Website tracks worst polluting power plants

Canada Critical Infrastructure Cyber Risks include state-sponsored actors probing the electricity grid and ICS/OT, ransomware on utilities, and espionage targeting smart cities, medical devices, and energy networks, pre-positioning for disruptive operations.

Key Points

Nation-state and criminal cyber risks to Canada's power, water, and OT/ICS, aiming to disrupt, steal data, or extort.

✅ State-sponsored probing of power grid and utilities

✅ OT/ICS exposure grows as systems connect to IT networks

✅ Ransomware, espionage, and pre-positioning for disruption

State-sponsored actors are "very likely" trying to shore up their cyber capabilities to attack Canada's critical infrastructure — such as the electricity supply, as underscored by the IEA net-zero electricity report indicating rising demand for clean power, to intimidate or to prepare for future online assaults, a new intelligence assessment warns.

"As physical infrastructure and processes continue to be connected to the internet, cyber threat activity has followed, leading to increasing risk to the functioning of machinery and the safety of Canadians," says a new national cyber threat assessment drafted by the Communications Security Establishment.

"We judge that state-sponsored actors are very likely attempting to develop the additional cyber capabilities required to disrupt the supply of electricity in Canada, even as cleaning up Canada's electricity remains critical for climate goals."

Today's report — the second from the agency's Canadian Centre for Cyber Security wing — looks at the major cyber threats to Canadians' physical safety and economic security.

The CSE does say in the report that while it's unlikely cyber threat actors would intentionally disrupt critical infrastructure — such as water and electricity supplies — to cause major damage or loss of life, they would target critical organizations "to collect information, pre-position for future activities, or as a form of intimidation."

The report said Russia-associated actors probed the networks of electricity utilities in the U.S. and Canada last year and Chinese state-sponsored cyber threat actors have targeted U.S. utility employees. Other countries have seen their industrial control systems targeted by Iranian hacking groups and North Korean malware was found in the IT networks of an Indian power plant, it said.

The threat grows as more critical infrastructure goes high-tech.

In the past, the operational technology (OT) used to control dams, boilers, electricity and pipeline operations has been largely immune to cyberattacks — but that's changing as manufacturers incorporate newer information technology in their systems and products and as the race to net-zero drives grid modernization, says the report.

That technology might make things easier and lower costs for utilities already facing debates over electricity prices in Alberta amid affordability concerns, but it comes with risks, said Scott Jones, the head of the cyber centre.

"So that means now it is a target, it is accessible and it's vulnerable. So what you could see is shutting off of transmission lines, you can see them opening circuit breakers, meaning electricity simply won't flow to our homes to our business," he told reporters Wednesday.

While the probability of such attacks remains low, Jones said the goal of Wednesday's briefing is to send out the early warnings.

"We're not trying to scare people. We're certainly not trying to scare people into going off grid by building a cabin in the woods. We're here to say, 'Let's tackle these now while they're still paper, while they're still a threat we're writing down.'"

Steve Waterhouse, a former cybersecurity officer for the Department of National Defence who now teaches at Université de Sherbrooke, said a saving grace for Canada could be the makeup of its electrical systems.

"Since in Canada, they're very centralized, it's easier to defend, and debates about bridging Alberta and B.C. electricity aim to strengthen resilience, while down in the States, they have multiple companies all around the place. So the weakest link is very hard to identify where it is, but the effect is a cascading effect across the country ... And it could impact Canada, just like we saw in the big Northeastern power outage, the blackout of 2003," he said.

"So that goes to say, we have to be prepared. And I believe most energy companies have been taking extra measures to protect and defend against these type of attacks, even as Canada points to nationwide climate success in electricity to meet emissions goals."

In the future, attacks targeting so-called smart cities and internet-connected devices, such as personal medical devices, could also put Canadians at risk, says the report. 

Earlier this year, for example, Health Canada warned the public that medical devices containing a particular Bluetooth chip — including pacemakers, blood glucose monitors and insulin pumps — are vulnerable to cyber attacks that could crash them.

The foreign signals intelligence agency also says that while state-sponsored programs in China, Russia, Iran and North Korea "almost certainly" pose the greatest state-sponsored cyber threats to Canadian individuals and organizations, many other states are rapidly developing their own cyber programs.

