PUC staff recalculates penalty in alleged market manipulation

By Knight Ridder Tribune


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Public Utility Commission staff cut the amount of the penalty they say TXU Corp. should pay for allegedly manipulating the wholesale power market.

The staff said in a filing that it recalculated the penalty after discovering a "variance in the computer code" and now recommends a $171 million penalty, down from the original recommendation of $210 million. The new amount would still represent the highest penalty ever assessed by the commission.

Commissioners are scheduled to hear the case in April, when they will decide whether TXU is guilty of market manipulation and, if so, how much to fine the Dallas power company. TXU spokeswoman Lisa Singleton said the company "vigorously denies" any wrongdoing.

Late last year, PUC staff accused TXU of refusing to sell power into the Texas grid on several occasions in summer 2005 in order to drive up prices.

The staff wrote in the revised notice of violation sent to TXU that lowering the recommended penalty doesn't change the issues in the case. Danielle Jaussaud, the PUC's director of market analysis, described the accusations in a recent filing: "TXU had the ability to substantially increase balancing energy prices because its energy offers were necessary to satisfy the demand in the... market; and... TXU abused its position by offering its energy into the market at prices well in excess of i s marginal cost."

The accusations stem from a report prepared last year by an outside consultant hired to monitor the Texas power market.

The consultant, Potomac Economics, crunched market-pricing data and concluded TXU had the ability and the opportunity to manipulate markets on various occasions during the summer of 2005. The report led PUC to hire the consultant to investigate TXU's market behavior, and Potomac found that TXU had manipulated the wholesale power market.

However, Potomac said in its revised report last week, it failed to update some natural gas pricing data during the investigation. After Potomac changed the data, the PUC staff recalculated its recommended penalty.

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Renewable growth drives common goals for electricity networks across the globe

Energy Transition Grid Reforms address transmission capacity, interconnection, congestion management, and flexibility markets, enabling renewable integration and grid stability while optimizing network charges and access in Australia, Ireland, and Great Britain.

 

Key Points

Measures to expand transmission, boost flexibility, and manage congestion for reliable, low-carbon electricity systems.

✅ Transmission upgrades and interconnectors ease congestion

✅ Flexible markets, DER, and storage bolster grid stability

✅ Evolving network charges and access incentivize siting

 

Electricity networks globally are experiencing significant increases in the volume of renewable capacity as countries seek to decarbonise their power sectors, even as clean energy's 'dirty secret' highlights integration trade-offs, without impacting the security of supply. The scale of this change is creating new challenges for power networks and those responsible for keeping the lights on.

The latest insight paper from Cornwall Insight – Market design amidst global energy transition – looks into this issue. It examines the outlook for transmission networks, and how legacy design and policies are supporting decarbonisation, aligning with IRENA findings on renewables and shaping the system. The paper focuses on three key markets; Australia, Ireland and Great Britain (GB).

Australia's main priority is to enhance transmission capacity and network efficiency; as concerns over excess solar risking blackouts grow in distribution networks, without this, the transmission system will be a barrier to growth for decentralised flexibility and renewables. In contrast, GB and Ireland benefit from interconnection with other national markets. This provides them with additional levers that can be pulled to manage system security and supply. However, they are still trying to hone and optimise network flexibility in light of steepening decarbonisation objectives.

Unsurprisingly, renewable energy resources have been growing in all three markets, with Ireland regarded as a leader in grid integration, with this expected to continue for the foreseeable future. Many of these projects are often located in places where network infrastructure is not as well developed, creating pressure on system operation as a result.

In all three markets, unit charges are rising, driven by a reduced charging base as decentralised energy grows quickly. This combination of changes is leading to network congestion, a challenge mirrored by the US grid overhaul for renewables underway, as transmission network development struggles to keep up, and flexibility markets are being optimised and changed.

In summary, reforms are on-going in each jurisdiction to accommodate the rapid physical transformation of the generation mix. Each has its objectives and tensions which are reflective of wider global reform programmes being undertaken in most developed, liberalised and decarbonising energy markets.

Gareth Miller, CEO of Cornwall Insight, said: “Despite differences in market design and characteristics, all three markets are grappling with similar issues, that comes from committing to deep decarbonisation. This includes the most appropriate methods for charging for networks, managing access to them and dealing with issues such as network congestion and constraint.

