Lawsuit may force PGE to close plant early

By Bend Bulletin


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Facing a Sierra Club lawsuit and heightened federal scrutiny of its Boardman coal-fired generating plant, Portland General Electric has drafted a much firmer proposal to close OregonÂ’s only coal plant by December 31, 2020, at least 20 years earlier than anticipated.

The new plan also tightens controls on sulfur dioxide pollution from 2018 to 2020. And it has backing from the Oregon Environmental Council, the CitizensÂ’ Utility Board and other groups, raising the possibility of ending a battle that has raged for years.

To secure the groupsÂ’ endorsements, PGE committed to working with them to try to find renewable replacement power, instead of just switching to natural gas.

The Department of Environmental Quality reopened its public comment period on its regional haze rule to consider PGEÂ’s latest proposal. The Environmental Quality Com- mission is expected to rule on BoardmanÂ’s required pollution controls in December.

Until PGEÂ’s latest offer, OregonÂ’s largest electric utility would have retained the option to install $500 million in pollution controls and keep operating through at least 2040, said Andy Ginsburg, DEQÂ’s air quality administrator.

The new offer, if approved by the Environmental Protection Agency, explicitly repeals the 2040 option in exchange for less pollution control — under $100 million — and closing early, Ginsburg said.

PGE could request the 2040 option again in coming years if the Sierra ClubÂ’s lawsuit or new federal rules upped the ante on pollution controls, a point the utility made clear in its offer to the DEQ. But the regulatory hurdles would be formidable, Ginsburg said.

“From a practical standpoint,” he said, “if the commission accepts this option, they’re going to be closing no later than 2020.”

Even with fewer controls, BoardmanÂ’s pollution over the rest of its operating life would be lower if it closed in 2020 than if PGE installed more controls and operated the plant through 2040, Ginsburg said.

The stakes are high. Boardman is OregonÂ’s largest generator of greenhouse gas emissions and haze- and smog-causing pollution that hampers visibility from Mount Hood to the Columbia River Gorge to Hells Canyon. The plant also supplies roughly 15 percent of PGEÂ’s generation, and relatively cheap coal helps it keep electric bills down.

The lawsuit from the Sierra Club, Friends of the Columbia Gorge and three other environmental groups alleges that PGE should have installed a full suite of pollution controls years ago, including a $300 million scrubber that would knock down sulfur dioxide emissions by at least 80 percent.

Earlier this month, the EPA backed up that assertion, issuing a notice of violation that accused PGE of operating the plant without adequate controls since 1998.

Attorney Aubrey Baldwin, who represents the environmental groups, said the notion of PGE pulling the 2040 option off the table is “kind of a myth” given the off-ramps in PGE’s new proposal. The Sierra Club wants PGE to close the plant earlier than 2020, perhaps as early as 2015.

“Ultimately, PGE is going to have to comply, whether that’s through a compromise or actual compliance with the Clean Air Act regulations as they’re written,” Baldwin said. Closing in 2020 “is not going to get them there.”

The Oregon Environmental Council signed on to PGEÂ’s latest proposal but was careful to say it wasnÂ’t ruling out a closure earlier than 2020.

Jana Gastellum, OECÂ’s global warming program director, said the council thinks PGEÂ’s removal of the 2040 option and its commitment to explore renewable alternatives is significant.

Given population growth, replacing Boardman solely with natural gas plants would still increase the stateÂ’s greenhouse gas emissions over time, she said.

PGE’s previous “low-carbon” alternative focused on politically untenable nuclear power. Other options include biomass, more efficient use of natural gas and wind power, and increased conservation, including more energy-efficiency upgrades in homes, industries and commercial buildings.

“If we just keep slapping up natural gas plants as a replacement and don’t maximize energy efficiency and renewables, over time we’ll get growth in emissions,” Gastellum said. “We’ve gotten climate change inserted into the conversation.”

Three other groups endorsed PGEÂ’s latest plan: the CitizensÂ’ Utility Board, Renewable Northwest Project and the Northwest Energy Coalition. Angus Duncan, founder and president of the Bonneville Environmental Foundation, also endorsed it.

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California avoids widespread rolling blackouts as heat strains power grid

California Heat Wave Grid Emergency sees CAISO issue Stage 3 alerts as record demand, extreme heat, and climate change strain renewable energy; conservation efforts avert rolling blackouts and protect grid reliability statewide.

