Lobbyist spending in Kansas doubles amid coal fight

Iraq Electricity Crisis intensifies as summer heat drives demand; households face power outages, reliance on private generators, distorted tariffs, and strained grid capacity despite government reforms, Siemens upgrades, and IEA warnings.

Key Points

A supply-demand gap causing outages, generator reliance, and grid inefficiencies across Iraq, worsened by summer peaks.

✅ Siemens deal to upgrade generation and grid

✅ Progressive tariffs to curb demand and waste

✅ Private generators fill gaps but raise costs

At a demonstration in June 2018, protesters in Basra loaded a black box resembling a coffin with the inscription “Electricity” onto the roof of a car. This was one demonstration of how much of a political issue electricity is in Iraq.

With what is likely to be another hot summer ahead, there is increasing pressure on the Baghdad government to improve access to electricity and water.

Many Iraqis blame the government for not providing adequate services despite the country’s oil wealth. Protests in southern Iraq last year turned violent, with demonstrators attacking governmental and political parties’ buildings; in neighboring Iran, blackouts also sparked protests over outages.

“It is very hard” to deal with the electricity issues, said Iraqi journalist Methaq al-Fayyadh, adding that the lack of reliable electricity was not a new problem and affects most parts of the country.

Dozens of people protested June 1 in Karbala against prices for new generators and demanded an improvement to the electricity situation.

In anticipation of high temperatures during Eid al-Fitr, the Electricity Ministry called on governorates to adhere to allocated quotas and told the public to ration electricity.

“Outages remain a daily occurrence for most households because increasing generating capacity has been outrun by increasing demand for electricity, as surging demand worldwide demonstrates,” noted the International Energy Agency (IAE) in April.

This is particularly the case, the authors said, as the hot summer months, when temperatures can top 50 degrees Celsius, drive up the use of air conditioning.

The Iraqi government has made improving the electricity supply one of its priorities, including nuclear power plans under consideration. The Electricity Ministry, headed by Luay al-Khatteeb, announced in May that national electricity production had reached 17 gigawatts.

Khatteeb presented comparative electricity data for May from 2018 and 2019, indicating production increases on every day of the month. IEA data indicate that available electricity supply has increased over the past five years and the gap between supply and demand has widened.

The government signed an agreement with German company Siemens this year to upgrade Iraq’s electricity grid, and in parallel deals with Iran to rehabilitate and develop the grid were finalized, according to Iranian officials. The agreement “includes the addition of new and highly efficient power generation capacity, rehabilitation and upgrade of existing plants and the expansion of transmission and distribution networks,” Siemens said.

The Iraqi prime minister’s office said the 4-year plan would be worth $15.7 billion. The first phase includes the installation of 13 transformer stations, cooling systems for power stations and building a 500-megawatt, gas-fired power plant south of Baghdad.

In an interview with Al-Monitor, Khatteeb said radical changes would happen in 2020, stating that the current situation was not “ideal” but “better” because of steps taken to create more energy, amid discussions on energy cooperation with Iran that could shape implementation.

Robert Tollast, of the Iraq Energy Institute, said the economics of the electricity system is distorted. Subsidies ensured that electricity provided by the national grid is almost free, he said. However, while the subsidies were designed to help the poor, the tariff system disadvantages them and does not create incentives to consume electricity more efficiently, he said.

A large part of families’ electricity expenditures goes to operators of privately owned generators, which run on fuel. These neighbourhood generators are used to close gaps in the electricity supply but are expensive, and regional fuel arrangements such as ENOC’s swap of Iraqi fuel have highlighted supply constraints. Generator operators have sometimes worked with armed groups to prevent upgrades to the grid that could hurt their business.

Until 1990, the Iraq electricity sector was considered among the best in the region. That legacy was destroyed by successive wars and international sanctions. With Iraq’s population growing at a rate of 1 million per year, peak demand is projected to double by 2030 if left unchecked, the IEA estimated.

Tollast said efforts to improve the distribution system and increase capacity are key but it is important “to tackle the problem from the demand side.” This entails implementing a progressive tariff scheme so users pay more if they consume more, he said. There is a “tremendous use of energy per capita in Iraq,” Tollast said.

In the current tariff structure, consumers pay a fixed price if they use more than 4,000-kilowatt hours per year, a relatively low amount, meaning the price per unit drops the more one consumes.

