Early Coal Plant Phase-out Can be Achieved

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The Ontario Clean Air Alliance said that the province could shut down all 6,434 MW of its remaining coal-fired capacity in 2010 if it canceled all its coal-fired power exports and operated at higher capacity factors the five natural gas-fired plants that will be coming online over the next three years.

OCAA acknowledged, however, that those conditions would raise electricity rates in Ontario by 3.3%, but the costs would be outweighed by gains in air quality and public health.

OCAA said that canceling coal-fired power exports in 2010 will reduce Ontario's projected coal-fired generation by 50% and will raise rates by no more than 1%. Replacing the remaining coal-fired generation with generation from the new gas plants would raise rates another 2.3%.

Ontario's government originally had promised to shut down province-owned Ontario Power Generation's four remaining coal plants by the end of 2007. Later, it extended that deadline to early 2009 and then to the end of 2014.

"Advancing the coal phase-out date from 2014 to 2010 will save over 3,000 lives, prevent up to 1.6 million asthma attacks and provide 50 to 80% of the total greenhouse gas emission reductions Ontario needs to achieve compliance with its Kyoto Protocol target for 2010," said OCAA Chairman Jack Gibbons.

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DP Energy Sells 325MW Solar Park to Medicine Hat

Saamis Solar Park advances Medicine Hat's renewable energy strategy, as DP Energy secures AUC approval for North America's largest urban solar, repurposing contaminated land; capacity phased from 325 MW toward an initial 75 MW.

 

Key Points

A 325 MW solar project in Medicine Hat, Alberta, repurposing contaminated land; phased to 75 MW under city ownership.

✅ City acquisition scales capacity to 75 MW in phased build

✅ AUC approval enables construction and grid integration

✅ Reuses phosphogypsum-impacted land near fertilizer plant

 

DP Energy, an Irish renewable energy developer, has finalized the sale of the Saamis Solar Park—a 325 megawatt (MW) solar project—to the City of Medicine Hat in Alberta, Canada. This transaction marks the development of North America's largest urban solar initiative, while mirroring other Canadian clean-energy deals such as Canadian Solar project sales that signal market depth.

Project Development and Approval

DP Energy secured development rights for the Saamis Solar Park in 2017 and obtained a development permit in 2021. In 2024, the Alberta Utilities Commission (AUC) granted approval for construction and operation, reflecting Alberta's solar growth trends in recent years, paving the way for the project's advancement.

Strategic Acquisition by Medicine Hat

The City of Medicine Hat's acquisition of the Saamis Solar Park aligns with its commitment to enhancing renewable energy infrastructure. Initially, the project was slated for a 325 MW capacity, which would significantly bolster the city's energy supply. However, the city has proposed scaling the project to a 75 MW capacity, focusing on a phased development approach, and doing so amid challenges with solar expansion in Alberta that influence siting and timing. This adjustment aims to align the project's scale with the city's current energy needs and strategic objectives.

Utilization of Contaminated Land

An innovative aspect of the Saamis Solar Park is its location on a 1,600-acre site previously affected by industrial activity. The land, near Medicine Hat's fertilizer plant, was previously compromised by phosphogypsum—a byproduct of fertilizer production. DP Energy's decision to develop the solar park on this site exemplifies a productive reuse of contaminated land, transforming it into a source of clean energy.

Benefits to Medicine Hat

The development of the Saamis Solar Park is poised to deliver multiple benefits to Medicine Hat:

  • Energy Supply Enhancement: The project will augment the city's energy grid, much like municipal solar projects that provide local power, providing a substantial portion of its electricity needs.

  • Economic Advantages: The city anticipates financial savings by reducing carbon tax liabilities, as lower-cost solar contracts have shown competitiveness, through the generation of renewable energy.

  • Environmental Impact: By investing in renewable energy, Medicine Hat aims to reduce its carbon footprint and contribute to global sustainability efforts.

DP Energy's Ongoing Commitment

Despite the sale, DP Energy maintains a strong presence in Canada, where Indigenous-led generation is expanding, with a diverse portfolio of renewable energy projects, including solar, onshore wind, storage, and offshore wind initiatives. The company continues to focus on sustainable development practices, striving to minimize environmental impact while maximizing energy production efficiency.

