Put green into your bottom line

By Globe and Mail


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Canada Savings Bonds are offering only 1.2-per-cent interest, and people are buying them because alternative reliable investments with predictable returns are hard to find. So it's important to look at an opportunity that's been waiting to be noticed – an investment that is as good for the environment as it is for the bottom line.

Energy conservation measures (ECMs) save money.

New lighting or better heating and air conditioning systems reduce the expense of running a building, and the money saved is just as good as money earned in any other way (or better, since it's tax free). The cost of such improvements should therefore be seen as an investment where the return usually begins immediately and often continues indefinitely.

These opportunities are available to everyone, including small businesses and homeowners, but they are especially relevant to large institutions such as universities and hospitals that have both physical plant responsibilities and endowments that they need to invest for maximum return.

Such organizations should immediately begin investing in energy conservation by liquidating other investments that yield less of a return than can be generated by investing in energy conservation measures.

Unfortunately, in the past, the focus has been on the upfront costs of making ECM improvements. These days, our current financial situation seems to permit even less spending on what's been viewed as environmental indulgence. But hard times should force us to make the comparison between spending on energy conservation measures and other potential uses of capital.

This is especially true in the case of large institutions that have both physical plant responsibilities and substantial endowment funds, because what that comparison shows is impressive. Consider the following examples.

If a building retrofit costs $1,000 and saves $200 per year in energy costs, it will pay for itself in five years. Most people wouldn't like the seemingly long payback time. But if the retrofit is, for example, a furnace upgrade and lasts for 10 years, then it will earn an average of 16 per cent per year, which is a far greater return than most options. If the retrofit is improved insulation and is expected to last 25 years, then the average return per year for each of those 25 years will be 19 per cent.

Some large institutions are aware energy conservation improvements offer savings and fund ECMs that can pay for themselves over time. Some decision-makers have accepted projects that can pay for themselves, even if they take as long as three years to do so. Money for these projects is sometimes taken from the utilities budget on the theory the savings will ultimately flow back to that side of the ledger. Many organizations, however, still demand such investments pay for themselves in a single year. If the cost cannot be recouped in one budget cycle, the opportunity is ignored.

Yet, even a three-year-payback policy is short-sighted because, as the examples show, the real opportunity to profit on the investment does not end after 36 months. If a new piece of equipment has an anticipated 20-year lifespan, then even if it takes, say, 12 years to pay back the upfront cost, there is still room for a healthy 20-year average-annual return of more than 5 per cent on the money spent. And some ECMs come with guarantees they will last for 15, 20 or 25 years.

Uncertainty about the future cost of energy makes it impossible to predict exactly how good the investment will be, but anticipating paying more is probably a safer bet than most investment decisions.

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UK must start construction of large-scale storage or fail to meet net zero targets.

UK Hydrogen Storage Caverns enable long-duration, low-carbon electricity balancing, storing surplus wind and solar power as green hydrogen in salt formations to enhance grid reliability, energy security, and net zero resilience by 2035 and 2050.

 

Key Points

They are salt caverns storing green hydrogen to balance wind and solar, stabilizing a low-carbon UK grid.

✅ Stores surplus wind and solar as green hydrogen in salt caverns

✅ Enables long-duration, low-carbon grid balancing and security

✅ Complements wind and solar; reduces dependence on flexible CCS

 

The U.K. government must kick-start the construction of large-scale hydrogen storage facilities if it is to meet its pledge that all electricity will come from low-carbon electricity sources by 2035 and reach legally binding net zero targets by 2050, according to a report by the Royal Society.

The report, "Large-scale electricity storage," published Sep. 8, examines a wide variety of ways to store surplus wind and solar generated electricity—including green hydrogen, advanced compressed air energy storage (ACAES), ammonia, and heat—which will be needed when Great Britain's electricity generation is dominated by volatile wind and solar power.

It concludes that large scale electricity storage is essential to mitigate variations in wind and sunshine, particularly long-term variations in the wind, and to keep the nation's lights on. Storing most of the surplus as hydrogen, in salt caverns, would be the cheapest way of doing this.

The report, based on 37 years of weather data, finds that in 2050 up to 100 Terawatt-hours (TWh) of storage will be needed, which would have to be capable of meeting around a quarter of the U.K.'s current annual electricity demand. This would be equivalent to more than 5,000 Dinorwig pumped hydroelectric dams. Storage on this scale, which would require up to 90 clusters of 10 caverns, is not possible with batteries or pumped hydro.

