Wisconsin Power and Light dealt wind farm setback

By The Capital Times


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Alliant Energy still plans to build a large wind farm in Fond du Lac County even though it is "disappointed" by a Public Service Commission of Wisconsin ruling regarding its financing.

Wisconsin Power & Light Co., Alliant's state utility unit, had applied for a permanent 12.9 percent rate of return for the Cedar Ridge Wind Farm under Act 7, a 2005 state law that provides for setting permanent rates of return for individual utility projects such as power plants and wind farms.

The law is designed to provide a degree of certainty to a utility, investors, and ratepayers on the recovery of a facility's costs.

The PSC issued a preliminary, oral decision setting the rate of return for Cedar Ridge at 10.5 percent for its 20-year life.

"We are disappointed in the terms of the PSCW's decision and we believe that the decision is contrary to the intention of Wisconsin Act 7 to encourage investment in new generation, including renewable energy," William D. Harvey, Alliant chairman, president and CEO, said in a statement. "WP&L will review the final order and communicate whether or not it intends to make the investment in accordance with the terms and conditions of the PSCW's Act 7 decision."

Alliant also can choose to let the project fall under its overall rate of return, which is set annually by the PSC. Alliant's 2007 rate of return is 11.2 percent.

The choice is "kind of like the difference between a fixed-rate mortgage and an ARM (adjustable rate mortgage)," Alliant spokeswoman Erin Dammen said.

Dammen said Alliant would make its decision after the PSC issues its final, written order on the rate of return for Cedar Ridge under the Act 7 application.

Not moving forward with the project is "an absolute last resort if we could not justify going forward with the project from a financial perspective," Dammen said. "Right now we are only considering the options that would allow us to continue with the project, either by financing through Act 7 or through traditional rate base."

Alliant also is waiting for the PSC decision on its application to construct the 60- to 99-megawatt wind farm.

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Canada will need more electricity to hit net-zero: IEA report

Canada Clean Electricity Expansion is urged by the IEA to meet net-zero targets, scaling non-emitting generation, electrification, EV demand, and grid integration across provinces to decarbonize industry, buildings, and transport while ensuring reliability and affordability.

 

Key Points

An IEA-backed pathway for Canada to scale non-emitting power, electrification, and grid links to meet net-zero goals.

✅ Double or triple clean generation to replace fossil fuels

✅ Integrate provincial grids to decarbonize dependent regions

✅ Manage EV and heating loads with reliability and affordability

 

Canada will need more electricity capacity if it wants to hit its climate targets, and cleaning up Canada's electricity will be critical, according to a new report from the International Energy Agency (IEA).

The report offers mainly a rosy picture of Canada's overall federal energy policy. But, the IEA draws attention to Canada's increasing future electricity demands, and ultimately, calls on Canada to leverage its non-emitting energy potential and expand renewable energy to hit its climate targets.  

"Canada's wealth of clean electricity and its innovative spirit can help drive a secure and affordable transformation of its energy system and help realize its ambitious goals," stated Fatih Birol, the IEA executive director, in a news release.

The IEA notes that Canada has one of the cleanest energy grids globally, with 83 per cent of electricity coming from non-emitting sources in 2020. But this reflects nationwide progress in electricity to date; the report warns this is not a reason for Canada to rest on its laurels. More electricity will be needed to displace fossil fuels if Canada wants to hit its 2030 targets, the report states, and "even deeper cuts" will be required to reach net-zero by 2050.

"Perhaps more significantly, however, Canada will need to ensure sufficient new clean generation capacity to meet the sizeable levels of electrification that its net-zero targets imply."

Investing in new coal, oil and gas projects must stop to hit climate goals, global energy agency says
The Liberals have promised to create a 100 percent net-zero-emitting electricity system by 2035, with regulating oil and gas emissions and electric car sales as part of the plan; by then, every new light-duty vehicle sold in Canada will be a zero-emission vehicle. The switch from gas guzzlers to plug-in electric vehicles will create new pressures on Canada's electrical grid, as will any turn away from fossil natural gas for home heating.

To meet these challenges, the IEA warns, Canada would need to double or triple the power generated from non-emitting sources compared to today, a shift whose cost could reach $1.4 trillion according to the Canadian Gas Association. 