The transfer of the Saamis Solar Park to the City of Medicine Hat represents a significant milestone in renewable energy development. It showcases effective land reutilization, strategic urban planning, and a shared commitment to sustainable energy solutions, aligning with federal green electricity procurement that reinforces market demand. This project not only enhances the city's energy infrastructure but also sets a precedent for integrating large-scale renewable energy projects within urban environments.

 

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Tucson Electric Power plans to end use of coal-generated electricity by 2032

Tucson Electric Power Coal Phaseout advances an Integrated Resource Plan to exit Springerville coal by 2032, lift renewables past 70 percent by 2035, add wind, solar, battery storage, and cut carbon emissions 80 percent.

 

Key Points

A 2032 coal exit and 2035 plan to lift renewables above 70 percent, add wind, solar, storage, and cut CO2 80 percent.

✅ Coal purchases end at Springerville units by 2032

✅ Renewables exceed 70 percent of load by 2035

✅ 80 percent CO2 cut from 2005 baseline via wind, solar, storage

 

In a dramatic policy shift, Tucson Electric Power says it will stop using coal to generate electricity by 2032 and will increase renewable energy's share of its energy load to more than 70% by 2035.

As part of that change, the utility will stop buying electricity from its two units at its coal-fired Springerville Generating Station by 2032. The plant, TEP's biggest power source, provides about 35% of its energy.

The utility already had planned to start up two New Mexico wind farms and a solar storage plant in the Tucson area by next year. The new plan calls for adding an additional 2,000 megawatts of renewable energy capacity by 2035.

The utility's switch from fossil fuels is spelled out in the plan, submitted to the Arizona Corporation Commission, amid shifts in federal power plant rules that could affect implementation. Called an Integrated Resource Plan, it would reduce TEP's carbon dioxide emissions 80% by 2035 compared with 2005 levels.

The plan drew generally positive reviews from a number of environmentalists and other representatives of an advisory committee that had worked with TEP for a year.

Two commissioners, Chairman Bob Burns and Tucsonan Lea Marquez Peterson, also generally praised the plan, although they held off on final judgment.

University of Arizona researchers said the plan would likely meet the utility's share of the worldwide goal of holding down global temperatures to less than 2 degrees Celsius, or about 3.6 degrees Fahrenheit, above pre-industrial levels, even as studies find that climate change threatens grid reliability in many regions.

But a representative of AARP and the Pima Council on Aging expressed concern because the plan would require 1% annual electric rate increases a year to put into effect.

Officials in the eastern Arizona town of Springerville aren't happy.

And Sierra Club official Sandy Bahr said the plan doesn't move fast enough to get TEP off coal. She listed 14 separate units of various Western coal-fired plants that are scheduled to shut down sooner than 2032, many in the 2020s.

But TEP says the plan best balances costs and environmental benefits compared with 24 others it reviewed.

"We know our customers want safe, reliable energy from resources that are both affordable and environmentally responsible. TEP's 2020 Integrated Resource Plan will help us maintain that delicate balance," TEP CEO David Hutchens wrote in the forward to the plan.

The plan isn't legally binding but is aimed at sending a signal to regulators and the public about TEP's future direction. TEP and other regulated Arizona utilities update such plans every three years.

TEP has been one of the West's more fossil-fuel-friendly utilities. It stuck with coal even as many other utilities were moving away from it, including Alliant Energy's carbon-neutral plan to cut emissions and costs, and as the Sierra Club called on utilities to move beyond what it termed a highly polluting energy source that emits large quantities of heat-trapping greenhouse gases linked by scientists to global warming.

Last year, TEP got 13% of its electricity from renewables such as wind farms and solar plants along with photovoltaic solar panels atop individual homes. Fossil fuels coal and natural gas supplied the rest, a University of Arizona study paid for by TEP found.

Economics, not just emissions, a big factor

TEP's previous resource plan, from 2017, called for boosting renewable use to 30% by 2030 and to cut coal to 38% of its electric load by then from 69% in 2017, reflecting broader 2017 utility trends across the industry.

A TEP official said last week the utility is heading in a different direction not only due to concerns about greenhouse gas emissions but because of changing economics.

"For the last several decades, coal was the most economical resource. It was the lowest-cost resource to supply energy for our customers, and it wasn't really close," said Jeff Yockey, TEP's resource planning director.

But over the past few years, first natural gas prices and more recently solar and wind energy prices have fallen dramatically, he said.

