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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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Texas Electricity Complaints surged to a three-year high, highlighting Public Utility Commission data on billing disputes, meter problems, and service issues in the competitive retail electricity market and consumer protection process.

Key Points

Consumer filings to Texas PUC about billing, service, and meters, with 2018 reaching a three-year high.

✅ 5,371 complaints/inquiries in FY2018; 43.8% involved billing disputes.

✅ Service issues 15.8% and meters 12.6%; PUC publishes complaint stats.

✅ Advocates urge monitoring to keep deregulated retail market healthy.

The number of electricity service-related complaints and inquiries filed with the state’s Public Utility Commission reached a three-year high this past fiscal year, an advocacy group said Tuesday.

According to the Texas Coalition for Affordable Power, a nonprofit that advocates for low electricity prices, Texans filed 5,371 complaints or inquiries with the commission between September 2017 and August of this year. That’s up from the 4,175 complaints or inquiries filed during the same period in 2017 and the 4,835 filed in 2016. The complaints and inquiries included concerns with billing, meters and service.

“This stark uptick in complaints is disappointing — especially after several years of generally improving numbers,” Jay Doegey, the coalition's executive director, said in a written statement. “In percentage terms, the year-to-year rise in complaints is the greatest in a decade. Clearly, many Texans remain frustrated with aspects of their electric service.”

The utility commission did not immediately respond to a request for comment.

While complaints and inquiries increased in 2018, the number of complaints and inquiries has generally decreased since 2009, when Texans filed 15,956 with the commission. That could be because there have been lower residential electricity prices and because Texans have become more familiar with the state’s competitive retail electricity system over the last decade, the coalition's report said.

And complaints from 2018 are well below 2003 levels, when the number of complaints and inquiries soared to more than 17,000, a year after Texas deregulated most of its electricity market structure at the time.

But Jake Dyer, a policy analyst at the coalition, said his group is closely watching the uptick in complaints this year as the Texas power grid faces recurring strains.

“We are invested in making sure the competition works,” Dyer said. “When you see an uptick like this, you should watch very closely to make sure the market remains healthy and to make sure there is not something else going on.”

However, Dyer said that it is too early to know what that something else that is going on might be.

According to the report, concerns about billing made up most of the complaints and inquiries filed this year at 43.8 percent. That’s up from 42.5 percent in fiscal year 2017. Concerns about the provision of electrical service and about electrical meters also ranked high, constituting 15.8 percent and 12.6 percent of the complaints and inquiries, respectively.

The Public Utility Commission publishes customer complaint statistics on its website. The Texas Coalition for Affordable Power takes into account both complaints and inquiries filed with the commission for its report in order “to gauge general consumer sentiment and to maintain a uniform methodology across the study period.”

Texans can file an official complaint with the the commission's Customer Protection Division. Under the complaint process, the complaint is sent to the electric company, which has 21 days to respond.

Some providers outside the competitive market, such as electric cooperatives, drew praise for performance during the 2021 winter storm.

Following the 2021 winter storm, Texas lawmakers proposed an electricity market bailout to stabilize costs and reliability.

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UK Energy Security Bill drives private investment, diversifies from fossil fuels with hydrogen and offshore wind, strengthens an independent system operator, and extends the retail price cap to shield consumers from volatile gas markets.

Key Points

A UK plan to reform energy, cut fossil fuel reliance, boost hydrogen and wind, and extend the retail price cap.

✅ Targets £100bn private investment and 480,000 jobs by 2030.

✅ Creates an independent system operator for grid planning.

✅ Extends retail energy price cap; mitigates volatile gas costs.

The British government said that plans to bolster the country's energy security, diversify away from fossil fuels amid the Europe energy crisis and protect consumers from spiralling prices are set to become law.

Britain's energy security bill will be introduced to Parliament on Wednesday and includes 26 measures to reform the energy system, including ending the gas-electricity price link, and reduce its dependency on fossil fuels and exposure to volatile gas prices.