"Such a shift will require significant regulatory action," the report states, highlighting the need for climate policy for electricity grids to guide implementation, and that will require the federal government to work closely with provinces and territories that control power generation and distribution.

The report notes that the further integration of territorial and provincial electrical grids could allow fossil fuel-dependent provinces, like Alberta, to decarbonize and electrify their economies.

The report, entitled Canada 2022 Energy Policy Review, offers what it calls an "in-depth" look at the commitments Canada has made to transform its energy policy. Since the IEA conducted its last review in 2015, Canada has committed to cutting greenhouse gas emissions by 40 to 45 per cent from 2005 levels by 2030 and achieving net-zero by 2050 under an extended national target.

The IEA is well-known for the production of its annual World Energy Outlook. The Paris-based autonomous intergovernmental organization provides analysis, data, and policy recommendations to promote global energy security and sustainability. Canada is a part of the intergovernmental body, which also conducts peer reviews of its members' energy policy.


Oil and gas emissions rising
Natural Resources Minister Jonathan Wilkinson responded to the report in the IEA news release.

"This report acknowledges Canada's ambitious efforts and historic investments to develop pathways to achieve net-zero emissions by 2050 and ensure a transition that aligns with our shared objective of limiting global warming to 1.5 degrees Celsius," Wilkinson's statement read.

The report notes that — despite that objective — absolute emissions from Canadian oil and gas extraction went up 26 per cent between 2000 and 2019, largely from increased production.

Minister of Natural Resources Jonathan Wilkinson responds to a question at a news conference after the federal cabinet was sworn in, in Ottawa, on Oct. 26, 2021. (Justin Tang/The Canadian Press)
"Canada will need to reconcile future growth in oil sands production with increasingly strict greenhouse gas requirements," the report states.

On the plus side, the IEA found emissions per barrel of oilsands crude have decreased by 20 per cent in the last decade from technical and operational improvements.

The improving carbon efficiency of the oilsands is a "trend that is expected to continue at even higher rates," said Ben Brunnen, vice-president of oilsands, fiscal and economic policy at the Canadian Association of Petroleum Producers.

That may become important, the IEA report notes, as energy investors and buyers look for low-carbon assets and more countries adopt net-zero policies.

Further innovation, such as carbon capture and storage, could help to turn things around for Canada's oil patch, the report says. The Liberals have also said they will place a hard cap on oil and gas emissions from production, but that does not include the burning of the fossil fuels. 

In 2021, the IEA released a report that determined to achieve net-zero by 2050, among many steps, investments needed to end in coal mines, oil and gas wells. Thursday's report, however, made no mention of that, which disappointed at least one environmental group.

"A glaring omission was that this assessment says nothing about production. We know that the most important thing we can do is to stop using and producing oil and gas," said Julia Levin, a senior climate and energy program manager at Environmental Defence.

"And yet that was absent from this report, and that really is a glaring omission, which is completely out of line with their [the IEA's] own work."

 

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Can Europe's atomic reactors bridge the gap to an emissions-free future?

EU Nuclear Reactor Life Extension focuses on energy security, carbon-free electricity, and safety as ageing reactors face gas shortages, high power prices, and regulatory approvals across the UK and EU amid winter supply risks.

 

Key Points

EU Nuclear Reactor Life Extension is the policy to keep ageing reactors safely generating affordable, low-carbon power.

✅ Extends reactor operation via inspections and component upgrades

✅ Addresses gas shortages, price volatility, and winter supply risks

✅ Requires national regulator approval and cost-benefit analysis

 

Shaken by the loss of Russian natural gas since the invasion of Ukraine, European countries are questioning whether they can extend the lives of their ageing nuclear reactors to maintain the supply of affordable, carbon-free electricity needed for net-zero across the bloc — but national regulators, companies and governments disagree on how long the atomic plants can be safely kept running.

Europe avoided large-scale blackouts last winter despite losing its largest supplier of natural gas, and as Germany temporarily extended nuclear operations to bolster stability, but industry is still grappling with high electricity prices and concerns about supply.

Given warnings from the International Energy Agency that the coming winters will be particularly at risk from a global gas shortage, governments have turned their attention to another major energy source — even as some officials argue nuclear would do little to solve the gas issue in the near term — that would exacerbate the problem if it too is disrupted: Europe’s ageing fleet of nuclear power plants.