Storage requirements on this scale are not currently foreseen by the government, and the U.K.'s energy transition faces supply delays. Work on constructing these caverns should begin immediately if the government is to have any chance of meeting its net zero targets, the report states.

Sir Chris Llewellyn Smith FRS, lead author of the report, said, "The need for long-term storage has been seriously underestimated. Demand for electricity is expected to double by 2050 with the electrification of heat, transport, and industrial processing, as well as increases in the use of air conditioning, economic growth, and changes in population.

"It will mainly be met by wind and solar generation. They are the cheapest forms of low-carbon electricity generation, but are volatile—wind varies on a decadal timescale, so will have to be complemented by large scale supply from energy storage or other sources."

The only other large-scale low-carbon sources are nuclear power, gas with carbon capture and storage (CCS), and bioenergy without or with CCS (BECCS). While nuclear and gas with CCS are expected to play a role, they are expensive, especially if operated flexibly.

Sir Peter Bruce, vice president of the Royal Society, said, "Ensuring our future electricity supply remains reliable and resilient will be crucial for our future prosperity and well-being. An electricity system with significant wind and solar generation is likely to offer the lowest cost electricity but it is essential to have large-scale energy stores that can be accessed quickly to ensure Great Britain's energy security and sovereignty."

Combining hydrogen with ACAES, or other forms of storage that are more efficient than hydrogen, could lower the average cost of electricity overall, and would lower the required level of wind power and solar supply.

There are currently three hydrogen storage caverns in the U.K., which have been in use since 1972, and the British Geological Survey has identified the geology for ample storage capacity in Cheshire, Wessex and East Yorkshire. Appropriate, novel business models and market structures will be needed to encourage construction of the large number of additional caverns that will be needed, the report says.

Sir Chris observes that, although nuclear, hydro and other sources are likely to play a role, Britain could in principle be powered solely by wind power and solar, supported by hydrogen, and some small-scale storage provided, for example, by batteries, that can respond rapidly and to stabilize the grid. While the cost of electricity would be higher than in the last decade, we anticipate it would be much lower than in 2022, he adds.

 

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BC Hydro says three LNG companies continue to demand electricity, justifying Site C

BC Hydro LNG Load Forecast signals rising electricity demand from LNG Canada, Woodfibre, and Tilbury, aligning Site C dam capacity with BCUC review, hydroelectric supply, and a potential fourth project in feasibility study British Columbia.

 

Key Points

BC Hydro's projection of LNG-driven power demand, guiding Site C capacity, BCUC review, and grid planning.

✅ Includes LNG Canada, Woodfibre, and Tilbury load requests

✅ Aligns Site C hydroelectric output with industrial electrification

✅ Notes feasibility study for a fourth LNG project

 

Despite recent project cancellations, such as the Siwash Creek independent power project now in limbo, BC Hydro still expects three LNG projects — and possibly a fourth, which is undergoing a feasibility study — will need power from its controversial and expensive Site C hydroelectric dam.

In a letter sent to the British Columbia Utilities Commission (BCUC) on Oct. 3, BC Hydro’s chief regulatory officer Fred James said the provincially owned utility’s load forecast includes power demand for three proposed liquefied natural gas projects because they continue to ask the company for power.

The letter and attached report provide some detail on which of the LNG projects proposed in B.C. are more likely to be built, given recent project cancellations.

The documents are also an attempt to explain why BC Hydro continues to forecast a surge in electricity demand in the province, as seen in its first call for power in 15 years driven by electrification, even though massive LNG projects proposed by Malaysia’s state owned oil company Petronas and China’s CNOOC Nexen have been cancelled.

An explanation is needed because B.C.’s new NDP government had promised the BCUC would review the need for the $9-billion Site C dam, which was commissioned to provide power for the province’s nascent LNG industry, amid debates over alternatives like going nuclear among residents. The commission had specifically asked for an explanation of BC Hydro’s electric load forecast as it relates to LNG projects by Wednesday.

The three projects that continue to ask BC Hydro for electricity are Shell Canada Ltd.’s LNG Canada project, the Woodfibre LNG project and a future expansion of FortisBC’s Tilbury LNG storage facility.

