UK net zero policies: What do changes mean?

Barakah Unit 1 100 Percent Power signals the APR-1400 reactor delivering 1400MW of clean baseload electricity to the UAE grid, advancing decarbonisation, reliability, and Power Ascension Testing milestones ahead of commercial operations in early 2021.

Key Points

The milestone where Unit 1 reaches full 1400MW output to the UAE grid, providing clean, reliable baseload electricity.

✅ Delivers 1400MW from a single generator to the UAE grid

✅ Enables clean, reliable baseload power with zero operational emissions

✅ Completes key Power Ascension Testing before commercial operations

The Emirates Nuclear Energy Corporation, ENEC, has announced that its operating and maintenance subsidiary, Nawah Energy Company, Nawah, has successfully achieved 100% of the rated reactor power capacity for Unit 1 of the Barakah Nuclear Energy Plant. This major milestone, seen as a crucial step in Abu Dhabi towards completion, brings the Barakah plant one step closer to commencing commercial operations, scheduled in early 2021.

100% power means that Unit 1 is generating 1400MW of electricity from a single generator connected to the UAE grid for distribution. This milestone makes the Unit 1 generator the largest single source of electricity in the UAE.

The Barakah Nuclear Energy Plant is the largest source of clean baseload electricity in the country, capable of providing constant and reliable power in a sustainable manner around the clock. This significant achievement accelerates the decarbonisation of the UAE power sector, while also supporting the diversification of the Nation’s energy portfolio as it transitions to cleaner electricity sources, similar to the steady development in China of nuclear energy programs now underway.

The accomplishment follows shortly after the UAE’s celebration of its 49th National Day, providing a strong example of the country’s progress as it continues to advance towards a sustainable, clean, secure and prosperous future, having made the UAE the first Arab nation to open a nuclear plant as it charts this path. As the Nation looks towards the next 50 years of achievements, the Barakah plant will generate up to 25 percent of the country’s electricity, while also acting as a catalyst of the clean carbon future of the Nation.

Mohamed Ibrahim Al Hammadi, Chief Executive Officer of ENEC said: "We are proud to deliver on our commitment to power the growth of the UAE with safe, clean and abundant electricity. Unit 1 marks a new era for the power sector and the future of the clean carbon economy of the Nation, with the largest source of electricity now being generated without any emissions. I am proud of our talented UAE Nationals, working alongside international experts who are working to deliver this clean electricity to the Nation, in line with the highest standards of safety, security and quality." Nawah is responsible for operating Unit 1 and has been responsible for safely and steadily raising the power levels since it commenced the start-up process in July, and connection to the grid in August.

Achieving 100% power is one of the final steps of the Power Ascension Testing (PAT) phase of the start-up process for Unit 1. Nawah’s highly skilled and certified nuclear operators will carry out a series of tests before the reactor is safely shut down in preparation for the Check Outage. During this period, the Unit 1 systems will be carefully examined, and any planned or corrective maintenance will be performed to maintain its safety, reliability and efficiency prior to the commencement of commercial operations.

Ali Al Hammadi, Chief Executive Officer of Nawah, said: "This is a key achievement for the UAE, as we safely work through the start-up process for Unit 1 of the Barakah plant. Successfully reaching 100% of the rated power capacity in a safe and controlled manner, undertaken by our highly trained and certified nuclear operators, demonstrates our commitment to safe, secure and sustainable operations as we now advance towards our final maintenance activities and prepare for commercial operations in 2021." The Power Ascension Testing of Unit 1 is overseen by the independent national regulator – the Federal Authority for Nuclear Regulation (FANR), which has conducted 287 inspections since the start of Barakah’s development. These independent reviews have been conducted alongside more than 40 assessments and peer reviews by the International Atomic Energy Agency, IAEA, and World Association of Nuclear Operators, WANO, reflecting milestones at nuclear projects worldwide that benchmark safety and performance.

