National power grid to be expanded by 2018 -- NEPCO

EV Subsidies in Canada influence greenhouse-gas emissions based on electricity grid mix; in Ontario and Quebec they reduce pollution, while fossil-fuel grids blunt benefits. Compare costs per tonne with carbon tax and renewable energy policies.

Key Points

Government rebates for electric vehicles, whose emissions impact and cost-effectiveness depend on provincial grid mix.

✅ Impact varies by grid emissions; clean hydro-nuclear cuts CO2.

✅ MEI estimates up to $523 per tonne vs $50 carbon price.

✅ Best value: tax carbon; target renewables, efficiency, hybrids.

Bad ideas sometimes look better, and sell better, than good ones – as with the proclaimed electric-car revolution that policymakers tout today. Not always, or else Canada wouldn’t be the mostly well-run place that it is. But sometimes politicians embrace a less-than-best policy – because its attractive appearance may make it more likely to win the popularity contest, right now, even though it will fail in the long run.

The most seasoned political advisers know it. Pollsters too. Voters, in contrast, don’t know what they don’t know, which is why bad policy often triumphs. At first glance, the wrong sometimes looks like it must be right, while better and best give the appearance of being bad and worst.

This week, the Montreal Economic Institute put out a study on the costs and benefits of taxpayer subsidies for electric cars. They considered the logic of the huge amounts of money being offered to purchasers in the country’s two largest provinces. In Quebec, if you buy an electric vehicle, the government will give you up to $8,000; in Ontario, buying an electric car or truck entitles you to a cheque from the taxpayer of between $6,000 and $14,000. The subsidies are rich because the cars aren’t cheap.

Will putting more electric cars on the road lower greenhouse-gas emissions? Yes – in some provinces, where they can be better for the planet when the grid is clean. But it all depends on how a province generates electricity. In places like Alberta, Saskatchewan, Nova Scotia and Nunavut territory, where most electricity comes from burning fossil fuels, an electric car may actually generate more greenhouse gases than one running on traditional gasoline. The tailpipe of an electric vehicle may not have any emissions. But quite a lot of emissions may have been generated to produce the power that went to the socket that charged it.

A few years ago, University of Toronto engineering professor Christopher Kennedy estimated that electric cars are only less polluting than the gasoline vehicles they replace when the local electrical grid produces a good chunk of its power from renewable sources – thereby lowering emissions to less than roughly 600 tonnes of CO2 per gigawatt hour.

Unfortunately, the electricity-generating systems in lots of places – from India to China to many American states – are well above that threshold. In those jurisdictions, an electric car will be powered in whole or in large part by electricity created from the burning of a fossil fuel, such as coal. As a result, that car, though carrying the green monicker of “electric,” is likely to be more polluting than a less costly model with an internal combustion or hybrid engine.

The same goes for the Canadian juridictions mentioned above. Their electricity is dirtier, so operating an electric car there won’t be very green. Alberta, for example, is aiming to generate 30 per cent of its electricity from renewable sources by 2030 – which means that the other 70 per cent of its electricity will still come from fossil fuels. (Today, the figure is even higher.) An Albertan trading in a gasoline car for an electric vehicle is making a statement – just not the one he or she likely has in mind.

In Ontario and Quebec, however, most electricity is generated from non-polluting sources, even though Canada still produced 18% from fossil fuels in 2019 overall. Nearly all of Quebec’s power comes from hydro, and more than 90 per cent of Ontario’s electricity is from zero-emission generation, mainly hydro and nuclear. British Columbia, Manitoba and Newfoundland and Labrador also produce the bulk of their electricity from hydro. Electric cars in those provinces, powered as they are by mostly clean electricity, should reduce emissions, relative to gas-powered cars.

But here’s the rub: Electric cars are currently expensive, and, as a recent survey shows, consequently not all that popular. Ontario and Quebec introduced those big subsidies in an attempt to get people to buy them. Those subsidies will surely put more electric cars on the road and in the driveways of (mostly wealthy) people. It will be a very visible policy – hey, look at all those electrics on the highway and at the mall!

However, that result will be achieved at great cost. According to the MEI, for Ontario to reach its goal of electrics constituting 5 per cent of new vehicles sold, the province will have to dish out up to $8.6-billion in subsidies over the next 13 years.