Waterhouse said he was glad to see the government agency call out the countries by name, representing a shift in approach in recent years.

"To tackle on and be ready to face a cyber-attack, you have to know your enemy," he said.

"You have to know what's vulnerable inside of your organization. You have to know how ... vulnerable it is against the threats that are out there."

Commercial espionage continues
State-sponsored actors will also continue their commercial espionage campaigns against Canadian businesses, academia and governments — even as calls to make Canada a post-COVID manufacturing hub grow — to steal Canadian intellectual property and proprietary information, says the CSE.

"We assess that these threat actors will almost certainly continue attempting to steal intellectual property related to combating COVID-19 to support their own domestic public health responses or to profit from its illegal reproduction by their own firms," says the "key judgments" section of the report.

"The threat of cyber espionage is almost certainly higher for Canadian organizations that operate abroad or work directly with foreign state-owned enterprises."

The CSE says such commercial espionage is happening already across multiple fields, including aviation, technology and AI, energy and biopharmaceuticals.

While state-sponsored cyber activity tends to offer the most sophisticated threats, CSE said that cybercrime continues to be the threat most likely to directly affect Canadians and Canadian organizations, through vectors like online scams and malware.

"We judge that ransomware directed against Canada will almost certainly continue to target large enterprises and critical infrastructure providers. These entities cannot tolerate sustained disruptions and are willing to pay up to millions of dollars to quickly restore their operations," says the report.

Cybercrime becoming more sophisticated 
According to the Canadian Anti-Fraud Centre, Canadians lost over $43 million to cybercrime last year. The CSE reported earlier this year that online thieves have been using the COVID-19 pandemic to trick Canadians into forking over their money — through scams like a phishing campaign that claimed to offer access to a Canada Emergency Response Benefit payment in exchange for the target's personal financial details.

Online foreign influence activities — a dominant theme in the CSE's last threat assessment briefing — continue and constitute "a new normal" in international affairs as adversaries seek to influence domestic and international political events, says the agency.

"We assess that, relative to some other countries, Canadians are lower-priority targets for online foreign influence activity," it said.

"However, Canada's media ecosystem is closely intertwined with that of the United States and other allies, which means that when their populations are targeted, Canadians become exposed to online influence as a type of collateral damage."

According to the agency's own definition, "almost certainly" means it is nearly 100 per cent certain in its analysis, while "very likely" means it is 80-90 per cent certain of its conclusions. The CSE says its analysis is based off of a mix of confidential and non-confidential intelligence and sources. 

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Canada Clean Electricity drives a net-zero grid by 2035, scaling renewables like wind, solar, and hydro, with storage, smart grids, interprovincial transmission, and electrification of vehicles, buildings, and industry to cut emissions and costs.

Key Points

Canada Clean Electricity is a shift to a net-zero grid by 2035 using renewables, storage, and smart grids to decarbonize

✅ Doubles non-emitting generation for electrified transport and heating

✅ Expands wind, solar, hydro with storage and smart-grid balancing

✅ Builds interprovincial lines and faster permitting with Indigenous partners

By Merran Smith and Mark Zacharias

Canada is an electricity heavyweight. In addition to being the world’s sixth-largest electricity producer and third-largest electricity exporter in the global electricity market today, Canada can boast an electricity grid that is now 83 per cent emission-free, not to mention residential electricity rates that are the cheapest in the Group of Seven countries.

Indeed, on the face of it, the country’s clean electricity system appears poised for success. With an abundance of sunshine and blustery plains, Alberta and Saskatchewan, the Prairie provinces most often cited for wind and solar, have wind- and solar-power potential that rivals the best on the continent. Meanwhile, British Columbia, Manitoba, Quebec, and Newfoundland and Labrador have long excelled at generating low-cost hydro power.

So it would only be natural to assume that Canada, with this solid head start and its generous geography, is already positioned to provide enough affordable clean electricity to power our much-touted net-zero and economic ambitions.

But the reality is that Canada, like most countries, is not yet prepared for a world increasingly committed to carbon neutrality, in part because demand for solar electricity has lagged, even as overall momentum grows.

