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New England Solar Interconnection Costs highlight distributed generation strains, transmission charges, distribution upgrades, and DAF fees as National Grid maps hosting capacity, driving queue delays and FERC disputes in Rhode Island and Massachusetts.

Key Points

Rising upfront grid upgrade and DAF charges for distributed solar in RI and MA, including some transmission costs.

✅ Upfront grid upgrades shifted to project developers

✅ DAF and transmission charges increase per MW costs

✅ Queue delays tied to hosting capacity and cluster studies

Solar developers in Rhode Island and Massachusetts say soaring charges to interconnect with the electric grid are threatening the viability of projects. 

As more large-scale solar projects line up for connections, developers are being charged upfront for the full cost of the infrastructure upgrades required, a long-common practice that they say is now becoming untenable amid debates over a new solar customer charge in Nova Scotia. 

“It is a huge issue that reflects an under-invested grid that is not ready for the volume of distributed generation that we’re seeing and that we need, particularly solar,” said Jeremy McDiarmid, vice president for policy and government affairs at the Northeast Clean Energy Council, a nonprofit business organization. 

Connecting solar and wind systems to the grid often requires upgrades to the distribution system to prevent problems, such as voltage fluctuations and reliability risks highlighted by Australian distributors in their networks. Costs can vary considerably from place to place, depending on the amount of distributed generation coming online and the level of capacity planning by regulators, said David Feldman, a senior financial analyst at the National Renewable Energy Laboratory.

“Certainly the Northeast often has more distribution challenges than much of the rest of the country just because it’s more populous and often the infrastructure is older,” he said. “But it’s not unique to the Northeast — in the Midwest, for example, there’s a significant amount of wind projects in the queues and significant delays.”

In Rhode Island and Massachusetts, where strong incentive programs are driving solar development, the level of solar coming online is “exposing the under-investment in the distribution system that is causing these massive costs that National Grid is assigning to particular projects or particular groups of projects,” McDiarmid said. “It is going to be a limiting factor for how much clean energy we can develop and bring online.”

Frank Epps, chief executive officer at Energy Development Partners, has been developing solar projects in Rhode Island since 2010. In that time, he said, interconnection charges on his projects have grown from about $80,000-$120,000 per megawatt to more than $400,000 per megawatt. He attributed the increase to a lack of investment in the distribution network by National Grid over the last decade.

He and other developers say the utility is now adding further to their costs by passing along not just the cost of improving the distribution system — the equivalent of the city street of the grid that brings power directly to customers — but also costs for modifying the transmission system — the interstate highway that moves bulk power over long distances to substations. 

Solar developers who are only requesting to hook into the distribution system, and not applying for transmission service, say they should not be charged for those additional upgrades under state interconnection rules unless they are properly authorized under the federal law that governs the transmission system. 

A Rhode Island solar and wind developer filed a complaint with the Federal Energy Regulatory Commission in February over transmission system improvement charges for its four proposed solar projects. Green Development said National Grid subsidiaries Narragansett Electric and New England Power Company want to charge the company more than $500,000 a year in operating and maintenance expenses assessed as so-called direct assignment facility charges. 

“This amount nearly doubles the interconnection costs associated with the projects,” which total 38.4 megawatts in North Smithfield, the company says in its complaint. “Crucially, these charges are linked to recovering costs associated with providing transmission service — even though no such transmission service is being provided to Green Development.”

But Ted Kresse, a spokesperson for National Grid, said the direct assignment facility, or DAF, construct has been in place for decades and has been applied to any customer affecting the need for transmission upgrades.

“It is the result of the high penetration and continued high volume of distributed generation interconnections that has recently prompted the need for transmission upgrades, and subsequently the pass-through of the associated DAF charges,” he said. 

Several complaints before the Rhode Island Public Utilities Commission object to these DAF and other transmission charges.

One petition for dispute resolution concerns four solar projects totaling 40 MW being developed by Energy Development Partners in a former gravel pit in North Kingstown. Brown University has agreed to purchase the power. 