This is an important milestone for the commercial performance of the Barakah plant. Barakah One Company, ENEC’s subsidiary in charge of the financial and commercial activities of the Barakah project signed a Power Purchase Agreement, PPA, with the Emirates Water and Electricity Company, EWEC, in 2016 to purchase all of the electricity generated at the plant for the next 60 years. Electricity produced at Barakah feeds into the national grid in the same manner as other power plants, flowing to homes and business across the country.

This milestone has been safely achieved despite the challenges of COVID-19. Since the beginning of the global pandemic, ENEC, and subsidiaries Nawah and Barakah One Company, along with companies that form Team Korea, including Korea Hydro & Nuclear Power, with KHNP’s work in Bulgaria illustrating its global role, have worked closely together, in line with all national and local health authority guidelines, to ensure the highest standards for health and safety are maintained for those working on the project. ENEC and Nawah’s robust business continuity plans were activated, alongside comprehensive COVID-19 prevention and management measures, including access control, rigorous testing, and waste water sampling, to support health and wellbeing.

The Barakah Nuclear Energy Plant, located in the Al Dhafra region of the Emirate of Abu Dhabi, is one of the largest nuclear energy new build projects in the world, with four APR-1400 units. Construction of the plant began in 2012 and has progressed steadily ever since. Construction of Units 3 and 4 are in the final stages with 93 percent and 87 percent complete respectively, benefitting from the experience and lessons learned during the construction of Units 1 and 2, while the construction of the Barakah Plant as a whole is now more than 95 percent complete.

Once the four reactors are online, Barakah Plant will deliver clean, efficient and reliable electricity to the UAE grid for decades to come, providing around 25 percent of the country’s electricity and, as other nations like Bangladesh expand with IAEA assistance, reinforcing global decarbonisation efforts, preventing the release of up to 21 million tons of carbon emissions annually – the equivalent of removing 3.2 million cars off the roads each year.

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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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Nova Scotia Power Rate Increase 2023-2024 approved by the UARB lifts electricity rates 14 percent, citing fuel costs and investments, despite Bill 212; includes ROE 9 percent, decarbonization deferral, and a storm cost recovery rider.

Key Points

An approved UARB rate case raising electricity bills about 14% over 2023-2024, with ROE 9% and cost recovery tools.

✅ UARB approves average 6.9% annual increases for 2023 and 2024.

✅ Maintains 9% ROE; sets storm cost rider trial and decarbonization deferral.

✅ Government opposed via Bill 212, but settlement mostly upheld.

Nova Scotia regulators approved a 14 per cent electricity rate hike on Thursday, defying calls by Premier Tim Houston to reject the increase.

Rates will rise on average by 6.9 per cent each year in 2023 and 2024.

In Newfoundland and Labrador, the NL Consumer Advocate called an 18 per cent electricity rate hike unacceptable amid affordability concerns.

The Nova Scotia Utility and Review Board (UARB) issued a 203-page decision ratifying most of the elements in a settlement agreement reached between Nova Scotia Power and customer groups after Houston's government legislated a rate, spending and profit cap on the utility in November.

The board said approval was in the public interest and the increase is "reasonable and appropriate."

"The board cannot simply disallow N.S. Power's reasonable costs to make rates more affordable. These principles ensure fair rates and the financial health of a utility so it can continue to invest in the system providing services to its customers," the three-member panel wrote.

"While the board can (and has) disallowed costs found to be imprudent or unreasonable, absent such a finding, N.S. Power's costs must be reflected in the rates."

In addition to the 14 per cent hike, the board maintained Nova Scotia Power's current return on equity of 9 per cent, with an earnings band of 8.75 to 9.25 per cent. It agreed in principle to establish a decarbonization deferral account to pay for the retirement of coal plants and related decommissioning costs, and implemented a storm cost recovery rider for a three-year trial period.

The board rejected several items in the agreement, including rolling some Maritime Link transmission capital projects into consumers' rates.

