisdiction as they did in the case on the price on pollution.”

Moe said Saskatchewan is always open to working with the federal government, but not at the expense of its “provincial, constitutional autonomy.”

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Black Hills Energy Corriedale Wind Farm Expansion earns regulatory approval in Wyoming, boosting capacity to over 52MW near Cheyenne with five turbines, supporting Renewable Ready customers and wind power goals under PUC and PSC oversight.

Key Points

An approved Wyoming wind project upgrade to over 52MW, adding five turbines to serve Renewable Ready customers.

✅ Adds 12.5MW via five new wind turbines near Cheyenne

✅ Cost increases to $79m; prior estimate $57m

✅ Approved by SD PUC after Wyoming PSC review

US company Black Hills Energy has received regulatory approval to increase the size of its Corriedale wind farm in Wyoming, where Wyoming wind exports to California are advancing, to over 52MW from 40MW previously.

The South Dakota Public Utilities Commission approved the additional 12.5MW capacity after the Wyoming Public Service Commission determined the boost was within commission rules, as federal initiatives like DOE wind energy awards continue to support the sector.

Black Hills Energy will install five additional turbines, raising the project cost to $79m from $57m, amid growing heartland wind investment across the region.
Corriedale will be built near Cheyenne and is expected to be placed in service in late 2020.

Similar market momentum is seen in Canada, where a Warren Buffett-linked Alberta wind farm is planned to expand capacity across the region.

Black Hills said that during the initial subscription period for its Renewable Ready program, applications of interest from eligible commercial, industrial and governmental agency customers were received in excess of the program's 40MW, underscoring the view that more energy sources can make stronger projects.

Black Hills Corporations chief executive and president Linden Evans said: “We are pleased with the opportunity to expand our Renewable Ready program, allowing us to meet our customers’ interest in renewable wind energy, which co-op members increasingly support.

“This innovative program expands our clean energy portfolio while meeting our customers’ evolving needs, particularly around cleaner and more sustainable energy, as projects like new energy generation coming online demonstrate.”

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Sudbury Electrification and Grid Expansion is driving record power demand, EV charging, renewable energy planning, IESO forecasts, smart grid upgrades, battery storage, and industrial electrification, requiring cleaner power plants and transmission capacity in northern Ontario.

Key Points

Rising electricity demand and clean energy upgrades in Sudbury to power EVs, industry, and a smarter, expanded grid.

✅ IESO projects system size may need to more than double

✅ EVs and smart devices increase peak and off-peak load

✅ Battery storage and V2G can support reliability and resiliency

Sudbury, Ont., is consuming more power than ever, amid an electricity supply crunch in Ontario, according to green energy organizations that say meeting the demand will require cleaner energy sources.

"This is the welfare of the entire city on the line and they are putting their trust in electrification," said David St. Georges, manager of communications at reThink Green, a non-profit organization focused on sustainability in Sudbury.

According to St. Georges, Sudbury and northern Ontario can meet the growing demand for electricity to charge clean power for EVs and smart devices. 

According to the Independent Electricity System Operator (IESO), making a full switch from fossil fuels to other renewable energy sources could require more power plants, while other provinces face electricity shortages of their own.

"We have forecasted that Ontario's electricity system will need significant expansion to meet this, potentially more than doubling in size," the IESO told CBC News in an emailed statement.

Electrification in the industrial sector is adding greater demand to the electrical grid as electric cars challenge power grids in many regions. Algoma Steel in Sault Ste. Marie and ArcelorMittal Dofasco in Hamilton both aim to get electric arc furnaces in operation. Together, those projects will require 630 megawatts.

"That's like adding four cities the size of Sudbury to the grid," IESO said.

Devin Arthur, chapter president of the Electric Vehicle society in Greater Sudbury, said the city is coming full circle with fully electrifying its power grid, reflecting how EVs are a hot topic in Alberta and beyond.

"We're going to need more power," he said.

"Once natural gas was introduced, that kind of switched back, and everyone was getting out of electrification and going into natural gas and other sources of power."

Despite Sudbury's increased appetite for electricity, Arthur added it's also easier to store now as Ontario moves to rely on battery storage solutions.

"What that means is you can actually use your electric vehicle as a battery storage device for the grid, so you can actually sell power from your vehicle that you've stored back to the grid, if they need that power," he said.

Harneet Panesar, chief operating officer for the Ontario Energy Board, told CBC the biggest challenge to going green is seeing if it can work around older infrastructure, while policy debates such as Canada's 2035 EV sales mandate shape the pace of change.

"You want to make sure that you're building in the right spot," he said.

"Consumers are shifting from combustion engines to EV drivetrains. You're also creating more dependency. At a very high level, I'm going to say it's probably going to go up in terms of the demand for electricity."

Fossil fuels are the first to go for generating electricity, said St. Georges.

