Lake Erie Cross-border Power-line Project Reaches Milestone

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A bold plan to build a billion-dollar underwater electrical transmission line across Lake Erie has reached a crucial milestone with filings to key regulators in Canada and the United States.

The project, which would transmit power from Ontario to the United States, or move it in the opposite direction, has been on the drawing board for a couple of years.

It would involve laying a high-capacity cable starting from Nanticoke, Ont., stretching about 120 kilometres across the lake floor to Erie County, Penn.

In late May, the projectÂ’s owner, U.S.-based transmission company ITC Holdings Corp. filed a permit application with CanadaÂ’s National Energy Board.

In the next few days, it will do the same with the U.S. Department of Energy, which would also have to give permission for the project to go ahead.

Several other regulators on both sides of the border must also give the nod before construction can start.

The project, called the Lake Erie Connector, would deliver Canadian-generated electricity to the grid that supplies power to 60 million Americans in a dozen states in the U.S. Northeast.

Some of those markets will need new sources of power in the coming years as coal-fired power plants are closed to meet environmental rules.

The new line would bypass the connections in Michigan or New York that now sometimes carry Ontario power to the United States but are often congested or unavailable during peak hours.

But it could also carry electricity from the United States to Ontario when there is an emergency or outage that requires a power boost, or if there is a shortage in the coming years when the provinceÂ’s nuclear plants are being refurbished or retired.

“The bi-directional design means that electricity can flow into Ontario from a new route, helping improve the security and reliability of the power grid in Ontario,” ITC Holdings spokesman Robert Doetsch said. “The line could also potentially play a role in emergency grid restoration in the province [and it] would provide Ontario with access to a new market to export its excess supply of energy.”

Mr. Doetsch said that if the regulatory approvals fall into place, financing and the ordering of equipment should happen in 2016 and 2017. Construction would then start in 2017 and the project could be up and running by 2019.

The Lake Erie Connector was initially developed by Canadian entrepreneur John Douglas, who is known for proposing huge and innovative power projects. A year ago, he sold the Lake Erie project to ITC Holdings – the largest independent transmission company in the United States – for an undisclosed sum.

Mr. Douglas, who made a fortune selling his wind farm developer Ventus Energy Inc. to French energy giant Suez SA in 2007, is still working for the Lake Erie project as a consultant. He is also developing other long-range transmission ventures, including an underwater line down the Hudson River from Montreal to New York, and another that would connect Peru to Chile.

Mr. Douglas said that when he was looking for a “project sponsor” for the Lake Erie project, ITC was a better fit than financial investors because of its “deep transmission expertise, understanding and experience.” The 1,000-megawatt Lake Erie line will include two transmission cables and a fibre optic communications line, and cost about $1-billion U.S. to build. Unlike most transmission lines that use alternating current, the proposed project will use high-voltage direct current, which works better in long underwater applications, can work in either direction and has less energy loss than AC.

Utilities that want access to the line would essentially pay a toll to ITC in return for carrying their power.

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Experts warn Albertans to lock in gas and electricity rates as prices set to soar

Alberta Energy Price Spike signals rising electricity and natural gas costs; lock in fixed rates as storage is low, demand surged in heat waves, and exports rose after Hurricane Ida, driving volatility and higher futures.

 

Key Points

An anticipated surge in Alberta electricity and natural gas prices, urging consumers to lock fixed rates to reduce risk.

✅ Fixed-rate gas near $3.79/GJ vs futures approaching $6/GJ

✅ Low storage after heat waves and U.S. export demand

✅ Switch providers or plans; UCA comparison tool helps

 

Energy economists are warning Albertans to review their gas and electricity bills and lock in a fixed rate if they haven't already done so because prices are expected to spike in the coming months.

"I have been urging anyone who will listen that every single Albertan should be on a fixed rate for this winter," University of Calgary energy economist Blake Shaffer said Monday. "And I say that for both natural gas and power."

Shaffer said people will rightly point out energy costs make up only roughly a third of their monthly bill. The rest of the costs for such things as delivery fees can't be avoided. 

But, he said, "there is an energy component and it is meaningful in terms of savings." 

For example, Shaffer said, when he checked last week, a consumer could sign a fixed rate gas contract for $3.79 a gigajoule and the current future price for gas is nearly $6 a gigajoule.

