Can U.S. compete with Canadian offshore wind?

By SolveClimate


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For years the promise of North America's first offshore wind farm has been just that – a promise. The reality has been a big disappointment: proposals pigeonholed by Bush-era dirty energy policies and NIMBY (not-in-my-backyard) opposition.

The Cape Wind project off Nantucket Sound was to be the continent's first offshore wind park. Eight years on, it remains in limbo. The latest hiccup? Two Indian tribes are trying to block the turbines by getting Nantucket Sound listed as a "traditional cultural property." In other words, more delay is on the way.

But the Massachusetts wind farm is no longer the only offshore game in town. With a pro-renewable energy administration in Washington, increasing state and provincial clean energy standards and coming carbon regulations, a big push is underway that could make North America the next big market for offshore wind generation.

The race is on. And for now Ontario, Canada, is in the driver's seat.

Toronto-based Trillium Power is expected to build the first major offshore wind fleet in the Great Lakes and probably North America. The 140-turbine facility will deliver 710 megawatts of power, courtesy of gusts blowing off Lake Ontario, enough to power 300,000 homes in the province.

Around 15 other such projects have been proposed in Ontario, including the largest in the world – a 4,400 megawatt wind farm on the Ontario side of Lake Erie.

Canadian Hydro Developers recently bought the rights to build the enormous offshore wind installation. The plan calls for 900 turbines across a 50-mile stretch of lake. Currently, the largest offshore wind farm in the world is one-tenth that size and sits off the coast of Denmark. That 91-turbine, 200-megawatt facility provides zero-carbon power to 200,000 homes.

If the Lake Erie project gets built, its wind turbines will churn out enough juice to power two million homes.

Canadian Hydro explains why it wanted in: "Canadian Hydro already owns and operates the two largest wind facilities in Canada. We are leading the way in Ontario by generating 40 percent of the province's installed renewable energy capacity, and we are eager to pioneer offshore wind in Ontario and North America."

But why Ontario? In a word, incentives.

The government of Dalton McGuinty just launched a feed-in tariff as part of the Green Energy Act in Ontario. The program will pay producers 19 cents for every kilowatt-hour of electricity their offshore turbines pump out.

For its part, the Ontario government is being spurred to action by its commitment to eliminate coal plants in the province by 2014. There are no plans for new nuclear to take coal's place. That's helped to make wind a No. 1 priority. The numbers are proof: In 2003, the province had 10 turbines; today, it has more than 670, with 975 turbines expected by 2012.

The Great Lakes are one of Ontario's greatest energy assets. Estimates claim the province has at least 34,500 megawatts of shallow water offshore wind potential spread over 64 different sites.

The province isn't alone in trying to tap the richness of those winds. Offshore wind power projects have been proposed in the states of Ohio, Michigan, New York and Wisconsin, though the processes there are expected to be slow and complex.

The Eastern seaboard states are expected to be the first to finalize offshore windfarms in the U.S. According to a study by Stanford University and the University of Delaware, a stretch of the Atlantic Ocean from Cape Cod to North Carolina has enough wind potential to generate 330,000 megawatts of electricity. That's almost twice the current energy demand in the nine-state Mid-Atlantic region.

Currently, the U.S. has no offshore wind installations. That will change, but whether it happens fast enough to beat its Canadian competitor has yet to be seen. Beating Europe is certainly out of the question: North America has fallen decades behind the continent, where some 30 offshore wind farms are presently in operation.

In a major step forward, though, President Obama's Department of Interior issued the first-ever leases for offshore wind facilities in June.

On top of that, the state of Delaware has approved Bluewater Wind's proposed project of up to 600 megawatts. The installation could meet half of the state's electricity needs. New Jersey has plans in the works for several 350-megawatt installations. Rhode Island, Maryland and New York are said to be in negotiations with developers, among other states.

And just last week, Duke Energy and the University of North Carolina announced plans for a pilot project involving three demonstrations of commercial turbines off North Carolina's coast.

Keeping up the competitive rhetoric, Duke Energy said its project's turbines "may be the first turbines placed in water in the United States."

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US Electricity Prices Rise Most in 41 Years as Inflation Endures

US Electricity Price Surge drives bills as BLS data show 15.8 percent jump; natural gas and coal costs escalate amid energy crisis, NYISO warns of wholesale prices and winter futures near $200 per MWh.