"But we're not there yet, because it's not a light switch solution. It takes time to get to that, which is another issue of electrification," he said.

"It's almost impossible for us not to go that direction."

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North American Grid Reliability faces extreme weather, climate change, demand spikes, and renewable variability; utilities, AESO, and NERC stress resilience, dispatchable capacity, interconnections, and grid alerts to prevent blackouts during heatwaves and cold snaps.

Key Points

North American grid reliability is the ability to meet demand during extreme weather while maintaining stability.

✅ Extreme heat and cold drive record demand and resource strain.

✅ Balance dispatchable and intermittent generation for resilience.

✅ Expand interconnections, capacity, and demand response to avert outages.

The recent alerts in Alberta's electricity grid during extreme cold have highlighted a broader North American issue, where power systems are more susceptible to being overwhelmed by extreme weather impacts on reliability.

Electricity Canada's chief executive emphasized that no part of the grid is safe from the escalating intensity and frequency of weather extremes linked to climate change across the sector.

“In recent years, during these extreme weather events, we’ve observed record highs in electricity demand,” he stated.

“It’s a nationwide phenomenon. For instance, last summer in Ontario and last winter in Quebec, we experienced unprecedented demand levels. This pattern of extremes is becoming more pronounced across the country.”

The U.S. has also experienced strain on its electricity grids due to extreme weather, with more blackouts than peers documented in studies. Texas faced power outages in 2021 due to winter storms, and California has had to issue several emergency grid alerts during heat waves.

In Canada, Albertans received a government emergency alert two weeks ago, urging an immediate reduction in electricity use to prevent potential rotating blackouts as temperatures neared -40°C. No blackouts occurred, with a notable decrease in electricity use following the alert, according to the Alberta Electric System Operator (AESO).

AESO's data indicates an increase in grid alerts in Alberta for both heatwaves and cold spells, reflecting dangerous vulnerabilities noted nationwide. The period between 2017 and 2020 saw only four alerts, in contrast to 17 since 2021.

Alberta's electricity grid reliability has sparked political debate, including proposals for a western Canadian grid to improve reliability, particularly with the transition from coal-fired plants to increased reliance on intermittent wind and solar power. Despite this debate, the AESO noted that the crisis eased when wind and solar generation resumed, despite challenges with two idled gas plants.

Bradley pointed out that Alberta's grid issues are not isolated. Every Canadian region is experiencing growing electricity demand, partly due to the surge in electric vehicles and clean energy technologies. No province has a complete solution yet.

“Ontario has had to request reduced consumption during heatwaves,” he noted. “Similar concerns about energy mix are present in British Columbia or Manitoba, especially now with drought affecting their hydro-dependent systems.”

The North American Electric Reliability Corporation (NERC) released a report in November warning of elevated risks across North America this winter for insufficient energy supplies, particularly under extreme conditions like prolonged cold snaps.

While the U.S. is generally more susceptible to winter grid disruptions, and summer blackout warnings remain a concern, the report also highlights risks in parts of Canada. Saskatchewan faces a “high” risk due to increased demand, power plant retirements, and maintenance, whereas Quebec and the Maritimes are at “elevated risk.”

Mark Olson, NERC’s manager of reliability assessments, mentioned that Alberta wasn't initially considered at risk, illustrating the challenges in predicting electricity demand amid intensifying extreme weather.

Rob Thornton, president and CEO of the International District Energy Association, acknowledged public concerns about grid alerts but reassured that the risk of a catastrophic grid failure remains very low.

“The North American grid is exceptionally reliable. It’s a remarkably efficient system,” he said.

However, Thornton emphasized the importance of policies for a resilient and reliable electricity system through 2050 and beyond. This involves balancing dispatchable and intermittent electricity sources, investing in extra capacity, enhancing macrogrids and inter-jurisdictional connections, and more.

“These grid alerts raise awareness, if not anxiety, about our energy future,” Thornton concluded.

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Solar Plus Storage is accelerating across utilities and microgrids, pairing rooftop solar with lithium-ion batteries to enhance grid resilience, reduce peak costs, prevent blackouts, and leverage tax credits amid falling prices and decarbonization goals.

Key Points

Solar Plus Storage combines solar generation with batteries to shift load, boost reliability, and cut energy costs.

✅ Cuts peak demand charges and enhances blackout resilience

✅ Falling battery and solar costs drive nationwide utility adoption

✅ Enables microgrids and grid services like frequency regulation

Todd Karin was prepared when California’s largest utility shut off power to millions of people to avoid the risk of wildfires last month. He’s got rooftop solar panels connected to a single Tesla Powerwall in his rural home near Fairfield, California. “We had backup power the whole time,” Karin says. “We ran the fridge and watched movies.”