A typical household would use about 15 gigajoules a month, he said, so a consumer could save $30 to $45 a month for five months. For people on lower or fixed incomes, "that is a pretty significant saving."

Comparable savings can also be achieved with electricity, he said.

Shaffer said research has shown households that are least able to afford sharp increases in gas and electrical bills are less likely to pick up the phone and call their energy provider and either negotiate a lower fixed rate contract or jump to a new provider. 

But, he said, it is definitely worth the time and effort, particularly as Calgary electricity bills are rising across the city. Alberta's Utilities Consumer Advocate has a handy cost comparison tool on its website that allows consumers to conduct regional price comparisons that will assist in making an informed decision.

"Folks should know that for most providers you can change back to a floating rate any time you want," Shaffer said.

Summer heat wave affected natural gas supply
Why are energy prices set to spike in Alberta, which is a major producer of natural gas?

Sophie Simmonds, managing director of the brokerage firm Anova Energy, said Alberta is now generating the majority of its power using natural gas. 

The heat wave in June and July created record electrical demand. Normally, natural gas is stored in the summer for use in the winter. But this year, there was much greater gas consumption in the summer and so less was stored. 

Alberta also set a new electricity usage record during a recent deep freeze, underscoring system stress.

On top of that, Alberta has been exporting much more natural gas to the United States since August and September because Hurricane Ida knocked out natural gas assets in the Gulf of Mexico.

"So what this means is we are actually going into winter with very, very low storage numbers," Simmonds said.

Why natural gas prices have surged to some of their highest levels in years
Canadians to remain among world's top energy users even as government strives for net zero
Consultant Matt Ayres said he believes rising electricity prices also are being affected by Alberta's transition from carbon-intensive fuel sources to less carbon-intensive fuel sources.

"That transition is not always smooth," said Ayres, who is also an adjunct assistant professor at the University of Calgary's School of Public Policy. 

"It is my view that at least some of the price increases we are seeing on electricity comes down to difficulties imposed by that transition and also by a reduction in competition amongst generators, as well as power market overhaul debates shaping policy." 

In 2019, under the leadership of Premier Jason Kenney the UCP government removed the former NDP government's rate cap on electricity at the time.

The NDP has called for the government to reinstate the cap but the UCP government has dismissed that as unsustainable and unrealistic.

 

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Egypt, Eni ink MoU on hydrogen production projects

Egypt-ENI Hydrogen MoU outlines joint feasibility studies for green and blue hydrogen using renewable energy, carbon capture, and CO2 storage, targeting domestic demand, exports, and net-zero goals within Egypt's energy transition.

 

Key Points

A pact to study green and blue hydrogen in Egypt, leveraging renewables, CO2 storage, and export/demand pathways.

✅ Feasibility study for green and blue hydrogen projects

✅ Uses renewables, SMR, carbon capture, and CO2 storage

✅ Targets local demand, exports, and net-zero alignment

 

The Egyptian Electricity Holding Company (EEHC) and the Egyptian Natural Gas Holding Company (EGAS) signed a memorandum of understanding (MoU) with the Italian energy giant Eni to assess the technical and commercial feasibility of green and blue hydrogen production projects in Egypt, which many see as central to power companies' future strategies worldwide today.

Under the MoU, a study will be conducted to assess joint projects for the production of green hydrogen using electricity generated from renewable energy and supported by regional electricity interconnections where relevant, and blue hydrogen using the storage of CO2 in depleted natural gas fields, according to a statement by the Ministry of Petroleum on Thursday.

The study will also estimate the potential local market consumption of hydrogen and export opportunities, taking cues from Ontario's hydrogen economy proposal to align electricity rates for growth.

This agreement is part of Eni's objective to achieve zero net emissions by 2050 and Egypt's strategy towards diversifying the energy mix and developing hydrogen projects in collaboration with major international companies, taking note of Italy's green hydrogen initiatives in Sicily as a comparable effort.

It signed the deal with Egyptian Natural Gas Holding (EGAS) and Egyptian Electricity Holding Co. (EEHC).

The companies will carry out a joint study on producing renewable energy powered green hydrogen, informed by electrolyzer investments in similar projects, where applicable. They will also work on blue hydrogen. This involves reforming natural gas and capturing the resulting CO2, in this instance in depleted natural gas fields.