“In all three countries, renewable projects are often placed in isolated locations, as seen in Scotland where more pylons are needed to keep the lights on, away from the traditional infrastructure that is closer to demand. However, as renewable growth is set to continue, the networks will need to transition from being demand-centric to more supply orientated.

“Both system operators and stakeholders will need to continually evaluate their market structures and designs to alleviate issues surrounding locational congestion and grid stability. Each market is at very different stages in the process in trying to improve any problems implementing solutions to allow for higher efficiencies in renewable energy integration.

“It is uncertain whether any of the proposed changes will fundamentally resolve the issues that come with increased renewables on the system. However, despite marked differences, they certainly could all learn from each other and elements of their network arrangements, as well as from US decarbonisation strategies research.”

 

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Climate change: Greenhouse gas concentrations again break records

Rising Greenhouse Gas Concentrations drive climate change, with CO2, methane, and nitrous oxide surging; WMO data show higher radiative forcing, elevated pre-industrial baselines, and persistent atmospheric concentrations despite Paris Agreement emissions pledges.

 

Key Points

Increasing atmospheric CO2, methane, and nitrous oxide levels that raise radiative forcing and drive warming.

✅ WMO data show CO2 at 407.8 ppm in 2018, above decade average

✅ Methane and nitrous oxide surged, elevating total radiative forcing

✅ Concentrations differ from emissions; sinks absorb about half

 

The World Meteorological Organization (WMO) says the increase in CO2 was just above the average rise recorded over the last decade.

Levels of other warming gases, such as methane and nitrous oxide, have also surged by above average amounts.

Since 1990 there's been an increase of 43% in the warming effect on the climate of long lived greenhouse gases.

The WMO report looks at concentrations of warming gases in the atmosphere rather than just emissions.

The difference between the two is that emissions refer to the amount of gases that go up into the atmosphere from the use of fossil fuels, such as burning coal for coal-fired electricity generation and from deforestation.

Concentrations are what's left in the air after a complex series of interactions between the atmosphere, the oceans, the forests and the land. About a quarter of all carbon emissions are absorbed by the seas, and a similar amount by land and trees, while technologies like carbon capture are being explored to remove CO2.

Using data from monitoring stations in the Arctic and all over the world, researchers say that in 2018 concentrations of CO2 reached 407.8 parts per million (ppm), up from 405.5ppm a year previously.

This increase was above the average for the last 10 years and is 147% of the "pre-industrial" level in 1750.

The WMO also records concentrations of other warming gases, including methane and nitrous oxide, and some countries have reported declines in certain potent gases, as noted in US greenhouse gas controls reports, though global levels remain elevated. About 40% of the methane emitted into the air comes from natural sources, such as wetlands, with 60% from human activities, including cattle farming, rice cultivation and landfill dumps.

Methane is now at 259% of the pre-industrial level and the increase seen over the past year was higher than both the previous annual rate and the average over the past 10 years.

Nitrous oxide is emitted from natural and human sources, including from the oceans and from fertiliser-use in farming. According to the WMO, it is now at 123% of the levels that existed in 1750.

Last year's increase in concentrations of the gas, which can also harm the ozone layer, was bigger than the previous 12 months and higher than the average of the past decade.

What concerns scientists is the overall warming impact of all these increasing concentrations. Known as total radiative forcing, this effect has increased by 43% since 1990, and is not showing any indication of stopping.

There is no sign of a slowdown, let alone a decline, in greenhouse gases concentration in the atmosphere despite all the commitments under the Paris agreement on climate change and the ongoing global energy transition efforts," said WMO Secretary-General Petteri Taalas.

"We need to translate the commitments into action and increase the level of ambition for the sake of the future welfare of mankind," he added.

"It is worth recalling that the last time the Earth experienced a comparable concentration of CO2 was three to five million years ago. Back then, the temperature was 2-3C warmer, sea level was 10-20m higher than now," said Mr Taalas.

The UN Environment Programme will report shortly on the gap between what actions countries are taking to cut carbon, for example where Australia's emissions rose 2% recently, and what needs to be done to keep under the temperature targets agreed in the Paris climate pact.

Preliminary findings from this study, published during the UN Secretary General's special climate summit last September, indicated that emissions continued to rise during 2018, although global emissions flatlined in 2019 according to the IEA.