Any change to the tariff system must be accompanied by a “political campaign” to explain the changes, said Tollast, adding that more investment in the electricity sector and a “change in culture” of using electricity was needed. “The current system is unsustainable, even with high oil prices,” he said.

Fayyadh said people don’t expect the government will be able to fix the electricity issue before summer, having failed to do so in the past.

Tollast struck a more optimistic tone, saying it was unlikely that Iran, which supplies about 40% of Iraq’s power, would cut its export of electricity to Iraq this year as it did in 2018. He added that the water situation was better than last year when the country experienced drought. Iraq has also been processing more flare gas, which can be used to generate electricity.

“There is an expectation that this year might not be as bad as last year,” he concluded.

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Smart Meter Texas real-time pricing faces rollback as utilities limit on-demand reads, impacting demand response, home area networks, ERCOT wholesale tracking, and thermostat automation, reducing efficiency gains promised through deregulation and smart meter investments.

Key Points

A plan linking smart meters to ERCOT prices, enabling near real-time usage alignment and automated demand response.

✅ Twice-hourly reads miss 15-minute ERCOT price spikes.

✅ Less than 1% of 7.3M meters use HAN real-time features.

✅ Limits hinder automation for HVAC, EV charging, and pool pumps.

Utilities made a promise several years ago when they built Smart Meter Texas that they’d come up with a way for consumers to monitor their electricity use in real time. But now they’re backing out of the deal with the approval of state regulators, leaving in the lurch retail power companies that are building their business model on the promise of real time pricing and denying consumers another option for managing their electricity costs.

Texas utilities collected higher rates to finance the building of a statewide smart meter network that would allow customers to track their electricity use and the quickly changing prices on wholesale power markets almost as they happened. Some retailers are building electricity plans around this promise, providing customers with in-home devices that would eventually track pricing minute-by-minute and allow them to automatically turn down or shut off air conditioners, pool pumps and energy sucking appliances when prices spiked on hot summer afternoons and turn them back on when they prices fell again.

The idea is to help save consumers money by allowing them to shift their electricity consumption to periods when power is cheaper, typically nights and weekends, even as utility revenue in a free-power era remains a debated topic.

“We’re throwing away a large part of (what) ratepayers paid for,” said John Werner, CEO of GridPlus Texas, one of the companies offering consumers a real-time pricing plan that is scheduled to begin testing next month. “They made the smart meters dumb meters.”

When Smart Meter Texas was launched a decade ago by a consortium of the state’s biggest utilities, it was considered an important part of deregulation. The competitive market for electricity held the promise that consumers would eventually have the technology to control their electricity use through a home area network and cut their power bills.

Regulators and legislators also were enticed by the possibility of making the electric system more efficient and relieving pressure on the power grid as consumers responded to high prices and cut consumption when temperatures soared, with ongoing discussions about Texas grid reliability informing policy choices.

One study found that smart meters coupled with smart real time consumption monitors could reduce electricity use between 3 percent and 5 percent, according to Call Me Power, a website sponsored by the European electricity price shopping service Selectra.

But utilities complained that the home area network devices were expensive to install and not used very often, and, with flat electricity demand weighing on growth, they questioned further investment. CenterPoint manager Esther Floyd Kent filed an affidavit with the commission in May that it costs the utility about $30,000 annually to support the network devices, plus maintenance.

Over a six-year period, CenterPoint paid $124,500, or about $20,000 a year, to maintain the system. As of April, there were only 4,067 network devices in CenterPoint’s service area, meaning the utility pays about $30.70 each year to maintain each device.

Centerpoint last year generated $9.6 billion in revenues and earned a $1.8 billion profit, according to its financial filings. CenterPoint officials did not respond to requests for comment.

Other utilities that are part of the Smart Meter consortium also complained to the Public Utility Commission that, up to now, the system hasn’t developed. All told, Texas has 7.3 million meters connected to Smart Meter Texas, but less than 1 percent are using the networking functions to track real-time prices and consumption, according to the testimony of Donny R. Helm, director of technology strategy and architecture for the state’s largest utility Oncor Electric Delivery Co. in Dallas.

The isssue was resolved recently through a settlement agreement that limits on-demand readings to twice an hour that Smart Meter Texas must provide customers. The price of power changes every 15 minutes, so a twice an hour reading may miss some price spikes.