And the environmental benefits achieved? Again, according to the MEI estimate, that huge sum will lower the province’s greenhouse-gas emissions by just 2.4 per cent. If the MEI’s estimate is right, that’s far too many bucks for far too small an environmental bang.

Here’s another way to look at it: How much does it cost to reduce greenhouse-gas emissions by other means? Well, B.C.’s current carbon tax is $30 a tonne, or a little less than 7 cents on a litre of gasoline. It has caused GHG emissions per unit of GDP to fall in small but meaningful ways, thanks to consumers and businesses making millions of little, unspectacular decisions to reduce their energy costs. The federal government wants all provinces to impose a cost equivalent to $50 a tonne – and every economic model says that extra cost will make a dent in greenhouse-gas emissions, though in ways that will not involve politicians getting to cut any ribbons or hold parades.

What’s the effective cost of Ontario’s subsidy for electric cars? The MEI pegs it at $523 per tonne. Yes, that subsidy will lower emissions. It just does so in what appears to be the most expensive and inefficient way possible, rather than the cheapest way, namely a simple, boring and mildly painful carbon tax.

Electric vehicles are an amazing technology. But they’ve also become a way of expressing something that’s come to be known as “virtue signalling.” A government that wants to look green sees logic in throwing money at such an obvious, on-brand symbol, or touting a 2035 EV mandate as evidence of ambition. But the result is an off-target policy – and a signal that is mostly noise.

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CPUC Decision on San Diego Community Power directs SDG&E to use updated forecasts, stabilizing electricity rates for CCA customers and supporting clean energy in San Diego with accurate rate forecasting and reduced volatility.

Key Points

A CPUC ruling directing SDG&E to use updated forecasts to ensure accurate, stable CCA rates and limit volatility.

✅ Uses 2021 sales forecasts for rate setting

✅ Aims to prevent undercollection and bill spikes

✅ Levels changes across customer classes

The California Public Utilities Commission on Thursday sided with the soon-to-launch San Diego community energy program in a dispute it had with San Diego Gas & Electric.

San Diego Community Power — which will begin to purchase power for customers in San Diego, Chula Vista, La Mesa, Encinitas and Imperial Beach later this year — had complained to the commission that data SDG&E intended to use to calculate rates, including community choice exit fees that could make the new energy program less attractive to prospective customers.

SDG&E argued it was using numbers it was authorized to employ as part of a general rate case amid a potential rate structure revamp that is still being considered by the commission.

But in a 4-0 vote, the commission, or CPUC, sided with San Diego Community Power and directed SDG&E to use an updated forecast for energy sales.

"This was not an easy decision," said CPUC president Marybel Batjer at the meeting, held remotely due to COVID-19 restrictions. "In my mind, this outcome best accounts for the shifting realities ... in the San Diego area while minimizing the impact on ratepayers during these difficult financial times."

In filings to the commission, SDG&E predicted a rate decrease of 12.35 percent in the coming year. While that appears to be good news for customers, Californians still face soaring electricity prices statewide, Commissioner Martha Guzman Aceves said the data set SDG&E wanted to use would lead to an undercollection of $150 million to $260 million.

That would result in rates that would be "artificially low," Guzman Aceves said, and rates "would inevitably go up quite a bit after the undercollection was addressed."

San Diego Community Power, or SDCP, said the temporary reduction would make its rates less attractive than SDG&E's, especially amid SDG&E's minimum charge proposal affecting low-usage customers, just as it is about to begin serving customers. SDCP's board members wrote an open letter last month to the commission, accusing the utility of "willful manipulation of data."

Working with an administrative law judge at the CPUC, Guzman Aceves authored a proposal requiring SDG&E to use numbers based on 2021 forecasts, as regulators simultaneously weigh whether the state needs more power plants to ensure reliability. The utility argued that could result in an increase of "roughly 40 percent" for medium and large commercial and industrial customers this year.

To help reduce potential volatility, Guzman Aceves, SDCP and other community energy supporters called for using a formula that would average out changes in rates across customer classes amid debates over income-based utility charges statewide. That's what the commissioners OK'd Thursday.

"It is essential that customer commodity rates be as accurate as we can possibly get them to avoid undercollections," said Commissioner Genevieve Shiroma.

San Diego Community Power is one of 23 community choice aggregation, or CCA, energy programs that have launched in California in the past decade.