Both reports will help inform delegates from almost 200 countries who will meet in Madrid next week for COP25, following COP24 in Katowice the previous year, the annual round of international climate talks.

 

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California Welcomes 70 Volvo VNR Electric Trucks

Switch-On Project Electric Trucks accelerate California freight decarbonization, deploying Volvo VNR Electric rigs with high-capacity charging infrastructure, zero-emissions operations, and connected safety features to cut greenhouse gases and improve urban air quality.

 

Key Points

A California program deploying Volvo VNR Electric trucks and charging to decarbonize freight and improve air quality.

✅ 70 Volvo VNR Electric trucks for regional logistics

✅ Strategic high-capacity charging for heavy-duty fleets

✅ Lower TCO via fuel savings and reduced maintenance

 

In a significant step toward sustainable transportation, the Switch-On project is bringing 70 Volvo VNR Electric trucks to California. This initiative aims to bolster the state's efforts to reduce emissions and transition to greener logistics solutions. The arrival of these electric vehicles marks an important milestone in California's commitment to combating climate change and improving air quality.

The Switch-On Project: Overview and Goals

The Switch-On project is a collaborative effort designed to enhance electric truck adoption in California. It focuses on developing the necessary infrastructure and technology to support electric vehicles (EVs) in the freight and logistics sectors, building on recent nonprofit investments at California ports. The project not only seeks to increase the availability of electric trucks but also aims to demonstrate their effectiveness in real-world applications.

California has set ambitious goals for reducing greenhouse gas emissions, particularly from the transportation sector, which is one of the largest contributors to air pollution. By introducing electric trucks into freight operations, the state aims to significantly cut emissions, improve public health, and pave the way for a more sustainable future.

The Volvo VNR Electric Trucks

The Volvo VNR Electric trucks are specifically designed for regional distribution and urban transport, aligning with Volvo's broader electric lineup as the company expands offerings, making them ideal for the needs of California’s freight industry. With a range of approximately 250 miles on a single charge, these trucks can efficiently handle most regional routes. Equipped with advanced technology, including regenerative braking and connectivity features, the VNR Electric models enhance operational efficiency and safety.

These trucks not only provide a cleaner alternative to traditional diesel vehicles but also promise lower operational costs over time. With reduced fuel expenses and lower maintenance needs, and emerging vehicle-to-grid pilots that can create new value streams, businesses can benefit from significant savings while contributing to environmental sustainability.

Infrastructure Development

A crucial aspect of the Switch-On project is the development of charging infrastructure to support the new fleet of electric trucks. The project partners are working on installing high-capacity charging stations strategically located throughout California while addressing utility planning challenges that large fleets will pose to the power system. This infrastructure is essential to ensure that electric trucks can be charged efficiently, minimizing downtime and maximizing productivity.

The charging stations are designed to accommodate the specific needs of heavy-duty vehicles, and corridor models like BC's Electric Highway provide useful precedents for network design, allowing for rapid charging that aligns with operational schedules. This development not only supports the new fleet but also encourages other logistics companies to consider electric trucks as a viable option for their operations.

Benefits to California

The introduction of 70 Volvo VNR Electric trucks will have several positive impacts on California. Firstly, it will significantly reduce greenhouse gas emissions from the freight sector, contributing to the state’s ambitious climate goals even as grid expansion will be needed to support widespread electrification across sectors. The transition to electric trucks is expected to improve air quality, particularly in urban areas that struggle with high pollution levels.

Moreover, the project serves as a model for other regions considering similar initiatives. By showcasing the practicality and benefits of electric trucks, California hopes to inspire widespread adoption across the nation. As the market for electric vehicles continues to grow, this project can play a pivotal role in accelerating the transition to sustainable transportation solutions.

Industry and Community Reactions

The arrival of the Volvo VNR Electric trucks has been met with enthusiasm from both industry stakeholders and community members. Logistics companies are excited about the opportunity to reduce their carbon footprints and operational costs. Meanwhile, environmental advocates applaud the project as a crucial step toward cleaner air and healthier communities.

California’s commitment to sustainable transportation has positioned it as a leader in the shift to electric vehicles amid an ongoing biofuels vs. EVs debate over the best path forward, setting an example for other states and countries.