The Public Utility Commission signed off on the deal, and so did several other groups including several retail electricity providers and the Office of Public Utility Counsel which represents residential customers and small businesses.

Michele Gregg, spokeswoman for the Public Utility Counsel, testified in December that the consumer advocate supported the change because widespread use of the networks never materialized. Catherine Webking, an Austin lawyer who represents the Texas Energy Association for Marketers, a group of retail electric providers, said she believes the deal was a reasonable resolution of providing the benefits of Smart Meter Texas while not incurring too much cost.

But Griddy, an electricity provider that offers customers the opportunity to pay wholesale power prices, which also issued a plea to customers during a price surge, said the state hasn’t given the smart-meter networks a chance and could miss out on its potential. Griddy was counting on the continued adoption of real time pricing as the next step for customers wanting to control their electricity costs.

Right now, Griddy sends out price alerts from the grid operator Electric Reliability Council of Texas so businesses like hotels can run washers and dryers when electricity prices are cheapest. But the company was counting on a smart-meter program that would allow customers to track wholesale prices and manage consumption themselves, making Griddy’s offerings attractive to more people.

Wholesale prices are generally cheaper than retail prices, but they can fluctuate widely, especially when the Texas power grid faces another crisis during extreme weather. Last year, wholesale prices averaged less than 3 cents per kilowatt hour, much lower than than retail rates that now are running above 11 cents, but they can spike at times of high demand to as much as $9 a kilowatt hour.

What customers want is to be able to use energy when it’s cheapest, said Greg Craig, Griddy’s CEO, and they want to do it automatically. They want to be able to program their thermostat so that if the price rises they can shut off their air conditioning and if the price falls, they can charge their electric-powered vehicle.

Griddy customers may still save money even without real time data, he said. But they won’t be able to see their usage in real time or see how much they’re spending.

“The big utilities have big investments in the existing way and going to real time and more transparency isn’t really in their best interest,” said Craig.

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U.S. coal-fired generation 2021 rose as higher natural gas prices, stable coal costs, and a recovering power sector shifted the generation mix; capacity factors rebounded despite low coal stocks and ongoing plant retirements.

Key Points

Coal output rose 22% on high gas prices and higher capacity factors; a 5% decline is expected in 2022.

✅ Natural gas delivered cost averaged $4.93/MMBtu, more than double 2020

✅ Coal capacity factor rose to ~51% from 40% in 2020

✅ 2022 coal generation forecast to fall about 5%

We expect 22% more U.S. coal-fired generation in 2021 than in 2020, according to our latest Short-Term Energy Outlook (STEO). The U.S. electric power sector has been generating more electricity from coal-fired power plants this year as a result of significantly higher natural gas prices and relatively stable coal prices, even as non-fossil sources reached 40% of total generation. This year, 2021, will yield the first year-over-year increase in coal generation in the United States since 2014, highlighted by a January power generation jump earlier in the year.

Coal and natural gas have been the two largest sources of electricity generation in the United States. In many areas of the country, these two fuels compete to supply electricity based on their relative costs and sensitivity to policies and gas prices as well. U.S. natural gas prices have been more volatile than coal prices, so the cost of natural gas often determines the relative share of generation provided by natural gas and coal.

Because natural gas-fired power plants convert fuel to electricity more efficiently than coal-fired plants, record natural gas generation has at times underscored that advantage, and natural gas-fired generation can have an economic advantage even if natural gas prices are slightly higher than coal prices. Between 2015 and 2020, the cost of natural gas delivered to electric generators remained relatively low and stable. This year, however, natural gas prices have been much higher than in recent years. The year-to-date delivered cost of natural gas to U.S. power plants has averaged $4.93 per million British thermal units (Btu), more than double last year’s price.

The overall decline in electricity demand in 2020 and record-low natural gas prices led coal plants to significantly reduce the percentage of time that they generated power. In 2020, the utilization rate (known as the capacity factor) of U.S. coal-fired generators averaged 40%. Before 2010, coal capacity factors routinely averaged 70% or more. This year’s higher natural gas prices have increased the average coal capacity factor to about 51%, which is almost the 2018 average, a year when wind and solar reached 10% nationally.