The study will also consider domestic hydrogen use and export options, including funding models like the Hydrogen Innovation Fund now in Ontario.

Eni said the MoU was in line with its plans to eliminate net emissions and emissions cancel emission intensity by 2050. The company noted the agreement was in line with Egypt’s plan for the energy transition, in which it pursues hydrogen plans with major international companies, alongside broader clean-tech collaboration such as Tesla cooperation discussions in Dubai, to accelerate progress.

 

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Typical Ontario electricity bill set to increase nearly 2% as fixed pricing ends

Ontario Electricity Rates update: OEB sets time-of-use and tiered pricing for residential customers, with kWh charges for peak, mid-peak, and off-peak periods reflecting COVID-19 impacts on demand, supply costs, and pricing.

 

Key Points

Ontario Electricity Rates are OEB-set time-of-use and tiered prices that set per-kWh costs for residential customers.

✅ Time-of-use: 21.7 peak, 15.0 mid-peak, 10.5 off-peak cents/kWh

✅ Tiered: 12.6 cents/kWh up to 1000 kWh, then 14.6 cents/kWh

✅ Average 700 kWh home pays about $2.24 more per month

 

Energy bills for the typical Ontario home are going up by about two per cent with fixed pricing coming to an end on Nov. 1, the Ontario Energy Board says. 

The province's electricity regulator has released new time-of-use pricing and says the rate for the average residential customer using 700 kWh per month will increase by about $2.24.

The change comes as Ontario stretches into its eight month of the COVID-19 pandemic with new case counts reaching levels higher than ever seen before.

Time-of-use pricing had been scrapped for residential bills for much for the pandemic with a single fixed COVID-19 hydro rate set for all hours of the day. The move, which came into effect June 1, was meant "to support families, small business and farms while Ontario plans for the safe and gradual reopening of the province," the OEB said at the time.

Ontario later set the off-peak price until February 7 around the clock to provide additional relief.

Fixed pricing meant customers' bills reflected how much power they used, rather than when they used it. Customers were charged 12.8 cents/kWh under the COVID-19 recovery rate no matter their time of use.

Beginning November, the province says customers can choose between time-of-use and tiered pricing options. Rates for time-of-use plans will be 21.7 cents/kWh during peak hours, 15 cents/kWh for mid-peak use and 10.5 cents/kWh for off-peak use. 

Customers choosing tiered pricing will pay 12.6 cents/kWh for the first 1000 kWh each month and then 14.6 cents/kWh for any power used beyond that.

The energy board says the increase in pricing reflects "a combination of factors, including those associated with the COVID-19 pandemic, that have affected demand, supply costs and prices in the summer and fall of 2020."

Asked for his reaction to the move Tuesday, Premier Doug Ford said, "I hate it," adding the province inherited an energy "mess" from the previous Liberal government and are "chipping away at it."

 

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The Banker Trying to Fix the UK's Electricity Grid

UK power grid bottleneck is stalling renewable energy, with connection queues, planning delays, and transmission infrastructure gaps raising costs, slowing decarbonization, and deterring investment as government considers reforms led by a new chief adviser.

 

Key Points

Delays and capacity gaps that hinder connecting new generation and demand, raising costs and slowing decarbonization.

✅ Connection queues delay projects for years

✅ Planning and NIMBY barriers stall transmission builds

✅ Investment costs on bills risk political pushback

 

During his three decades at investment bank Morgan Stanley, Franck Petitgas developed a reputation for solving problems that vexed others. Fixing the UK’s creaking power grid could be his most challenging task yet.

Earlier this year, Prime Minister Rishi Sunak appointed Petitgas as his chief business adviser, and the former financier has been pushing to tackle the gridlock that’s left projects waiting endlessly for a connection, an issue he sees as one of the biggest problems for industry.

But there are no easy solutions to tackle the years-long queue to get on the grid or the drawn-out planning process for building clean power generation, with the energy transition stalled by supply delays compounding the problem. And sluggish progress in expanding and improving the electricity network is preventing the construction of new housing developments and offices, as well as slowing the transition to greener power.

That transition has already taken a knock after Sunak last week controversially watered down some of the UK’s climate ambitions, citing in part the cost to consumers. He also acknowledged the issues surrounding the grid and promised the “most transformative plans” in response, drawing on lessons from Europe’s power crisis where applicable. Those are due to be unveiled within weeks. 