CCAs compete with traditional power companies amid California's evolving power competition landscape, in one important role — purchasing power for a given community. They were created to boost the use of cleaner energy sources, such as wind and solar, at rates equal to or lower than investor-owned utilities.

However, CCAs do not replace utilities because the incumbent power companies still perform all of the tasks outside of power purchasing, such as transmission and distribution of energy and customer billing.

When a CCA is formed, California rules stipulate the utility customers in that area are automatically enrolled in the CCA. If customers prefer to stay with their previous power company, they can opt out of joining the CCA.

The shift of customers from SDG&E to San Diego Community Power is expected to be large. The total number of accounts for SDCP is expected to be 770,000, which would make it the second-largest CCA in the state. That's why SDCP considered Thursday's CPUC decision to be so important.

"At a time when customers are choosing between sticking with San Diego Gas & Electric and migrating to a CCA, we want them to have accurate bill information," said Commissioner Clifford Rechtschaffen.

"SDCP is very happy with today's CPUC decision, and that the commissioners shared our goal of limiting rate volatility for businesses and families in the region," said SDCP interim CEO Bill Carnahan. "This is definitely a win for accurate rate forecasting, and our mutual customers, and we look forward to working with SDG&E on next steps."

In an email, SDG&E spokeswoman Helen Gao said, "We are committed to continuing to work collaboratively with local Community Choice Aggregation programs to support their successful launch in 2021 and ensure that our mutual customers receive excellent customer service."

San Diego Community Power's case before the CPUC was joined by the California Community Choice Association, a trade group advocating for CCAs, and the Clean Energy Alliance — the North County-based CCA representing Del Mar, Solana Beach and Carlsbad that is scheduled to launch this summer.

SDCP will begin its rollout this year, folding in about 71,000 municipal, commercial and industrial accounts. The bulk of its roughly 700,000 residential accounts is expected to come in January 2022.

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U.S. Natural Gas Power Demand is surging for electricity generation amid summer heat, with ERCOT, Texas grid reserves tight, EIA reporting coal and nuclear retirements, renewables intermittency, and pipeline expansions supporting combined-cycle capacity and prices.

Key Points

It is rising use of natural gas for power, driven by summer heat, plant retirements, and new combined-cycle capacity.

✅ ERCOT reserve margin 9%, below 14% target in Texas

✅ Gas share of U.S. power near 40-43% this summer

✅ Coal and nuclear retirements shift capacity to combined cycle

As the hot months linger, it will be natural gas that is leaned on most to supply the electricity that we need to run our air conditioning loads on the grid and keep us cool.

And this is surely a great and important thing: "Heat causes most weather-related deaths, National Weather Service says."

Generally, U.S. gas demand for power in summer is 35-40% higher than what it was five years ago, with so much more coming (see Figure).

The good news is regions across the country are expected to have plenty of reserves to keep up with power demand.

The only exception is ERCOT, covering 90% of the electric load in Texas, where a 9% reserve margin is expected, below the desired 14%.

Last summer, however, ERCOT’s reserve margin also was below the desired level, yet the grid operator maintained system reliability with no load curtailments.

Simply put, other states are very lucky that Texas has been able to maintain gas at 50% of its generation, despite being more than justified to drastically increase that.

At about 1,600 Bcf per year, the flatness of gas for power demand in Texas since 2000 has been truly remarkable, especially since Lone Star State production is up 50% since then.

Increasingly, other U.S. states (and even countries) are wanting to import huge amounts of gas from Texas, a state that yields over 25% of all U.S. output.

Yet if Texas justifiably ever wants to utilize more of its own gas, others would be significantly impacted.

At ~480 TWh per year, if Texas was a country, it would be 9th globally for power use, even ahead of Brazil, a fast growing economy with 212 million people, and France, a developed economy with 68 million people.

In the near-term, this explains why a sweltering prolonged heat wave in July in Texas, with a hot Houston summer setting new electricity records, is the critical factor that could push up still very low gas prices.

But for California, our second highest gas using state, above-average snowpack should provide a stronger hydropower for this summer season relative to 2018.

Combined, Texas and California consume about 25% of U.S. gas, with Texas' use double that of California.

Across the U.S., gas could supply a record 40-43% of U.S. electricity this summer even as the EIA expects solar and wind to be larger sources of generation across the mix

Our gas used for power has increased 35-40% over the past five years, and January power generation also jumped on the year, highlighting broad momentum.