None of those projects have officially been sanctioned but “service requests from industrial sector customers, including LNG, are generally included in our industrial load forecast,” the report noted, even as Manitoba Hydro warned about energy-intensive customers in a separate notice.

In a redacted section of the report, BC Hydro also raises the possibility of a fourth LNG project, which is exploring the need for power in B.C.

“BC Hydro is currently undertaking feasibility studies for another large LNG project, which is not currently included in its Current Load Forecast,” one section of the report notes, though the remainder of the section is redacted.

The Site C dam, which has become a source of controversy in B.C. and was an important election issue, is currently under construction and, following two new generating stations recently commissioned, is expected to be in service by 2024, a timeline which had been considered to provide LNG projects with power by the time they are operational.

BC Hydro’s letter to the BCUC refers to media and financial industry reports that indicate global LNG markets will require more supply by 2023.

“While there remains significant uncertainty, global LNG demand will continue to grow and there is opportunity for B.C. LNG,” the report notes.

 

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Ontario will not renew electricity deal with Quebec

Ontario-Quebec Electricity Trade Agreement ends as Ontario pivots to IESO procurement, hydropower alternatives, natural gas capacity, and energy auctions, impacting grid reliability, power imports, and GHG emissions across both provincial markets.

 

Key Points

A seven-year power import pact; Ontario will end it, shifting to IESO procurement and gas capacity.

✅ Seasonal hydropower exchange of 2.3 TWh annually.

✅ IESO projects Quebec supply constraints by decade end.

✅ Ontario adds gas, auctions; near-term sector GHGs rise.

 

The Ontario government does not plan to renew the Ontario-Quebec electricity trade agreement, Radio-Canada is reporting.

The seven-year contract, which expires next year, aims to reduce Ontario's greenhouse gas (GHG) emissions by buying 2.3 Terawatt-hours of electricity from Quebec annually — that corresponds to about seven per cent of Hydro-Quebec's average annual exports.

The announcement comes as the provincially owned Quebec utility continues its legal battle over a plan to export power to Massachusetts.

The Ontario agreement has guaranteed a seasonal exchange of energy, since Quebec has a power surplus in summer, and the province's electricity needs increase in the winter. Ontario plans on exercising its last and only option in the summer of 2026, for a block of 500 megawatts.

The office of the Ontario Minister of Energy Todd Smith says the province will save money by relying "on a competitive procurement process" instead, amid debates over clean, affordable electricity policy in Ontario. And, the Independent Electricity System Operator (IESO), the equivalent of Hydro-Quebec in Ontario, added that, at any rate, Quebec is expected to "run out of electricity in the middle or at the end of the decade."

During the Quebec election campaign, Premier Francois Legault said his province needed to increase hydroelectricity production because he is expecting demand for hydroelectricity to increase by an additional 100 terawatt-hours in the coming decades — half of Hydro-Quebec's current annual output.

Coalition Avenir Quebec pitches more hydro dams to Quebec voters
The provinces will still continue to buy and sell power, reaching deals through annual energy auctions.

Eloise Edom, an associate researcher at Polytechnique Montreal's Institut de l'energie Trottier, says the announcement came as somewhat of a surprise because "we're still talking about a lot of energy."

Hydro-Quebec refused to comment on "the SIERE [Independent Electricity System Operator]'s intentions for the agreement, which ends next year," said company spokesperson Lynn St-Laurent.

No green options
Yet Ontario is running out of electricity, even as questions persist about whether it is embracing clean power to meet demand, in part because of plans to refurbish nuclear reactors at the Bruce and Darlington generator stations.

Windsor has already lost out on a $2.5-billion factory because the region is short of electricity for new industrial loads. And by 2025, Toronto will run out of power for the electrification of its transit system, according to the latest estimates from the IESO.

The Ford government recently announced that it hopes to extend the life of the Pickering nuclear station amid ongoing debate. It is also evaluating the possibility of increasing hydroelectricity production at its existing dams.

For now, Ontario is banking on its natural gas plants to meet demand, which have won most recent IESO tenders for contracts running until 2026. Last Friday, the province announced that it was going to buy an additional 1,500 megawatts by 2027.

