Carbon taxes will hurt poor the most, says civil rights activist

By Electricity Forum


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Green activists seeking to put high taxes on carbon dioxide emissions and strangle energy production in North America – including Canadian oil sands – will put a disproportionately high burden on low-income families and the poor, according to a leading American civil rights activist.

Niger Innis, National Spokesman for the Congress of Racial Equality, (CORE) made the charge in a speech at an event sponsored by the Winnipeg-based Frontier Center for Public Policy.

Innis said that higher energy prices discriminate against the poor. He cited these U.S. statistics:

• The average median-income family in the U.S. today has to spend about a nickel of every dollar of their income on energy.

• The average low-income family has to spend 20 cents on the dollar to buy their energy.

• The average poor family has to devote 50 cents or more of each dollar on energy.

“As energy prices go up, the poor suffer the most. And not just because energy costs more. Because higher energy prices mean higher prices for everything, especially food and housing, medicine and so on and so on,” he said.

“Of course, I believe that those motivations are inherently immoral. Because the consequences, however unintentional, hurt the poorest of our society the most,” he said.

Innis also serves as the national co-chairman of the Alliance to Stop the War on the Poor, a coalition of civil rights, religious, consumer, agriculture and veterans leaders that are fighting against government policies that raise the cost of energy.

“Virtually every study done by virtually every economist has found the same thing: raising the cost of energy by putting a tax on carbon will raise the cost of energy, of food, of almost all goods and services by a huge amount,” he said. “In the U.S., energy bills for the average citizen may easily double. Some studies show costs going up two, three, four times what they are now.”

“And so I ask: will citizens agree to pay all of those higher costs, especially when the United Nation’s science says that it will result in temperature changes over the next century that we can barely measure?”

Innis said that a new study to be released this week by the NextGen Energy Council will show that, based on all of the science behind the United Nation’s predictions on climate change, if we shut down every power plant in North America right now, and keep them off for the next 100 years, we would only affect the temperature in the year 2100 by less than one-tenth of one percent of a degree Celsius. “This calculation does not come from climate change skeptics. It is based on the same science that the environmentalists’ say cannot be questioned.

“Now, you tell me,” he asked, “is that barely measurable temperature change over 100 years something that the citizens of North America will conclude is worth all of the additional costs we will saddle ourselves with?”

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

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

 

Key Points

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

✅ Uses 2021 sales forecasts for rate setting

✅ Aims to prevent undercollection and bill spikes

✅ Levels changes across customer classes

 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

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Bruce Power awards $914 million in manufacturing contracts

Bruce Power Major Component Replacement secures Ontario-made nuclear components via $914M contracts, supporting refurbishment, clean energy, low-cost electricity, and advanced manufacturing, extending reactor life to 2064 while boosting jobs, supply chain growth, and economy.

 

Key Points

A refurbishment program investing $914M in advanced manufacturing to extend reactors and deliver low-cost, clean power.

✅ $914M Ontario-made components for steam generators, tubes, fittings

✅ Extends reactor life to 2064; clean, low-cost electricity for Ontario

✅ Supports 22,000 jobs annually; boosts supply chain and economy

 

Today, Bruce Power signed $914 million in advanced manufacturing contracts for its Major Component Replacement, which gets underway in 2020, as the reactor refurbishment begins across the site and will allow the site to provide low-cost, carbon-free electricity to Ontario through 2064.

The Major Component Replacement (MCR) Project agreements include:

  • $642 million to BWXT Canada Inc. for the manufacturing of 32 steam generators to be produced at BWXT’s Cambridge facility.
  • $144 million to Laker Energy Products for end fittings, liners and flow elements, which will be manufactured at its Oakville location.
  • $62 million to Cameco Fuel Manufacturing, in Cobourg, for calandria tubes and annulus spacers for all six MCRs.
  • $66 million for Nu-Tech Precision Metals, in Arnprior, for the production of zirconium alloy pressure tubes for Units 6 and 3.

 

Bruce Power’s Life-Extension Program, which started in January 2016 with Asset Management Program investments and includes the MCRs on Units 3-8, remains on time and on budget.”

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By signing these contracts today, we have secured ‘Made in Ontario‘ solutions for the components we will need to successfully complete our MCR Projects, extending the life of our site to 2064,” said Mike Rencheck, Bruce Power’s President and CEO.

