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EV Decarbonization Strategy weighs life-cycle emissions and climate targets, highlighting mode shift to public transit, cycling, and walking, grid decarbonization, renewable energy, and charging infrastructure to cut greenhouse gases while reducing private car dependence.

Key Points

A plan to cut transport emissions by pairing EV adoption with mode shift, clean power, and less private car use.

✅ Prioritize mode shift: transit, cycling, and walking.

✅ Electrify remaining vehicles with clean, renewable power.

✅ Expand charging, improve batteries, and manage critical minerals.

California recently announced that it plans to ban the sales of gas-powered vehicles by 2035, a move similar to a 2035 electric vehicle mandate seen elsewhere, Ontario has invested $500 million in the production of electric vehicles (EVs) and Tesla is quickly becoming the world's highest-valued car company.

It almost seems like owning an electric vehicle is a silver bullet in the fight against climate change, but it isn't, as a U of T study explains today. What we should also be focused on is whether anyone should use a private vehicle at all.
 
As a researcher in sustainable mobility, I know this answer is unsatisfying. But this is where my latest research has led.

Battery EVs, such as the Tesla Model 3 - the best selling EV in Canada in 2020 - have no tailpipe emissions. But they do have higher production and manufacturing emissions than conventional vehicles, and often run on electricity that comes from fossil fuels.

Almost 18 per cent of the electricity generated in Canada came from fossil fuels in 2019, and even as Canada's EV goals grow more ambitious today, the grid mix varies from zero in Quebec to 90 per cent in Alberta.
 
Researchers like me compare the greenhouse gas emissions of an alternative vehicle, such as an EV, with those of a conventional vehicle over a vehicle lifetime, an exercise known as a life-cycle assessment. For example, a Tesla Model 3 compared with a Toyota Corolla can provide up to 75 per cent reduction in greenhouse gases emitted per kilometre travelled in Quebec, but no reductions in Alberta.

Hundreds of millions of new cars

To avoid extreme and irreversible impacts on ecosystems, communities and the overall global economy, we must keep the increase in global average temperatures to less than 2 C - and ideally 1.5 C - above pre-industrial levels by the year 2100.

We can translate these climate change targets into actionable plans. First, we estimate greenhouse gas emissions budgets using energy and climate models for each sector of the economy and for each country. Then we simulate future emissions, taking alternative technologies into account, as well as future potential economic and societal developments.

I looked at the U.S. passenger vehicle fleet, which adds up to about 260 million vehicles, while noting the potential for Canada-U.S. collaboration in this transition, to answer a simple question: Could the greenhouse gas emissions from the sector be brought in line with climate targets by replacing gasoline-powered vehicles with EVs?

The results were shocking. Assuming no changes to travel behaviours and a decarbonization of 80 per cent of electricity, meeting a 2 C target could require up to 300 million EVs, or 90 per cent of the projected U.S. fleet, by 2050. That would require all new purchased vehicles to be electric from 2035 onwards.

To put that into perspective, there are currently 880,000 EVs in the U.S., or 0.3 per cent of the fleet. Even the most optimistic projections, despite hype about an electric-car revolution gaining steam, from the International Energy Agency suggest that the U.S. fleet will only be at about 50 per cent electrified by 2050.

Massive and rapid electrification

Still, 90 per cent is theoretically possible, isn't it? Probably, but is it desirable?

In order to hit that target, we'd need to very rapidly overcome all the challenges associated with EV adoption, such as range anxiety, the higher purchase cost and availability of charging infrastructure.
 
A rapid pace of electrification would severely challenge the electricity infrastructure and the supply chain of many critical materials for the batteries, such as lithium, manganese and cobalt. It would require vast capacity of renewable energy sources and transmission lines, widespread charging infrastructure, a co-ordination between two historically distinct sectors (electricity and transportation systems) and rapid innovations in electric battery technologies. I am not saying it's impossible, but I believe it's unlikely.

Read more: There aren't enough batteries to electrify all cars - focus on trucks and buses instead

So what? Shall we give up, accept our collective fate and stop our efforts at electrification?

On the contrary, I think we should re-examine our priorities and dare to ask an even more critical question: Do we need that many vehicles on the road?

Buses, trains and bikes

Simply put, there are three ways to reduce greenhouse gas emissions from passenger transport: avoid the need to travel, shift the transportation modes or improve the technologies. EVs only tackle one side of the problem, the technological one.