 

Key Points

A sharp rise in power bills driven by higher natural gas and coal costs and tighter wholesale markets.

✅ BLS reports electricity bills up 15.8% year over year

✅ Natural gas bills up 33% as fuel costs soar

✅ NYISO flags winter wholesale prices near $200/MWh

 

Electricity bills for US consumers jumped the most since 1981, gaining 15.8% from the same period a year ago, according to the US Bureau of Labor Statistics, and residential bills rose 5% in 2022 across the U.S.

Natural gas bills, which crept back up last month after dipping in July, surged 33% from the same month last year, labor data released Tuesday showed, as electricity and natural gas pricing dynamics continue to ripple through markets. Broader energy costs slipped for a second consecutive month because of lower gasoline and fuel oil prices. Even with that drop, total energy costs were still about 24% above August 2021 levels.

Electricity costs are relentlessly climbing because prices for the two biggest power-plant fuels -- natural gas and coal -- have surged in the last year as the US economy rebounds from the pandemic and as Russia’s war in Ukraine triggers an energy crisis in Europe, where German electricity prices nearly doubled over a year. Another factor is the hot and humid summer across most of the lower 48 states drove households and businesses to crank up air conditioners. Americans likely used a record amount of power in the third quarter, according to US Energy Information Administration projections, even as U.S. power demand is seen sliding 1% in 2023 on milder weather.

New York’s state grid operator warned of a “sharp rise in wholesale electric costs expected this winter” with spiking global demand for fossil fuels, lagging supply and instability from Russia’s war in Ukraine driving up oil and gas prices, with multiple energy-crisis impacts on U.S. electricity and gas still unfolding, according to a Tuesday report. Geopolitical factors are ultimately reflected in wholesale electricity prices and supply charges to consumer bills, the New York Independent System Operator said, and as utilities direct more spending to delivery rather than production.

Electricity price futures for this winter have increased fourfold from last year, and potential deep-freeze disruptions to the energy sector could add volatility, with prices averaging near $200 a megawatt-hour, the grid operator said. That has been driven by natural gas futures for the upcoming winter, which are more than double current prices to nearly $20 per million British thermal units.

 

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Congressional Democrats push FERC to act on aggregated DERs

FERC DER Aggregation advances debates over distributed energy resources as Congress presses action on Order 841, grid resilience, and wholesale market access, including rooftop solar, storage, and virtual power plant participation across PJM and ISO-NE.

 

Key Points

FERC DER Aggregation enables grouped distributed resources to join wholesale markets, providing capacity and flexibility.

? Opens wholesale market access for aggregated DER portfolios

? Aligns with Order 841, storage, and grid resilience goals

? Raises jurisdictional questions between FERC and state regulators

 

The Monday letter from Congressional Democrats illustrates growing frustration in Washington over the lack of FERC action on multiple power sector issues, including the aging U.S. grid and related challenges.

Last May, after the FERC technical conference, 16 Democratic Senators wrote to then-Chairman Kevin McIntyre urging him to develop guidance for grid operators on aggregated DERs.

In July, McIntyre responded, saying that FERC was "diligently reviewing the record," but the commission has taken no action since.

Since then, "DER adoption and renewable energy aggregation have continued to grow," House and Senate lawmakers wrote in their identical Monday letters, "driven not only by state and federal policies, but consumer interest in choosing cost-competitive technologies such as rooftop solar, smart thermostats and customer-sited energy generation and storage, reflecting key utility trends in the sector."

The lawmakers wrote they were "encouraged" by FERC Chairman Neil Chatterjee's comments in June 2018, writing that he "specifically cited the role DERs will play in our continued grid transition."

In that speech at the S&P Global Platts 2018 Transmission Planning and Development Conference, Chatterjee noted "growing interest" in non-transmission alternatives, including "DERs and storage."

"How the Commission treats filings associated with those first-of-kind projects could prove an important factor in investors’ assessments of whether similar non-traditional projects are bankable or not — and more broadly signal whether FERC is open to innovation in the transmission sector,” he said.

In addition to the DER order and rehearing decision on Order 841, FERC has multiple other power sector initiatives that have not seen official action in months, even as major changes to electricity pricing are debated by stakeholders.