Nuclear accounts for nearly 10% of energy consumed in the European Union, with transport, industry, heating and cooling traditionally relying on coal, oil and natural gas.

Historically nuclear has provided about a quarter of EU electricity and 15% of British power, even as Germany shut down its last three nuclear plants recently, underscoring diverging national paths.

Taken together, the UK and EU have 109 nuclear reactors running, even as Europe is losing nuclear power in several markets, most of which were built in the 1970s and 1980s and were commissioned to last about 30 years.

That means 95 of those reactors — nearly 90% of the fleet — have passed or are nearing the end of their original lifespan, igniting debates over how long they can safely continue to be granted operating extensions, with some arguing it remains a needed nuclear option for climate goals despite age-related concerns.

Regulations differ across borders, with some countries such as Germany turning its back on nuclear despite an ongoing energy crisis, but life extension discussions are usually a once-a-decade affair involving physical inspections, cost/benefit estimates for replacing major worn-out parts, legislative amendments, and approval from the national nuclear safety authority.

 

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Top Senate Democrat calls for permanent renewable energy, storage, EV tax credits

Clean Energy Tax Incentives could expand under Democratic proposals, including ITC, PTC, and EV tax credits, boosting renewable energy, energy storage, and grid modernization within a broader infrastructure package influenced by Green New Deal goals.

 

Key Points

Federal incentives like ITC, PTC, and EV credits that cut costs and speed renewables, storage, and grid upgrades.

✅ Proposes permanence for ITC, PTC, and EV tax credits

✅ Could accelerate solar, wind, storage, and grid upgrades

✅ Passage depends on bipartisan infrastructure compromise

 

The 115th U.S. Congress has not even adjourned for the winter, and already a newly resurgent Democratic Party is making demands that reflect its majority status in the U.S. House come January.

Climate appears to be near the top of the list. Last Thursday, Senator Chuck Schumer (D-NY), the Democratic Leader in the Senate, sent a letter to President Trump demanding that any infrastructure package taken up in 2019 include “policies and funding to transition to a clean energy economy and mitigate the risks that the United States is already facing due to climate change.”

And in a list of policies that Schumer says should be included, the top item is “permanent tax incentives for domestic production of clean electricity and storage, energy efficient homes and commercial buildings, electric vehicles, and modernizing the electric grid.”

In concrete terms, this could mean an extension of the Investment Tax Credit (ITC) for solar and energy storage, the Production Tax Credit (PTC) for wind and the federal electric vehicle (EV) tax credit program as well.

 

Pressure from the Left

This strong statement on climate change, clean energy and infrastructure investment comes as at least 30 incoming members of the U.S. House of Representatives have signed onto a call for the creation of a committee to explore a “Green New Deal” and to move the nation to 100% renewable energy by 2030.*

It also comes as Schumer has come under fire by activists for rumors that he plans to replace Senator Maria Cantwell (D-Washington) with coal state Democrat Joe Manchin (D-West Virginia) as the top Democrat on the Senate Energy and Natural Resources Committee.

As such, one possible way to read these moves is that centrist leaders like Schumer are responding to pressure from an energized and newly elected Left wing of the Democratic Party. It is notable that Schumer’s program includes many of the aims of the Green New Deal, while avoiding any explicit use of that phrase.

 

Implications of a potential ITC extension

The details of levels and timelines are important here, particularly for the ITC.

The ITC was set to expire at the end of 2016, but was extended in legislative horse-trading at the end of 2015 to a schedule where it remains at 30% through the end of 2019 and then steps down for the next three years, and disappears entirely for residential projects. Since that extension the IRS has issued guidance around the use of co-located energy storage, as well as setting a standard under which PV projects can claim the ITC for the year that they begin construction.

This language around construction means that projects can start work in 2019, complete in 2023 and still claim the 30% ITC, and this may be why we at pv magazine USA are seeing an unprecedented boom in project pipelines across the United States.

Of course, if the ITC were to become permanent some of those projects would be pushed out to later years. But as we saw in 2016, despite an extension of the ITC many projects were still completed before the deadline, leading to the largest volume of PV installed in the United States in any one year to date.

This means that if the ITC were extended by the end of 2020, we could see the same thing all over again – a boom in projects created by the expected sunset, and then after a slight lull a continuation of growth.