Our gas used for power has increased 35-40% over the past five years. DATA SOURCE: EIA; JTC

Indeed, U.S. natural gas for electricity has continued to soar, even as overall electricity consumption has trended lower in some years, at nearly 10,700 Bcf last year, a 16% rise from 2017 and easily the highest ever.

Gas is expected to supply 37% of U.S. power this year, even as coal-fired generation saw a brief uptick in 2021 in EIA data, versus 27% just five years ago (see Figure).

Capacity wise, gas is sure to continue to surge its share 45% share of the U.S. power system.

"More than 60% of electric generating capacity installed in 2018 was fueled by natural gas."

We know that natural gas will continue to be the go-to power source: coal and nuclear plants are retiring, and while growing, wind and solar are too intermittent, geography limited, and transmission short to compensate like natural gas can.

"U.S. coal power capacity has fallen by a third since 2010," and last year "16 gigawatts (16,000 MW) of U.S. coal-fired power plants retired."

This year, some 2,000 MW of coal was retired in February alone, with 7,420 MW expected to be closed in 2019.

Ditto for nuclear.

Nuclear retirements this year include Pilgrim, Massachusetts’s only nuclear plant, and Three Mile Island in Pennsylvania.

This will take a combined ~1,600 MW of nuclear capacity offline.

Another 2,500 MW and 4,300 MW of nuclear are expected to be leaving the U.S. power system in 2020 and 2021, respectively.

As more nuclear plants close, EIA projects that net electricity generation from U.S. nuclear power reactors will fall by 17% by 2025.

From 2019-2025 alone, EIA expects U.S. coal capacity to plummet nearly 25% to 176,000 MW, with nuclear falling 15% to 83,000 MW.

In contrast, new combined cycle gas plants will grow capacity almost 30% to around 310,000 MW.

Lower and lower projected commodity prices for gas encourage this immense gas build-out, not to mention non-stop increases in efficiency for gas-based units.

Remember that these are official U.S. Department of Energy estimates, not coming from the industry itself.

In other words, our Department of Energy concludes that gas is the future.

Our hotter and hotter summers are therefore more and more becoming: "summers for natural gas"

Ultimately, this shows why the anti-pipeline movement is so dangerous.

"Affordable Energy Coalition Highlights Ripple Effect of Natural Gas Moratorium."

In April, President Trump signed two executive orders to promote energy infrastructure by directing federal agencies to remove bottlenecks for gas transport into the Northeast in particular, where New England oil-fired generation has spiked, and to streamline federal reviews of border-crossing pipelines and other infrastructure.

Builders, however, are not relying on outside help: all they know is that more U.S. gas demand is a constant, so more infrastructure is mandatory.

They are moving forward diligently: for example, there are now some 27 pipelines worth $33 billion already in the works in Appalachia.

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Futaba Partial Reopening marks limited access to the Fukushima exclusion zone, highlighting radiation decontamination progress, the train station restart, and regional recovery ahead of the Tokyo Olympics after the 2011 nuclear disaster and evacuation.

Key Points

A lift of entry bans in Futaba, signaling Fukushima recovery, decontamination progress, and a train station restart.

✅ Unrestricted access to 2.4 km² around Futaba Station

✅ Symbolic step ahead of Tokyo Olympics torch relay

✅ Decommissioning and decontamination to span decades

Japan's government on Wednesday opened part of the last town that had been off-limits due to radiation since the Fukushima nuclear disaster nine years ago, in a symbolic move to show the region's recovery ahead of the Tokyo Olympics, even as grid blackout risks have drawn scrutiny nationwide.

The entire population of 7,000 was forced to evacuate Futaba after three reactors melted down due to damage at the town's nuclear plant caused by a magnitude 9. 0 quake and tsunami March 11, 2011.

The partial lifting of the entry ban comes weeks before the Olympic torch starts from another town in Fukushima, as new energy projects like a large hydrogen system move forward in the prefecture. The torch could also arrive in Futaba, about 4 kilometres (2.4 miles) from the wrecked nuclear plant.

Unrestricted access, however, is only being allowed to a 2.4 square-kilometre (less than 1 square-mile) area near the main Futaba train station, which will reopen later this month to reconnect it with the rest of the region for the first time since the accident. The vast majority of Futaba is restricted to those who get permission for a day visit.