The highest profile is its open proceeding on grid resilience, set up last January after FERC rejected a coal and nuclear bailout proposal from the Department of Energy. In October, the CEO of the PJM Interconnection, the nation’s largest wholesale power market, urged FERC to issue a final order in the docket, calling for "leadership" from the commission.

Chatterjee, however, has not indicated when FERC could decide on the case. In December, Commissioner Rich Glick told a Washington audience he is "not entirely sure where the chairman wants to go with that proceeding yet."

Outside of resilience, FERC also has open reviews of both its pipeline certificate policy and implementation of the Public Utilities Regulatory Policy Act, a key law supporting renewable energy. McIntrye set those reviews in motion during his tenure as chairman, but after his death in January the timing of both remains unclear.

In recent months, Chatterjee has also delayed FERC votes on major export facilities for liquefied natural gas and a political spending case involving PJM after impasses between Republicans and Democrats on FERC.

Two members from each party currently sit on the commission. That allows Democrats to deadlock commission votes on natural gas facilities and other issues — a partisan divide on display this week when they clashed with the chairman over offshore wind.

As the commission considers final guidance on DERs, the boundaries of federal jurisdiction are likely to be a key issue. At the technical conference, states from the Midcontinent ISO argued FERC should allow them to choose whether to let aggregated DERs participate in retail and wholesale markets. Other states argued the value proposition of distributed resources may rely on that sort of dual participation.

Despite the lack of action from FERC, some grid operators are moving forward with aggregated distributed resources in New England market reform efforts and elsewhere, demonstrating momentum. Last week, a residential solar-plus-storage aggregation cleared the ISO-NE capacity auction for the first time, committing to provide 20 MW of capacity beginning in 2022.

On the Senate side, Sens. Sheldon Whitehouse, R.I., and Ed Markey, Mass., led the letter to FERC. In the House, Reps. Peter Welch, Vt., and Mike Levin, Calif., led the signatories.

 

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The City of Vancouver is hosting an ABB FIA Formula E World Championship race next year, organizers have announced

Vancouver Formula E 2022 delivers an all-electric, net-zero motorsport event in False Creek, featuring sustainability initiatives, clean mobility showcases, concerts, and tourism boosts, with major economic impact, jobs, and a climate action conference.

 

Key Points

A net-zero, all-electric race in False Creek, uniting EV motorsport with sustainability, concerts, and local jobs.

✅ Net-zero, all-electric FIA championship round in Canada

✅ False Creek street circuit with concerts and green mobility expo

✅ Projected $80M impact and thousands of local jobs

 

The City of Vancouver is hosting an ABB FIA Formula E World Championship race next year, organizers have announced, aligning with the city's EV-ready policy to accelerate adoption.

The all-electric race is being held in the city's False Creek neighbourhood over the 2022 July long weekend as green energy investments accelerate nationwide, according to promoter OSS Group Inc.

Earlier this year, Vancouver city council voted unanimously in support of a multi-day Formula E event that would include a conference on climate change and sustainability amid predicted EV-demand bottlenecks in B.C.

"Formula E is a win on so many levels, from being a net-zero event that supports sustainable transportation to being a huge boost for our hard-hit tourism sector, our residents, who can access rebates for home and workplace charging, and our local economy," Coun. Sarah Kirby-Yung said in a news release Thursday.

As the region advances sustainable mobility, B.C.'s EV charging expansion continues to lead the country.

The promoter said the Formula E race will bring $80 million in economic value and thousands of jobs to the city, with infrastructure like new EV chargers at YVR also underway, but did not provide any details on how it came to those estimates.

More details on the events surrounding the race, including planned concerts and other EV showcases like Everything Electric, are expected to be announced in the fall.

The last time a Formula E World Championship event came to Canada was the Montreal ePrix in 2017. Montreal Mayor Valerie Plante later cancelled planned Formula E events for 2018 and 2019, citing cost overruns and sponsorship troubles.

 

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Putting Africa on the path to universal electricity access

West and Central Africa Electricity Access hinges on utility reform, renewable energy, off-grid solar, mini-grids, battery storage, and regional grid integration, lowering costs, curbing energy poverty, and advancing SDG7 with sustainable, reliable power solutions.

 

Key Points

Expanding reliable power via renewables, grid trade, and off-grid systems to cut energy poverty and unlock inclusive growth.