And while EVs do decrease emissions compared with conventional vehicles, we should be comparing them to buses, including leading electric bus fleets in North America, trains and bikes. When we do, their potential to reduce greenhouse gas emissions disappears because of their life cycle emissions and the limited number of people they carry at one time.

If we truly want to solve our climate problems, we need to deploy EVs along with other measures, such as public transit and active mobility. This fact is critical, especially given the recent decreases in public transit ridership in the U.S., mostly due to increasing vehicle ownership, low gasoline prices and the advent of ride-hailing (Uber, Lyft)

Governments need to massively invest in public transit, cycling and walking infrastructure to make them larger, safer and more reliable, rather than expanding EV subsidies alone. And we need to reassess our transportation needs and priorities.

The road to decarbonization is long and winding. But if we are willing to get out of our cars and take a shortcut through the forest, we might get there a lot faster.

Author: Alexandre Milovanoff - Postdoctoral Researcher, Environmental Engineering, University of Toronto 

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Sustainable Marine tidal energy delivers in-stream power to Nova Scotia's grid from Grand Passage, proving low-impact, renewable generation and advancing a floating tidal array at FORCE and Minas Passage in the Bay of Fundy.

Key Points

The first in-stream tidal project supplying clean power to Nova Scotia's grid, proven at Grand Passage.

✅ First to deliver in-stream tidal power to Canada's grid

✅ Demonstration at Grand Passage informs FORCE deployments

✅ Low-impact design and environmental monitoring validated

Sustainable Marine has officially powered up its tidal energy operation in Canada and is delivering clean electricity to the power system in Nova Scotia, on the country’s Atlantic coast, as the province moves to increase wind and solar projects in the years ahead. The company’s system in Grand Passage is the first to deliver in-stream tidal power to the grid in Canada, following provincial approval to harness Bay of Fundy tides that is spurring further development.

The system start-up is the culmination of more than a decade of research, development and testing, including lessons from Scottish tidal projects in recent years and a powerful tidal turbine feeding onshore grids, managing the technical challenges associated with operating in highly energetic environments and proving the ultra-low environmental impact of the tidal technology.

Sustainable Marine is striving to deliver the world’s first floating tidal array at FORCE (Fundy Ocean Research Centre for Energy). This project will be delivered in phases, drawing upon the knowledge gained and lessons learned in Grand Passage, and insights from offshore wind pilots like France’s first offshore wind turbine in Europe. In the coming months the company will continue to operate the platform at its demonstration site at Grand Passage, gradually building up power production, while New York and New England clean energy demand continues to rise, to further prove the technology and environmental monitoring systems, before commencing deployments in the Minas Passage – renowned as the Everest of tidal energy.

The Bay of Fundy’s huge tidal energy resource contains more than four times the combined flow of every freshwater river in the world, with the potential to generate approximately 2,500 MW of green energy, underscoring why independent electricity planning will be important for integrating marine renewables.

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FERC Transmission Planning Overhaul streamlines interregional grid buildouts, enabling high-voltage lines, renewable integration, and grid reliability to scale, cutting fossil reliance while boosting decarbonization, climate resilience, and affordability across regions facing demand and extreme weather.

Key Points

Federal rule updating interregional grid planning to integrate renewables, share costs, and improve reliability.

✅ Accelerates high-voltage, interregional lines for renewable transfer

✅ Optimizes transmission planning and cost allocation frameworks

✅ Boosts grid reliability, resilience, and emissions reductions

The US took a significant step towards a cleaner energy future on May 13th, 2024. The Federal Energy Regulatory Commission (FERC) approved the first major update to the country's electric transmission policy in over a decade, while congressional Democrats continue to push for action on aggregated DERs within FERC's remit today. This overhaul aims to streamline the process of building new power lines, specifically those that connect different regions. This improved connectivity is crucial for integrating more renewable energy sources like wind and solar into the national grid.

The current system faces challenges in handling the influx of renewables, and the aging U.S. grid amplifies those hurdles today. Renewable energy sources are variable by nature – the sun doesn't always shine, and the wind doesn't always blow. Traditionally, power grids have relied on constantly running power plants, like coal or natural gas, to meet electricity demands. These plants can be easily adjusted to produce more or less power as needed. However, renewable energy sources require a different approach.