Conclusion

The Switch-On project represents a major advancement in California's efforts to transition to electric transportation. With the deployment of 70 Volvo VNR Electric trucks, the state is not only taking a significant step toward reducing emissions but also demonstrating the feasibility of electric logistics solutions.

As infrastructure develops and more electric trucks hit the roads, California is paving the way for a greener, more sustainable future in transportation. The success of this project could have far-reaching implications, influencing policies and practices in the broader freight industry and beyond.

 

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Europe's largest shore power plant opens

AIDAsol shore power Rostock-Warnemfcnde delivers cold ironing for cruise ships, up to 20 MVA at berths P7 and P8, cutting port emissions during berthing and advancing AIDA's green cruising strategy across European ports.

 

Key Points

Rostock-Warnemfcnde shore power supplies two cruise ships up to 20 MVA, enabling cold ironing and cutting emissions.

✅ Up to 20 MVA; powers two cruise ships at berths P7 and P8

✅ Enables cold ironing for AIDA fleet to reduce berth emissions

✅ Part of AIDA green cruising with fuel cells and batteries

 

In a ceremony held in Rostock-Warnemünde yesterday during Germany’s 12th National Maritime Conference, the 2,174-passenger cruise ship AIDAsol inaugurated Europe’s largest shore power plants for ships.

The power plant has been established under a joint agreement between AIDA Cruises, a unit of Carnival Corporation & plc (NYSE/LSE: CCL; NYSE: CUK), the state government of Mecklenburg-Western Pomerania, the city of Rostock and the Port of Rostock.

“With our green cruising strategy, we have been investing in a sustainable cruise market for many years,” said AIDA Cruises President Felix Eichhorn. “The shore power plant in Rostock-Warnemünde is another important step — after the facility in Hamburg — on our way to an emission-neutral cruise that we want to achieve with our fleet. I would like to thank the state government of Mecklenburg-Western Pomerania and all partners involved for the good and trusting cooperation. Together, we are sending out an important signal, not just in Germany, but throughout Europe.”

CAN POWER TWO CRUISE SHIPS AT A TIME
The shore power plant, which was completed in summer 2020, is currently the largest in Europe and aligns with port electrification efforts such as the all-electric berth at London Gateway in the UK. With an output of up to 20 megavolt amperes (MVA), two cruise ships can be supplied with electricity at the same time at berths P7 and P8 in Warnemünde.

In regular passenger operation AIDAsol needs up to 4.5 megawatts per hour (MWh) of electricity.

The use of shore power to supply ships with energy is a decisive step in AIDA Cruises’ plans to reduce local emissions to zero during berthing, complementing recent progress with electric ships on the B.C. coast, as a cruise ship typically stays in port around 40% of its operating time.

As early as 2004, when the order for the construction of AIDAdiva was placed, and for all other ships put into service in subsequent years, the company has considered the use of shore power as an option for environmentally friendly ship operation.

Since 2017, AIDA Cruises has been using Europe’s first shore power plant in Hamburg-Altona, where AIDAsol is in regular operation, while operators like BC Ferries add hybrid ferries to expand low-emission service in Canada. Currently, 10 ships in the AIDA fleet can either use shore power where available or are technically prepared for it.

The aim is to convert all ships built from 2000 onwards, supporting future solutions like offshore charging with wind power.

With AIDA Cruises starting a cruise season from Kiel, Germany, on May 22, AIDAsol will also be the first cruise ship to complete the final tests on a newly built shore power plant there, as innovations such as Berlin’s electric flying ferry highlight the broader shift toward electrified waterways. Construction of that plant is the result of a joint initiative by the state government of Schleswig-Holstein, the city and the port of Kiel and AIDA Cruises. AIDAsol is scheduled to arrive in Kiel on the afternoon of May 13.

As part of its green cruising strategy, AIDA Cruises has been investing in a sustainable cruise operation for many years, paralleling urban shifts toward zero-emission bus fleets in Berlin. Other steps on the path to the zero emission ship of the future are already in preparation. This year, AIDAnova will receive the first fuel cell to be used on an ocean-going cruise ship. In 2022, the largest battery storage system to date in cruise shipping will go into operation on board an AIDA ship, similar to advances in battery-electric ferries in the U.S. In addition, the company is already addressing the question of how renewable fuels can be used on board cruise ships in the future.