 

Key Points

A grid emergency in California's heat wave, with CAISO Stage 3 alerts amid record demand and risk of rolling blackouts.

✅ CAISO triggered Stage 3 alerts, then downgraded by 8 pm PT

✅ Record 52,061 MW demand; conservation reduced grid stress

✅ Extreme heat and climate change heightened outage risks

 

California has avoided ordering rolling blackouts after electricity demand reached a record-high Tuesday night from excessive heat across the state, even as energy experts warn the U.S. grid faces mounting climate stresses. 

The California Independent System Operator, which oversees the state’s electrical grid, imposed its highest level energy emergency on Tuesday, a step that comes before ordering rolling blackouts and allows the state to access emergency power sources.

The Office of Emergency Services also sent a text alert to residents requesting them to conserve power. The operator downgraded the Stage 3 alert around 8:00 p.m. PT on Tuesday and said that “consumer conservation played a big part in protecting electric grid reliability,” and in bolstering grid resilience overall.

The state capital of Sacramento reached 116 degrees Fahrenheit on Tuesday, according to the National Weather Service, surpassing a record that was set almost 100 years ago. And nearly a half-dozen cities in the San Francisco Bay Area tied or set all-time highs, the agency said.

CAISO said peak power demand on Tuesday reached 52,061 megawatts, surpassing a previous high of 50,270 megawatts on July 24, 2006, while nearby B.C. electricity demand has also hit records during extreme weather.

While the operator did not order rolling blackouts, three Northern California cities saw brief power outages, and severe storms have caused similar disruptions statewide in recent months. As of 7:00 am PT on Wednesday, nearly 8,000 customers in California were without power, according to PowerOutage.us. 

Gov. Gavin Newsom, in a Twitter video on Tuesday, warned the temperatures across California were unprecedented and the state is headed into the worst part of the heat wave, which is on track to be the hottest and longest on record for September.

“The risk for outages is real and it’s immediate,” Newsom said. “These triple-digit temperatures throughout much of the state are leading, not surprisingly, to record demand on the energy grid.”

The governor urged residents to pre-cool their homes earlier in the day when more power is available and turn thermostats to 78 degrees or higher after 4:00 pm PT. “Everyone has to do their part to help step up for just a few more days,” Newsom said.

The possibility for widespread outages reflects how power grids in California and other states are becoming more vulnerable to climate-related disasters such as heat waves, storms and wildfires across California.

California, which has set a goal to transition to 100% carbon-free electricity by 2045, has shuttered a slew of gas power plants in the past few years, leaving the state increasingly dependent on solar energy.

At times, the state has produced a clean energy surplus during peak solar generation, underscoring the challenges of balancing supply and demand.

The megadrought in the American West has generated the driest two decades in the region in at least 1,200 years, and human-caused climate change has fueled the problem, scientists said earlier this year. Conditions will likely continue through 2022 and persist for years.

 

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Schott Powers German Plants with Green Electricity

Schott Green Electricity CPPA secures renewable energy via a solar park in Schleswig-Holstein, supporting decarbonization in German glass manufacturing; the corporate PPA with ane.energy delivers about 14.5 GWh annually toward climate-neutral production by 2030.

 

Key Points

Corporate PPA for 14.5 GWh solar in Germany, cutting Schott plant emissions and advancing climate-neutral operations.

✅ 14.5 GWh solar from Schleswig-Holstein via ane.energy

✅ Powers Mainz HQ and plants in GrFCnenplan, Mitterteich, Landshut

✅ Two-year CPPA covers ~5% of Schott's German electricity needs

 

Schott, a leading specialty glass manufacturer, is advancing its sustainability initiatives in step with Germany's energy transition by integrating green electricity into its operations. Through a Corporate Power Purchase Agreement (CPPA) with green energy specialist ane.energy, Schott aims to significantly reduce its carbon footprint and move closer to its goal of climate-neutral production by 2030.

Transition to Renewable Energy

As of February 2025, amid a German renewables milestone for the power sector, Schott has committed to sourcing approximately 14.5 gigawatt-hours of clean energy annually from a solar park in Schleswig-Holstein, Germany. This renewable energy will power Schott's headquarters in Mainz and its plants in Grünenplan, Mitterteich, and Landshut. The CPPA covers about 5% of the company's annual electricity needs in Germany and is initially set for a two-year term, reflecting lessons from extended nuclear power during recent supply challenges.