“Today’s announcements represent a $914 million investment in Ontario’s highly skilled workforce, which will create untold economic opportunities for the communities in which they operate for many years to come.”We look forward to growing our already excellent relationships with these supplier partners and unions as we work toward our common goal, supported by an operating record, of continuing to keep Canada’s largest infrastructure project on time and on budget."

By extending the life of Bruce Power’s reactors to 2064, the company will create and sustain 22,000 jobs annually, both directly and indirectly, across Ontario, while investing $4 billion a year into the province’s economy, underscoring the economic benefits of nuclear development across Canada.

At the same time, Bruce Power will produce 30 per cent of Ontario’s electricity at 30 per cent less than the average cost to generate residential power, while also producing zero carbon emissions, aligning with Pickering NGS life extensions across the province.The Hon. Glenn Thibeault, Minister of Energy, said today’s announcement is good news for the people of Ontario.”

Bruce Power’s Life-Extension Program makes sense for Ontario, and the announcements made today will create good jobs and benefit our economy for decades to come,” Minister Thibeault said.

“Moving forward with the refurbishment project is part of our government’s plan to support care and opportunity, while producing affordable, reliable and clean energy for the people of Ontario.”Kim Rudd, Parliamentary Secretary to the Minister of Natural Resources and MP for Northumberland-Peterborough South, offered her support and congratulations.”

Related planning includes Bruce C project exploration funding that supports long-term nuclear options in Ontario.

Canada’s nuclear industry, including its advanced manufacturing capability, is respected internationally,” Rudd said. “Bruce Power’s announcement today related to the advanced manufacturing of key components throughout Ontario as part of its Life-Extension Program will allow these suppliers to have a secure base to not only meet Canada’s needs, but export internationally.”

 

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EU Plans To Double Electricity Use By 2050

European Green Deal Electrification accelerates decarbonization via renewables, electric vehicles, heat pumps, and clean industry, backed by sustainable finance, EIB green lending, just transition funds, and energy taxation reform to phase out fossil fuels.

 

Key Points

An EU plan to replace fossil fuels with renewable electricity in transport, buildings, and industry, supported by green finance.

✅ Doubles electricity's share to cut CO2 and phase out fossil fuels.

✅ Drives EVs, heat pumps, and electrified industry via renewables.

✅ Funded by EIB lending, EU budget, and just transition support.

 

The European Union is preparing an ambitious plan to completely decarbonize by 2050. Increasing the share of electricity in Europe’s energy system – electricity that will increasingly come from renewable sources - will be at the center of this strategy, aligning with the broader global energy transition under way, the new head of the European Commission’s energy department said yesterday.

This will mean more electric cars, electric heating and electric industry. The idea is that fossil fuels should no longer be a primary energy source, heating homes, warming food or powering cars. In the medium term they should only be used to generate electricity, a shift mirrored by New Zealand's electricity shift efforts, which then powers these things, resulting in less CO2 emissions.

“First assessments show we need to double the share of electricity in energy consumption by 2050,” Ditte Juul-Jørgensen said at an event in Brussels this week, a goal echoed by recent calls to double investment in power systems from world leaders. “We’ve already seen an increase in the last decade, but we need to go further”.

Juul-Jørgensen, who started in her job as director-general of the commission’s energy department in August, has come to the role at a pivotal time for energy. The 2050 decarbonization proposal from the Commission, the EU’s executive branch, is expected to be approved next month by EU national leaders. A veto from Poland that has blocked adoption until now is likely to be overcome if Poland and other Eastern European countries are offered financial assistance from a “just transition fund”, according to EU sources.

Ursula von der Leyen, the incoming President of the Commission, has promised to unveil a “European Green Deal” in her first 100 days in office designed to get the EU to its 2050 goal. Juul-Jørgensen will be working with the incoming EU Energy Commissioner, Kadri Simson, on designing this complex strategy. The overall aim will be to phase out fossil fuels, and increase the use of electricity from green sources, amid trends like oil majors pivoting to electric across Europe today.

“This will be about how do we best make use of electricity to feed into other sectors,” Juul-Jørgensen said. “We need to think about transforming it into other sources, and how to best transport it.”