Global energy prices have skyrocketed this year, and UK natural gas and electricity have risen sharply, particularly after Russia's invasion of Ukraine which has led to many European countries trying to reduce reliance on Russian pipeline gas and seek cheaper alternatives.

The bill will help drive 100 billion pounds ($119 billion) of private sector investment by 2030 into industries to diversify Britain's energy supply, including hydrogen and offshore wind, which could help lower costs as a 16% decrease in bills in April is anticipated, and create around 480,000 jobs by the end of the decade, the government said.

"We’re going to slash red tape, get investment into the UK, and grab as much global market share as possible in new technologies to make this plan a reality," Business and Energy Secretary Kwasi Kwarteng, amid high winter energy costs, said in a statement.

The bill will establish a new independent system operator to coordinate and plan Britain's energy system, while MPs move to restrict prices for gas and electricity through oversight.

It will also enable the extension of a cap on retail energy prices beyond 2023, with the price cap cost under scrutiny, which limits the amount suppliers can charge for each unit of gas and electricity.

The bill will also enable the secretary of state to prevent potential disruptions to the downstream oil sector due to industrial action or malicious protests, the government added.

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Bruce Power Major Component Replacement secures Ontario-made nuclear components via $914M contracts, supporting refurbishment, clean energy, low-cost electricity, and advanced manufacturing, extending reactor life to 2064 while boosting jobs, supply chain growth, and economy.

Key Points

A refurbishment program investing $914M in advanced manufacturing to extend reactors and deliver low-cost, clean power.

✅ $914M Ontario-made components for steam generators, tubes, fittings

✅ Extends reactor life to 2064; clean, low-cost electricity for Ontario

✅ Supports 22,000 jobs annually; boosts supply chain and economy

Today, Bruce Power signed $914 million in advanced manufacturing contracts for its Major Component Replacement, which gets underway in 2020, as the reactor refurbishment begins across the site and will allow the site to provide low-cost, carbon-free electricity to Ontario through 2064.

The Major Component Replacement (MCR) Project agreements include:

• $642 million to BWXT Canada Inc. for the manufacturing of 32 steam generators to be produced at BWXT’s Cambridge facility.
• $144 million to Laker Energy Products for end fittings, liners and flow elements, which will be manufactured at its Oakville location.
• $62 million to Cameco Fuel Manufacturing, in Cobourg, for calandria tubes and annulus spacers for all six MCRs.
• $66 million for Nu-Tech Precision Metals, in Arnprior, for the production of zirconium alloy pressure tubes for Units 6 and 3.

Bruce Power’s Life-Extension Program, which started in January 2016 with Asset Management Program investments and includes the MCRs on Units 3-8, remains on time and on budget.”

#google#

By signing these contracts today, we have secured ‘Made in Ontario‘ solutions for the components we will need to successfully complete our MCR Projects, extending the life of our site to 2064,” said Mike Rencheck, Bruce Power’s President and CEO.

“Today’s announcements represent a $914 million investment in Ontario’s highly skilled workforce, which will create untold economic opportunities for the communities in which they operate for many years to come.”We look forward to growing our already excellent relationships with these supplier partners and unions as we work toward our common goal, supported by an operating record, of continuing to keep Canada’s largest infrastructure project on time and on budget."

By extending the life of Bruce Power’s reactors to 2064, the company will create and sustain 22,000 jobs annually, both directly and indirectly, across Ontario, while investing $4 billion a year into the province’s economy, underscoring the economic benefits of nuclear development across Canada.

At the same time, Bruce Power will produce 30 per cent of Ontario’s electricity at 30 per cent less than the average cost to generate residential power, while also producing zero carbon emissions, aligning with Pickering NGS life extensions across the province.The Hon. Glenn Thibeault, Minister of Energy, said today’s announcement is good news for the people of Ontario.”

Bruce Power’s Life-Extension Program makes sense for Ontario, and the announcements made today will create good jobs and benefit our economy for decades to come,” Minister Thibeault said.