The developer signed interconnection service agreements with Narragansett Electric in 2019 requiring payment of $21.6 million for costs associated with connecting the projects at a new Wickford Junction substation. Last summer, Narragansett sought to replace those agreements with new ones that reclassified a portion of the costs as transmission-level costs, through New England Power, National Grid’s transmission subsidiary.

That shift would result in additional operational and maintenance charges of $835,000 per year for the estimated 35-year life of the projects, the complaint says.

“This came as a complete shock to us,” Epps said. “We’re not just paying for the maintenance of a new substation. We are paying a share of the total cost that the system owner has to own and operate the transmission system. So all of the sudden, it makes it even tougher for distributed energy resources to be viable.”

In its response to the petition, National Grid argues that the charges are justified because the solar projects will require transmission-level upgrades at the new substation. The company argues that the developer should be responsible for the costs rather than ratepayers, “who are already supporting renewable energy development through their electric rates.”

Seth Handy, one of the lawyers representing Green Development in the FERC complaint, argues that putting transmission system costs on distribution assets is unfair because the distributed resources are “actually reducing the need to move electricity long distances. We’ve been fighting these fights a long time over the underestimating of the value of distributed energy in reducing system costs.”

Handy is also representing the Episcopal Diocese of Rhode Island before the state Supreme Court in its appeal of an April 2020 public utilities commission order upholding similar charges for a proposed 2.2-megawatt solar project at the diocese’s conference center and camp in Glocester. 

Todd Bianco, principal policy associate at the utilities commission, said neither he nor the chairperson can comment on the pending dockets contesting these charges. But he noted that some of these issues are under discussion in another docket examining National Grid’s standards for connecting distributed generation. Among the proposals being considered is the appointment of an independent ombudsperson to resolve interconnection disputes. 

Separately, legislation pending before the Rhode Island General Assembly would remove responsibility for administering the interconnection of renewable energy from utilities, and put it under the authority of the Rhode Island Infrastructure Bank, a financing agency.

Handy, who recently testified in support of the bill, said he believes National Grid has too many conflicting interests to administer interconnecting charges in a timely, transparent and fair fashion, and pointed to utility moves such as changes to solar compensation in other states as examples. In particular, he noted the company’s interests in expanding natural gas infrastructure. 

“There are all kinds of economic interests that they have that conflict with our state policy to provide lower-cost renewable energy and more secure energy solutions,” Handy said.

In testimony submitted to the House Committee on Corporations opposing the legislation, National Grid said such powers are well beyond the purpose and scope of the infrastructure bank. And it cited figures showing Rhode Island is third in the country for the most installed solar per square mile (behind New Jersey and Massachusetts).

Nadav Enbar, program manager at the Electric Power Research Institute, a nonprofit research organization for the utility industry, said interconnection delays and higher costs are becoming more common due to “the incredible uptake” in distributed renewable energy, particularly solar.

That’s impacting hosting capacity, the room available to connect all resources to a circuit without causing adverse harm to reliability and safety. 

“As hosting capacity is being reduced, it’s causing an increasing number of situations where utilities need to study their systems to guarantee interconnection without compromising their systems,” he said. “And that is the reason why you’re starting to see some delays, and it has translated into some greater costs because of the need for upgrades to infrastructure.”

The cost depends on the age or absence of infrastructure, projected load growth, the number of renewable energy projects in the queue, and other factors, he said. As utilities come under increasing pressure to meet state renewable goals, and as some states pilot incentives like a distributed energy rebate in Illinois to drive utility innovation, some (including National Grid) are beginning to provide hosting capacity maps that provide detailed information to developers and policymakers about the amount of distributed energy that can be accommodated at various locations on the grid, he said. 

In addition, the coming availability of high-tech “smart inverters” should help ease some of these problems because they provide the grid with more flexibility when it comes to connecting and communicating with distributed energy resources, Enbar said. 

In Massachusetts, the Department of Public Utilities has opened a docket to explore ways to better plan for and share the cost of upgrading distribution infrastructure to accommodate solar and other renewable energy sources as part of a grid overhaul for renewables nationwide. National Grid has been conducting “cluster studies” there that attempt to analyze the transmission impacts of a group of solar projects and the corresponding interconnection cost to each developer.