The federal government’s forthcoming Clean Electricity Standard – a policy promised by the governing Liberals during the most recent election campaign and restated for an international audience by Prime Minister Justin Trudeau at the United Nations’ COP26 climate summit – would require all electricity in the country to be net zero by 2035 nationwide, setting a new benchmark. But while that’s an encouraging start, it is by no means the end goal. Electrification – that is, hooking up our vehicles, heating systems and industry to a clean electricity grid – will require Canada to produce roughly twice as much non-emitting electricity as it does today in just under three decades.

This massive ramp-up in clean electricity will require significant investment from governments and utilities, along with their co-operation on measures and projects such as interprovincial power lines to build an electric, connected and clean system that can deliver benefits nationwide. It will require energy storage solutions, smart grids to balance supply and demand, and energy-efficient buildings and appliances to cut energy waste.

While Canada has mostly relied on large-scale hydroelectric and nuclear power in the past, newer sources of electricity such as solar, wind, geothermal, and biomass with carbon capture and storage will, in many cases, be the superior option going forward, thanks to the rapidly falling costs of such technology and shorter construction times. And yet Canada added less solar and wind generation in the past five years than all but three G20 countries – Indonesia, Russia and Saudi Arabia, with some experts calling it a solar power laggard in recent years. That will need to change, quickly.

In addition, Canada’s Constitution places electricity policy under provincial jurisdiction, which has produced a patchwork of electricity systems across the country that use different energy sources, regulatory models, and approaches to trade and collaboration. While this model has worked to date, given our low consumer rates and high power reliability, collaborative action and a cohesive vision will be needed – not just for a 100-per-cent clean grid by 2035, but for a net-zero-enabling one by 2050.

Right now, it takes too long to move a clean power project from the proposal stage to operation – and far too long if we hope to attain a clean grid by 2035 and a net-zero-enabling one by 2050. This means that federal, provincial, territorial and Indigenous governments must work with rural communities and industry stakeholders to accelerate the approvals, financing and construction of clean energy projects and provide investor certainty.

In doing so, Canada can set a course to carbon neutrality while driving job creation and economic competitiveness, a transition many analyses deem practical and profitable in the long run. Our closest trading partners and many of the world’s largest companies and investors are demanding cleaner goods. A clean grid underpins clean production, just as it underpins our climate goals.

The International Energy Agency estimates that, for the world to reach net zero by 2050, clean electricity generation worldwide must increase by more than 2.5 times between today and 2050. Countries are already plotting their energy pathways, and there is much to learn from each other.

Consider South Australia. The state currently gets 62 per cent of its electricity from wind and solar and, combined with grid-scale battery storage, has not lost a single hour of electricity in the past five years. South Australia expects 100 per cent of its electricity to come from renewable sources before 2030. An added bonus given today’s high energy prices: Annual household electricity costs have declined there by 303 Australian dollars ($276) since 2018.

The transition to clean energy is not about sacrificing our way of life – it’s about improving it. But we’ll need the power to make it happen. That work needs to start now.

Merran Smith is the executive director of Clean Energy Canada, a program at the Morris J. Wosk Centre for Dialogue at Simon Fraser University in Vancouver. Mark Zacharias is a special adviser at Clean Energy Canada and visiting professor at the Simon Fraser University School of Public Policy.

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Nighttime thermoradiative power converts outgoing infrared radiation into electricity using semiconductor photodiodes, leveraging negative illumination and sky cooling to harvest renewable energy from Earth-to-space heat flow when solar panels rest, regardless of weather.

Key Points

Nighttime thermoradiative power converts Earth's outgoing infrared heat into electricity using semiconductor diodes.

✅ Uses negative illumination to tap Earth-to-space heat flow

✅ Infrared semiconductor photodiodes generate small nighttime current

✅ Theoretical output ~4 W/m^2; lab demo reached 64 nW/m^2

There's a stark contrast between the freezing temperatures of space and the relatively balmy atmosphere of Earth, and that contrast could help generate electricity, scientists say – and alongside concepts such as space-based solar power, utilizing the same optoelectronic physics used in solar panels. The obvious difference this would have compared with solar energy is that it would work during the night time, a potential source of renewable power that could keep on going round the clock and regardless of weather conditions.