"The [Ontario energy] minister's expectations may be that the increase in natural gas prices is temporary and that it will fade," energy economist Jean-Thomas Bernard said. "With this in mind, he probably does not want to sign a long-term contract [with Hydro-Quebec] and prefers to buy electricity on a day-to-day basis and through calls for tenders."

If the Quebec deal expires, Ontario, Canada's second highest GHG emitter, would have to increase its emissions for the sector, at least in the medium term, with electricity getting dirtier as gas fills the gap.

Last year, the IESO found that it would be very difficult to set a moratorium on natural gas before 2030. The IESO must produce a final report on the subject for the energy minister by the end of November.


 

 

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Shopping for electricity is getting cheaper in Texas

Texas Electricity Prices are shifting as deregulation matures, with competitive market shopping lowering residential rates, narrowing gaps with regulated areas, and EIA data showing long term declines versus national averages across most Texans.

 

Key Points

Texas Electricity Prices are average residential rates in deregulated and regulated markets across the state.

✅ Deregulated areas saw 17.4% residential price declines since 2006

✅ Regulated zones experienced a 5.5% increase over the same period

✅ Competitive shopping narrowed the gap; Texas averaged below US

 

Shopping for electricity is becoming cheaper for most Texans, according to a new study from the Texas Coalition for Affordable Power. But for those who live in an area with only one electricity provider, prices have increased in a recent 10-year period, the study says.

About 85 percent of Texans can purchase electricity from a number of providers in a deregulated marketplace, while the remaining 15 percent must buy power from a single provider, often an electric cooperative, in their area.

The report from the Texas Coalition for Affordable Power, which advocates for cities and local governments and negotiates their power contracts, pulls information from the U.S. Energy Information Administration to compare prices for Texans in the two models. Most Texans could begin choosing their electricity provider in 2002.

Buying power tends to be more expensive for Texans who live in a part of the state with a deregulated electricity market. But that gap is continuing to shrink as Texans become more willing to shop for power, even as electricity complaints have periodically risen. In 2015, the gap “was the smallest since the beginning of deregulation,” according to the report.

Between 2006 and 2015, the last year for which data is available, average residential electric prices for Texans in a competitive market decreased by 17.4 percent, while average prices increased by 5.5 percent in the regulated areas, even as the Texas power grid has periodically faced stress.

“These residential price declines are promising, and show the retail electric market is maturing,” Jay Doegey, executive director for the Texas Coalition for Affordable Power, said in a statement. “We’re encouraged by the price declines, but more progress is needed.”

The study attributes the decline to the prevalence of “low-priced individual deals” in the competitive areas, while policymakers consider market reforms to bolster reliability.

Overall, the average price of electricity in Texas (which produces and consumes the most electricity in the U.S.) — including the price in the deregulated marketplace, for the third time in four years — was below the national average in 2015.

 

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UK EV Drivers Demand Fairer Vehicle Taxes

UK EV Per-Mile Taxes are reshaping road pricing and vehicle taxation for electric cars, raising fairness concerns, climate policy questions, and funding needs for infrastructure and charging networks across the country.

 

Key Points

They are per-mile road charges on EVs to fund infrastructure, raising fairness, emissions, and vehicle taxation concerns.

✅ Propose tax relief or credits for EV owners

✅ Consider emission-based road user charging

✅ Invest in charging networks and road infrastructure

 

As the UK continues its push towards a greener future with increased adoption of electric vehicles (EVs) and surging EV interest during supply disruptions, a growing number of electric car drivers are voicing their frustration over the current tax system. The debate centers around the per-mile vehicle taxes that are being proposed and implemented, which many argue are unfairly burdensome on EV owners. This issue has sparked a broader campaign advocating for a more equitable approach to vehicle taxation, one that reflects the evolving landscape of transportation and environmental policy.

Rising Costs for Electric Car Owners

Electric vehicles have been hailed as a crucial component in the UK’s strategy to reduce carbon emissions and combat climate change. Government incentives, such as grants for EV purchases and tax breaks, have been instrumental in encouraging the shift from petrol and diesel cars to cleaner alternatives, even as affordability concerns persist among many UK consumers. However, as the number of electric vehicles on the road grows, the financial dynamics of vehicle taxation are coming under scrutiny.

One of the key issues is the introduction and increase of per-mile vehicle taxes. While these taxes are designed to account for road usage and infrastructure costs, they have been met with resistance from EV drivers who argue that they are being disproportionately affected. Unlike traditional combustion engine vehicles, electric cars typically have lower running costs compared to petrol or diesel models and, in many cases, benefit from lower or zero emissions. Yet, the current tax system does not always reflect these advantages.