✅ Utility reform lowers costs and improves service reliability

✅ Regional grid integration enables clean, least-cost power trade

✅ Off-grid solar and mini-grids electrify remote communities

 

As commodity prices soar and leaders around the world worry about energy shortages and prices of gasoline at the pump, millions of people in Africa still lack access to electricity.  One-half of the people on the continent cannot turn on a fan when temperatures go up, can’t keep food cool, or simply turn the lights on. This energy access crisis must be addressed urgently.

In West and Central Africa, only three countries are on track to give every one of their people access to electricity by 2030. At this slow pace, 263 million people in the region will be left without electricity in ten years.  West Africa has one of the lowest rates of electricity access in the world; only about 42% of the total population, and 8% of rural residents, have access to electricity.

These numbers, some far too big, others far too small, have grave consequences. Electricity is an important step toward enhancing people’s opportunities and choices. Access is key to boosting economic activity and contributes to improving human capital, which, in turn, is an investment in a country’s potential.  

Without electricity, children can’t do their schoolwork at night. Businesspeople can’t get information on markets or trade with each other. Worse, as the COVID-19 pandemic has shown so starkly, limited access to energy constrains hospital and emergency services, further endangering patients and spoiling precious medicine.  

What will it take to power West and Central Africa?  
As the African continent recovers from COVID-19 impacts, now is the critical time to accelerate progress towards universal energy access to drive the region’s economic transformation, promote socio-economic inclusion, and unlock human capital growth. Without reliable access to electricity, the holes in a country’s social fabric can grow bigger, those without access growing disenchanted with inequality.  

Tackling the Africa region’s energy access crisis requires four bold approaches. 

First, this involves making utilities financially viable. Many power providers in the region are cash-strapped, operate dilapidated and aging generation fleet and infrastructure. Therefore, they can’t deliver reliable and affordable electricity to their customers, let alone deliver electricity to those that currently must rely on inadequate alternatives to electricity. Overall, fewer than half of the utilities in Sub-Saharan Africa recover their operating costs, resulting in GDP losses as high as four percent in some countries.

Improving the performance of national utilities and greening their power generation mix is a prerequisite to lowering the costs of supply, thus expanding electricity access to those currently unelectrified, usually lower-income and often remote households. 

In that effort — and this a critical second point — West and Central African countries need to look beyond their borders and further integrate their national utilities and grids to other systems in the region. The region has an abundance of affordable clean energy sources — hydropower in Guinea, Mali, and Cote d’Ivoire; high solar irradiation in the Sahel — but the regional energy market is fragmented. 

Without efficient regional trade, many countries are highly dependent on one or two energy resources and heavily reliant on inefficient, polluting generation sources, requiring fuel imports linked to volatile international oil prices.

The vision of an integrated regional power market in countries of the Economic Community of West African States (ECOWAS) is coming a step closer to reality thanks to an ambitious program of cross-border interconnection projects. If countries take full advantage of this grid, the share of the region’s electricity consumption traded across borders would more than double from 8 percent today to about 17 percent by 2030. Overall, regional power trade could lower the lifecycle cost of West Africa’s power generation system by about 10 percent and provide greener energy by 2030. 

Third, electrification efforts need to be open to private sector investments and innovations, such as renewables like solar energy and battery storage, which have made a tremendous impact in enabling access for millions of poor and underserved households.  Specifically, off-grid solar systems and mini-grids have become a proven reliable way to provide affordable modern electricity services, powering homes in rural communities, healthcare facilities, and schools.

Burkina Faso, which enjoys one of the best solar radiation conditions in the region, is a successful example of leveraging the transformative impact of solar energy and battery storage. With support from the World Bank, the country is deploying solar energy to power its national grid, as well as mini-grids and individual household systems. Solar power with battery storage is competitive in Burkina Faso compared to other technologies and its government was successful in attracting private sector investments to support this technology.

Last, achieving universal electricity access will involve significant commitment from political leaders, especially developing policies and regulations that can attract high-quality investments.  

A significant step in that direction was achieved at the World Bank’s 2020 Annual Meetings with a commitment to set up the Powering Transformation Platform in each African country. Through the platform, each government will set their country-specific vision, goals and metrics, track progress, and explore and exchange innovative ideas and emerging best practices according to their own national energy needs and plans. 

This platform will bring together the elements needed to bring electricity to all in West and Central Africa and help attract new financing.