Nova Scotia Power welcomed the ruling in a statement, describing it as "the culmination of an extensive and transparent regulatory process over the past year."

Natural Resources and Renewables Minister Tory Rushton, who has said the government cannot order lower power rates in Nova Scotia, stated the UARB decision was not what the government wanted, but he did not indicate the government has any plans to bring forward legislation to overturn it. 

"We're disappointed by the decision today. We've always been very clear that we were standing by ratepayers right from the get-go but we also respect the independent body of the UARB and their decision today."

Pressure from the province
Houston claimed the settlement breached his government's legislation, known as Bill 212 in Nova Scotia, which he said was intended to protect ratepayers. It 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.

Bill 212 was passed after the board concluded weeks of public hearings into Nova Scotia Power's request for an electricity rate increase, its first general rate application in 10 years. Nova Scotia Power is a subsidiary of Halifax-based Emera, which is a publicly traded company.

The legislation triggered credit downgrades from two credit rating agencies who said it compromised the independence of the Nova Scotia Utility and Review Board.

In Newfoundland and Labrador, electricity users have begun paying for Muskrat Falls as project costs flow through rates, highlighting broader pressures on Atlantic Canada utilities.

In its decision, the board accepted that legislation was intended to protect ratepayers but did not preclude increases in rates.

"Given the exclusion of fuel and purchased power costs when these were expected to cause significant upward pressure on rates, it also did not preclude large increases in rates. Instead, the protection afforded by the Public Utilities Act amendments appears to be focused on N.S. Power's non-fuel costs, with several amendments targeting N.S. Power's cost of capital and earnings."

The board noted the province was the only intervenor in the rate case to object to the settlement.

Opposition reaction
Rushton said despite the outcome, Bill 212 achieved its goal, which was to protect ratepayers.

"Without Bill 212 the rates would have actually been higher," he said. "It would have double-digit rates for this year and next year and now it's single digits."

NDP Leader Claudia Chender said the end result is that Nova Scotians are still facing "incredibly unaffordable power."

Similar criticism emerged in Saskatchewan after an 8 per cent SaskPower increase, which the NDP opposed during provincial debates.

"It's really unfortunate for a lot of Nova Scotians who are heading into a freezing weekend where heat is not optional."

Chender said a different legislative approach is needed to change the regulatory system, and more needs to be done to help people pay their electricity bills.

Liberal MLA Kelly Regan echoed that sentiment.

"There are lots of people who can absorb this. There are a lot of people who cannot, and those are the people that we should be worried about right now. This is why we've been saying all along the government needs to actually give money directly to Nova Scotians who need help with power rates."

Rushton said the government has introduced programs to help Nova Scotians pay for heat, including raising the income threshold to access the Heating Assistance Rebate Program and creating incentives to install heat pumps.

Elsewhere, some governments have provided a lump-sum credit on electricity bills to ease short-term costs for households.

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DARPA RADICS Power Grid Security targets DoD resilience to cyber attacks, delivering early warning, detection, isolation, and characterization tools, plus a secure emergency network to protect critical infrastructure and speed grid restoration and communications.

Key Points

A DoD/DARPA initiative to detect, contain, and rapidly recover the U.S. grid from sophisticated cyber attacks.

✅ Early warning separates attacks from routine outages

✅ Pinpoints intrusion points and malware used

✅ Builds secure emergency network for rapid restoration

The U.S. Department of Defense is growing increasingly concerned about hackers taking down our power grid and crippling the nation, reflecting a renewed focus on grid protection across agencies, which is why the Pentagon has created a $77-million security plan that it hopes will be up and running by 2020.

The U.S. power grid is threatened every few days. While these physical and cyber attacks have never led to wide-scale outages, attacks are getting more sophisticated. According to a 494-page report released by the Department of Energy in January and a new grid report card, the nation’s grid “faces imminent danger from cyber attacks.” Such a major, sweeping attack could threaten “U.S. lifeline networks, critical defense infrastructure, and much of the economy; it could also endanger the health and safety of millions of citizens.” If it were to happen today, America could be powered-down and vulnerable for weeks.