Strategic Implementation

To achieve climate-neutral production by 2030, Schott is focusing on transitioning from gas to electricity sourced from renewable sources like photovoltaics, alongside complementary pathways such as hydrogen-ready power plants being developed nationally. Operating a single melting tank requires energy equivalent to the annual consumption of up to 10,000 single-family homes. Therefore, Schott has strategically selected suitable plants for this renewable energy supply to meet its substantial energy requirements.

Industry Leadership

Schott's collaboration with ane.energy demonstrates the company's commitment to sustainability and its proactive approach to integrating renewable energy into industrial operations. This partnership not only supports Schott's decarbonization goals but also sets a precedent for other manufacturers in the glass industry to adopt green energy solutions, mirroring advances like green hydrogen steel in heavy industry.

Schott's initiative to power its German glass plants with green electricity underscores the company's dedication to environmental responsibility and its strategic efforts to achieve climate-neutral production by 2030, aligning with the national coal and nuclear phaseout underway. This move reflects a broader trend in the manufacturing sector toward sustainable practices and the adoption of renewable energy sources, even as debates continue over a possible nuclear phaseout U-turn in Germany.

 

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Clorox accelerates goal of achieving 100% renewable electricity in the U.S. and Canada to 2021

Clorox Enel 70 MW VPPA accelerates renewable energy, sourcing Texas solar from the Roadrunner project to support 100% renewable electricity, Scope 2 reductions, and grid decarbonization through a virtual power purchase agreement starting in 2021.

 

Key Points

A 12-year virtual power purchase agreement for 70 MW of Texas solar to advance Clorox's 100% renewable electricity goal.

✅ 12-year contract supporting 100% renewable electricity by 2021

✅ Supplies 70 MW from Enel's Roadrunner solar project in Texas

✅ Cuts Scope 2 emissions via grid-delivered virtual PPA

 

The Clorox Company and a wholly owned subsidiary of Enel Green Power North America announced today the signing of a 12-year, 70 megawatt (MW) virtual power purchase agreement (VPPA) for the purchase of renewable energy, aligned with carbon-free electricity investments across the power sector beginning in 2021. Representing about half of Clorox's 100% renewable electricity goal in its operations in the U.S. and Canada, this agreement is expected to help Clorox accelerate achieving its goal in 2021, four years ahead of the company's original plan.

"Climate change and rising greenhouse gas emissions pose a real threat to the health of our planet and ultimately the long-term well-being of people globally. That's why we've taken action for more than 10 years to measure and reduce the carbon footprint of our operations," said Benno Dorer, chair and CEO, The Clorox Company. "Our agreement with Enel helps to expand U.S. renewable energy infrastructure, reflecting our view that companies like Clorox play an important role in addressing global climate change, as landmark policies like the U.S. climate deal further accelerate the transition. We believe this agreement will significantly contribute toward Clorox achieving our goal of 100% renewable electricity in our operations in the U.S. and Canada in 2021, four years earlier than originally planned. Our commitment to climate stewardship is an important pillar of our new IGNITE strategy and part of our overall efforts to drive Good Growth – growth that's profitable, sustainable and responsible."

The 70MW VPPA between Clorox and Enel Green Power North America for the purchase of renewable energy delivered to the electricity grid is for the second phase of Enel's Roadrunner solar project to be built in Texas, and complement global clean energy collaborations such as Canada-Germany hydrogen cooperation announced recently. Roadrunner is a 497-direct current megawatt (MWdc) solar project that is being built in two phases. The first phase, currently under construction, comprises around 252 MWdc and is expected to be completed by the end of 2019, while the remaining 245 MWdc of capacity is expected to be completed by the end of 2020. Once fully operational, the solar plant could generate up to 1.2 terawatt-hours (TWh) of electricity annually, while avoiding an estimated 800,000 metric tons of carbon dioxide emissions per year.

Based on the U.S. Environmental Protection Agency Greenhouse Gas Equivalencies Calculator[i], this VPPA is estimated to avoid approximately 140,000 metric tons of CO2 emissions each year. This is equivalent to the annual impact that 165,000 acres of U.S. forest can have in removing CO2 from the atmosphere, and illustrates why cleaning up Canada's electricity is central to emissions reductions in the power sector, or the carbon impact of the electricity needed to power more than 24,000 U.S. homes annually.