Solar panels are basically large-scale photodiodes - devices made out of a semiconducting material that converts the photons (light particles) coming from the Sun into electricity by exciting electrons in a material such as silicon, while concepts like space solar beaming could complement them during adverse weather.

In this experiment, the photodiodes work 'backwards': as photons in the form of infrared radiation - also known as heat radiation - leave the system, a small amount of energy is produced, similar to how raindrop electricity harvesting taps ambient fluxes in other experiments.

This way, the experimental system takes advantage of what researchers call the "negative illumination effect" – that is, the flow of outgoing radiation as heat escapes from Earth back into space. The setup explained in the new study uses an infrared semiconductor facing into the sky to convert this flow into electrical current.

"The vastness of the Universe is a thermodynamic resource," says one of the researchers, Shanhui Fan from Stanford University in California.

"In terms of optoelectronic physics, there is really this very beautiful symmetry between harvesting incoming radiation and harvesting outgoing radiation."

It's an interesting follow-up to a research project Fan participated in last year: a solar panel that can capture sunlight while also allowing excess heat in the form of infrared radiation to escape into space.

In the new study, this "energy harvesting from the sky" process can produce a measurable amount of electricity, the researchers have shown – though for the time being it's a long way from being efficient enough to contribute to our power grids, but advances in peer-to-peer energy sharing could still make niche deployments valuable.

In the team's experiments they were able to produce 64 nanowatts per square metre (10.8 square feet) of power – only a trickle, but an amazing proof of concept nevertheless. In theory, the right materials and conditions could produce a million times more than that, and analyses of cheap abundant electricity show how rapidly such advances compound, reaching about 4 watts per square metre.

"The amount of power that we can generate with this experiment, at the moment, is far below what the theoretical limit is," says one of the team, Masashi Ono from Stanford.

When you consider today's solar panels are able to generate up to 100-200 watts per square metre, and in China solar is cheaper than grid power across every city, this is obviously a long way behind. Even in its earliest form, though, it could be helpful for keeping low-power devices and machines running at night: not every renewable energy device needs to power up a city.

Now that the researchers have proved this can work, the challenge is to improve the performance of the experimental device. If it continues to show promise, the same idea could be applied to capture energy from waste heat given off by machinery, and results in humidity-powered generation suggest ambient sources are plentiful.

"Such a demonstration of direct power generation of a diode facing the sky has not been previously reported," explain the researchers in their published paper.

"Our results point to a pathway for energy harvesting during the night time directly using the coldness of outer space."

The research has been published in Applied Physics Letters.

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Nevada Renewable Portfolio Standard 2030 targets 50% clean energy, advancing solar, geothermal, and wind, cutting GHG emissions, phasing out coal, and expanding storage, EV infrastructure, and in-state renewables under PUCN oversight and tax abatements.

Key Points

A state mandate requiring 50% of electricity from renewables by 2030, driving solar, geothermal, wind, and storage.

✅ 50% clean power by 2030; 100% carbon-free target by 2050

✅ Growth in solar, geothermal, wind; coal phase-out; natural gas remains

✅ RETA incentives spur 6.1 GW capacity, jobs, and in-state investment

Nevada is on track to meet its Renewable Portfolio Standard of 50% of electricity generated by renewable energy sources by 2030, according to the Governor's Office of Energy's annual Status of Energy Report.

Based on compliance reports the Public Utilities Commission of Nevada has received, across all providers, about 20% of power is currently generated by renewable resources, and, nationally, renewables ranked second in 2020 as filings show Nevada's investor-owned utility and other power providers have plans to reach the state's ambitious RPS of 50% by 2030, according to the report released Jan. 28.

"Because transportation and electricity generation are Nevada's two largest contributors to greenhouse gas emissions, GOE's program work in 2021 underscored our focus on transportation electrification and reaching the state's legislatively required renewable portfolio standard," GOE Director David Bobzien said in a statement Jan. 28. "While electricity generated from renewable resources currently accounts for about 25% of the state's electricity, a share similar to projections that renewables will soon provide about one-fourth of U.S. electricity overall, we continue to collaborate with the Public Utilities Commission of Nevada, electricity providers, the renewable energy industry and conservation organizations to ensure Nevada reaches our target of 50% clean energy by 2030."