“Moving forward with the refurbishment project is part of our government’s plan to support care and opportunity, while producing affordable, reliable and clean energy for the people of Ontario.”Kim Rudd, Parliamentary Secretary to the Minister of Natural Resources and MP for Northumberland-Peterborough South, offered her support and congratulations.”

Related planning includes Bruce C project exploration funding that supports long-term nuclear options in Ontario.

Canada’s nuclear industry, including its advanced manufacturing capability, is respected internationally,” Rudd said. “Bruce Power’s announcement today related to the advanced manufacturing of key components throughout Ontario as part of its Life-Extension Program will allow these suppliers to have a secure base to not only meet Canada’s needs, but export internationally.”

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Nova Scotia Cap-and-Trade Program joins Western Climate Initiative to leverage emissions trading IT systems, track allowances, and manage compliance, while setting in-province caps, carbon pricing signals, and third-party verified reporting for industrial and fuel suppliers.

Key Points

A provincial emissions trading system using WCI services to cap GHGs, track allowances, and enforce verified compliance.

✅ Uses WCI IT system to manage allowances and registry

✅ Initial trading limited to in-province participants

✅ Third-party verification and annual reporting deadlines

Nova Scotia is yet to set targets for its new cap and trade regime to reduce greenhouse gases, but the province announced Monday that it has joined the Western Climate Initiative Inc. -- a non-profit corporation formed to provide administrative and technical services to states and provinces with emissions trading programs.

Environment Minister Iain Rankin said joining the initiative would allow the province to use its IT system to manage and track its new cap and trade program.

Rankin said the province can join without trading greenhouse gas emission allowances with other jurisdictions -- California, Quebec, and Ontario are currently linked through the program, with Hydro-Québec's U.S. sales highlighting cross-border dynamics. Nova Scotia currently has no plans to trade outside the province as it works on emissions caps Rankin said will be ready sometime in June.

#google#

Nova Scotia is yet to set targets for its new cap and trade regime to reduce greenhouse gases, but the province announced Monday that it has joined the Western Climate Initiative Inc. -- a non-profit corporation formed to provide administrative and technical services to states and provinces with emissions trading programs.

Environment Minister Iain Rankin said joining the initiative would allow the province to use its IT system to manage and track its new cap and trade program.

Rankin said the province can join without trading greenhouse gas emission allowances with other jurisdictions -- California, Quebec, and Ontario are currently linked through the program. Nova Scotia currently has no plans to trade outside the province as it works on emissions caps Rankin said will be ready sometime in June.

"By keeping our system internal it ensures that our greenhouse gas reductions are happening within our province," said Rankin. "But we do have that opportunity (to join) and if there are new entrants or we need more access to credits then that may shift our strategy."

The use of the system will cost Nova Scotia about US$314,000 for 2018-19, with an annual cost in subsequent years of about US$228,000 or more, if the province requests modifications.

"If we were to do something like that internally we would have to build a full database and hire more people, so this was an obvious choice for us," said Rankin.

Nova Scotia has already met the national reduction target of 30 per cent below 2005 levels and says it's on track to have 40 per cent of electricity generation from renewables by 2020, underscoring how cleaning up Canada's electricity supports climate pledges.

Stephen Thomas, energy campaign coordinator for the Ecology Action Centre, called the province's move an "important small step," stressing the importance of using the same administrative rules as the other jurisdictions involved.

But Thomas said Nova Scotia should go further and trade emissions with California, Quebec, and Ontario, and also put a price on carbon by auctioning credits as they do.

Thomas said Nova Scotia's system stands to be volatile because of the smaller number of participants -- about 20 including Nova Scotia Power, Northern Pulp, Lafarge, and large oil and gasoline companies such as ExxonMobil, Imperial and Irving.

"It's very likely to favour Nova Scotia Power as the largest single emitter with the most credits to sell here, and that would change if we had a linked system, at a time when Canada will need more electricity to hit net-zero according to the IEA," Thomas said.