"We are proud to support Clorox on their path towards 100% renewable electricity in its operations in the U.S. and Canada by helping them achieve about half their goal through this agreement," said Georgios Papadimitriou, head of Enel Green Power North America. "This agreement with Clorox reinforces the continued significance of renewable energy as a fundamental part of any company's sustainability strategy."

Schneider Electric Energy & Sustainability Services advised Clorox on this power purchase agreement and, amid heightened investor attention exemplified by the Duke Energy climate report, supported the company in its project selection, analysis, negotiations and deal execution.

 

Clorox Commits to Scope 1, 2 and 3 Science-Based Targets

For more than 10 years, Clorox has consistently achieved its goals to reduce greenhouse gas emissions in its operations. Clorox is focused on setting emissions reduction targets in line with climate science. As a participant in the Science Based Targets Initiative, Clorox has committed to setting and achieving science-based greenhouse gas emissions reduction targets in its operations (Scopes 1 and 2) and across its value chain (Scope 3), and consistent with national pathways such as Canada's net-zero 2050 target pursued by policymakers. The targets are considered "science-based" if they are in line with what the latest climate science says is necessary to meet the goals of the 2015 Paris Agreement – a global environmental accord to address climate change and its negative impacts.

Clorox's climate stewardship goals are part of its new integrated corporate strategy called IGNITE, which includes several other environmental, social and governance (ESG) goals and reflects lessons from Canada's electricity progress in scaling clean power. More comprehensive information about Clorox's IGNITE ESG goals can be found here. Information on Clorox's 2020 ESG strategy can be found in its fiscal year 2019 annual report.

 

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B.C.'s Green Energy Ambitions Face Power Supply Challenges

British Columbia Green Grid Constraints underscore BC Hydro's rising imports, peak demand, electrification, hydroelectric variability, and transmission bottlenecks, challenging renewable energy expansion, energy security, and CleanBC targets across industry and zero-emission transportation.

 

Key Points

They are capacity and supply limits straining B.C.'s clean electrification, driving imports and risking reliability.

✅ Record 25% imports in FY2024 raise emissions and costs

✅ Peak demand and transmission limits delay new connections

✅ Drought reduces hydro output; diversified generation needed

 

British Columbia's ambitious green energy initiatives are encountering significant hurdles due to a strained electrical grid and increasing demand, with a EV demand bottleneck adding pressure. The province's commitment to reducing carbon emissions and transitioning to renewable energy sources is being tested by the limitations of its current power infrastructure.

Rising Demand and Dwindling Supply

In recent years, B.C. has experienced a surge in electricity demand, driven by factors such as population growth, increased use of electric vehicles, and the electrification of industrial processes. However, the province's power supply has struggled to keep pace, and one study projects B.C. would need to at least double its power output to electrify all road vehicles. In fiscal year 2024, BC Hydro imported a record 13,600 gigawatt hours of electricity, accounting for 25% of the province's total consumption. This reliance on external sources, particularly from fossil-fuel-generated power in the U.S. and Alberta, raises concerns about energy security and sustainability.

Infrastructure Limitations

The current electrical grid is facing capacity constraints, especially during peak demand periods, and regional interties such as a proposed Yukon connection are being discussed to improve reliability. A report from the North American Electric Reliability Corporation highlighted that B.C. could be classified as an "at-risk" area for power generation as early as 2026. This assessment underscores the urgency of addressing infrastructure deficiencies to ensure a reliable and resilient energy supply.

Government Initiatives and Investments

In response to these challenges, the provincial government has outlined plans to expand the electrical system. Premier David Eby announced a 10-year, $36-billion investment to enhance the grid's capacity, including grid development and job creation measures to support local economies. The initiative focuses on increasing electrification, upgrading high-voltage transmission lines, refurbishing existing generating facilities, and expanding substations. These efforts aim to meet the growing demand and support the transition to clean energy sources.

The Role of Renewable Energy

Renewable energy sources, particularly hydroelectric power, play a central role in B.C.'s energy strategy. However, the province's reliance on hydroelectricity has its challenges. Drought conditions in recent years have led to reduced water levels in reservoirs, impacting the generation capacity of hydroelectric plants. This variability underscores the need for a diversified energy mix, with options like a hydrogen project complementing hydro, to ensure a stable and reliable power supply.