 

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Medicine Hat Grant Winners to Upgrade Grid and Use AI for Energy Savings

Medicine Hat Smart Grid AI modernizes electricity distribution with automation, sensors, and demand response, enhancing energy efficiency and renewable integration while using predictive analytics and real-time data to reduce consumption and optimize grid operations.

 

Key Points

An initiative using smart grid tech and AI to optimize energy use, cut waste, and improve renewable integration.

✅ Predictive analytics forecast demand to balance load and prevent outages.

✅ Automation, sensors, and meters enable dynamic, resilient distribution.

✅ Integrates solar and wind with demand response to cut emissions.

 

The city of Medicine Hat, Alberta, is taking bold steps toward enhancing its energy infrastructure and reducing electricity consumption with the help of innovative technology. Recently, several grant winners have been selected to improve the city's electricity grid distribution and leverage artificial intelligence (AI) to adapt to electricity demands while optimizing energy use. These projects promise to not only streamline energy delivery but also contribute to more sustainable practices by reducing energy waste.

Advancing the Electricity Grid

Medicine Hat’s electricity grid is undergoing a significant transformation, thanks to a new set of initiatives funded by government grants that advance a smarter electricity infrastructure vision for the region. The city has long been known for its commitment to sustainable energy practices, and these new projects are part of that legacy. The winners of the grants aim to modernize the city’s electricity grid to make it more resilient, efficient, and adaptable to the changing demands of the future, aligning with macrogrid strategies adopted nationally.

At the core of these upgrades is the integration of smart grid technologies. A smart grid is a more advanced version of the traditional power grid, incorporating digital communications and real-time data to optimize the delivery and use of electricity. By connecting sensors, meters, and control systems across the grid, along with the integration of AI data centers where appropriate, the grid can detect and respond to changes in demand, adjust to faults or outages, and even integrate renewable energy sources more efficiently.

One of the key aspects of the grant-funded projects involves automating the grid. Automation allows for the dynamic adjustment of power distribution in response to changes in demand or supply, reducing the risk of blackouts or inefficiencies. For instance, if an area of the city experiences a surge in energy use, the grid can automatically reroute power from less-used areas or adjust the distribution to avoid overloading circuits. This kind of dynamic response is crucial for maintaining a stable and reliable electricity supply.

Moreover, the enhanced grid will be able to better incorporate renewable energy sources such as solar and wind power, reflecting British Columbia's clean-energy shift as well, which are increasingly important in Alberta’s energy mix. By utilizing a more flexible and responsive grid, Medicine Hat can make the most of renewable energy when it is available, reducing reliance on non-renewable sources.

Using AI to Reduce Energy Consumption

While improving the grid infrastructure is an essential first step, the real innovation comes in the form of using artificial intelligence (AI) to reduce energy consumption. Several of the grant winners are focused on developing AI-driven solutions that can predict energy demand patterns, optimize energy use in real-time, and encourage consumers to reduce unnecessary energy consumption.

AI can be used to analyze vast amounts of data from across the electricity grid, such as weather forecasts, historical energy usage, and real-time consumption data. This analysis can then be used to make predictions about future energy needs. For example, AI can predict when the demand for electricity will peak, allowing the grid operators to adjust supply ahead of time, ensuring a more efficient distribution of power. By predicting high-demand periods, AI can also assist in optimizing the use of renewable energy sources, ensuring that solar and wind power are utilized when they are most abundant.

In addition to grid management, AI can help consumers save energy by making smarter decisions about how and when to use electricity. For instance, AI-powered smart home devices can learn household routines and adjust heating, cooling, and appliance usage to reduce energy consumption without compromising comfort. By using data to optimize energy use, these technologies not only reduce costs for consumers but also decrease overall demand on the grid, leading to a more sustainable energy system.

The AI initiatives are also expected to assist businesses in reducing their carbon footprints. By using AI to monitor and optimize energy use, industrial and commercial enterprises can cut down on waste and reduce energy-related operational costs, while anticipating digital load growth signaled by an Alberta data centre agreement in the province. This has the potential to make Medicine Hat a more energy-efficient city, benefiting both residents and businesses alike.

A Sustainable Future

The integration of smart grid technology and AI-driven solutions is positioning Medicine Hat as a leader in sustainable energy practices. The city’s approach is focused not only on improving energy efficiency and reducing waste but also on making electricity consumption more manageable and adaptable in a rapidly changing world. These innovations are a crucial part of Medicine Hat's long-term strategy to reduce carbon emissions and meet climate goals while ensuring reliable and affordable energy for its residents.