The new FERC policy focuses on building more interregional transmission lines. These high-voltage power lines would allow electricity generated in regions with abundant solar or wind power, and even enable imports of green power from Canada in certain corridors, to be transmitted to areas with lower renewable energy resources. For example, solar energy produced in sunny states like California could be delivered to meet peak demand on the East Coast during hot summer days.

This improved connectivity offers several advantages. Firstly, it allows for a more efficient use of renewable resources. Secondly, it reduces the need for fossil fuel-based power plants, leading to cleaner air and lower greenhouse gas emissions. Finally, a more robust grid is better equipped to handle extreme weather events, which are becoming increasingly common due to climate change, and while Biden's climate law shows mixed results on decarbonization, stronger transmission supports resilience.

The need for an upgrade is undeniable. The Biden administration has set ambitious goals for decarbonizing the power sector by 2035, including proposals for a clean electricity standard as a pathway to those targets. A study by the US Department of Energy estimates that achieving this target will require more than doubling the country's regional transmission capacity and increasing interregional capacity by more than fivefold. The aging US grid is already struggling to keep up with current demands, and without significant improvements, it could face reliability issues in the future.

The FERC's decision has been met with praise from environmental groups and renewable energy companies. They see it as a critical step towards achieving a clean energy future. However, some stakeholders, including investor-owned utilities, have expressed concerns about the potential costs associated with building new transmission lines, citing persistent barriers to development identified in recent Senate testimony. Finding the right balance between efficiency, affordability, and environmental responsibility will be key to the success of this initiative.

The road ahead won't be easy. Building new power lines is a complex process that can face opposition from local communities, and broader disputes over electricity pricing changes often complicate planning and approvals. However, the potential benefits of a modernized grid are significant. By investing in this overhaul, the US is taking a crucial step towards a more reliable, sustainable, and cleaner energy future.

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Global Electricity Demand Surge underscores rising coal generation, lagging renewables deployment, and escalating emissions, as nations prioritize reliable power; nuclear energy and grid decarbonization emerge as pivotal solutions to the electricity transition.

Key Points

A rapid post-lockdown rise in power consumption, outpacing renewables growth and driving higher coal use and emissions.

✅ Coal generation rises faster than wind and solar additions

✅ Emissions increase as economies prioritize reliable baseload power

✅ Nuclear power touted for rapid grid decarbonization

By Robert Bryce

As the Covid lockdowns are easing, the global economy is recovering and that recovery is fueling blistering growth in electricity use. The latest data from Ember, the London-based “climate and energy think tank focused on accelerating the global electricity transition,” show that global power demand soared by about 5% in the first half of 2021. That’s faster growth than was happening back in 2018 when electricity use was increasing by about 4% per year.

The numbers from Ember also show that despite lots of talk about the urgent need to reduce greenhouse gas emissions, coal demand for power generation continues to grow and emissions from the electric sector continue to grow: up by 5% over the first half of 2019. In addition, they show that while about half of the growth in electricity demand was met by wind and solar, as low-emissions sources are set to cover almost all new demand over the next three years, overall growth in electricity use is still outstripping the growth in renewables. 

The soaring use of electricity, and increasing emissions from power generation confirm the sage wisdom of Rasheed Wallace, the volatile former power forward with the Detroit Pistons and other NBA teams, and now an assistant coach at the  University of Memphis, who coined the catchphrase: “Ball don’t lie.” If Wallace or one of his teammates was called for a foul during a basketball game that he thought was undeserved, and the opposing player missed the ensuing free throws, Wallace would often holler, “ball don’t lie,” as if the basketball itself was pronouncing judgment on the referee’s errant call. 

I often think about Wallace’s catchphrase while looking at global energy and power trends and substitute my own phrase: numbers don’t lie.

Over the past few weeks Ember, BP, and the International Energy Agency have all published reports which come to the same two conclusions: that countries all around the world — and China's electricity sector in particular — are doing whatever they need to do to get the electricity they need to grow their economies. Second, they are using lots of coal to get that juice. 