Although rising natural gas prices have resulted in more U.S. coal-fired generation than last year, this increase in coal generation will most likely not continue as solar and wind expand in the generation mix. The electric power sector has retired about 30% of its generating capacity at coal plants since 2010, and no new coal-fired capacity has come online in the United States since 2013. In addition, coal stocks at U.S. power plants are relatively low, and production at operating coal mines has not been increasing as rapidly as the recent increase in coal demand. For 2022, we forecast that U.S. coal-fired generation will decline about 5% in response to continuing retirements of generating capacity at coal power plants and slightly lower natural gas prices.

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Texas PUC Appointments signal post-storm reform as Gov. Greg Abbott taps Peter Lake and advances Will McAdams for Senate confirmation, affecting ERCOT oversight, grid reliability, wholesale power pricing, and securitization for co-ops.

Key Points

Texas PUC appointments add Peter Lake and Will McAdams to steer ERCOT, grid reliability, and market policy.

✅ Peter Lake nominated chair to replace Arthur D'Andrea.

✅ Will McAdams advances toward Senate confirmation.

✅ Focus on ERCOT oversight, price cap debate, grid resilience.

A new set of Texas electricity regulators began to take shape Monday, as Gov. Greg Abbott nominated a finance expert to be the next chairman of the Public Utility Commission while his earlier choice of a PUC member moved toward Senate confirmation.

The Republican governor put forward Peter Lake of Austin, who has spent more than five years as an Abbott appointee to the Texas Water Development Board, as his second commission pick in as many weeks.

“I am confident he will bring a fresh perspective and trustworthy leadership to the PUC,” Abbott said of Lake, who once worked as a trader of futures and derivatives for a firm belonging to the Chicago Mercantile Exchange and more recently has eagerly promoted bonds for the State Water Implementation Fund for Texas.

“Peter’s expertise in the Texas energy industry and business management will make him an asset to the agency,” Abbott, who has touted grid readiness in recent months, said in a written statement. “I urge the Senate to swiftly confirm Peter’s appointment.”

On Monday, the Senate appeared to be moving quickly to confirm Abbott’s April 1 selection for the PUC, Will McAdams, president of Associated Builders and Contractors of Texas and a former legislative aide who helped write policy for regulated industries such as electricity.

McAdams was among the 129 nominees that the Senate Nominations Committee voted out, 8-0. His nomination heads now to the Senate floor.

All three of Abbott’s handpicked PUC commissioners who were in place before and during February’s calamitous winter storm have since quit or said they’re resigning, even as Sierra Club criticism of Abbott's demands intensified in the aftermath.

February’s polar vortex left in its wake physical and financial wreckage after a nonprofit grid operator answering to the PUC, amid calls for market reforms to avoid blackouts, shut off electricity to more than 4 million Texans, causing the deaths of at least 125 people, 13 of them in the Dallas-Fort Worth area.

Gov. Greg Abbott on Thursday named Will McAdams to the embattled Public Utility Commission of Texas. McAdams is a construction industry lobbyist with strong ties to the GOP-controlled Legislature. In Feb. 17 file photo, winter storm's snowfall andn large electrical transmission lines in South Arlington are pictured.

In a 45-minute confirmation hearing, McAdams, as lawmakers discussed ways to improve electricity reliability statewide, drew praise – and few tough questions.

McAdams, who previously worked for three GOP senators, testified that had he been on the commission in February, he would not have kept in place a controversial, $9,000-per-megawatt hour price cap on wholesale power for about 32 hours on Feb. 18-19.

“I don’t see myself making that decision,” he said.

McAdams, though, hedged slightly, saying he’s not privy to all information that the Electric Reliability Council of Texas, or ERCOT, and the PUC may have had at their disposal during the crisis.

The comments were notable because Lt. Gov. Dan Patrick and the Senate have fought with Abbott and the House over $16 billion in overcharges that, according to an independent market monitor, wrongly accrued near the end of the Feb. 15-19 outages.

Sen. Charles Schwertner, R-Georgetown, said the commission’s former chairwoman, DeAnn Walker, and Bill Magness, president of ERCOT, decided to hold the high cap in place because there “was still great concern about grid stability, even though there was significant reserves.”

He pressed McAdams to call that incorrect, which McAdams did.

“Given the fact pattern that I’m privy to, senator,” it wasn’t the right move, he said. “But again, there may be other facts out there. There probably are.”

McAdams acknowledged many homeowners and businesses were traumatized.