He said it's important to have a linked system and a regional approach in Atlantic Canada, which has more emissions per person and more emissions per GDP than places like Ontario, Quebec and California, and where policies like Newfoundland's rate reduction plan can influence electricity strategy.

"Reducing emissions, because we are so emissions-intensive here, is a little bit cheaper," said Thomas. "So it's possible that Ontario, Quebec and California could pay Nova Scotia to reduce its emissions."

Under its program, Nova Scotia requires industrial facilities generating 50,000 tonnes or more of greenhouse gas emissions per year to report emissions.

Regulations also cover petroleum product suppliers that import or produce 200 litres of fuel or more per year for consumption and natural gas distributors whose products produce at least 10,000 tonnes of greenhouse gas emissions a year.

Companies were to have reported to the Environment Department by May 1 but Rankin said the deadline has been pushed back to June 1, a deadline that was to be followed in subsequent years in any event. Reports must be verified by a third party by Sept. 1 every year.

The Liberal government passed enabling legislation for cap and trade last fall.

As for the upcoming emissions caps, Rankin isn't tipping the province's hand yet, even as B.C.'s 2050 targets face a shortfall in some forecasts.

"Those caps will recognize the investments that have already been made and therefore will be the most cost-effective program that we can put together to meet the federal requirement," he said.

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Downed Power Line Vehicle Safety: Follow stay-in-the-car protocol, call 911, avoid live wires and utility poles, and use the bunny hop to escape only for fire. Electrical hazards demand emergency response caution.

Key Points

Stay in the car, call 911, and use a bunny hop escape only if fire threatens during downed power line incidents.

✅ Stay in vehicle; tell bystanders to keep back and call 911.

✅ Exit only for fire; jump clear and bunny hop away.

✅ Treat all downed lines as live; avoid paths to ground.

Ameren Illinois and Safe Electricity are urging the public to stay in their cars and call 911 in the event of an accident involving a power pole that brings down power lines on or around the car.

In a media simulation Tuesday at the Ameren facility on West Lafayette Avenue, Ameren Illinois employees demonstrated the proper way to react if a power line has fallen on or around a vehicle, as some utilities consider on-site staffing measures during outbreaks. Although the situation might seem rare, Illinois motorists alone hit 3,000 power poles each year, said Krista Lisser, communications director for Safe Energy.

“We want to get the word out that, if you hit a utility pole and a live wire falls on your vehicle, stay in your car,” Lisser said. “Our first reaction is we panic and think we need to get out, a sign of the electrical knowledge gap many people have. That’s not the case, you need to stay in because, when that live wire comes down, electricity is all around you. You may not see it, it may not arc, it may not flash, you may not know if there’s electricity there.”

Should someoneinvolved in such an accident see a good Samaritan attempting to help, he should try to tell the would-be rescuer to stay back to prevent injury to the Samaritan, Ameren Illinois Communications Executive Brian Bretsch said.

“We have seen instances where someone comes up and wants to help you,” Bretsch said. “You want to yell, ‘Please stay away from the vehicle. Everyone is OK. Please stay away.’ You’ll see … instances every now and then where the Samaritan will come up, create that path to ground and get injured, and there are also climbers seeking social media glory who put themselves at risk.”

The only instance in which one should exit a car in the vicinity of a downed wire is if the vehicle is on fire and there is no choice but to exit. In that situation, those in the car should “bunny hop” out of the car by jumping from the car without touching the car and the ground at the same time, Bretsch and Lisser said.

After the initial jump, those escaping the vehicle should continue jumping with both feet together and hands tucked in and away from danger until they are safely clear of the downed wire.

It’s important for everyone to be informed, because an encounter with a live wire could easily result in serious injury, as in the Hydro One worker injury case, or death, Lisser said.

“They’re so close to our roads, especially in our rural communities, that it’s quite a common occurrence,” Lisser said. “Just stay away from (downed lines), especially after storms and amid grid oversight warnings that highlight reliability risks … Always treat a downed line as a live wire. Never assume the line is dead.”

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