The Taxation Debate

The crux of the debate lies in how vehicle taxes are structured and implemented. Per-mile taxes are intended to ensure that all road users contribute fairly to the maintenance of transport infrastructure. However, the implementation of such taxes has raised concerns about fairness and affordability, particularly for those who have invested heavily in electric vehicles.

Critics argue that per-mile taxes do not adequately take into account the environmental benefits of driving an electric car, noting that the net impact depends on the electricity generation mix in each market. While EV owners are contributing to a cleaner environment by reducing emissions, they are also facing higher taxes that could undermine the financial benefits of their greener choice. This has led to calls for a reassessment of the tax system to ensure that it aligns with the UK’s climate goals and provides a fair deal for electric vehicle drivers.

Campaigns for Fairer Taxation

In response to these concerns, several advocacy groups and individual EV owners have launched campaigns calling for a more balanced approach to vehicle taxation. These campaigns emphasize the need for a system that supports the transition to electric vehicles and recognizes their role in reducing environmental impact, drawing on ambitious EV targets abroad as useful benchmarks.

Key proposals from these campaigns include:

  1. Tax Relief for EV Owners: Advocates suggest providing targeted tax relief for electric vehicle owners to offset the costs of per-mile taxes. This could include subsidies or tax credits that acknowledge the environmental benefits of EVs and help to make up for higher road usage fees.

  2. Emission-Based Taxation: An alternative approach is to design vehicle taxes based on emissions rather than mileage. This system would ensure that those driving high-emission vehicles contribute more to road maintenance, while EV owners, who are already reducing emissions, are not penalized.

  3. Infrastructure Investments: Campaigners also call for increased investments in infrastructure that supports electric vehicles, such as charging networks and proper grid management practices that balance load. This would help to address concerns about the adequacy of current road maintenance and support the growing number of EVs on the road.

Government Response and Future Directions

The UK government faces the challenge of balancing revenue needs with environmental goals. While there is recognition of the need to update the tax system in light of increasing EV adoption, there is also a focus on ensuring that any changes are equitable and do not disincentivize the shift towards cleaner vehicles, while considering whether the UK grid can handle additional EV demand reliably.

Discussions are ongoing about how to best implement changes that address the concerns of electric vehicle owners while ensuring that the transportation infrastructure remains adequately funded. The outcome of these discussions will be critical in shaping the future of vehicle taxation in the UK and supporting the country’s broader environmental objectives.

Conclusion

As electric vehicle adoption continues to rise in the UK, the debate over vehicle taxation becomes increasingly important. The campaign for fairer per-mile taxes highlights the need for a tax system that supports the transition to cleaner transportation while also being fair to those who have made environmentally conscious choices. Balancing these factors will be key to achieving the UK’s climate goals and ensuring that all road users contribute equitably to the maintenance of transport infrastructure. The ongoing dialogue and policy adjustments will play a crucial role in shaping a sustainable and just future for transportation in the UK.

 

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Ontario announces SMR plans to four reactors at Darlington

Ontario Darlington SMR Expansion advances four GE Hitachi BWRX-300 reactors with OPG, adding 1,200 MW of baseload nuclear power to support electrification, grid reliability, and clean energy growth across Ontario and Saskatchewan.

 

Key Points

Plan to build four BWRX-300 SMRs at Darlington, delivering 1,200 MW of clean, reliable baseload power under OPG.

✅ Four GE Hitachi BWRX-300 units, 1,200 MW total

✅ Shared infrastructure cuts costs and timelines

✅ Supports electrification, grid reliability, net zero

 

The day after Ontario announced it would be building an additional 4,800 megawatts of nuclear reactors at Bruce Nuclear Generating Station, the province announced it would be dramatically expanding its planned rollout of small modular reactors at its Darlington Nuclear Generating Station, and confirmed plans to refurbish Pickering B as part of its broader strategy.

Ontario Power Generation OPG was always going to be the first to build the GE-Hitachi BWRX-300 small modular reactor SMR, with the U.S.’s Tennessee Valley Authority among others like SaskPower and several European nations following suit. But the OPG was originally going to build just one. On July 7, OPG and the Province of Ontario announced they would be bumping that up to four units of the BWRX-300.