“The public’s confidence in the ability of the PUC to effectively regulate our electric markets has been badly damaged and shaken,” he said.

McAdams spoke favorably of renewable energy, calling wind and solar “absolutely valuable resources,” as the electricity sector faces profound change nationwide. To whatever extent those are not available, the PUC should “firm that up” with “dispatchable forms of generation,” such as gas, coal and nuclear, McAdams said.

He also called for lawmakers to consider providing electricity market bailout through “securitization,” or low-interest bond financing, to rural electric co-ops that were unable to pay the massive wholesale power bills they racked up during the February crisis.

“It would prevent those systems from having to front-load those costs onto their own members and smooth that out over a term of years,” while preventing an “uplift” of costs to other market participants who wisely hedged against soaring prices, McAdams said.

Noting that more than 400 bills have been filed to change ERCOT and how it’s governed, and as Texans prepare to vote on grid modernization funding this year, McAdams told the Senate panel, “It is clear to me that the Legislature wants meaningful changes to the status quo – to ensure that something positive comes out of this tragedy.”

Lake, who if confirmed by the Senate would replace Arthur D’Andrea as PUC chairman, grew up in Tyler. He attended prep school in New England and earned an undergraduate degree from the University of Chicago and a master of business administration degree from Stanford University.

He then worked for a commodities trading firm, a behavioral health company and as a business consultant before he became director of business development for Tyler-based Lake Ronel Oil Co. in 2014.

In late 2015, Abbott named Lake to the Texas Water Development Board and in February 2018 picked him to be the chairman of the three-member board that seeks to ensure water supplies for a fast-growing state.

Lake has steered the water board as it rolled out additional loans for water projects, approved by the Legislature and voters in 2013, and took the lead after Hurricane Harvey on flood control planning and infrastructure financing.

He’s posted exuberantly on Twitter as he toured agricultural water installations, lakes in West Texas and river authorities.

If confirmed, Lake and McAdams each would make $189,500 a year.

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Ukraine Power Grid Attacks disrupt critical infrastructure as missiles and drones strike power plants, substations, and lines, causing blackouts. Emergency repairs, international aid, generators, and renewables bolster resilience and keep hospitals and water running.

Key Points

Russian strikes on Ukraine's power infrastructure cause blackouts; repairs and aid sustain hospitals and water.

✅ Missile and drone strikes target plants, substations, and lines.

✅ Crews restore power under fire; air defenses protect sites.

✅ Allies supply equipment, generators, and grid repair expertise.

Ukraine is facing an ongoing battle to maintain its electrical grid in the wake of relentless Russian attacks targeting power plants and energy infrastructure. These attacks, which have intensified in the last year, are part of Russia's broader strategy to weaken Ukraine's ability to function amid the ongoing war. Power plants, substations, and energy lines have become prime targets, with Russian forces using missiles and drones to destroy critical infrastructure, as western Ukraine power outages have shown, leaving millions of Ukrainians without electricity and heating during harsh winters.

The Ukrainian government and energy companies are working tirelessly to repair the damage and prevent total blackouts, while also trying to ensure that civilians have access to vital services like hospitals and water supplies. Ukraine has received support from international allies in the form of technical assistance and equipment to help strengthen its power grid, and electricity reserve updates suggest outages can be avoided if no new strikes occur. However, the ongoing nature of the attacks and the complexity of repairing such extensive damage make the situation extraordinarily difficult.

Despite these challenges, Ukraine's resilience is evident, even as winter pressures on the battlefront intensify operations. Energy workers are often working under dangerous conditions, risking their lives to restore power and prevent further devastation. The Ukrainian government has prioritized the protection of energy infrastructure, with military forces being deployed to safeguard workers and critical assets.

Meanwhile, the international community continues to support Ukraine through financial and technical aid, though some U.S. support programs have ended recently, as well as providing temporary power solutions, like generators, to keep essential services running. Some countries have even sent specialized equipment to help repair damaged power lines and energy plants more quickly.

The humanitarian consequences of these attacks are severe, as access to electricity means more than just light—it's crucial for heating, cooking, and powering medical equipment. With winter temperatures often dropping below freezing, plans to keep the lights on are vital to protect vulnerable communities, and the lack of reliable energy has put many lives at risk.