Kresse, of National Grid, said the company favors cost-sharing methodologies under consideration that would “provide a pathway to spread cost over the total enabled capacity from the upgrade, as opposed to spreading the cost over only those customers in the queue today.” 

Solar developers want regulators to take an even broader approach that factors in how the deployment of renewables and the resulting infrastructure upgrades benefit not just the interconnecting generator, but all customers. 

“Right now, if your project is the one that causes a multimillion-dollar upgrade, you are assigned that cost even though that upgrade is going to benefit a lot of other projects, as well as make the grid stronger,” said McDiarmid, of the clean energy council. “What we’re asking for is a way of allocating those costs among a variety of developers, as well as to the grid itself, meaning ratepayers. There’s a societal benefit to increasing the modernization of the grid, and improving the resilience of the grid.”

In the meantime, BlueHub Capital, a Boston-based solar developer focused on serving affordable housing developments, recently learned from National Grid that, as a part of one of the area studies, it will be required to pay $5.8 million in transmission and distribution upgrades to interconnect a 2-megawatt solar-plus-storage project that leverages cheaper batteries to enhance resilience, approved for a brownfield site in Gardner, Massachusetts. 

According to testimony submitted to the department, the sum is supposed to be paid within the next year, even though the project will have to wait to be interconnected until April 2027, when a new transmission line is completed. In addition, BlueHub will be responsible for DAF charges totaling $3.4 million over the 20-year life of the project. 

“We’re being asked to pay a fortune to provide solar that the state wants,” said DeWitt Jones, BlueHub’s president. “It’s so expensive that the upgrades are driving everyone out of the interconnection queue. The costs stay the same, but they fall on fewer projects. We need a process of grid design and modernization to guide this.”

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Alliant Energy Net-Zero Carbon Plan outlines carbon-neutral electricity by 2050, coal retirements by 2040, major solar and wind additions, gas transition, battery storage, hydrogen, and carbon credits to reduce emissions and lower customer costs.

Key Points

Alliant Energy's strategy to reach carbon-neutral power by 2050 via coal phaseout, renewables, storage, and offsets.

✅ Targets net-zero electricity by 2050

✅ Retires all coal by 2040; expands solar and wind

✅ Uses storage, hydrogen, and offsets to bridge gaps

Alliant Energy has joined a small but growing group of utilities aiming for carbon-neutral electricity by 2050.

In a report released Wednesday, the Madison-based company announced a goal of “net-zero carbon dioxide emissions” from its electricity generation along with plans to eliminate all coal-powered generation by 2040, a decade earlier than the company’s previous target.

Alliant, which is pursuing plans that would make it the largest solar energy generator in Wisconsin, said it is on track to cut its 2005 carbon emissions in half by 2030.

Both goals are in line with targets an international group of scientists warn is necessary to avoid the most catastrophic impacts of climate change. But reducing greenhouse gasses was not the primary motivation, said executive vice president and general counsel Jim Gallegos.

“The primary driver is focused on our customers and communities and setting them up … to be competitive,” Gallegos said. “We do think renewables are going to do it better than fossil fuels.”

Alliant has told regulators it can save customers up to $6.5 billion over the next 35 years by adding more than 1,600 megawatts of renewable generation, closing one of its two remaining Wisconsin coal plants and taking other undisclosed actions.

In a statement, Alliant chairman and CEO John Larsen said the goal is part of broader corporate and social responsibility efforts “guided by our strategy and designed to deliver on our purpose — to serve customers and build stronger communities.”

Coal out; gas remains
The goal applies only to Alliant’s electricity generation — the company has no plans to stop distributing natural gas for heating — and is “net-zero,” meaning the company could use some form of carbon capture or purchase carbon credits to offset continuing emissions.

The plan relies heavily on renewable generation — seen in regions embracing clean power across North America — including the addition of up to 1,000 megawatts of new Wisconsin solar plants by the end of 2023 and 1,000 megawatts of Iowa wind generation added over the past four years — as well as natural gas generators to replace its aging coal fleet.