Californians worried about an insecure energy future are increasingly looking to this kind of solution. Karin, a 31-year-old postdoctoral fellow at Lawrence Berkeley National Laboratory, spent just under $4,000 for his battery by taking advantage of tax credits. He's also saving money by discharging the battery on weekday evenings, when energy is more expensive during peak demand periods. He expects to save around $1,500 over the 10 years the battery is under warranty.

The economics don’t yet work for every household, but the green-power combo of solar panels plus batteries is popping up on a much bigger scale in some unexpected places. Owners of a rice processing plant in Arkansas are building a system to generate 26 megawatts of solar power and store another 40 MW. The plant will cut its power bill by a third, and owners say they will pass the savings to local rice growers. New York’s JFK Airport is installing solar plus storage to reduce its power load by 10 percent, while Pittsburgh International Airport is building a 20-MW solar and natural gas microgrid to keep it independent from the local utility. Officials at both airports are worried about recent power shutdowns due to weather and overload-related blackouts.

And residents of the tiny northern Missouri town of Green City (pop. 608) are getting 2.5 MW of solar plus four hours of battery storage from the state’s public utility next year. The solar power won’t go directly to townspeople, but instead will back up the town’s substation, reducing the risk of a potential shutdown. It’s part of a $68 million project to improve the reliability of remote substations far from electric generating stations.

“It’s a pretty big deal for us,” says Chad Raley, who manages technology and renewables at Ameren, a Missouri utility that is building three rural solar-plus-storage projects to better manage the flow of electricity across the local grid. “It gives us so much flexibility with renewable generation. We can’t control the sun or clouds or wind, but we can have battery storage.”

The first solar-plus-storage installations started about a decade ago on a small scale in sunny states like California, Hawaii, and Arizona. Now they’re spreading across the country, driven by falling prices of both solar panels and lithium-ion batteries the size of a shipping container imported from both China and South Korea, with wind, solar, and batteries making up most of the utility-scale pipeline nationwide. These countries have ramped up production efficiencies and lowered labor costs, leaving many US manufacturers in the dust. In fact, the price of building a comparable solar-plus-storage generating facility is now cheaper than operating a coal-fired power plant, industry officials say. In certain circumstances, the cost is equal to some natural gas plants.

“This is not just a California, New York, Massachusetts thing,” says Kelly Speakes-Backman, CEO of the Energy Storage Association, an industry group in Washington. She says more than 30 states have renewable storage on the grid. Utilities have proposed and states have approved 7 gigawatts to be installed by 2030, and most new storage will be paired with solar across the US.

Speakes-Backman estimates the unit cost of electricity produced from a solar-plus-storage system will drop 10 to 15 percent each year through 2024, supporting record growth in solar and storage investments. “If you have the option of putting out a polluting or non-polluting generating source at the same price, what are you going to pick?” says Speakes-Backman.

She notes that PJM, a large Mid-Atlantic wholesale grid operator, announced it will deploy battery storage to help smooth out fluctuating power from two wind farms it operates. “When the grid fluctuates, storage can react to it quickly and can level out the supply,” she says. In the Midwest, grid-level battery storage is also being used to absorb extra wind power. Batteries hold onto the wind and put it back onto the grid when people need it.

While the solar-plus-storage trend isn’t yet putting a huge dent in our fossil fuel use, according to Paul Denholm, an energy analyst at the National Renewable Energy Laboratory in Golden, Colorado, it is a good beginning and has the side effect of cutting air pollution. By 2021, solar and other renewable energy sources will overtake coal as a source of energy, and the US is moving toward 30% electricity from wind and solar, according to a new report by the Institute for Energy Economics and Financial Analysis, a nonprofit think tank based in Cleveland.

That’s a glimmer of hope in a somewhat dreary week of news on carbon emissions. A new United Nations report released this week finds that the planet is on track to warm by 3.9 degrees Celsius (7 Fahrenheit) by 2100 unless drastic cuts are made by phasing out gas-powered cars, eliminating new coal-fired power plants, and changing how we grow and manage land, and scientists are working to improve solar and wind power to limit climate change as well.

Energy-related greenhouse gas emissions in the US rose 2.7 percent in 2018 after several years of decline. The Trump administration has rolled back climate policies from the Obama years, including withdrawing from the Paris climate accords.

There may be hope from green power initiatives outside the Beltway, though, and from federal proposals like a tenfold increase in US solar that could remake the electricity system. Arizona plans to boost solar-plus-storage from today’s 6 MW to a whopping 850 MW by 2025, more than the entire capacity of large-scale batteries in the US today. And some folks might be cheering the closing of the West’s biggest coal-fired power plant, the 2.25-gigawatt Navajo Generating Station, in Arizona, which had spewed soot and carbon dioxide over the region for 45 years until last week. The closure might help the planet and clear the hazy smog over the Grand Canyon.

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