The state's RPS, enacted in 1997 and last modified in 2019, requires an increase in renewable energy, starting with 22% in 2020 and increasing to 50% by 2030. The increase in renewables will reduce GHG emissions and help the state reach its goal of 100% carbon-free power by 2050, while states like Rhode Island have a 100% by 2030 plan, highlighting varying timelines.

Renewable additions
The state added 1.332 GW of renewable capacity in 2021 as part of the Renewable Energy Tax Abatement program, at a time when U.S. renewable energy hit a record 28% in April, for a total renewable capacity of 6.117 GW, according to the report.

The RETA program awards partial sales and use tax and partial property-tax abatements to eligible renewable energy facilities, which increase Nevada's tax revenue and create jobs in a growing industry. Eligible projects must employ at least 50% Nevada workers, pay 175% of Nevada's average wage during construction, and offer health care benefits to workers and their dependents.

Since its adoption in 2010, the GOE has approved 60 projects, including large-scale solar PV, solar thermal, biomass, geothermal and wind projects throughout the state, according to the report. Projects granted abatements in 2021 include:

• 100-MW Citadel Solar Project
• 150-MW Dry Lake Solar + Storage Project
• 714-MW Gemini Solar Project
• 55-MW North Valley Power Geothermal Project
• 113-MW Boulder Flats Solar Project
• 200-MW Arrow Canyon Solar Project

"Nevada does not produce fossil fuels of any significant amount, and gasoline, jet fuel and natural gas for electricity or direct use must be imported," according to the report. "Transitioning to domestically produced renewable resources and electrified transportation can provide cost savings to Nevada residents and businesses, as seen in Idaho's largely renewable mix today, while reducing GHG emissions. About 86% of the fuel for energy that Nevada consumes comes from outside the state."

Phasing out coal plants
Currently, more than two-thirds of the state's electricity is produced by natural gas-fired power plants, with renewables covering most of the remaining generation, according to the report. Nevada continues to phase out its remaining coal power plants, as renewables surpassed coal nationwide in 2022, which provide less than 10% of produced electricity.

"Nevada has seen a significant increase in capturing its abundant renewable energy resources such as solar and geothermal," according to the report. "Renewable energy production continues to grow, powering Nevada homes and business and serves to diversify the state's economy by exporting solar and geothermal to neighboring states, as California neared 100% renewable electricity for the first time. Nevada has more than tripled its renewable energy production since 2011."

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Texas power grid highlights ERCOT reliability strains from extreme heat, climate change, and low wind, as natural gas and renewables balance tight capacity amid EV charging growth, heat pumps, and blackout risk across the U.S.

Key Points

Texas power grid is ERCOT-run and isolated, balancing natural gas and wind amid extreme weather and electrification.

✅ Isolated from other U.S. grids, limited import support

✅ Vulnerable to extreme heat, winter storms, low wind

✅ Demand growth from EVs and heat pumps stresses capacity

Texas has a unique state-run power grid facing a Texas grid crisis that has raised concerns, but its issues with extreme weather, and balancing natural gas and wind, hold lessons for an entire U.S. at risk for power outages from climate change.

Grid operator the Electric Reliability Council of Texas, or ERCOT, which has drawn criticism from Elon Musk recently, called on consumers to voluntarily reduce power use on Monday when dangerous heat gripped America’s second-most populous state.

The action paid off as the Texas grid avoided blackouts — and a repeat of its winter crisis — despite record or near-record temperatures that depleted electric supplies amid a broader supply-chain crisis affecting utilities this summer, and risked lost power to more than 26 million customers. ERCOT later on Monday lifted the call for conservation.

For sure, it’s a unique situation, as the state-run power grid system runs outside the main U.S. grids. Still, all Americans can learn from Texas about the fragility of a national power grid that is expected to be challenged more frequently by hot and cold weather extremes brought on by climate change, including potential reliability improvements policymakers are weighing.