Or it is possible that a combination of raw economics, increased investor and utility interest, and accelerating renewable energy mandates will cause solar growth rates to continue every year, and that any changes in the ITC will only be a bump against a larger trend.

While the basis for expiration of the EV tax credit is the number of vehicles sold, not any year, both the battery storage and EV industries, which many see at an inflection point, could see similar effects if the ITC and EV tax credits are made permanent.

 

Will consensus be reached?

It is also unclear that any such infrastructure package will be taken up by Republicans, or that both parties will be able to come to a compromise on this issue. While the U.S. Congress passed an infrastructure bill in 2017, given the sharp and growing differences between the two parties, and divergent trade approaches such as the 100% tariff on Chinese-made EVs, it is not clear that they will be able to come to a meaningful compromise during the next two years.

 

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Hydro One crews restore power to more than 277,000 customers following damaging storms in Ontario

Hydro One Power Restoration showcases outage recovery after a severe windstorm, with crews repairing downed power lines, broken poles and crossarms, partnering with utilities and contractors to boost grid resilience and promote emergency kit preparedness.

 

Key Points

A coordinated response by Hydro One and partners to repair storm damage, restore outages, strengthen grid resilience.

✅ Crews repaired downed lines, broken poles, and crossarms

✅ Partners and contractors aided rapid outage restoration

✅ Investments improve grid resilience and emergency readiness

 

Hydro One crews have restored power to more than 277,000 customers following back-to-back storms, with impacts felt in communities like Sudbury where local crews worked to reconnect service, including a damaging windstorm on that caused 57 broken poles, 27 broken crossarms, as well as downed power lines and fallen trees on lines. Hydro One crews restored power to more than 140,000 customers within 24 hours of Friday's windstorm, even as Toronto outages persisted for some customers elsewhere.

'We understand power outages bring life to a halt, which is why we are continuously improving our storm response, as employee COVID-19 support demonstrated, while making smart investments in a resilient, reliable and sustainable electricity system to energize life for families, businesses and communities for years to come,' said David Lebeter, Chief Operating Officer, Hydro One. 'We thank our customers for their patience as our crews worked tirelessly, alongside our utility partners and contractors, including Ontario crews in Florida, to restore power as quickly and as safely as possible.'

Hydro One thanks all of its utility partners and contractors who assisted with restoration efforts following the windstorm (alongside similar Quebec outages that highlighted the broader impact), including Durham High Voltage, EPCOR, ERTH Power, K-Line Construction Ltd., Lakeland Power Distribution Ltd., North Bay Hydro, Sproule Powerline Construction Ltd. and Valard Construction.

Hydro One encourages customers to restock their emergency kits following these storms, which utilities such as BC Hydro have also characterized as atypical, and to be aware of support programs like our pandemic relief fund that can help during difficult periods, to ensure they're prepared for an emergency or extended power outage.

 

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Judge: Texas Power Plants Exempt from Providing Electricity in Emergencies

Texas Blackout Liability Ruling clarifies appellate court findings in Houston, citing deregulated energy markets, ERCOT immunity, wholesale generators, retail providers, and 2021 winter storm lawsuits over grid failures and wrongful deaths.

 

Key Points

Houston judges held wholesale generators owe no duty to retail customers, limiting liability for 2021 blackout lawsuits.

✅ Court cites deregulated market and lack of privity to consumers

✅ Ruling shields generators from 2021 winter storm civil suits

✅ Plaintiffs plan appeals; legislature may address liability

 

Nearly three years after the devastating Texas blackout of 2021, a panel of judges from the First Court of Appeals in Houston has determined that major power companies cannot be held accountable for their failure to deliver electricity during the power grid crisis that unfolded, citing Texas' deregulated energy market as the reason.

This ruling appears likely to shield these companies from lawsuits that were filed against them in the aftermath of the blackout, leaving the families of those affected uncertain about where to seek justice.

In February 2021, a severe cold front swept over Texas, bringing extended periods of ice and snow. The extreme weather conditions increased energy demand while simultaneously reducing supply by causing power generators and the state's natural gas supply chain to freeze. This led to a blackout that left millions of Texans without power and water for nearly a week.

The state officially reported that almost 250 people lost their lives during the winter storm and subsequent blackout, although some analysts argue that this is a significant undercount and warn of blackout risks across the U.S. during severe heat as well.