As I discuss in my recent book, A Question of Power: Electricity and the Wealth of Nations, Electricity is the world’s most important and fastest-growing form of energy. The Ember data proves that. At a growth rate of 5%, global electricity use will double in about 14 years, and as surging electricity demand is putting power systems under strain around the world, the electricity sector also accounts for the biggest single share of global carbon dioxide emissions: about 25 percent. Thus, if we are to have any hope of cutting global emissions, the electricity sector is pivotal. Further, the soaring use of electricity shows that low-income people and countries around the world are not content to stay in the dark. They want to live high-energy lives with access to all the electronic riches that we take for granted.  

 Ember’s data clearly shows that decarbonizing the global electric grid will require finding a substitute for coal. Indeed, coal use may be plummeting in the U.S. and western Europe, where U.S. electricity consumption has been declining, but over the past two years, several developing countries including Mongolia, China, Bangladesh, Vietnam, Kazakhstan, Pakistan, and India, all boosted their use of coal. This was particularly obvious in China, where, between the first half of 2019 and the first half of 2021, electricity demand jumped by about 14%. Of that increase, coal-fired generation provided roughly twice as much new electricity as wind and solar combined. In Pakistan, electricity demand jumped by about 7%, and coal provided more than three times as much new electricity as nuclear and about three times as much as hydro. (Wind and solar did not grow at all in Pakistan over that period.) 

Hate coal all you like, but its century-long persistence in power generation proves its importance. That persistence proves that climate change concerns are not as important to most consumers and policymakers as reliable electricity. In 2010, Roger Pielke Jr. dubbed this the Iron Law of Climate Policy which says “When policies on emissions reductions collide with policies focused on economic growth, economic growth will win out every time.” Pielke elaborated on that point, saying the Iron Law is a “boundary condition on policy design that is every bit as limiting as is the second law of thermodynamics, and it holds everywhere around the world, in rich and poor countries alike. It says that even if people are willing to bear some costs to reduce emissions (and experience shows that they are), they are willing to go only so far.”

Over the past five years, I’ve written a book about electricity, co-produced a feature-length documentary film about it (Juice: How Electricity Explains the World), and launched a podcast that focuses largely on energy and power. I’m convinced that Pielke’s claim is exactly right and should be extended to electricity and dubbed the Iron Law of Electricity which says, “when forced to choose between dirty electricity and no electricity, people will choose dirty electricity every time.” I saw this at work in electricity-poor places all over the world, including India, Lebanon, and Puerto Rico. 

Pielke, a professor at the University of Colorado as well as a highly regarded author on the politics of climate change and sports governance, has since elaborated on the Iron Law. During an interview in Juice, he explained it thusly: “The Iron Law says we’re not going to reduce emissions by willingly getting poor. Rich people aren't going to want to get poorer, poor people aren't going to want to get poorer.” He continued, “If there is one thing that we can count on it is that policymakers will be rewarded by populations if they make people wealthier. We're doing everything we can to try to get richer as nations, as communities, as individuals. If we want to reduce emissions, we really have only one place to go and that's technology.”

Pielke’s point reminds me of another of my favorite energy analysts, Robert Rapier, who made a salient point in his Forbes column last week. He wrote, “Despite the blistering growth rate of renewables, it’s important to keep in mind that overall global energy consumption is growing. Even though global renewable energy consumption has increased by about 21 exajoules in the past decade, overall energy consumption has increased by 51 exajoules. Increased fossil fuel consumption made up most of this growth, with every category of fossil fuels showing increased consumption over the decade.” 

The punchline here – despite my tangential reference to Rasheed Wallace — is obvious: The claims that massive reductions in global carbon dioxide emissions must happen soon are being mocked by the numbers. Countries around the world are acting in their interest, particularly when it comes to their electricity needs and that is resulting in big increases in emissions. As Ember concludes in their report, wind and solar are growing, and some analyses suggest renewables could eclipse coal by 2025, but the “electricity transition” is “not happening fast enough.”

Ember explains that in the first half of 2021, wind and solar output exceeded the output of the world’s nuclear reactors for the first time. It also noted that over the past two years, “Nuclear generation fell by 2% compared to pre-pandemic levels, as closures at older plants across the OECD, especially amid debates over European nuclear trends, exceeded the new capacity in China.” While that may cheer anti-nuclear activists at groups like Greenpeace and Friends of the Earth, the truth is obvious: the only way – repeat, the only way – the electric sector will achieve significant reductions in carbon dioxide emissions is if we can replace lots of coal-fired generation with nuclear reactors and do so in relatively short order, meaning the next decade or so. Renewables are politically popular and they are growing, but they cannot, will not, be able to match the soaring demand for the electricity that is needed to sustain modern economies and bring developing countries out of the darkness and into modernity. 