In response to the ongoing crisis, Ukraine has also focused on enhancing its energy independence, seeking alternatives to Russian-supplied energy. This includes exploring renewable energy sources, such as solar and wind power, and new energy solutions adopted by communities to overcome winter blackouts, which could help reduce reliance on traditional energy grids and provide more resilient options in the future.

The battle for energy infrastructure in Ukraine illustrates the broader struggle of the country to maintain its sovereignty and independence in the face of external aggression. The destruction of power plants is not only a military tactic but also a psychological one—meant to instill fear and disrupt daily life. However, the unwavering spirit of the Ukrainian people, alongside international support, including Ukraine's aid to Spain during blackouts as one example, continues to ensure that the fight to "keep the lights on" is far from over.

As Ukraine works tirelessly to repair its energy grid, it also faces the challenge of preparing for the long-term impact of these attacks. The ongoing war has highlighted the importance of securing energy infrastructure in modern conflicts, and the world is watching as Ukraine's resilience in this area could serve as a model for other nations facing similar threats.

Ukraine’s energy struggle is far from over, but its determination to keep the lights on remains a beacon of hope and defiance in the face of ongoing adversity.

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Income Graduated Fixed Charge aligns CPUC billing with utility fixed costs, lowers usage rates, supports electrification, and shifts California investor-owned utilities' electric bills by income, with CARE and Climate Credit offsets for low-income households.

Key Points

A CPUC proposal: an income-based monthly fixed fee with lower usage rates to align costs and aid low-income customers.

✅ Income-tiered fixed fees: $0-$42; CARE: $14-$22, by utility territory

✅ Usage rates drop 16%-22% to support electrification and cost-reflective billing

✅ Lowest-income save ~$10-$20; some higher earners pay ~$10+ more monthly

The Public Advocates Office (PAO) for the California Public Utilities Commission (CPUC) has proposed adding a monthly income-based fixed charge on electric utility bills based on income level.  

The rate change is designed to lower bills for the lowest-income residents while aligning billing more directly with utility costs. 

PAO’s recommendation for the Income Graduated Fixed Charge places fees between $22 and $42 per month in the three major investor-owned utilities’ territories, including an SDG&E minimum charge debate under way, for customers not enrolled in the California Alternative Rates for Energy (CARE) program. As seen below, CARE customers would be charged between $14 per month and $22 a month, depending on income level and territory.

For households earning $50,000 or less per year, the fixed charge would be $0, but only if the California Climate Credit is applied to offset the fixed cost.

Meanwhile, usage-based electricity rates are lowered in the PAO proposal, part of major changes to electric bills statewide. Average rates would be reduced between 16% to 22% for the three major investor-owned utilities.

The lowest-income bracket of Californians is expected to save roughly $10 to $20 a month under the proposal, while middle-income customers may see costs rise by about $20 a month, even as lawmakers seek to overturn income-based charges in Sacramento.

“We anticipate the vast majority of low-income customers ($50,000 or less per year) will have their monthly bills decrease by $10 or more, and a small proportion of the highest income earners ($100,000+ per year) will see their monthly bills rise by $10 or more,” said the PAO.

The charges are an effort to help suppress ever-increasing electricity generation and transmission rates, which are among the highest in the country, with soaring electricity prices reported across California. Rates are expected to rise sharply as wildfire mitigation efforts are implemented by the utilities found at fault for their origin.

“We are very concerned. However, we do not see the increases stopping at this point,” Linda Serizawa, deputy director for energy, PAO, told pv magazine. “We think the pace and scale of the [rate] increases is growing faster than we would have anticipated for several years now.”

Consumer advocates and regulators face calls for action on surging electricity bills across the state.

The proposed changes are also meant to more directly couple billing with the fixed charges that utilities incur, as California considers revamping electricity rates to clean the grid. For example, activities like power line maintenance, energy efficiency programs, and wildfire prevention are not expected to vary with usage, so these activities would be funded through a fixed charge.

Michael Campbell of the PAO’s customer programs team, and leader of the proposed program, likened paying for grid enhancements and other social programs with utility rate increases to “paying for food stamps by taxing food.” Instead, a fixed charge would cover these costs.

PAO said the move to lower rates for usage should help encourage electrification as California moves to replace heating and cooling, appliances, and gas combustion cars with electrified counterparts. In addition, lower rates mean the cost burden of running these devices is improved.

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