The three reactor meltdowns at the town's Fukushima Dai-ichi nuclear power plant spewed massive amounts of radiation that contaminated the surrounding area and at its peak, forced more than 160,000 people to flee, even as regulators later granted TEPCO restart approval for a separate Niigata plant elsewhere in Japan.

The gate at a checkpoint was opened at midnight Tuesday, and Futaba officials placed a signboard at their new town office, at a time when the shutdown of Germany's last reactors has reshaped energy debates abroad.

“I'm overwhelmed with emotion as we finally bring part of our town operations back to our home town," said Futaba Mayor Shiro Izawa. “I pledge to steadily push forward our recovery and reconstruction."

Town officials say they hope to see Futaba’s former residents return, but prospects are grim because of lingering concern about radiation, and as Germany's nuclear exit underscores shifting policies abroad. Many residents also found new jobs and ties to communities after evacuating, and only about 10% say they plan to return.

Futaba's registered residents already has decreased by 1,000 from its pre-disaster population of 7,000. Many evacuees ended up in Kazo City, north of Tokyo, after long bus trips, various stopovers and stays in shelters at an athletic arena and an abandoned high school. The town's government reopened in a makeshift office in another Fukushima town of Iwaki, while abroad projects like the Bruce reactor refurbishment illustrate long-term nuclear maintenance efforts.

Even after radiation levels declined to safe levels, the region's farming and fishing are hurt by lingering concerns among consumers and retailers. The nuclear plant is being decommission in a process that will take decades, with spent fuel removal delays extending timelines, and it is building temporary storage for massive amounts of debris and soil from ongoing decontamination efforts.

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2022 US Renewable Power Milestone highlights EIA data: wind and solar outpaced coal and nuclear, hydropower contributed, with falling levelized costs, grid integration, battery storage, and transmission upgrades shaping affordable, reliable clean power growth.

Key Points

The year US renewables, led by wind and solar, generated more power than coal and nuclear, per EIA.

✅ Wind and solar rose; levelized costs fell 70%-90% over decade

✅ Renewables surpassed coal and nuclear in 2022 per EIA

✅ Grid needs storage and transmission to manage intermittency

Electricity generated from renewables surpassed coal in the United States for the first time in 2022, as wind and solar surpassed coal nationwide, the U.S. Energy Information Administration has announced.

Renewables also surpassed nuclear generation in 2022 after first doing so last year, and wind and solar together generated more electricity than nuclear for the first time in the United States.

Growth in wind and solar significantly drove the increase in renewable energy and contributed 14% of the electricity produced domestically in 2022, with solar producing about 4.7% of U.S. power overall. Hydropower contributed 6%, and biomass and geothermal sources generated less than 1%.

“I’m happy to see we’ve crossed that threshold, but that is only a step in what has to be a very rapid and much cheaper journey,” said Stephen Porder, a professor of ecology and assistant provost for sustainability at Brown University.

California produced 26% of the national utility-scale solar electricity followed by Texas with 16% and North Carolina with 8%.

The most wind generation occurred in Texas, which accounted for 26% of the U.S. total, while wind is now the most-used renewable electricity source nationwide, followed by Iowa (10%) and Oklahoma (9%).

“This booming growth is driven largely by economics,” said Gregory Wetstone, president and CEO of the American Council on Renewable Energy, as renewables became the second-most prevalent U.S. electricity source in 2020 nationwide. “Over the past decade, the levelized cost of wind energy declined by 70 percent, while the levelized cost of solar power has declined by an even more impressive 90 percent.”

“Renewable energy is now the most affordable source of new electricity in much of the country,” added Wetstone.

The Energy Information Administration projected that the wind share of the U.S. electricity generation mix will increase from 11% to 12% from 2022 to 2023 and that solar will grow from 4% to 5% during the period, and renewables hit a record 28% share in April according to recent data. The natural gas share is expected to remain at 39% from 2022 to 2023, and coal is projected to decline from 20% last year to 17% this year.

“Wind and solar are going to be the backbone of the growth in renewables, but whether or not they can provide 100% of the U.S. electricity without backup is something that engineers are debating,” said Brown University’s Porder.

Many decisions lie ahead, he said, as the proportion of renewables that supply the energy grid increases, with renewables projected to soon be one-fourth of U.S. electricity generation over the near term.