Countries like China, Vietnam, India, and others need an alternative to coal for power generation. They need new nuclear reactors that are smaller, safer, and cheaper than the existing designs. And they need it soon. I will be writing about those reactors in future columns.

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Yukon SMR Feasibility Study examines small modular reactors as low-emissions nuclear power for Yukon's grid and remote communities, comparing costs, safety, waste, and reliability with diesel generation, renewables, and energy efficiency.

Key Points

An official assessment of small modular reactors as low-emission power options for Yukon's grid and remote sites.

✅ Compares SMR costs vs diesel, hydro, wind, and solar

✅ Evaluates safety, waste, fuel logistics, decommissioning

✅ Considers remote community loads and grid integration

The Yukon government is looking for ways to reduce the territory's emissions, and wondering if nuclear power is one way to go.

The territory is undertaking a feasibility study, and, as some developers note, combining multiple energy sources can make better projects, to determine whether there's a future for SMRs — small modular reactors — as a low-emissions alternative to things such as diesel power.

The idea, said John Streicker, Yukon's minister of energy, mines and resources, is to bring the SMRs into the Yukon to generate electricity.

"Even the micro ones, you could consider in our remote communities or wherever you've got a point load of energy demand," Streicker said. "Especially electricity demand."

For remote coastal communities elsewhere in Canada, tidal energy is being explored as a low-emissions option as well.

SMRs are nuclear reactors that use fission to produce energy, similar to existing large reactors, but with a smaller power capacity. The International Atomic Energy Agency (IAEA) defines reactors as "small" if their output is under 300 MW. A traditional nuclear power plant produces about three times as much power or more.

They're "modular" because they're designed to be factory-assembled, and then installed where needed. 

Several provinces have already signed an agreement supporting the development of SMRs, and in Alberta's energy mix that conversation spans both green and fossil power, and Canada's first grid-scale SMRs could be in place in Ontario by 2028 and Saskatchewan by 2032.

A year ago, the government of Yukon endorsed Canada's SMR action plan, at a time when analysts argue that zero-emission electricity by 2035 is practical and profitable, agreeing to "monitor the progress of SMR technologies throughout Canada with the goal of identifying potential for applicability in our northern jurisdiction."

The territory is now following through by hiring someone to look at whether SMRs could make sense as a cleaner-energy alternative in Yukon. 

The territorial government has set a goal of reducing emissions by 45 per cent by 2030, excluding mining emissions, even as some analyses argue that zero-emissions electricity by 2035 is possible, and "future emissions actions for post-2030 have not yet been identified," reads the government's request for proposals to do the SMR study. 

Streicker acknowledges the potential for nuclear power in Yukon is a bit of "long shot" — but says it's one that can't be ignored.

"We need to look at all possible solutions," he said, as countries such as New Zealand's electricity sector debate their future pathways.

"I don't want to give the sense like we're putting all of our emphasis and energy towards nuclear power. We're not."

According to Streicker, it's nothing more than a study at this point.

Don't bother, researcher says
Still, M.V. Ramana, a professor at the School of Public Policy and Global Affairs at the University of British Columbia, said it's a study that's likely a waste of time and money. He says there's been plenty of research already, and to him, SMRs are just not a realistic option for Yukon or anywhere in Canada.

"I would say that, you know, that study can be done in two weeks by a graduate student, essentially, all right? They just have to go look at the literature on SMRs and look at the critical literature on this," Ramana said.

Ramana co-authored a research paper last year, looking at the potential for SMRs in remote communities or mine sites. The conclusion was that SMRs will be too expensive and there won't be enough demand to justify investing in them.

He said nuclear reactors are expensive, which is why their construction has "dried up" in much of the world.

"They generate electricity at very high prices," he said.

'They just have to go look at the literature,' said M.V. Ramana, a professor at the School of Public Policy and Global Affairs at the University of British Columbia. (Paul Joseph)
"[For] smaller reactors, the overall costs go down. But the amount of electricity that they will generate goes down even further."