Balancing Environmental Goals and Energy Needs

B.C.'s commitment to environmental sustainability is evident in its policies, such as the CleanBC initiative, which aims to phase out natural gas heating in new homes by 2030 and achieve 100% zero-emission vehicle sales by 2035, supported by networks like B.C.'s Electric Highway that expand charging access. While these goals are commendable, they place additional pressure on the electrical grid. The increased demand from electric vehicles and electrified heating systems necessitates a corresponding expansion in power generation and distribution infrastructure.

British Columbia's green energy ambitions are commendable and align with global efforts to combat climate change. However, achieving these goals requires a robust and resilient electrical grid capable of meeting the increasing demand for power. The province's reliance on external power sources and the challenges posed by climate variability highlight the need for strategic investments in infrastructure and a diversified energy portfolio, guided by BC Hydro review recommendations to keep electricity affordable. By addressing these challenges proactively, B.C. can pave the way for a sustainable and secure energy future.

 

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Nova Scotia Premier calls on regulators to reject 14% electricity rate hike agreement

Nova Scotia Power Rate Increase Settlement faces UARB scrutiny as regulators weigh electricity rates, fuel costs, storm rider provisions, Bill 212 limits, and Muskrat Falls impacts on ratepayers and affordability for residential and industrial customers.

 

Key Points

A deal proposing 13.8% electricity hikes for 2023-2024, before the UARB, covering fuel costs, a storm rider, and Bill 212.

✅ UARB review may set different rates than the settlement

✅ Fuel cost prepayment and hedging incentives questioned

✅ Storm rider shifts climate risk onto ratepayers

 

Nova Scotia Premier Tim Houston is calling on provincial regulators to reject a settlement agreement between Nova Scotia Power and customer groups that would see electricity rates rise by nearly 14% electricity rate hike over the next two years.

"It is our shared responsibility to protect ratepayers and I can't state strongly enough how concerned I am that the agreement before you does not do that," Houston wrote in a letter to the Nova Scotia Utility and Review Board late Monday.

Houston urged the three-member panel to "set the agreement aside and reach its own conclusion on the aforementioned application."

"I do not believe, based on what I know, that the proposed agreement is in the best interest of ratepayers," he said.

The letter does not spell out what his Progressive Conservative government would do if the board accepts the settlement reached last week between Nova Scotia Power and lawyers representing residential, small business and large industrial customer classes.

Other groups also endorsed the deal, although Nova Scotia Power's biggest customer — Port Hawkesbury Paper — did not sign on.

'We're protecting the ratepayers'
Natural Resources Minister Tory Rushton said the province was not part of the negotiations leading up to the settlement.

"As a government or department we had no intel on those conversations that were taking place," he said Tuesday. "So, we saw the information the same as the public did late last week, and right now we're protecting the ratepayers of Nova Scotia, even though the province cannot order Nova Scotia Power to lower rates under current law. We want to make sure that that voice is still heard at the UARB level."

Rushton said he didn't want to presuppose what the UARB will say.

"But I think the premier's been very loud and clear and I believe I have been, too. The ratepayers are at the top of our mind. We have different tools at our [disposal] and we'll certainly do what we can and need to [do] to protect those ratepayers."


The settlement agreement
If approved by regulators, rates would rise by 6.9 per cent in 2023 and 6.9 per cent in 2024 — almost the same amount on the table when hearings before the review board ended in September.

The Houston government later intervened with legislation, known as Bill 212, that capped rates to cover non-fuel costs by 1.8 per cent. It did not cap rates to cover fuel costs or energy efficiency programs.

In a statement announcing the agreement, Nova Scotia Power president Peter Gregg claimed the settlement adhered "to the direction provided by the provincial government through Bill 212."

Consumer advocate Bill Mahody, representing residential customers, told CBC News the proposed 13.8 per cent increase was "a reasonable rate increase given the revenue requirement that was testified to at the hearing."

Settlement 'remarkably' similar to NSP application
The premier disagrees, noting that the settlement and rate application that triggered the rate cap are "remarkably consistent."

He objects to the increased amount of fuel costs rolled into rates next year before the annual true up of actual fuel costs, which are automatically passed on to ratepayers.