This presents challenges for engineers and policy-makers, Porder said, because existing energy grids were built to deliver power from a consistent source. Renewables such as solar and wind generate power intermittently. So battery storage, long-distance transmission and other steps will be needed to help address these challenges, he said.

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New England oil-fired generation surges as ISO New England manages a cold snap, dual-fuel switching, and a natural gas price spike, highlighting winter reliability challenges, LNG and pipeline limits, and rising CO2 emissions.

Key Points

Reliance on oil-burning power plants during winter demand spikes when natural gas is costly or constrained.

✅ Driven by dual-fuel switching amid high natural gas prices

✅ ISO-NE winter reliability rules encourage oil stockpiles

✅ Raises CO2 emissions despite coal retirements and renewables growth

New England is relying on oil-fired generators for the most electricity since 2018 as a frigid blast boosts demand for power and natural gas prices soar across markets. 

Oil generators were producing more than 4,200 megawatts early Thursday, accounting for about a quarter of the grid’s power supply, according to ISO New England. That was the most since Jan. 6, 2018, when oil plants produced as much as 6.4 gigawatts, or 32% of the grid’s output, said Wood Mackenzie analyst Margaret Cashman.  

Oil is typically used only when demand spikes, because of higher costs and emissions concerns. Consumption has been consistently high over the past three weeks as some generators switch from gas, which has surged in price in recent months. New England generators are producing power from oil at an average rate of almost 1.8 gigawatts so far this month, the highest for January in at least five years. 

Oil’s share declined to 16% Friday morning ahead of an expected snowstorm, which was “a surprise,” Cashman said. 

“It makes me wonder if some of those generators are aiming to reserve their fuel for this weekend,” she said.

During the recent cold snap, more than a tenth of the electricity generated in New England has been produced by power plants that haven’t happened for at least 15 years.

Burning oil for electricity was standard practice throughout the region for decades. It was once our most common fuel for power and as recently as 2000, fully 19% of the six-state region’s electricity came from burning oil, according to ISO-New England, more than any other source except nuclear power at the time.

Since then, however, natural gas has gotten so cheap that most oil-fired plants have been shut or converted to burn gas, to the point that just 1% of New England’s electricity came from oil in 2018, whereas about half our power came from natural gas generation regionally during that period. This is good because natural gas produces less pollution, both particulates and greenhouse gasses, although exactly how much less is a matter of debate.

But as you probably know, there’s a problem: Natural gas is also used for heating, which gets first dibs. Prolonged cold snaps require so much gas to keep us warm, a challenge echoed in Ontario’s electricity system as supply tightens, that there might not be enough for power plants – at least, not at prices they’re willing to pay.

After we came close to rolling brownouts during the polar vortex in the 2017-18 winter because gas-fired power plants cut back so much, ISO-NE, which has oversight of the power grid, established “winter reliability” rules. The most important change was to pay power plants to become dual-fuel, meaning they can switch quickly between natural gas and oil, and to stockpile oil for winter cold snaps.

We’re seeing that practice in action right now, as many dual-fuel plants have switched away from gas to oil, just as was intended.

That switch is part of the reason EPA says the region’s carbon emissions have gone up in the pandemic, from 22 million tons of CO2 in 2019 to 24 million tons in 2021. That reverses a long trend caused partly by closing of coal plants and partly by growing solar and offshore wind capacity: New England power generation produced 36 million tons of CO2 a decade ago.

So if we admit that a return to oil burning is bad, and it is, what can we do in future winters? There are many possibilities, including tapping more clean imports such as Canadian hydropower to diversify supply.

The most obvious solution is to import more natural gas, especially from fracked fields in New York state and Pennsylvania. But efforts to build pipelines to do that have been shot down a couple of times and seem unlikely to go forward and importing more gas via ocean tanker in the form of liquefied natural gas (LNG) is also an option, but hits limits in terms of port facilities.

Aside from NIMBY concerns, the problem with building pipelines or ports to import more gas is that pipelines and ports are very expensive. Once they’re built they create a financial incentive to keep using natural gas for decades to justify the expense, similar to moves such as Ontario’s new gas plants that lock in generation. That makes it much harder for New England to decarbonize and potentially leaves ratepayers on the hook for a boatload of stranded costs.

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