“But the biggest challenge from what I see today is that of investment and finance - the changes we have to make are very significant.”

 

Financing problems

The Commission is going to try to tackle the challenges of financing the energy transition with two tools: dedicated climate funding in the EU budget, and dedicated climate lending from the European Investment Bank.

“The EIB will play an increasing role in future. We hope to see agreement [with the EIB board] on that in the coming months so there’s a clear operator in the EIB to support the green transition. We’re looking at something around €400 billion a year.”

The Commission’s proposed dedicated climate spending in the next seven-year budget must still be approved by the 28 EU national governments. Juul-Jørgensen said there is unanimous agreement on the amount: 25% of the budget. But there is disagreement about how to determine what is green spending.

“A lot of work has been ongoing to ensure that when it comes to counting it reflects the reality of the investments,” she said. “We’re working on the taxonomy on sustainable finance - internally identifying sectors contributing to overall climate objectives.”

 

Electricity pact

Juul-Jørgensen was speaking at an event organized by the the Electrification Alliance, a pact between nine industry organizations to lobby for electricity to be put at the heart of the European green deal. They signed a declaration at the event calling for a variety of measures to be included in the green deal, reflecting debates over a fully renewable grid by 2030 in other jurisdictions, including a change to the EU’s energy taxation regime which incentivizes a switch from fossil fuel to electricity consumption.

“Electrification is the most important solution to turn the vision of a fossil-free Europe into reality,” said Laurence Tubiana, CEO of the European Climate Foundation, one of the signatories, and co-architect of the Paris Agreement.

“We are determined to deliver, but we must be mindful of the different starting points and secure sufficient financing to ensure a fair transition”, said Magnus Hall, President of electricity industry association Eurelectric, another signatory.

The energy taxation issue has been particularly tricky for the EU, since any change in taxation rules requires the unanimous consent of all 28 EU countries. But experts say that current taxation structures are subsidizing fossil fuels and punishing electricity, as recent UK net zero policy changes illustrate, and unless this is changed the European Green Deal can have little effect.

“Yes this issue will be addressed in the incoming commission once it takes up its function,” Juul-Jørgensen said in response to an audience question. “We all know the challenge - the unanimity requirement in the Council - and so I hope that member states will agree to the direction of work and the need to address energy taxation systems to make sure they’re consistent with the targets we’ve set ourselves.”

But some are concerned that the transformation envisioned by the green deal will have negative impacts on some of the most vulnerable members of society, including those who work in the fossil fuel sector.

This week the Centre on Regulation in Europe sent an open letter to Frans Timmermans, the Commission Vice President in charge of climate, warning that they need to be mindful of distributional effects. These worries have been heightened by the yellow vest protests in France, which were sparked by French President Emmanuel Macron’s attempt to increase fuel taxes for non-electric cars.

“The effectiveness of climate action and sustainability policies will be challenged by increasing social and political pressures,” wrote Máximo Miccinilli, the center’s director for energy. “If not properly addressed, those will enhance further populist movements that undermine trust in governance and in the public institutions.”

Miccinilli suggests that more research be done into identifying, quantifying and addressing distributional effects before new policies are put in place to phase out fossil fuels. He proposes launching a new European Observatory for Distributional Effects of the Energy Transition to deal with this.

EU national leaders are expected to vote on the 2050 decarbonization target, building on member-state plans such as Spain's 100% renewable electricity goal by mid-century, at a summit in Brussels on December 12, and Von der Leyen will likely unveil her European Green Deal in March.

 

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Nova Scotia's last paper mill seeks new discount electricity rate

Nova Scotia Power Active Demand Control Tariff lets the utility direct Port Hawkesbury Paper load, enabling demand response, efficiency, and industrial electricity rates, while regulators assess impacts on ratepayers, grid reliability, mill viability, and savings.

 

Key Points

A four-year tariff letting the utility control the mill load for demand response, efficiency, and lower costs.

✅ Utility can increase or reduce daily consumption at the mill

✅ Projected savings of $10M annually for other ratepayers to 2023

✅ Regulators reviewing cost allocation, monitoring, and viability

 

Nova Scotia Power is scheduled to appear before government regulators Tuesday morning seeking approval for a unique discount rate for its largest customer.