Shortly after his appointment, Petitgas offered reassurances to business leaders at a meeting in Downing Street that solutions were being worked on, according to people familiar with the matter. But there’s a lack of confidence across business that enough will be done.

Cost is a big factor in the expansion of the electricity grid, and some argue a state-owned generation model could ease bills over time. Improving the onshore network alone could require investment of between £100 billion and £240 billion ($122-$293 billion) by 2050, according to a government analysis last year. 

With network expansion funded through power bills, that’s a big ask, particularly with Sunak trailing in polls ahead of an election expected next year.

“It’s very difficult for politicians to say more money should be on bills,” said Emma Pinchbeck, chief executive of Energy UK, a trade body. “So you get to a situation where no one wants to pay for the infrastructure investment until it’s really sticky, and that’s where we’ve got to with the grid.”

There are huge competitive and economic implications if the UK falls further behind. With US President Joe Biden spending an estimated $370 billion on climate measures through his Inflation Reduction Act, and China already a world leader in electric vehicles, Britain’s grid inaction is holding it back in the global race to decarbonize, said Jess Ralston, an analyst at the Energy and Climate Intelligence Unit think tank.

“The UK is dithering and delaying, and not making any strategic decisions,” she said. “You can see companies just saying ‘I’m going to the US, or I’m going to China’.” 

In a statement, the government said it’s a “priority to speed up the time taken to connect new power generators and power consumers to the grid.” It added that it’s taking “significant steps to accelerate grid infrastructure,” including support for new Channel interconnectors announced this year.

The government expects demand for electricity to double by 2035 and that will mean more generation that needs to be linked up to the network by cables and pylons. Local grids will also have to expand to accommodate more connection points for electric vehicles and homes, and invest in large-scale energy storage capacity to balance supply.

But so far, the rapid rise in renewable energy investment has not been accompanied by matching spend on the power network, according to BloombergNEF, a pattern seen in Germany’s grid expansion woes as well.

“The pace and scale of what we now have to deliver is significantly different from the last few decades,” said Carl Trowell, president of UK strategic infrastructure at National Grid. “It’s a national endeavor.”

In June, Electricity Networks Commissioner Nick Winser sent the government recommendations for how to accelerate construction of more transmission infrastructure. He said efforts to decarbonize the power sector will be “wasted if we cannot get the power to homes and businesses.”

“We need a seriously stronger sense of urgency,” said Kevin O’Donovan, country manager for Statkraft UK, which is holding off investment in four wind farms and two solar projects due to grid connection delays.

In addition to cost, the other major stumbling block is planning. Politicians in the governing Conservative Party are wary of angering voters with new infrastructure in rural areas that typically vote Tory. Across the country, “Not In My Back Yard” campaigners – NIMBYs — pose a major challenge to projects.

Petitgas, 62, retired from Morgan Stanley last year after nearly 30 years at the bank, where he led its international division from London. The issues over connections and planning have been repeatedly pointed out to Petitgas by investors and trade groups over a series of meetings this year, according to people familiar with the matter, requesting anonymity discussing private talks.

Yet with a general election looming and the issue plagued by political headaches, many are skeptical that Sunak can find the solutions needed.

One business chief said Downing Street considers the issue too tricky and expensive to tackle in the short-term. Others are concerned that while Petitgas has license from Sunak, he doesn’t have influence across the relevant departments to get grids to the top of the agenda.

 

Wind Farms

Multiple parts of the UK’s climate plans are under pressure. Earlier this month, an auction for contracts to build new wind farms received zero bids from developers, even as wind leads the power mix in many regions, marking yet another green setback. 

The UK is already behind on its target of having 50 gigawatts of offshore wind built by 2030, up from 14 GW today. The challenge is accelerating development without railroading local communities.

Within Sunak’s Conservative Party, some lawmakers are pushing back on new infrastructure in their local areas. A group including Environment Secretary Therese Coffey and former Home Secretary Priti Patel is campaigning against building new pylons across a stretch of eastern England.

According to Adam Bell, director of policy at consultancy Stonehaven, backbench pressure means Sunak is unlikely to take major action on the grid in the near term. He doesn’t see the prime minister accepting Winser’s recommendations, least of all accelerating planning decisions.

“Over the last year, Sunak has favored party management over things that will benefit the country,” Bell said. 