But Jeff Hanson, Alliant’s director of sustainability, said eliminating or offsetting all carbon emissions will require new tools, such as battery storage or possibly carbon-free fuels such as hydrogen, and awareness of the Three Mile Island debate over the role of nuclear power in the mix.

“Getting to the 2040 goals, that’s all based on the technologies of today,” Hanson said. “Can we get to net zero today? The challenge would be a pretty high bar to clear.”

Gallegos said the plan does not call for the construction of more large-scale natural gas generators like the recently completed $700 million West Riverside Energy Center in Beloit, though natural gas will remain a key piece of Alliant’s generation portfolio.

Alliant announced plans in May to close its 400-megawatt Edgewater plant in Sheboygan by the end of 2022, echoing how Alberta is retiring coal by 2023 as markets shift, but has not provided a date for the shutdown of the jointly owned 1,100-megawatt Columbia Energy Center near Portage, which received about $1 billion worth of pollution-control upgrades in the past decade.

Alliant’s Iowa subsidiary plans to convert its 52-year-old, 200-megawatt Burlington plant to natural gas by the end of next year and a pair of small coal-fired generators in Linn County by 2025. That leaves the 250-megawatt plant in Lansing, which is now 43 years old, and the 734-megawatt Ottumwa plant as the remaining coal-fired generators, even as others keep a U.S. coal plant running indefinitely elsewhere.

Earlier this year, the utility asked regulators to approve a roughly $900 million investment in six solar farms across the state with a total capacity of 675 megawatts, similar to plans in Ontario to seek new wind and solar to address supply needs. The company plans to apply next year for permission to add up to 325 additional megawatts.

Alliant said the carbon-neutral plan, which entails closing Edgewater along with other undisclosed actions, would save customers between $2 billion and $6.5 billion through 2055 compared to the status quo.

Tom Content, executive director of the Citizens Utility Board, said the consumer advocacy group wants to ensure that ratepayers aren’t forced to continue paying for coal plants that are no longer needed while also paying for new energy sources and would like to see a bigger role for energy efficiency and more transparency about the utilities’ pathways to decarbonization.

‘They could do better’
Environmental groups said the announcement is a step in the right direction, though they say utilities need to do even more to protect the environment and consumers.

Amid competition from cheaper natural gas and renewable energy and pressure from environmentally conscious investors, U.S. utilities have been closing coal plants at a record pace in recent years, as industry CEOs say a coal comeback is unlikely in the U.S., a trend that is expected to continue through the next decade.

“This is not industry leadership when we’re talking about emission reductions,” said Elizabeth Katt Reinders, regional campaign director for the Sierra Club, which has called on Alliant to retire the Columbia plant by 2026.

Closing Edgewater and Columbia would get Alliant nearly halfway to its emissions goals while saving customers more than $250 million over the next decade, according to a Sierra Club study released earlier this year.

“Retiring Edgewater was a really good decision. Investing in 1,000 megawatts of new solar is game-changing for Wisconsin,” Katt Reinders said. “In the same breath we can say this emissions reduction goal is unambitious. Our analysis has shown they can do far more far sooner.”

Scott Blankman, a former Alliant executive who now works as director of energy and air programs for Clean Wisconsin, said Alliant should not run the Columbia plant for another 20 years.

“If they’re saying they’re looking to get out of coal by 2040 in Wisconsin I’d be very disappointed,” Blankman said. “I do think they could do better.”

Alliant is the 15th U.S. investor-owned utility to set a net-zero target, according to the Natural Resources Defense Council, joining Madison Gas and Electric, which announced a similar goal last year. Minnesota-based Xcel Energy, which serves customers in western Wisconsin, was the first large investor-owned utility to set such a target, as state utilities report declining returns in coal operations.

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Estonia energy prices 2021 show sharp electricity hikes versus the EU average, mixed natural gas trends, kWh tariffs on Nord Pool spiking, and VAT, taxes, and support measures shaping household bills.

Key Points

EU-high electricity growth, early gas dip, then Nord Pool spikes; taxes, VAT, and subsidies shaped energy bills.

✅ Electricity up 7% on year; EU average 2.8% in H1 2021.