Under the four-year plan, Nova Scotia Power would control the supply of electricity to Port Hawkesbury Paper, a move referenced in a grid operations report that urges changes, with the right to direct the company to increase or reduce daily consumption throughout the year.

The rate proposal is supported by the mill, which says it needs to lower its power bill to keep its operation viable.

The rate went into effect on Jan. 1 on a temporary basis, pending the outcome of a hearing this week before the Nova Scotia Utility and Review Board, amid broader calls for an independent body to lead electricity planning.

The mill accounts for 10 per cent of the provincial electricity load, even as a neighbouring utility pursues more Quebec power for the region, producing glossy paper used in magazines and catalogs.

Nova Scotia Power says controlling how much electricity the mill uses — and when — will allow it to operate the system much more efficiently, as it expands biomass generation initiatives, saving other customers $10 million a year until the rate expires in 2023.

Ceding control 'not an easy decision'
In its opening statement that was filed in advance, Port Hawkesbury Paper said ceding the control of its electrical supply to Nova Scotia Power was "not an easy decision" to make, but the company is confident the arrangement will work.

In September 2019, Nova Scotia Power and the mill jointly applied for an "extra large active demand control tariff," which would provide electricity to the mill for about $61 per megawatt hour, well below the full cost of generating the electricity.

The utility said "fully allocating costs" would result in "prices in excess of $80/MWh ... and [would] not [be] financially viable for the mill."

In its statement, Port Hawkesbury Paper said since the initial filing "there have been greater near term declines in market demand and pricing for PHP's product than was forecast at that time, continuing to put pressure on our business and further highlighting the need to maintain the balance provided for in the new tariff."

Consumer advocate sees 'advantage,' but will challenge
Bill Mahody represents Nova Scotia Power's 400,000 residential customers before the review board. He wants proof the mill will pay enough toward the cost of generating the electricity it uses, amid concerns over biomass use in the province today.

"We filed evidence, as have others involved in the proceeding, that would call into question whether or not the rate design is capturing all of those costs and that will be a significant issue before the board," Mahody said.

Still, he sees value in the proposal.

The proposed new rate went into effect on Jan. 1 on a temporary basis. (The Canadian Press)
"This proposed rate gives Nova Scotia Power the ability to control that sizable Port Hawkesbury Paper load to the advantage of other ratepayers, as the province pursues more wind and solar projects, because Nova Scotia Power would be reducing the costs that other ratepayers are going to face," he said.

Mahody is also calling for a mechanism to monitor whether the mill's position actually improves to the point where it could pay higher rates.

"An awful lot can change during a four-year period, with new tidal power projects underway, and I think the board ought to have the ability to check in on this and make sure that their preferential rate continues to be justified," he said.

Major employer
Port Hawkesbury Paper, owned by Stern Partners in Vancouver, has received discounted power rates since it bought the idled mill in 2012. But the "load retention tariff" as it was called, expired at the end of 2019.

Regulators have accepted Nova Scotia Power's argument that it would cost other customers more if the mill ceased to operate.

The mill said it spends between $235 million and $265 million annually, employing 330 people directly and supporting 500 other jobs indirectly.

The Nova Scotia government pledged $124 million in financial assistance as part of the reopening in 2012.

 

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✅ Predictive maintenance, condition monitoring, ROI

 

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Net-zero roadmap can cut electricity costs by a third in Germany - Wartsila

Germany net-zero roadmap charts coal phase-out by 2030, rapid renewables buildout, energy storage, and hydrogen-ready gas engines to cut emissions and lower LCOE by 34%, unlocking a resilient, flexible, low-cost power system by 2040.

 

Key Points

Plan to phase out coal by 2030 and gas by 2040, scaling renewables, storage, and hydrogen to cut LCOE and emissions.

✅ Coal out by 2030; gas phased 2040 with hydrogen-ready engines

✅ Add 19 GW/yr renewables; 30 GW storage by 2040

✅ 34% lower LCOE, 23% fewer emissions vs slower path

 

Germany can achieve significant reductions in emissions and the cost of electricity by phasing out coal in 2030 under its coal phase-out plan but must have a clear plan to ramp up renewables and pivot to sustainable fuels in order to achieve net-zero, according to a new whitepaper from Wartsila.