Over the last 3 years, the World Bank has doubled its investments to increase electricity access rates in Central and West Africa.  We have committed more than $7.8 billion to support 40 electricity access programs, of which more than half directly support new electricity connections. These operations are expected to provide access to 16 million people. The aim is to increase electricity access rates in West and Central Africa from 50 percent today to 64 percent by 2026.

However, World Bank’s financing alone is not enough. Our estimates show that nearly $20 billion are required for universal electrification across Sub-Saharan Africa, aligning with calls to quadruple power investment to meet demand, with about $10 billion annually needed for West and Central Africa. 

Closing the funding gap will require mobilizing traditional and new partners, especially the private sector, which is willing to invest if enabling conditions are in place, as well as philanthropic capital, that can fill in the space in areas not yet commercially attractive. The World Bank is ready to play a catalytical role in leveraging new investments. 

This is vital as less than a decade remains to reach the 2030 SDG7 goal of ensuring electricity for all through affordable, reliable, and modern energy services. As headlines worldwide focus on soaring energy prices in the developed world, we cannot lose sight of the vast populations in Africa that still cannot access basic energy services. This is the true global energy crisis.  

 

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Report call for major changes to operation of Nova Scotia's power grid

Nova Scotia Energy Modernization Act proposes an independent system operator, focused energy regulation, coal phase-out by 2030, renewable integration, transmission upgrades, and competitive market access to boost consumer trust and grid reliability across the province.

 

Key Points

Legislation to create an independent system operator and energy regulator, enabling coal phase-out and renewable integration.

✅ Transfers grid control from Nova Scotia Power to an ISO

✅ Establishes a focused energy regulator for multi-sector oversight

✅ Accelerates coal retirement, renewables build-out, and grid upgrades

 

Nova Scotia is poised for a significant overhaul in how its electricity grid operates, with the electricity market headed for a reshuffle as the province vows changes, following a government announcement that will strip the current electric utility of its grid access control. This move is part of a broader initiative to help the province achieve its ambitious energy objectives, including the cessation of coal usage by 2030.

The announcement came from Tory Rushton, the Minister of Natural Resources, who highlighted the recommendations from the Clean Electricity Task Force's report to make the electricity system more accountable to Nova Scotians according to the authors. The report suggests the creation of two distinct entities: an autonomous system operator for energy system planning and an independent body for energy regulation.

Minister Rushton expressed the government's agreement with these recommendations, while the premier had earlier urged regulators to reject a 14% rate hike to protect customers, stating plans to introduce a new Energy Modernization Act in the next legislative session.

Under the proposed changes, Nova Scotia Power, a privately-owned entity, will retain its operational role but will relinquish control over the electricity grid. This responsibility will shift to an independent system operator, aiming to foster competitive practices essential for phasing out coal—currently a major source of the province’s electricity.

Additionally, the existing Utility and Review Board, which recently approved a 14% rate increase despite political opposition, will undergo rebranding to become the Nova Scotia Regulatory and Appeals Board, reflecting a broader mandate beyond energy. Its electricity-related duties will be transferred to the newly proposed Nova Scotia Energy Board, which will oversee various energy sectors including electricity, natural gas, and retail gasoline.

The task force, led by Alison Scott, a former deputy energy minister, and John MacIsaac, an ex-executive of Nalcor Energy, was established by the province in April 2023 to determine the needs of the electrical system in meeting Nova Scotia's environmental goals.

Minister Rushton praised the report for providing a clear direction towards achieving the province's 2030 environmental targets and beyond. He estimated that establishing the recommended bodies would take 18 months to two years, and noted the government cannot order the utility to cut rates under current law, promising job security for current employees of Nova Scotia Power and the Utility and Review Board throughout the transition.

The report advocates for the new system operator to improve consumer trust by distancing electricity system decisions from Nova Scotia Power's corporate interests. It also critiques the current breadth of the Utility and Review Board's mandate as overly extensive for addressing the energy transition's long-term requirements.

Nova Scotia Power's president, Peter Gregg, welcomed the recommendations, emphasizing their role in the province's shift towards renewable energy, as neighboring jurisdictions like P.E.I. explore community generation to build resilience, he highlighted the importance of a focused energy regulator and a dedicated system operator in advancing essential projects for reliable customer service.