Their prices are projected to keep falling, along with the cost of battery-fueled storage of solar energy for use when the sun is down, he said.

"Coal just isn't the most economical resource" now, Yockey said.

Yet the utility still needs, for now, the extra energy capacity that coal provides, he said, even as other states outline ways to improve grid reliability through targeted investments.

"Being a utility with no nuclear or hydro(electric) energy, with coal, there is reliability, a fuel on the ground, 30 or 90 days supply," he said. "It's the only source not subject to disruption in the next hour. It's our only long-term, stable fuel supply. Over time, we will be able to overcome that."

UA researchers, community panel worked on plan

TEP paid the UA $100,000 to have three researchers prepare two reports, one comparing 24 different proposals and a second comparing TEP's fossil fuel/renewable split with those of other utilities.

Also, the utility appointed an advisory council representing environmental, business and government interests that met regularly to guide TEP in producing the plan. The utility chose a preferred energy "portfolio," Yockey said.

The goal "was very much about basically achieving significant emissions reductions as quickly as we can and as cost effectively as we can," he said. TEP wanted the biggest cumulative emission cut possible over 15 years.

"If it was just about cost, we wouldn't have selected the portfolio that we selected. It wasn't the lowest cost portfolio."

UA assistant research professors Ben McMahan and Will Holmgren said combined carbon dioxide emission reductions from TEP's new plan over 15 years would be expected to hit the Paris accord's 2-degree target.

"There is considerable uncertainty about what will happen between now and 2050, but the preferred portfolio's early start on reductions and lowest cumulative emissions is certainly a positive sign that well below 2C is achievable," the researchers said in an email.

Environmentalists pleased, but some want coal cut sooner

The Sierra Club, Western Resource Advocates, the Southwest Energy Efficiency Project and Pima County offered varying degrees of praise for the new TEP plan.

In a memo Friday, County Administrator Chuck Huckelberry congratulated TEP for "the comprehensive, inclusive and transparent process" used to develop the plan.

Because of UA's involvement, TEP's advisory council and the public "can feel confident that the utility is on track to make significant progress in curbing greenhouse gas emissions to combat climate change," Huckelberry wrote.

The TEP plan "is the most aggressive commitment to reducing emissions by a utility in Arizona," said Autumn Johnson of Western Resource Advocates in a news release.

"Adding clean energy generation and storage while accelerating the retirement of coal units will ensure a healthier and better future for Arizonans," said Johnson, an energy policy analyst in Phoenix.

The Sierra Club will have a technical expert review the plan and already wants more energy savings, said Bahr, director of the group's Grand Canyon chapter. But overall, this plan is a step in the right direction for TEP, she said.

By comparison, Arizona Public Service's new resource plan only calls for 45% renewable energy by 2030, Bahr noted, while California regulators consider more power plants to ensure reliability. APS committed to going coal-free by 2031.

A Sierra Club proposal that the UA reviewed called for TEP to quit coal by 2027.

But TEP analyzed that proposal and concluded it would require $300 million in investments and would reduce the utility's cumulative emissions by only 2.4 million tons, to 70.2 million tons by 2035, Yockey said.

The Sierra Club plan was the most expensive portfolio investigated, Yockey said.

"The difference is in the timing. We still have a fair amount of value in our coal plants which we need to depreciate, which we do over time," Yockey said. "Trying to replace the capacity that coal provides in the near term with storage and solar is very expensive, although those costs are declining."

Seniors on fixed incomes could be hurt, advocate says

Rene Pina, an advisory council member representing two senior citizen organizations, praised the plan's goals but was concerned about impacts of even 1% annual rate increases on elderly people on fixed incomes.

They can't always handle such an increase, he said.

One possible fix is that TEP could ease eligibility requirements for its low-income energy assistance program, aligning with equity-focused electricity regulation principles, to allow more seniors to benefit, said Pina, representing AARP and the Pima Council on Aging.

"The program is structured so it just barely disqualifies most of our seniors. Their social security pension is just barely over the low-income limit. It can easily be adjusted without any problems to the utility," Pina said.

Advisory council member Rob Lamb, an engineer with GHLN, an architecture-engineering firm, said he was very pleased with TEP's plan.