The grid will also be tested by increased demand to power electric vehicles (EVs) and conversions to electric heat pumps — all as part of a transition to a “greener” future.

Why is Texas different?
ERCOT, the main, but not only, Texas grid, is unique in its state-run, and not regional, format used by the rest of the country. Because it’s an energy-rich state, Texas has been able to set power prices below those seen in other parts of the country, and its independence gives it more pricing authority, while lawmakers consider market reforms to avoid blackouts. But during unusual strain on the system, such as more people blasting their air conditioners longer to combat a record heat wave, it also has no where else to turn.

A lethal winter power shortage in February 2021, during a Texas winter storm that left many without power and water, notoriously put the state and its independent utility in the spotlight when ERCOT failed to keep residents warm and pipes from bursting. Texas’s 2021 outage left more than 200 people dead and rang up $20 billion in damage. Fossil-fuel CL00, 0.80% backers pointed to the rising use of intermittent wind power, which generates 23% of Texas’s electricity. Others said natural-gas equipment was frozen under the extreme conditions.

This week, ERCOT is asking for voluntary conservation between 2 p.m. and 8 p.m. local time daily due to record high electricity demand from the projected heat wave, and also because of low wind. ERCOT said current projections show wind generation coming in at less than 10% of capacity. ERCOT stressed that no systemwide outages are expected, and Gov. Greg Abbott has touted grid readiness heading into fall, but it was acting preemptively.

A report late last year from the North American Electric Reliability Corp. (NERC) said the Texas system without upgrades could see a power shortfall of 37% in extreme winter conditions. NERC’s outlook suggested the state and ERCOT isn’t prepared for a repeat of weather extremes.

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Maryland Renewable Energy Violations highlight RPS compliance gaps as facilities selling renewable energy certificates, including waste-to-energy, biomass, and paper mills, face emissions and permit issues, prompting PSC and Attorney General scrutiny of environmental standards.

Key Points

Alleged RPS noncompliance by REC-eligible plants, prompting PSC review and potential decertification under Maryland law.

✅ Complaint targets waste-to-energy, biomass plants, and paper mills

✅ Facilities risk loss of REC certification for environmental violations

✅ PSC may investigate nonreporting; AG reviewing evidence

Many facilities that supply Maryland with renewable energy have exceeded pollution limits or otherwise broken environmental rules, violating a state law, according to a complaint sent by environmental groups to state energy and law enforcement officials.

Maryland law says that any company that contributes to a state renewable energy goal — half the state’s energy portfolio must come from renewable sources by 2030 — must “substantially comply” with rules on air and water quality and waste management. The complaint says more than two dozen power generators, including paper mills and trash incinerators, have records of formal or informal enforcement actions by environmental authorities.

For years, environmental groups have criticized Maryland policy that counts power plants that produce planet-warming carbon dioxide and health-threatening pollution as “renewable” energy generation, and similar tensions have emerged in California’s reliance on fossil fuels despite ambitious targets, but lawmakers concerned about protecting industrial jobs have resisted reforms. The renewable label qualifies the companies for subsidies drawn from energy bills across the state.

In a complaint filed this week, the groups asked the attorney general and Public Service Commission to step in.

“We’re subsidizing companies to produce dirty energy, but we’re also using ratepayer money to support companies that in many instances are paying environmental fines or just flouting the law,” said Timothy Whitehouse, executive director of Public Employees for Environmental Responsibility. “There’s no one to hold them to account in Maryland.”

A spokeswoman for Attorney General Brian Frosh said his office would review the complaint, which was signed by Whitehouse and Mike Ewall, executive director of the Energy Justice Network.

Public Service Commission officials said the facilities must notify them if found out of compliance with environmental rules, while at the federal level FERC action on aggregated DERs is shaping market participation, and the commission can then revoke certification under the state renewable energy program. In a statement, commission officials said they would launch an investigation if any facility had failed to notify them of any environmental violations, and encouraged anyone with evidence of such a transgression to file a complaint.

Companies named in the document accused the groups of painting an inaccurate picture.

“This complaint is based on misleading arguments designed to halt waste-to-energy practices that have clear environmental benefits recognized by the global scientific community,” said Jim Connolly, vice president of environment, health and safety for Wheelabrator, which owns a Baltimore trash incinerator.