✅ Gas fell 1% in H1; later spiked with global market.

✅ VAT, taxes, excise and aid impacted household costs.

Estonia saw one of the highest rates in growth of electricity prices in the first half of 2021, compared with the same period in key trends in 2020 across Europe. These figures were posted before the more recent, record level of electricity and natural gas prices; the latter actually dropped slightly in Estonia in the first half of the year.

While electricity prices rose 7 percent on year in the first half of 2021 in Estonia, the average for the EU as a whole, where energy prices drove inflation across the bloc, stood at 2.8 percent over the same period, BNS reports.

Hungary (€10 per 100 Kwh) and Bulgaria (€10.20 per 100 Kwh) saw the lowest electricity prices EU-wide, while at €31.9 per KWH, Germany's power prices posted the most expensive rate, while Denmark, Belgium and Ireland also had high prices, in excess of €25 per Kwh.

Slovenia saw the highest electricity price rise, at 15 percent, and even the United States' electricity prices saw their steepest rise in decades during the same era, while Estonia was in third place, joint with Romania at 7 percent as noted, and behind Poland (8 percent).

Lithuania, on the other hand, experienced the third highest electricity price fall over the first half of 2021, compared with the same period in 2020, at 6 percent, behind only Cyprus (7 percent) and the Netherlands (10 percent, largely due to a tax cut).

Urmas Reinsalu: VAT on electricity, gas and heating needs to be lowered
The EU average price of electricity was €21.9 percent per Kwh, with taxes and excise accounting for 39 percent of this, even as prices in Spain surged across the day-ahead market.

Estonia has also seen severe electricity price rises in the second half of the year so far, with records set and then promptly broken several times earlier in October, while an Irish electricity provider raised prices amid similar pressures, and a support package for low income households rolled out for the winter season (October to March next year). The price on the Nord Pool market as of €95.01 per Kwh; a day earlier it had stood at €66.21 per Kwh, while on October 19 the price was €140.68 per Kwh.

Gas prices
Natural gas prices to household, meanwhile, dropped in Estonia over the same period, at a sharper rate (1 percent) than the EU average (0.5 percent), according to Eurostat.

Gas prices across the EU were lowest in Lithuania (€2.8 per 100 Kwh) and highest in the Netherlands (€9.6 per KWH), while the highest growth was seen in Denmark (19 percent), in the first half of 2021.

Natural gas prices dropped in 20 member states, however, with the largest drop again coming in Lithuania (23 percent).

The average price of natural gas EU-side in the first half of 2021 was €6.4, and taxes and excise duties accounted on average for 36 percent of the total.

The second half of the year has seen steep gas price rises in Estonia, largely the result of increases on the world market, though European gas benchmarks later fell to pre-Ukraine war levels.

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EU Solar Impact on Electricity Prices highlights how rising solar PV penetration drives negative pricing, shifts peak hours, pressures wholesale markets, and challenges grid balancing, interconnection, and flexibility amid changing demand and renewables growth.

Key Points

Explains how rising solar PV cuts wholesale prices, shifts negative-price hours, and strains grid flexibility.

✅ Negative pricing events surge with higher solar penetration.

✅ Afternoon price dips replace night-time wind-led lows.

✅ Grid balancing, interconnectors, and flexibility become critical.

The latest EU electricity market report has confirmed the affect deeper penetration of solar is having on wholesale electricity prices more broadly.

The Quarterly Report on European Electricity Markets for the final three months of last year noted the number of periods of negative electricity pricing doubled from 2019, to almost 1,600 such events, as global renewables set new records in deployment across markets.

Having experienced just three negative price events in 2019, the Netherlands recorded almost 100 last year “amid a dramatic increase in solar PV capacity,” in the nation, according to the report.

Whilst stressing the exceptional nature of the Covid-19 pandemic on power consumption patterns, the quarterly update also noted a shift in the hours during which negative electric pricing occurred in renewables poster child Germany. Previously such events were most common at night, during periods of high wind speed and low demand, but 2020 saw a switch to afternoon negative pricing. “Thus,” stated the report, “solar PV became the main driver behind prices falling into negative territory in the German market in 2020, as Germany's solar boost accelerated, and also put afternoon prices under pressure generally.”