 

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BC Hydro rebate and B.C. Affordability Credit coming as David Eby sworn in as premier

BC Affordability & BC Hydro Bill Credits provide inflation relief and cost of living support, lowering electricity bills for families and small businesses through automatic utility credits and income-tested tax rebates across British Columbia.

 

Key Points

BC relief lowering electricity bills and offering rebates to help families and businesses facing inflation.

✅ $100 credit for residential BC Hydro users; applied automatically.

✅ Avg $500 bill credit for small and medium commercial customers.

✅ Income-based BC Affordability Credit via CRA in January.

 

The new B.C. premier announced on Friday morning families and small businesses in B.C. will get a one-time cost of living credit on their BC Hydro bill this fall, and a new B.C. Affordability Credit in January.

Eby focused on the issue of affordability in his speech following being sworn in as B.C.’s 37th premier, including electricity costs addressed by BC Hydro review recommendations that aim to keep power affordable.

A BC Hydro bill credit of $100 will be provided to all eligible residential and commercial electricity customers, including those who receive their electricity service indirectly from BC Hydro through FortisBC or a municipal utility.

“People and small businesses across B.C. are feeling the squeeze of global inflation,” Eby said.

“It’s a time when people need their government to continue to be there for them. That’s why we’re focused on helping people most impacted by the rising costs we’re seeing around the world – giving people a bit of extra credit, especially at a time of year when expenses can be quick to add up.”

Eby takes over as premier of the province with a growing number of concerns piling up on his plate, even as the province advances grid development and job creation projects to support long-term growth.

Economists in the province have warned of turbulent economic times ahead due to global economic pressures and power supply challenges tied to green energy ambitions.

The one-time $100 cost of living credit works out to approximately one month of electricity for a family living in a detached home or more than two months of electricity for a family living in an apartment.

Commercial ratepayers, including small and medium businesses like restaurants and tourism operators, will receive a one-time bill credit averaging $500 as B.C. expands EV charging infrastructure to accelerate electrification.

The amount will be based on their prior year’s electricity consumption.

British Columbians will have the credit automatically applied to their electricity accounts.

BC Hydro customers will have the credit applied in early December. Customers of FortisBC and municipal utilities will likely begin to see their bill credits applied early in the new year.

‘I proudly and unreservedly turn to the tallest guy in the room’: John Horgan on David Eby

The B.C. Affordability Credit is separate and will be based on income.

Eligible people and families will automatically receive the new credit through the Canada Revenue Agency, the same way the enhanced Climate Action Tax Credit was received in October.

An eligible person making an income of up to $36,901 will receive the maximum BC Affordability Credit with the credit fully phasing out at $79,376.

An eligible family of four with a household income of $43,051 will get the maximum amount, with the credit fully phasing out by $150,051.

This additional support means a family of four can receive up to an additional $410 in early January 2023 to help offset some of the added costs people are facing, while EV owners can access more rebates for home and workplace charging to reduce transportation expenses.

“Look for B.C.’s new Affordability Credit in your bank account in January 2023,” Eby said.

“We know it won’t cover all the bills, but we hope the little bit extra helps folks out this winter.”

Eby’s swearing-in marks a change at the premier’s office but not a shift in focus.

The premier expects to continue on with former premier John Horgan’s mandate with a focus on affordability issues and clean growth supported by green energy investments from both levels of government.

In a ceremony held in the Musqueam Community Centre, Eby made a commitment to make meaningful improvements in the lives of British Columbians and continue work with First Nations communities, with clean-tech growth underscored by the B.C. battery plant announcement made with the prime minister.

The ceremony was the first-ever swearing-in hosted by a First Nation in British Columbia.

“British Columbia is a wonderful place to call home,” Eby said.

“At the same time, people are feeling uncertain about the future and worried about their families. I’m proud of the work done by John Horgan and our government to put people first. And there’s so much more to do. I’m ready to get to work with my team to deliver results that people will be able to see and feel in their lives and in their communities.”

 

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Electricity Demand In The Time Of COVID-19

COVID-19 Impact on U.S. Power Demand shows falling electricity load, lower wholesale prices, and resilient utilities in competitive markets, with regional differences tied to weather, renewable energy, stay-at-home orders, and hedging strategies.