"One of the things a lot of people don't realize when they put together a plan like that, is they have to balance environment with 'Hey, what's the reliability of service? Are we going to be able to keep our rates for something that will work?'" Lamb said.

"This a very balanced and resilient portfolio."

 

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Electricity use actually increased during 2018 Earth Hour, BC Hydro

Earth Hour BC highlights BC Hydro data on electricity use, energy savings, and participation in the Lower Mainland and Vancouver Island amid climate change and hydroelectric power dynamics.

 

Key Points

BC observance tracking BC Hydro electricity use and conservation during Earth Hour, amid hydroelectric power dominance.

✅ BC Hydro reports rising electricity use during Earth Hour 2018

✅ Savings fell from 2% in 2008 to near zero province-wide

✅ Hydroelectric grid yields low GHG emissions in BC

 

For the first time since it began tracking electricity use in the province during Earth Hour, BC Hydro said customers used more power during the 60-minute period when lights are expected to dim, mirroring all-time high electricity demand seen recently.

The World Wildlife Fund launched Earth Hour in Sydney, Australia in 2007. Residents and businesses there turned off lights and non-essential power as a symbol to mark the importance of combating climate change.

The event was adopted in B.C. the next year and, as part of that, BC Hydro began tracking the megawatt hours saved.

#google#

In 2008, residents and businesses achieved a two per cent savings in electricity use. But since then, BC Hydro says the savings have plummeted.

The event was adopted in B.C. the next year and, as part of that, BC Hydro began tracking the megawatt hours saved.

In 2008, residents and businesses achieved a two per cent savings in electricity use. But since then, BC Hydro says the savings have plummeted, as record-breaking demand in 2021 and beyond changed consumption patterns.

 

Lights on

For Earth Hour this year, which took place 8:30-9:30 p.m. on March 24, BC Hydro says electricity use in the Lower Mainland increased by 0.5 per cent, even as it activated a winter payment plan to help customers manage bills. On Vancouver Island it increased 0.6 per cent.

In the province's southern Interior and northern Interior, power use remained the same during the event.

On Friday, the utility released a report called: "lights out". Why Earth Hour is dimming in BC. which explores the decline of energy savings related to Earth Hour in the province.

The WWF says the way in which hydro companies track electricity savings during Earth Hour is not an accurate measure of participation, and tracking of emerging loads like crypto mining electricity use remains opaque, and noted that more countries than ever are turning off lights for the event.

For 2018, the WWF shifted the focus of Earth Hour to the loss of wildlife across the globe.

BC Hydro says in its report that the symbolism of Earth Hour is still important to British Columbians, but almost all power generation in B.C. is hydroelectric, though recent drought conditions have required operational adjustments, and only accounts for one per cent of greenhouse gas emissions.

 

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Hydro One CEO's $4.5M salary won't be reduced to help cut electricity costs

Hydro One CEO Salary shapes debate on Ontario electricity costs, executive compensation, sunshine list transparency, and public disclosure rules, as officials argue pay is not driving planned hydro rate cuts for consumers.

 

Key Points

Hydro One CEO pay disclosed in public filings, central to debates on Ontario electricity rates and transparency.

✅ 2016 compensation: $4.5M (salary + bonuses)

✅ Excluded from Ontario's sunshine list after privatization

✅ Government says pay won't affect planned hydro rate cuts

 

The $4.5 million in pay received by Hydro One's CEO is not a factor in the government's plan to cut electricity costs for consumers, an Ontario cabinet minister said Thursday amid opposition concerns about the executive's compensation and wider sector pressures such as Manitoba Hydro's rising debt in other provinces.

Treasury Board President Liz Sandals made her comments on the eve of the release of the province's so-called sunshine list.

The annual disclosure of public-sector salaries over $100,000 will be released Friday, but Hydro One salaries such as that of company boss Mayo Schmidt won't be on it.Though the government still owns most of Hydro One — 30 per cent has been sold — the company is required to follow the financial disclosure rules of publicly traded companies, which means disclosing the salaries of its CEO, CFO and next three highest-paid executives, and financial results such as a Q2 profit decline in filings.

New filings show that Schmidt was paid $4.5 million in 2016 — an $850,000 salary plus bonuses — and those top five executives were paid a total of about $11.7 million. 

"Clearly that's a very large amount," said Sandals. Sandals wouldn't say whether or not she thought the pay was appropriate at a time when the government is trying to reduce system costs and cut people's hydro bills.