#google#

The DoD is working on an automated system to speed up recovery time to a week or less — what it calls the Rapid Attack Detection, Isolation, and Characterization (RADICS) program. DARPA, the Pentagon’s research arm, originally solicited proposals in late 2015, asking for technology that did three things. Primarily, it had to detect early warning signs and distinguish between attacks and normal outages, especially after intrusions at U.S. electric utilities underscored the risk, but it also had to pinpoint the access point of the attack and determine what malicious software was used. Finally, it must include an emergency system that can rapidly connect various power-supply centers, without any human coordination. This would allow emergency and military responders to have an ad hoc communication system in place moments after an attack.

“If a well-coordinated cyberattack on the nation’s power grid were to occur today, the time it would take to restore power would pose daunting national security challenges,” said DARPA program manager John Everett, in a statement, at the time. “Beyond the severe domestic impacts, including economic and human costs, prolonged disruption of the grid would hamper military mobilization and logistics, impairing the government’s ability to project force or pursue solutions to international crises.”

DARPA plans to spend $77 million on RADICS, while DOE funding to improve the grid complements these initiatives. Last November, SRI International announced it had received $7.3 million from the program. In December, Raython was granted $9 million. The latest addition is BAE Systems, which received $8.6 million last month to develop technology that detects and contains power-grid threats, and creates a secure emergency provisional system that restores some power and communication in the wake of an attack — what is being called a secure emergency network.

According to the military news site Defense Systems, BAE’s SEN would rely on radio, satellite, or wireless internet — particularly as ransomware attacks continue to rise — whatever is available that allows the grid to continue working. The SEN would serve as a wireless connection between separate power grid stations.

While the ultimate goal of the RADICS program will be the restoration of civilian power and communications, the SEN will prioritize communication networks that would be used for defense or combat, so the U.S. government can still wage war while the rest of us are in the dark.

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Agrivoltaics in Alberta integrates solar energy with agriculture, boosting crop yields and water conservation. The Strathmore Solar project showcases dual land use, sheep grazing for vegetation control, and PPAs that expand renewable energy capacity.

Key Points

A dual-use model where solar arrays and farming co-exist, boosting yields, saving water, and diversifying revenue.

✅ Strathmore Solar: 41 MW on 320 acres with managed sheep grazing

✅ 25-year TELUS PPA secures power and renewable energy credits

✅ Panel shade cuts irrigation needs and protects crops from extremes

Alberta is emerging as a leader in agrivoltaics—the innovative practice of integrating solar energy production with agricultural activities, aligning with the province's red-hot solar growth in recent years. This approach not only generates renewable energy but also enhances crop yields, conserves water, and supports sustainable farming practices. A notable example of this synergy is the Strathmore Solar project, a 41-megawatt solar farm located on 320 acres of leased industrial land owned by the Town of Strathmore. Operational since March 2022, it exemplifies how solar energy and agriculture can coexist and thrive together.

The Strathmore Solar Initiative

Strathmore Solar is a collaborative venture between Capital Power and the Town of Strathmore, with a 25-year power purchase agreement in place with TELUS Corporation for all the energy and renewable energy credits generated by the facility. The project not only contributes significantly to Alberta's renewable energy capacity, as seen with new solar facilities contracted at lower cost across the province, but also serves as a model for agrivoltaic integration. In a unique partnership, 400 to 600 sheep from Whispering Cedars Ranch are brought in to graze the land beneath the solar panels. This arrangement helps manage vegetation, reduce fire hazards, and maintain the facility's upkeep, all while providing shade for the grazing animals. This mutually beneficial setup maximizes land use efficiency and supports local farming operations, illustrating how renewable power developers can strengthen outcomes with integrated designs today. 