The task force's 12 recommendations also include the requirement for Nova Scotia Power to submit an annual asset management plan for regulatory approval and to produce reports on vegetation and wood pole management. It suggests the government assess Ontario's hydro policies for potential adaptation in Nova Scotia and calls for upgrades to the transmission grid infrastructure, with projected costs detailed by Stantec.

Alison Scott remarked on the comparative expense of coal power against renewable sources like wind, suggesting that investments in the grid to support renewables would be economically beneficial in the long run.

 

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$453M Manitoba Hydro line to Minnesota could face delay after energy board recommendation

Manitoba-Minnesota Transmission Project faces NEB certificate review, with public hearings, Indigenous consultation, and cross-border approval weighing permit vs certificate timelines, potential land expropriation, and Hydro's 2020 in-service date for the 308-MW intertie.

 

Key Points

A cross-border hydro line linking Manitoba and Minnesota, now under NEB review through a permit or certificate process.

✅ NEB recommends certificate with public hearings and cabinet approval

✅ Stakeholders cite land, health, and economic impacts along route

✅ Hydro targets May-June 2020 in-service despite review

 

A recommendation from the National Energy Board could push back the construction start date of a $453-million hydroelectric transmission line from Manitoba to Minnesota.

In a letter to federal Natural Resources Minister Jim Carr, the regulatory agency recommends using a "certificate" approval process, which could take more time than the simpler "permit" process Manitoba Hydro favours.

The certificate process involves public hearings, reflecting First Nations intervention seen in other power-line debates, to weigh the merits of the project, which would then go to the federal cabinet for approval.

The NEB says this process would allow for more procedural flexibility and "address Aboriginal concerns that may arise in the circumstances of this process."

The Manitoba-Minnesota Transmission Project would provide the final link in a chain that brings hydroelectricity from generating stations in northern Manitoba, through the Bipole III transmission line and, like the New England Clean Power Link project, across the U.S. border as part of a 308-megawatt deal with the Green Bay-based Wisconsin Public Service.

When Hydro filed its application in December 2016, it had expected to have approval by the end of August 2017 and to begin construction on the line in mid-December, in order to have the line in operation by May or June 2020.  

Groups representing stakeholders along the proposed route of the transmission line had mixed reactions to the energy board's recommendation.

A lawyer representing a coalition of more than 120 landowners in the Rural Municipality of Taché and around La Broquerie, Man., welcomed the opportunity to have a more "fulsome" discussion about the project.

"I think it's a positive step. As people become more familiar with the project, the deficiencies with it become more obvious," said Kevin Toyne, who represents the Southeast Stakeholders Coalition.

Toyne said some coalition members are worried that Hydro will forcibly expropriate land in order to build the line, while others are worried about potential economic and health impacts of having the line so close to their homes. They have proposed moving the line farther east.

When the Clean Environment Commission — an arm's-length provincial government agency — held public hearings on the proposed route earlier this year, the coalition brought their concerns forward, echoing Site C opposition voiced by northerners, but Toyne says both the commission and Hydro ignored them.

Hydro still aiming for 2020 in-service date

The Manitoba Métis Federation also participated in those public hearings. MMF president David Chartrand worries about the impact a possible delay, as seen with the Site C work halt tied to treaty rights, could have on revenue from sales of hydroelectric power to the U.S.

"I know that a lot of money, billions have been invested on this line. And if the connection line is not done, then of course this will be sitting here, not gaining any revenue, which will affect every Métis in this province, given our Hydro bill's going to go up," Chartrand said.The NEB letter to Minister Carr requests that he "determine this matter in an expedited manner."

Manitoba Hydro spokesperson Bruce Owen said in an email that the Crown corporation will participate in whatever process, permit or certificate, the NEB takes.

"Manitoba Hydro does not have any information at this point in time that would change the estimated in-service date (May-June 2020) for the Manitoba-Minnesota Transmission Project," he said.

The federal government "is currently reviewing the NEB's recommendation to designate the project as subject to a certificate, which would result in public hearings," said Alexandre Deslongchamps, a spokesperson for Carr.

"Under the National Energy Board Act, an international power line requires either the approval by the NEB through a permit or approval by the Government of Canada by a certificate. Both must be issued by the NEB," he wrote in an email to CBC News.

By law, the certificate process is not to take longer than 15 months.

 

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