The environmental case is also shaky, according to a statement signed last year by dozens of Canadian environmental and community groups, including the Sierra Club, Greenpeace, the Council of Canadians and the Canadian Environmental Law Associaton (CELA). The statement calls SMRs a "dirty, dangerous distraction" from tackling climate change and criticized the federal government for investing in the technology.

"We have to remember that the majority of the rhetoric we hear is from nuclear advocates. And so they are promoting what I would call, and other legal scholars and academics have called, a nuclear fantasy," said Kerrie Blaise of CELA.

Blaise describes the nuclear industry as facing an unknown future, with some of North America's larger reactors set to be decommissioned in the coming years. SMRs are therefore touted as the future.

"They're looking for a solution. And so that I would say climate change presents that timely solution for them."

Blaise argues the same safety and environmental questions exist for SMRs as for any nuclear reactors — such as how to produce and transport fuel safely, what to do with waste, and how to decommission them — and those can't be glossed over in a single-minded pursuit of lower carbon emissions.  

Main focus is still renewables, minister says
Yukon's energy minister agrees, and he's eager to emphasize that the territory is not committed to anything right now beyond a study.

"Every government has a responsibility to do diligence around this," Streicker said.

A solar farm in Old Crow, Yukon. The territory's energy minister says Yukon is still primarily focussed on renewables, and energy efficiency. (Caleb Charlie)
He also dismisses the idea that studying nuclear power is any sort of distraction from his government's response to climate change right now. Yukon's main focus is still renewable energy such as solar and wind power, though Canada's solar progress is often criticized as lagging, increasing efficiency, and connecting Yukon's grid to the hydro project in Atlin, B.C., he said.

Streicker has been open to nuclear energy in the past. As a federal Green Party candidate in 2008, Streicker broke with the party line to suggest that nuclear could be a viable energy alternative. 

He acknowledges that nuclear power is always a hot-button issue, and Yukoners will have strong feelings about it. A lot will depend on how any future regulatory process works, he says.

In taking action on climate, this Arctic community wants to be a beacon to the world
Cameco signs agreement with nuclear reactor company
"There's some people that think it's the 'Hail Mary,' and some people that think it's evil incarnate," he said. 

"Buried deep within Our Clean Future [Yukon's climate change strategy], there's a line in there that says we should keep an eye on other technologies, for example, nuclear. That's what this [study] is — it's to keep an eye on it."

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US utilities COVID-19 resilience shows electric utilities maintaining demand stability, reaffirming earnings guidance, and accessing the bond market for low-cost financing, as Dominion, NextEra, and Con Edison manage recession risks.

Key Points

It is the sector's capacity to sustain demand, financing access, and guidance despite pandemic recession pressures.

✅ Bond market access locks in low-cost, long-term debt

✅ Stable residential load offsets industrial weakness

✅ Guidance largely reaffirmed by major utilities

Dominion Energy (D) expects "incremental residential load" gains, consistent with COVID-19 electricity demand patterns, as a result of COVID-19 fallout. Southern Company CEO Tom Fanning says his company is "nowhere near" a need to review earnings guidance because of a potential recession, in a region where efficiency and demand response can help level electricity demand for years.

Sempra Energy (SRE) has reaffirmed earnings per share guidance for 2020 and 2021, as well timing for the sale of assets in Chile and Peru, and peers such as Duke Energy's renewables plan have reaffirmed capital investments to deliver cleaner energy and economic growth. And Xcel Energy (XEL) says it still "hasn’t seen material impact on its business."

Several electric utilities have demonstrated ability to tap the bond market, in line with utility sector trends in recent years, to lock in low-cost financing, as America moves toward broader electrification, despite ongoing turmoil. Their ranks include Dominion Energy, renewable energy leader NextEra Energy (NEE) and Consolidated Edison (ED), which last week sold $1 billion of 30-year bonds at a coupon rate of just 3.95 percent.

It’s still early days for US COVID-19 fallout. And most electric companies have yet to issue guidance. That’s understandable, since so much is still unknown about the virus and the damage it will ultimately do to human health and the global economy. But so far, the US power industry is showing typical resilience in tough times, as it coordinates closely with federal partners to maintain reliability.

Will it last? We won’t know for certain until there’s a lot more data. NextEra is usually first to report its Q1 earnings reports and detailed guidance. But that’s not expected until April 23. And companies may delay financials further, should the virus and efforts to control it impede collection and analysis of data, and as they address electricity shut-off risks affecting customers.

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