The Ontario government is working with Ontario Power Generation (OPG) to commence planning and licensing for three additional small modular reactors (SMRs), for a total of four SMRs at the Darlington nuclear site. Once deployed, these four units would produce a total 1,200 megawatts (MW) of electricity, equivalent to powering 1.2 million homes, helping to meet increasing demand from electrification and fuel the province’s strong economic growth, the Ontario Ministry of Energy said in a release.

“Our government’s open for business approach has led to unprecedented investments across the province — from electric vehicles and battery manufacturing to critical minerals to green steel,” said Todd Smith, Minister of Energy. “Expanding Ontario’s world-leading SMR program will ensure we have the reliable, affordable and clean electricity we need to power the next major international investment, the new homes we are building and industries as they grow and electrify.”

For the first time since 2005, Ontario’s electricity demand is rising. While the government has implemented its plan to meet rising electricity demand this decade, the experts at Ontario’s Independent Electricity System Operator have recommended the province advance new nuclear generation and pursue life-extension at Pickering NGS to provide reliable, baseload power to meet increasing electricity needs in the 2030s and beyond.

Subject to Ontario Government and Canadian Nuclear Safety Commission (CNSC) regulatory approvals on construction, the additional SMRs could come online between 2034 and 2036. That is the same timeframe that SaskPower is looking at for its first, and possibly second, units.

The initial unit is expected to go online in 2028 following Ontario’s first SMR groundbreaking at Darlington.

The Darlington site, which already hosts four reactors, was originally considered for an expansion of “large nuclear,” which is why OPG was already well on its way for site approvals of additional nuclear power generation. The plan changed to one, singular, SMR. Now that has been updated to four.

The announcement has significant impact on Saskatchewan, and its plans to build four of its own SMRs. The timing would allow Ontario Power Generation to apply learnings from the construction of the first unit to deliver cost savings on subsequent units. This is also the strategy SaskPower is following – allow Ontario to build the first, then learn from that experience.

Building multiple units will also allow common infrastructure such as cooling water intake, transmission connection and control room to be utilized by all four units instead of just one, reducing costs even further, the Ministry said.

“A fleet of SMRs at the Darlington New Nuclear Site is key to meeting growing electricity demands and net zero goals,” said Ken Hartwick, OPG President and CEO. “OPG has proven its large nuclear project expertise through the on-time, on budget Darlington Refurbishment project. By taking a similar approach to building a fleet of SMRs, we will deliver cost and schedule savings, and power 1.2 million homes from this site by the mid-2030s.”

The Darlington SMR project is situated on the traditional and treaty territories of the seven Williams Treaties First Nations and is also located within the traditional territory of the Huron Wendat peoples. OPG is actively engaging and consulting with potentially impacted Indigenous communities, including exploring economic opportunities in the Darlington SMR project such as commercial participation and employment.

The Ministry noted, “Ontario’s robust nuclear supply chain is uniquely positioned to support SMR development and deployment in Ontario, Canada and globally. Building additional SMRs at Darlington would provide more opportunities for Ontario companies and broader economic benefits as suppliers of nuclear equipment, components, and services to make further investments to expand their operation to serve the growing SMR market both domestically and abroad.”

Supporting new SMR development and investing in nuclear power is part of the Ontario government’s larger plan, aligned with a Canadian interprovincial nuclear initiative that brings provinces together, to prepare for electricity demand in the 2030s and 2040s that will build on Ontario’s clean electricity advantage and ensure the province has the power to maintain it’s position as leader in job creation and a magnet for the industries of the future, the Ministry said.

In February, World Nuclear News (WNN) reported that Poland was considering up to 79 small modular reactors of the same design as OPG and SaskPower. And on June 5, it reported, “Canada’s Ontario Power Generation will provide operator services to Poland’s Orlen Synthos Green Energy under a letter of intent signed between the partners, extending their existing cooperation on the deployment of small modular reactors.”

WNN added, “The letter of intent is aimed at concluding future agreements under which OPG and its subsidiaries could provide operator services for SMR reactors to OSGE in connection with the deployment of SMRs in Poland and other European countries. The partnership would include a number of SMR-related activities including: development and deployment; operations and maintenance; operator training; commissioning; and regulatory support.”

 

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