Maryland launched its renewable energy program in 2004, diversifying the state’s energy portfolio with more environmentally friendly sources of power, even as regional debates over a Maine-Québec transmission line highlight cross-border impacts. Under the program, separate from the electricity they generate and sell to the grid, renewable power facilities can sell what are known as renewable energy certificates. Utilities such as Baltimore Gas and Electric Co. are required to buy a growing number of the certificates each year, essentially subsidizing the renewable energy facilities with money from ratepayer bills.

A dozen types of power generation qualify to sell the certificates: Solar, wind, geothermal and hydroelectric plants, as well as “biomass” facilities that burn wood and other organic matter, waste-to-energy plants that burn household trash and paper mills that burn a byproduct known as black liquor.

The complaint focuses on waste incinerators, biomass plants and paper mills, all of which environmental groups have cast as counter to the renewable energy program’s environmental goals, even as ACORE criticized a coal and nuclear subsidy proposal in federal proceedings.

“By subsidizing these corporations, Maryland is diverting the hard-earned income of Maryland ratepayers to wealthy corporations with poor environmental compliance records and undermining the state’s transition to clean renewable energy,” Whitehouse and Ewall wrote.

For example, they note that the Wheelabrator plant in Southwest Baltimore has been fined for exceeding mercury limits in the past. That occurred in 2011, when the plant settled with state regulators for violations in 2010 and 2009.

Connolly said there is “no question” the facility complies with Maryland’s renewable energy law.

Incinerators in Montgomery County and in Fairfax County, Virginia, that are owned by Covanta and sell the energy certificates in Maryland have been cited for accidental fires inside both facilities. The Maryland incinerator violated emissions rules in 2014, the same year that New Jersey forbade the Virginia facility from selling energy certificates into that state’s renewable energy program over concerns it wasn’t following ash testing regulations.

James Regan, a spokesman for Covanta, said both facilities “have excellent compliance records and they operate well below their permitted limits.” He said the Virginia facility is complying with ash testing requirements, and that both facilities emit far lower levels of pollutants such as particulate matter than vehicles do.

“It’s clear to us there’s a lot of misleading and wrong information in this document," Regan said.

The Environmental Protection Agency endorsed waste-to-energy facilities under former President Barack Obama because, while burning household trash emits carbon dioxide, scientists said that still had a smaller impact on global warming than sending trash to landfills, even as industry groups have backed the EPA in a legal challenge to the ACE rule as regulatory approaches shifted.

Environmentalists and community groups say the facilities still are harmful because they emit high levels of pollutants such as mercury, nitrogen oxides and lead. The concerns prompted Baltimore City Council to pass an ordinance in February that tightened emissions limits on the Wheelabrator facility, even as the new EPA pollution limits for coal and gas plants are being proposed, so dramatically that the company said it would no longer be able to operate once the rules go into effect in 2022.

The complaint does not mention the century-old Luke paper mill in Western Maryland that long faced criticism for its participation in the renewable energy program, but which owner Verso Co. closed this year.

It does say several of paper company WestRock’s mills in North Carolina and Virginia have faced both formal and informal EPA enforcement actions for violation of the Clean Water Act, including evolving EPA wastewater limits for power plants and other facilities, and the Clean Air Act. A WestRock spokesperson could not be reached for comment.

The complaint also says a large biomass facility in South Boston, Virginia, owned by the Northern Virginia Electric Cooperative has a record of noncompliance with the Clean Air Act over three years.

John Rainey, the plant’s operations director, said it “experienced some small exceedances to its permit limits,” but that it addressed the issues with Virginia environmental officials and has installed new technology.

All those plants have sold credits in Maryland.

Whitehouse said the environmental groups’ goal is to clean up Maryland’s renewable energy program. They did not file a lawsuit because he said there was no clear cause of action to take the state to court, but said he hopes the complaint nonetheless spurs action.

“It’s not acceptable in a clean energy program that we’re subsidizing some of the most dirty sources of energy,” he said. “Those sources aren’t even in compliance with the law, and no one seems to care.”

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