The modelling, published in Wärtsilä new white paper ‘Achieving net-zero power system in Germany by 2040’, compares the current plan to phase out coal by 2030 and gas by 2045 with an accelerated plan, where gas is phased out by 2040. By accelerating the path to net-zero, Germany can unlock a 34% reduction in the levelised cost of energy, as well as a 23% reduction in the total emissions, or 562 million tonnes of carbon dioxide in real terms.

The modelling offers a clear, three-step roadmap to achieve net-zero: rapidly increase renewables, energy storage and begin future-proofing gas engines in this decade; phase out coal by 2030; and phase out gas by 2040, converting remaining engines to run on sustainable fuels.

The greatest rewards are available if Germany front-loads decarbonisation. This can be done by rapidly increasing renewable capacity, adding 19 GW of wind and solar PV capacity per year. It must also add a total of 30GW of energy storage by 2040.

Håkan Agnevall, President and CEO of Wärtsilä Corporation said: “Germany stands on the precipice of a new, sustainable energy era. The new Federal Government has indicated its plans to consign coal to history by 2030. However, this is only step one. Our white paper demonstrates the need to implement a three-step roadmap to achieve net-zero. It is time to put a deadline on fossil fuels and create a clear plan to transition to sustainable fuels.”

While a rapid coal phase-out has been at the centre of recent climate policy debates, including the ongoing nuclear debate over Germany’s energy mix, the pathway to net-zero is less clear. Wärtsilä’s modelling shows that gas engines should be used to accelerate the transition by providing a short-term bridge to enable net zero and navigate the energy transition while balancing the intermittency of renewables until sustainable fuels are available at scale.

However, if Germany follows the slower pathway and reaches net-zero by 2045, it risks becoming reliant on gas as baseload power for much of the 2030s amid renewable expansion challenges that persist, potentially harming its ability to reach its climate goals. 

Creating the infrastructure to pivot to sustainable fuels is one of the greatest challenges facing the German system. The ability to convert existing capacity to run purely on hydrogen via hydrogen-ready power plants will be key to reaching net-zero by 2040 and unlocking the significant system-wide benefits on offer.

Jan Andersson, General Manager of Market Development in Germany, Wärtsilä Energy added: “To reach the 2040 target and unlock the greatest benefits, the most important thing that Germany can do is build renewables now. 19 GW is an ambitious target, but Germany can do it. History shows us that Germany has been able to achieve high levels of renewable buildout in previous years. It must now reach those levels consistently.

“Creating a clear plan which sets out the steps to net zero is essential. Renewable energy is inherently intermittent, so flexible energy capacity will play a vital role. While batteries provide effective short-term flexibility, gas is currently the only practical long-term option. If Germany is to unlock the greatest benefits from decarbonisation, it must have a clear plan to integrate sustainable fuel. From 2030, all new thermal capacity must run solely on hydrogen.”

Analysis of the last decade demonstrates that the rapid expansion of renewable energy is possible, and that renewables overtook coal and nuclear in generation. Previously, Germany has built large amounts of renewable capacity, including 8GW of solar PV in 2010 and 2011, 5.3 GW of onshore wind in 2017, and 2.5 GW of offshore wind in 2015.

The significant reductions in the cost of electricity demonstrated in the modelling are driven by the fact that renewables are far cheaper to run than coal or gas plants, even as coal still provides about a third of electricity in Germany. The initial capital investment is far outweighed by the ongoing operational expense of fossil fuel-based power.

As well as reducing emissions and costs, Germany’s rapid path to net-zero can also unlock a series of additional benefits. If coal is phased out by 2030 but capacity is not replaced by high levels of renewable energy, Germany risks becoming a significant energy importer, peaking at 162 TWh in 2035. The accelerated pathway would reduce imports by a third.

Likewise, more renewable energy will help to electrify district heating, meaning Germany can move away from carbon-intensive fuels sooner. If Germany follows the accelerated path, 57% of Germany’s heating could be electrified in 2045, compared to 10% under the slower plan.

Jan Andersson concluded: “The opportunities on offer are vast. Germany can provide the blueprint for net zero and galvanise an entire continent. Now is the time for the new government to seize the initiative.”

 

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