The report also highlighted two instances of scarce electricity–in mid September and on December 9–as evidence of the problems associated with accommodating a rising proportion of intermittent clean energy capacity into the grid, and called for more joined-up cross-border power networks, amid pushback from Russian oil and gas across the continent.

Rising solar generation–along with higher gas output, year on year–also helped the Netherlands generate a net surplus of electricity last year, after being a net importer “for many years.” The EU report also noted a beneficial effect of rising solar generation capacity on Hungary‘s national electricity account, and cited a solar “boom” in that country and Poland, mirroring rapid solar PV growth in China in recent years.

With Covid-19 falls in demand helping renewables generate more of Europe's electricity (39%) than fossil fuels (36%) for the first time, as renewables surpassed fossil fuels across Europe, the market report observed the 5% of the bloc's power produced from solar closed in on the 6% accounted for by hard coal. In the final three months of the year, European solar output rose 12%, year on year, to 18 TWh and “the increase was almost single-handedly driven by Spain,” the study added.

With coal and lignite-fired power plunging 22% last year across the bloc, it is estimated the European power sector reduced its carbon footprint 14% as part of Europe's green surge although the quarterly report warned cold weather, lower wind speeds and rising gas prices in the opening months of this year are likely to see carbon emissions rebound.

There was good news on the transport front, though, with the report stating the scale of the European “electrically-charged vehicle” fleet doubled in 2020, to 2 million, with almost half a million of the new registrations arriving in the final months of the year. That meant cars with plug sockets accounted for a remarkable 17% of new purchases in Q4, twice the proportion seen in China and a slice of the pie six times bigger than such products claimed in the U.S.

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Ottawa Hydro Substation Heritage Designation highlights Hydro Ottawa's 1920s architecture, Art Deco facades, and municipal utility history, protecting key voltage-reduction sites in Glebe, Carling-Merivale, Holland, King Edward, and Old Ottawa South.

Key Points

A city plan to protect Hydro Ottawa's 1920s substations for architecture, utility role, and civic electrical heritage.

✅ Protects five operating voltage-reduction sites citywide

✅ Recognizes Art Deco and early 20th century utility architecture

✅ Allows emergency demolition to ensure grid safety

The city of Ottawa is looking to designate five hydro substations built nearly a century ago as heritage structures, a move intended to protect the architectural history of Ottawa's earliest forays into the electricity business, even as Ottawa electricity consumption has shifted in recent years.

All five buildings are still used by Hydro Ottawa to reduce the voltage coming from transmission lines before the electricity is transmitted to homes and businesses, and when severe weather causes outages, Sudbury Hydro crews work to reconnect service across communities.

Electricity came to Ottawa in 1882 when two carbon lamps were installed on LeBreton Flats, heritage planner Anne Fitzpatrick told the city's built heritage subcommittee on Tuesday. It became a lucrative business, and soon a privately owned monopoly that drew public scrutiny similar to debates over retroactive charges in neighboring jurisdictions.

In 1905, city council held a special meeting to buy the electrical company, which led to a dramatic drop in electricity rates for residents, a contrast with recent discussions about peak hydro rates for self-isolating customers.

The substations are now owned by Hydro Ottawa, which agreed to the heritage designations on the condition it not be prevented from emergency demolitions if it needs to address incidents such as damaging storms in Ontario while it works to "preserve public safety and the continuity of critical hydro electrical services."

Built in 1922, the substation at the intersection of Glebe and Bronson avenues was the first to be built by the new municipal electrical department, long before modern battery storage projects became commonplace on Ontario's grid.

The largest of the substations being protected dates back to 1929 and is found at the corner of Carling Avenue and Merivale Road. It was built to accommodate a growing population in areas west of downtown including Hintonburg and Mechanicsville.

The substation on Holland Avenue near the Queensway is different from the others because it was built in 1924 to serve the Ottawa Electric Railway Company. The streetcar company operated from 1891 to 1959, and urban electrical infrastructure can face failures such as the Hydro-Québec manhole fire that left thousands without power.