In the wake of the storm, Texans affected by the energy system's failure began filing lawsuits, and lawmakers proposed a market bailout as political debate intensified. Some of these legal actions were directed against power generators whose plants either ceased to function during the storm or ran out of fuel for electricity generation.

After several years of legal proceedings, a three-judge panel was convened to evaluate the merits of these lawsuits.

This week, Chief Justice Terry Adams issued a unanimous opinion on behalf of the panel, stating, "Texas does not currently recognize a legal duty owed by wholesale power generators to retail customers to provide continuous electricity to the electric grid, and ultimately to the retail customers."

The opinion further clarified that major power generators "are now statutorily precluded by the legislature from having any direct relationship with retail customers of electricity."

This separation of power generation from transmission and retail electric sales in many parts of Texas resulted from energy market deregulation in the early 2000s, with the goal of reducing energy costs, and prompted electricity market reforms aimed at avoiding future blackouts.

Under the previous system, power companies were "vertically integrated," controlling generators, transmission lines, and selling the energy they produced directly to regional customers. However, in deregulated areas of Texas, competition was introduced, creating competing energy-generating companies and retail electric providers that purchase power wholesale and then sell it to residential consumers; meanwhile, electric cooperatives in other parts of the state remained member-owned providers.

Tré Fischer, a partner at the Jackson Walker law firm representing the power companies, explained, "One consequence of that was, because of the unbundling and the separation, you also don't have the same duties and obligations [to consumers]. The structure just doesn't allow for that direct relationship and correspondingly a direct obligation to continually supply the electricity even if there's a natural disaster or catastrophic event."

In the opinion, Justice Adams noted that when designing the Texas energy market, amid renewed interest in ways to improve electricity reliability across the grid, state lawmakers "could have codified the retail customers' asserted duty of continuous electricity on the part of wholesale power generators into law."

The recent ruling applies to five representative cases chosen by the panel out of hundreds filed after the blackout. Due to this decision, it is improbable that any of the lawsuits against power companies will succeed, according to the court's interpretation.

However, plaintiffs' attorneys have indicated their intention to appeal. They may request a review of the panel's opinion by the entire First Court of Appeals or appeal directly to the state supreme court.

The state Supreme Court had previously ruled that the Electric Reliability Council of Texas (ERCOT), the state's power grid operator, enjoys sovereign immunity and cannot be sued over the blackout.

This latest opinion raises the question of who, if anyone, can be held responsible for deaths and losses resulting from the blackout, a question left unaddressed by the court. Fischer commented, "If anything [the judges] were saying that is a question for the Texas legislature."

 

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Disrupting Electricity? This Startup Is Digitizing Our Very Analog Electrical System

Solid-State AC Switching reimagines electrification with silicon-based, firmware-driven controls, smart outlets, programmable circuit breakers, AC-DC conversion, and embedded sensors for IoT, energy monitoring, surge protection, and safer, globally compatible devices.

 

Key Points

Solid-state AC switching replaces mechanical switches with silicon chips for intelligent, programmable power control.

✅ Programmable breakers trip faster and add surge and GFCI protection

✅ Shrinks AC-DC conversion, boosting efficiency and device longevity

✅ Enables sensor-rich, IoT-ready outlets with energy monitoring

 

Electricity is a paradox. On the one hand, it powers our most modern clean cars and miracles of computing like your phone and laptop. On the other hand, it’s one of the least updated, despite efforts to build a smarter electricity infrastructure nationwide, and most ready-for-disruption parts of our homes, offices, and factories.

A startup in Silicon Valley plans to change all that, in California’s energy transition where reliability is top of mind, and has just signed deals with leading global electronics manufacturers to make it happen.

“The end point of the electrification infrastructure of every building out there right now is based on old technology,” Thar Casey, CEO of Amber Solutions, told me recently on the TechFirst podcast. “Basically some was invented ... last century and some came in a little bit later on in the fifties and sixties.”

Ultimately, it’s an almost 18th century part of modern homes.

Even smart homes, with add-ons like the Tesla Powerwall, still rely on legacy switching.

The fuses, breakers, light switches, and electrical outlets in your home are ancient technology that would easily understood by Thomas Edison, who was born in 1847. When you flip a switch and instantly flood your room with light, it feels like a modern right. But you are simply pushing a piece of plastic which physically moves one wire to touch another wire. That completes a circuit, electricity flows, and ... let there be light.