Mayo Schmidt, President & CEO of Hydro One Limited and Hydro One Inc. (Hydro One )

But she suggested the CEO's salary was not a factor in efforts to bring down hydro prices, even as Hydro One shares fell after a leadership shakeup in a later period. "The CEO salary is not part of the equation of will 'we be able to make the cut,"' she said. "Regardless of what those salaries are, we will make a 25-per-cent-off cut." The cut coming this summer is actually an average of 17 per cent -- the 25-per-cent figure factors in an earlier eight-per-cent rebate.

NDP Leader Andrea Horwath, who has proposed to make hydro public again in Ontario, said the executive salaries are relevant to cutting hydro costs.

"All of this is cost of operating the electricity system, it's part of the operating of Hydro One and so of course those increased salaries are going to impact the cost of our electricity," she said.

Schmidt was appointed Aug. 31, 2015, and in the last four months of that year earned $1.3 million, but the former CEO was paid $745,000 in 2014. About 3,800 workers were paid over $100,000 that year, none of whom will be on the sunshine list this year.

Progressive Conservative energy critic Todd Smith has a private member's bill that would put Hydro One salaries back on the list, amid investor concerns about Hydro One that cite too many unknowns.

"The Wynne Liberals don't want the people of Ontario to know that their rates have helped create a new millionaire's club at Hydro One," Smith said. "Hydro One is still under the majority ownership of the public, but Premier Kathleen Wynne has removed these salaries from the public's watchful eye."

The previous sunshine list showed 115,431 people were earning more than $100,000 — an increase of nearly 4,000 people despite the fact 3,774 Hydro One workers were not on the list for the first time.

Tom Mitchell, the former CEO at Ontario Power Generation who resigned last summer, topped the 2015 list at $1.59 million.

 

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NEW Hydro One shares down after Ontario government says CEO, board out

Hydro One Leadership Shakeup unsettles investors as Ontario government ousts CEO and board, pressuring shares; analysts cite political and regulatory risk, stock volatility, trimmed price targets, and dividend stability at the regulated utility.

 

Key Points

An abrupt CEO exit and board overhaul at Hydro One, driving share declines and raising political and regulatory risk.

✅ Shares fall as CEO retires and board resigns under provincial pressure.

✅ Analysts cut price targets; warn of political, regulatory risks.

✅ New board to pick CEO; province consults on compensation.

 

Hydro One Ltd. shares slid Thursday with some analysts sounding warnings of greater uncertainty after the new Ontario government announced the retirement of the electrical utility's chief executive and the replacement of its board of directors.

 After sagging by almost eight per cent in early trading on the Toronto Stock Exchange, following news that Q2 profit plunged 23% amid weaker electricity revenue, shares of the company were later down four per cent, or 81 cents, at $19.36 as of 11:42 a.m. ET.

On Wednesday, after stock markets had closed for the day, Ontario Premier Doug Ford announced the immediate retirement of Hydro One CEO Mayo Schmidt. He leaves with a $400,000 payout in lieu of post-retirement benefits and allowances, Hydro One said.

Doug Ford's government forces out Hydro One '$6-million man'

During the recent provincial election campaign, Ford vowed to fire Schmidt, who earned $6.2 million last year and whose salary wouldn't be reduced despite calls to cut electricity costs.

Paul Dobson, Hydro One's chief financial officer, will serve as acting CEO until a new top executive is selected.

Ford also said the entire board of directors of the utility would resign. Hydro One said a new board — four members of which will be nominated by the province — will select the company's next CEO, and the province will be consulted on the next leader's compensation.

A new board is expected to be formed by mid-August.

The provincial government is the largest single investor in Hydro One, holding a 47 per cent stake. The company was partly privatized by the former Liberal government in 2015, while the NDP has proposed to make hydro public again in Ontario to change course.

 

Doug Ford promises to keep Pickering nuclear plant open until 2024

In response to the government's move to supplant the utility's board and CEO, some analysts cautioned investors about too many unknowns in the near-term outlook, citing raised political or regulatory risks.

Analyst Jeremy Rosenfield of iA Securities cut his rating on Hydro One shares to hold from buy, and reduced his 12-month price target for the stock to $24 from $26.