"If Nova Scotia Power is effectively paid in advance, what motive do they have to hedge and mitigate the adjustment eventually required," Houston asked in his letter.

He also objected to the inclusion of a storm rider in rates to cover extreme weather, which he said pushed the risk of climate change on to ratepayers.

Premier second-guesses Muskrat Falls approval
Houston also second-guessed the board for approving Nova Scotia Power's participation in the Muskrat Falls hydro project in Labrador.

"The fact that Nova Scotians have paid over $500 million for this project with minimal benefit, and no one has been held accountable, is wrong," he said. "It was this board of the day that approved the contracts and entered the final project into rates."

Ratepayers are committed to paying $1.7 billion for the Maritime Link to bring the green source of electricity into the province, while rate mitigation talks in Newfoundland lack public details for their customers.

Although the Maritime Link was built on time and on budget by an affiliated company, only a fraction of Muskrat Falls hydro has been delivered because of ongoing problems in Newfoundland, including an 18% electricity rate hike deemed unacceptable by the province's consumer advocate.

"I find it remarkable that those contracts did not include different risk sharing mechanisms; they should have had provisions for issues in oversight of project management. Nevertheless, it was approved, and is causing significant harm to ratepayers in the form of increased rates."

Houston notes that because of non-delivery from Muskrat Falls, Nova Scotia Power has been forced to buy much more expensive coal to burn to generate electricity.


Opposition reaction
Opposition parties in Nova Scotia reacted to Houston's letter.

NDP Leader Claudia Chender dismissed it as bluster.

"It exposes his Bill 212 as not really helping Nova Scotians in the way that he said it would," she said. "Nothing in the settlement agreement contravenes that bill. But it seems that he's upset that he's been found out. And so here we are with another intervention in an independent regulatory body."

Liberal Leader Zach Churchill said the government should intervene to help ratepayers directly.

"We just think that it makes more sense to do that directly by supporting ratepayers through heating assistance, lump-sum electricity credits, rebate programs and expanding the eligibility for that or to provide funding directly to ratepayers instead of intervening in the energy market in this way," he said.

The premier's office said that no one was available when asked about an interview on Tuesday.

"The letter speaks for itself," the office responded.

Nova Scotia Power issued a statement Tuesday. It did not directly address Houston's claims.

"The settlement agreement is now with the NS Utility and Review Board," the utility said.

"The UARB process is designed to ensure customers are represented with strong advocates and independent oversight. The UARB will determine whether the settlement results in just and reasonable rates and is in the public interest."

 

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BC Hydro activates "winter payment plan"

BC Hydro Winter Payment Plan lets customers spread electricity bills over six months during cold weather, easing costs amid colder-than-average temperatures in British Columbia, with low-income conservation support, energy-saving kits, and insulation upgrades.

 

Key Points

Allows BC Hydro customers to spread winter electricity bills over six months, with added low-income efficiency support.

✅ Spread Dec-Mar bills across six months

✅ Eases costs during colder-than-average temperatures

✅ Includes low-income conservation and energy-saving kits

 

As colder temperatures set in across the province again this weekend, BC Hydro says it is activating its winter payment plan to give customers the opportunity to spread out their electricity bills as demand can reach record levels during extreme cold periods.

"Our meteorologists are predicting colder-than-average temperatures will continue over the next of couple of months and we want to provide customers with help to manage their payments," said Chris O'Riley, BC Hydro's president.

All BC Hydro customers will be able to spread payments from the billing period spanning Dec. 1, 2017 to March 31, 2018 over a six-month period.

Cold weather in the second half of December 2017 led to surging electricity demand that was higher than the previous 10-year average and has at times hit all-time highs during peak usage periods, according to BC Hydro.

Hydro operations also respond to summer conditions, as drought and low rainfall can force adjustments in power generation strategies.

People who heat their homes with electricity — about 40 per cent of British Columbians —  have the highest overall bills in the province, $197 more in December than in July, when air conditioning use can affect energy costs.

This is the second year the Crown corporation has activated a cold-weather payment plan, part of broader customer assistance programs it offers.  

BC Hydro has also increased funding for its low-income conservation programs by $2.2 million for a total of $10 million over the next three years. 

The low-income program provides energy-saving kits that include things like free energy assessments, insulation upgrades and weather stripping. 

 

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