This substation on King Edward Avenue was built in 1931 and designed by architect William Beattie, who also designed York Street Public School in Lowertown and the substation on Carling Avenue. 

The last substation to be built in a 'bold and decorative style' is at 39 Riverdale Ave. in Old Ottawa South, according to city staff. It was designed in an Art Deco style by prominent architect J. Albert Ewart, who was also behind the Civic Hospital and nearby Southminster Church on Bank Street.

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OPG Credit Rating affirmed by DBRS at A (low) issuer and unsecured debt, R-1 (low) CP, Stable trends, backed by a supportive regulatory regime, strong leverage metrics, and provincial support; monitor Darlington Refurbishment costs.

Key Points

It is DBRS's confirmation of OPG at A (low) issuer and unsecured, R-1 (low) CP, with Stable outlooks.

✅ Stable trends; strong cash flow-to-debt and capital ratios

✅ Provincial financing via OEFC; Fair Hydro Trust ring-fenced

✅ Darlington Refurbishment on budget; cost overruns remain risk

DBRS Limited (DBRS) confirmed the Issuer Rating and the Unsecured Debt rating of Ontario Power Generation Inc. (OPG or the Company) at A (low) and the Commercial Paper (CP) rating at R-1 (low), amid sector developments such as Hydro One leadership efforts to repair government relations and measures like staff lockdowns at critical sites.

All trends are Stable. The ratings of OPG continue to be supported by (1) the reasonable regulatory regime in place for the Company's regulated generation facilities, including stable pricing signals for large users, (2) strong cash flow-to-debt and debt-to-capital ratios and (3) continuing financial support from its shareholder, the Province of Ontario (the Province; rated AA (low) with a Stable trend by DBRS). The Province, through its agent, the Ontario Electricity Financial Corporation (rated AA (low) with a Stable trend by DBRS), provides most of OPG's financing (approximately 43% of consolidated debt). The Company's remaining debt includes project financing (31%), including projects such as a battery energy storage system proposed near Woodstock, non-recourse debt issued by Fair Hydro Trust (Senior Notes rated AAA (sf), Under Review with Negative Implications by DBRS; 11%), CP (2%) and Senior Notes issued under the Medium Term Note Program (12%).

In March 2019, the Province introduced 'Bill 87, Fixing the Hydro Mess Act, 2019' which includes winding down the Fair Hydro Plan, and later introduced electricity relief to mitigate customer bills during the COVID-19 pandemic. OPG will remain as the Financial Services Manager for the outstanding Fair Hydro Trust debt, which will become obligations of the Province. DBRS does not expect this development to have a material impact on the Company as (1) the Fair Hydro Trust debt will continue to be bankruptcy-remote and ring-fenced from OPG (all debt is non-recourse to the Company) and (2) the credit rating on the Company's investment in the Subordinated Notes (rated AA (sf), Under Review with Negative Implications by DBRS) will likely remain investment grade while the Junior Subordinated Notes (rated A (sf), Under Review with Developing Implications by DBRS) will not necessarily be negatively affected by this change (see the DBRS press release, 'DBRS Maintains Fair Hydro Trust, Series 2018-1 and Series 2018-2 Notes Under Review,' dated March 26, 2019, for more details).

OPG's key credit metrics improved in 2018, following the approval of its 2017-2021 rates application by the Ontario Energy Board in December 2017, alongside the Province's energy-efficiency programs that shape demand. The Company's profitability strengthened significantly, with corporate return on equity (ROE) of 7.8% (adjusted for a $205 million gain on sale of property; 5.1% in 2017) closer to the regulatory allowed ROE of 8.78%. However, DBRS continues to view a positive rating action as unlikely in the short term because of the ongoing large capital expenditures program, including the $12.8 billion Darlington Refurbishment project, amid ongoing oversight following the nuclear alert investigation in Ontario. However, a downgrade could occur should there be significant cost overruns with the Darlington Refurbishment project that result in stranded costs. DBRS notes that the Darlington Refurbishment project is currently on budget and on schedule.

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