 

Key Points

It outlines reduced load and prices, while regulatory design and hedging support utility stability across regions.

✅ Load down in NY, New England, PJM; weather drives South up.

✅ Wholesale prices fall 8-10% in key markets.

✅ Decoupling, contracts, hedging support utility earnings.

 

On March 27, Bloomberg New Energy Finance (BNEF) released a report on electricity demand and wholesale market prices impact from COVID-19 fallout. The model compares expected load based largely on weather with actual observed electricity demand changes.

So far, the hardest hit power grid is New York, with load down 7 and prices off by 10 percent. That’s expected, given New York City is the current epicenter of the US health crisis.

Next is New England, with 5 percent lower demand and 8 percent reduced wholesale prices for the week from March 19-25. BNEF says the numbers could go higher following advisories and orders issued March 24 for some 70 percent of the region’s population to stay at home.

Demand on the biggest grid in the US, the PJM (Pennsylvania/Jersey/Maryland), is 4 percent lower, with prices dropping 8 percent, as recent capacity auction payouts fell sharply. BNEF believes there will be more impact as stay at home orders are ramped up in several states.

California’s power demand for March 19-25 was 5 percent below what BNEF’s model expects without COVID-19 impact. That reflects a full week of stay-at-home orders from Governor Newsom issued March 19.

Health officials in Los Angeles and elsewhere expect a spike in COVID-19 cases in coming weeks. But BNEF’s model now actually projects rising electricity load for the state, due to what it calls "freakishly mild weather a year ago."

Rounding out the report, power demand is up for a band of southern states stretching from Florida to the desert Southwest, with weather more than offsetting public response to COVID-19 so far. BNEF says the Northwest’s grid "has not yet been highly impacted," while the Southeast is "generally in line" with pre-virus expectations.

Clearly, all of this data can change quickly and radically. Only California and New York are currently in full shutdown mode. Following them are New England (70 percent), the Midwest (65 percent), Texas (50 percent), PJM (50 percent) and the Northwest (50 percent).

In contrast, only small parts of Florida, the Southeast and Southwest are restricting movement. That could mean a big future increase for shut-ins, with heightened risks of electricity shut-offs that burden households and a corresponding impact on power demand.

Also, weather will play a major role on what happens to actual electricity demand, just as it always does. A very hot summer, for example, could offset virus-related shut-ins, just as it apparently is now in states like Texas. And it should be pointed out that regions vary widely by exposure to recession-sensitive sources of demand, such as heavy industry.

Most important for investors, however, is the built in protection US utility earnings enjoy from declining power demand, even amid broader energy crisis pressures facing the sector. For one thing, US power grids in California, ERCOT (Texas), MISO (Midwest), New England, New York and PJM have wholesale power markets, where producers compete for sales and the lowest bidder sets the price.

In those states, most regulated utilities don’t produce power at all. In fact, companies’ revenue is decoupled entirely from demand in California, as well as much of New England. In the roughly three-dozen states where utilities still operate as integrated monopolies, demand does affect revenue, and in many regions flat electricity demand already persists. But the cost of electricity is passed through directly to customers, whether produced or purchased.

A number of US electric companies have invested in renewable energy facilities as part of broader electrification trends nationwide. These sell their output under long-term contracts primarily with other utilities and government entities.

This isn’t a risk free business: For the past year, generators selling electricity to bankrupt PG&E Corp (PCG) have had their cash trapped at the power plant level as surety for lenders. But even PG&E has honored its contracts. And with states continuing aggressive mandates for renewable energy adoption, growth doesn’t appear at risk to COVID-19 fallout either.

The wholesale price of power from natural gas, coal and many nuclear plants was already sliding before COVID-19, due to renewables adoption and low natural gas prices, even as coal and nuclear disruptions raise reliability concerns. But here too, big producers like Exelon Corp (EXC) and Vistra Energy (VST) have employed aggressive price hedging near term, with regulated utilities and retail businesses protecting long-term health, respectively.

Bottom line: It’s early days for the COVID-19 crisis and much can still change. But so far at least, the US power industry is absorbing the blow of reduced demand, just as it’s done in previous crises.

That means future selloffs in the ongoing bear market are buying opportunities for best in class electric utilities, not a reason to sell. For top candidates, see the Conrad’s Utility Investor Portfolios and Dream Buy List in the March issue. 

 

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