Casey wants to change all that. To transform our hard-wired electrical worlds and make them, in a sense, soft wired. And the addressable market is literally tens of billions of devices.

The core innovation is a transition to solid-state switches.

“Take your table, which is a solid piece of wood,” Casey says. “If you can mimic what an electromechanical switch does, opening and closing, inside that table without any actual moving parts, that means you are now solid state AC switching.”

And solid-state is exactly what Silicon Valley is all about.

“Solid state it means it can be silicon,” Casey says. “It can be a chip, it can be smaller, it can be intelligent, you can have firmware, you can add software ... now you have a mini computer.”

That’s a significant innovation with a huge number of implications. It means that the AC to DC converters attached to every appliance you plug into the wall — the big “bricks” that are part of your power cord, for instance — can now be a tiny fraction of the size. Appliance run on DC, direct current, and the electricity in your walls is AC, alternating current; similar principles underpin advanced smart inverters in solar systems, and it needs to be converted before it’s usable, and that chunk of hardware, with electrolytics, magnetics, transformers and more, can now be replaced, saving space in thermostats, CO2 sensors, coffee machines, hair dryers, smoke detectors ... any small electric device.

(Since those components generally fail before the device does, replacing them is a double win.)

Going solid state also means that you can have dynamic input range: 45 volts all the way up to 600 volts.

So you can standardize one component across many different electric devices, and it’ll work in the U.S., it’ll work in Europe, it’ll work in Japan, and it will work whether it’s getting 100 or 120 or 220 volts.

Building it small and building it solid state has other benefits as well, Casey says, including a much better circuit breaker for power spikes as the U.S. grid faces climate change impacts today.

“This circuit breaker is programmable, it has intelligence, it has WiFi, it has Bluetooth, it has energy monitoring metering, it has surge protection, it has GFCI, and here’s the best part: we trip 3000 times faster than a mechanical circuit breaker.”

What that means is much more ambient intelligence that can be applied all throughout your home. Rather than one CO2 sensor in one location, every power outlet is now a CO2 sensor that can feed virtual power plant programs, too. And a particulate matter sensor and temperature sensor and dampness sensor and ... you name it.

Amber’s next-generation system-on-chip complete replacement for smart outlets
Amber’s next-generation system-on-chip complete replacement for smart outlets JOHN KOETSIER
“We put as many as fifteen functions ... in one single gang box in a wall,” Casey told me.

Solid state is the gift that keeps giving, because now every outlet can be surge-protected. Every outlet can have GFCI — ground fault circuit interruption — not just the ones in your bathroom. And every outlet and light switch in your home can participate in the sensor network that powers your home security system. Oh, and, if you want, Alexa or Siri or the Google Assistant too. Plus energy-efficient dimmers for all lighting appliances that don’t buzz.

So when can you buy Amber switches and outlets?

In a sense, never.

Casey says Amber isn’t trying to be a consumer-facing company and won’t bring these innovations to market themselves. This July, Amber announced a letter of intent with a global manufacturer that includes revenue, plus MOUs with six other major electronics manufacturers. Letters of intent can be a dime a dozen, as can memoranda of understanding, but attaching revenue makes it more serious and significant.

The company has only raised $6.7 million, according to Craft, and has a number of competitors, such as Blixt, which has funding from the European Union, and Atom Power, which is already shipping technology. But since Amber is not trying to be a consumer product and take its innovations to market itself, it needs much less cash to build a brand and a market. You’ll be able to buy Amber’s technology at some point; just not under the Amber name.

“We have over 25 companies that we’re in discussions with,” Casey says. “We’re going to give them a complete solution and back them up and support them toward success. Their success will be our success at the end of the day.”

Ultimately, of course, cost will be a big part of the discussion.

There are literally tens of billions of switches and outlets on the planet, and modernizing all of them won’t happen overnight. And if it’s expensive, it won’t happen quickly either, even as California turns to grid-scale batteries to ease strain.

Casey is a big cagey with costs — there are still a lot of variables, after all. But it seems it won’t cost that much more than current technology.

“This can’t be $1.50 to manufacture, at least not right now, maybe down the road,” he told me. “We’re very competitive, we feel very good. We’re talking to these partners. They recognize that what we’re bringing, it’s a cost that is cost effective.”

 

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