Rosenfield said the stock is still a defensive investment supported by stable earnings and cash flows, good earnings growth and healthy dividend.

However, he said in a research note that "the heightened potential for further political interference in the province's electricity market and regulated utility framework represent key risk factors that are likely to outweigh Hydro One's fundamentals over the near term."

 

Potential challenge to find new CEO

Laurentian Bank Securities analyst Mona Nazir said in a research note that the magnitude of change all at once was "surprising but not shocking."

She said the agreement that will see Hydro One consult with the provincial government on matters involving executive pay could have an impact on the hiring of a new CEO for the utility.

"Given the government's open and public criticism of the company and a potential ceiling on compensation, it may be challenging to attract top talent to the position," she wrote.

Laurentian cut its rating on the Hydro One to hold and reduced its price target to $21 from $24.

Analysts at CIBC World Markets said investors face an uncertain future, noting parallels with debates at Manitoba Hydro over political direction.

"In particular, we are are concerned about the government meddling in with [power] rates," wrote Robert Catellier and Archit Kshetrapal in a research note, adding they believe the new provincial government is aiming for a 12 per cent reduction in customers' power bills.

CIBC reduced its price target on Hydro One's shares to $20.50 from its previous target of $24.

 

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COVID-19 crisis shows need to keep electricity options open, says Birol

Electricity Security and Firm Capacity underpin reliable supply, balancing variable renewables with grid flexibility via gas plants, nuclear power, hydropower, battery storage, and demand response, safeguarding telework, e-commerce, and critical healthcare operations.

 

Key Points

Ability to meet demand by combining firm generation and flexible resources, keeping grids stable as renewables grow.

✅ Balances variable renewables with dispatchable generation

✅ Rewards flexibility via capacity markets and ancillary services

✅ Enhances grid stability for critical loads during low demand

 

The huge disruption caused by the coronavirus crisis, and the low-carbon electricity lessons drawn from it, has highlighted how much modern societies rely on electricity and how firm capacity, such as that provided by nuclear power, is a crucial element in ensuring supply, International Energy Agency (IEA) Executive Director Fatih Birol said.

In a commentary posted on LinkedIn, Birol said: "The coronavirus crisis reminds us of electricity's indispensable role in our lives. It's also providing insights into how that role is set to expand and evolve in the years and decades ahead."

Reliable electricity supply is crucial for teleworking, e-commerce, operating ventilators and other medical equipment, among all its other uses, he said, adding that the hundreds of millions of people who live without any access to electricity are far more vulnerable to disease and other dangers.

"Although new forms of short-term flexibility such as battery storage are on the rise, and initiatives like UK home virtual power plants are emerging, most electricity systems rely on natural gas power plants - which can quickly ramp generation up or down at short notice - to provide flexibility, underlining the critical role of gas in clean energy transitions," Birol said.

"Today, most gas power plants lose money if they are used only from time to time to help the system adjust to shifts in demand. The lower levels of electricity demand during the current crisis are adding to these pressures. Hydropower, an often forgotten workhorse of electricity generation, remains an essential source of flexibility.

"Firm capacity, including nuclear power in countries that have chosen to retain it as an option, is a crucial element in ensuring a secure electricity supply even as soaring electricity and coal use complicate transitions. Policy makers need to design markets that reward different sources for their contributions to electricity security, which can enable them to establish viable business models."

In most economies that have taken strong confinement measures in response to the coronavirus - and for which the IEA has available data - electricity demand has declined by around 15%, largely as a result of factories and businesses halting operations, and in New York City load patterns were notably reshaped during lockdowns. If electricity demand falls quickly while weather conditions remain the same, the share of variable renewables like wind and solar can become higher than normal, and low-emissions sources are set to cover almost all near-term growth.

"With weaker electricity demand, power generation capacity is abundant. However, electricity system operators have to constantly balance demand and supply in real time. People typically think of power outages as happening when surging electricity demand overwhelms supply. But in fact, some of the most high-profile blackouts in recent times took place during periods of low demand," Birol said.

"When electricity from wind and solar is satisfying the majority of demand, and renewables poised to eclipse coal by 2025 are reshaping the mix, systems need to maintain flexibility in order to be able to ramp up other sources of generation quickly when the pattern of supply shifts, such as when the sun sets. A very high share of wind and solar in a given moment also makes the maintenance of grid stability more challenging."

 

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