In addition to the immediate benefits of these projects, the broader impact is likely to influence other municipalities across Canada, including insights from Toronto's electricity planning for rapid growth, and beyond. As the technology matures and proves successful, it could set a benchmark for other cities looking to modernize their energy grids and adopt sustainable, AI-driven solutions.

By investing in these forward-thinking technologies, Medicine Hat is not only future-proofing its energy infrastructure but also taking decisive steps toward a greener, more energy-efficient future. The collaboration between local government, technology providers, and the community marks a significant milestone in the city’s commitment to innovation and sustainability.

 

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P.E.I. government exploring ways for communities to generate their own electricity

P.E.I. Community Energy Independence empowers local microgrids through renewable generation, battery storage, and legislative reform, enabling community-owned power, stable electricity rates, and grid-friendly distributed generation across Island communities with wind, biomass, and net metering models.

 

Key Points

A program enabling communities to generate and store renewable power under supportive laws and grid-friendly models.

✅ Legislative review of Electric Power and Renewable Energy Acts

✅ Community microgrids with wind, biomass, and battery storage

✅ Grid integration without raising rates via Maritime Electric

 

The P.E.I. government is taking steps to review energy legislation and explore new options when it comes to generating power across Island communities.

Energy Minister Steven Myers said one of those options will be identifying ways for Island communities to generate their own energy, aligning with a federal electrification study now examining how electricity can reduce or eliminate fossil fuels. 

He said the move would provide energy independence, create jobs and economic development, and save the communities on their energy bills, as seen with an electricity bill credit in Newfoundland that eased costs for consumers.

But the move will require sweeping legislative changes, that may include the merging of the Electric Power Act and the Renewable Energy Act, similar to an electricity market overhaul in Connecticut seen in other jurisdictions.  

Myers said creating energy independence should ensure a steady supply of electricity while also ensuring costs remain reasonable for P.E.I. residents, even as a Nova Scotia electricity rate hike highlights regional cost pressures.   

"We have communities that are looking to generate their own electricity for their own needs," said Myers, adding the province will not dictate what energy sources communities can invest in. 

He also said the province wants to find new community-based models that will complement existing services.

"How do we do that in a way that we don't impact the grid, that we don't impact the service that Maritime Electric is delivering, mindful of a seasonal rate backlash in New Brunswick that illustrates consumer concerns, that we don't drive up the rates for all other Islanders."

Last fall, a group of P.E.I. MLAs traveled to Samsø, a small Danish island, where they learned about renewable and sustainable energy systems being used there.

The province is looking at storage options so it can store power generated during the day to be used in the evening when electricity use is at its highest. (CBC)
Samsø produces 100 per cent of its electricity from wind and biomass, and utilities like HECO meeting renewable goals early show how quickly transitions can occur. The P.E.I. government said the Island produces 25 per cent of its electricity from wind. 

Following the trip, Myers said he was impressed by the control the island had over its energy production and would like to see if a similar model could work on P.E.I. 

Myers said the legislative review will also look at different ways to store energy on the Island. 

He said that will allow communities to sell that excess energy into the provincial electricity grid, and those revenues could be redirected into that community's priorities. 

'For the survival and the future of their community'
"This is kind of a model that we had suggested that would be in place that would allow people in their own community to produce a revenue stream for themselves that they could then turn into projects like rinks, or parks, or tennis courts or whatever it is that community thinks is the most important thing for the survival and the future of their community," said Myers. 

Energy Minister Steven Myers says creating energy independence could create a steady supply of electricity while also ensuring costs remain reasonable for P.E.I. residents. (Randy McAndrew/CBC)
The province said Maritime Electric, Summerside Electric and the P.E.I. Energy Corporation will be involved in the review, recognizing that a Nova Scotia ruling on rate-setting powers underscores regulatory limits 

Government also wants to hear from Islanders and will be accepting written submissions beginning Monday. Myers said the province is also planning to host public consultations, but because of COVID-19, those will be held virtually in mid-June.

Myers calls this a major move, one that will take time. He said he doesn't expect the legislation to be made public until the spring of 2021.

"I want to make sure we take our time and do the proper consultation."

 

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