Benefits of Agrivoltaics in Alberta

The integration of solar panels with agricultural practices offers several advantages for a province that is a powerhouse for both green energy and fossil fuels already across sectors:

• Enhanced Crop Yields: Studies have shown that crops grown under solar panels can experience increased yields due to reduced water evaporation and protection from extreme weather conditions.
  
  

• Water Conservation: The shade provided by solar panels helps retain soil moisture, leading to a decrease in irrigation needs.
  
  

• Diversified Income Streams: Farmers can generate additional revenue by selling renewable energy produced by the solar panels back to the grid.
  
  

• Sustainable Land Use: Agrivoltaics allows for dual land use, enabling the production of both food and energy without the need for additional land.
  
  

These benefits are evident in various agrivoltaic projects across Alberta, where farmers are successfully combining crop cultivation with solar energy production amid a renewable energy surge that is creating thousands of jobs.

Challenges and Considerations

While agrivoltaics presents numerous benefits, there are challenges to consider as Alberta navigates challenges with solar expansion today across Alberta:

• Initial Investment: The setup costs for agrivoltaic systems can be high, requiring significant capital investment.
  
  

• System Maintenance: Regular maintenance is essential to ensure the efficiency of both the solar panels and the agricultural operations.
  
  

• Climate Adaptability: Not all crops may thrive under the conditions created by solar panels, necessitating careful selection of suitable crops.

Addressing these challenges requires careful planning, research, and collaboration between farmers, researchers, and energy providers.

Future Prospects

The success of projects like Strathmore Solar and other agrivoltaic initiatives in Alberta indicates a promising future for this dual-use approach. As technology advances and research continues, agrivoltaics could play a pivotal role in enhancing food security, promoting sustainable farming practices, and contributing to Alberta's renewable energy goals. Ongoing projects and partnerships aim to refine agrivoltaic systems, making them more efficient and accessible to farmers across the province.

The integration of solar energy production with agriculture in Alberta is not just a trend but a transformative approach to sustainable farming. The Strathmore Solar project serves as a testament to the potential of agrivoltaics, demonstrating how innovation can lead to mutually beneficial outcomes for both the agricultural and energy sectors.

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Alberta Capacity Market Overhaul faces scrutiny over electricity costs, reliability targets, investor certainty, and AESO design, as UCP reviews NDP reforms, renewables integration, and deregulated energy-only alternatives impacting generators, ratepayers, and future power price volatility.

Key Points

A shift paying generators for capacity and energy to improve reliability; critics warn of higher electricity costs.

✅ UCP reviewing NDP plan and subsidies amid market uncertainty

✅ AESO cites reliability needs as coal retires, renewables grow

✅ Critics predict overprocurement and premature launch cost spikes

Jason Kenney's government is facing renewed pressure to cancel a massive overhaul of Alberta's power market that one player says will needlessly spike costs by hundreds of millions of dollars, amid an electricity sector in profound change today.

Nick Clark, who owns the Calgary-based electricity retailer Spot Power, has sent the Alberta government an open letter urging it to walk away from the electricity market changes proposed by the former NDP government.

"How can you encourage new industry to open up when one of their raw material costs will increase so dramatically?" Clark said. "The capacity market will add more costs to the consumer and it will be a spiral downwards."

But NDP Leader Rachel Notley, whose government ushered in the changes, said fears over dramatic cost increases are unfounded.

"There are some players within the current electricity regime who have a vested interest in maintaining the current situation," Notley said

Kenney's UCP vowed during the recent election to review the current and proposed electricity market options, as the electricity market heads for a reshuffle, with plans to report on its findings within 90 days.

The party also promised to scrap subsidies for renewable power, while ensuring "a market-based electricity system" that emphasizes competition in Alberta's electricity market for consumers.

The New Democrats had opted to scrap the current deregulated power market — in place since the Klein era — after phasing out coal-fired generation and ushering in new renewable power as part of changes in how Alberta produces and pays for electricity under their climate change strategy.

The Alberta Electric System Operator, which oversees the grid, says the province will need new sources of electricity to replace shuttered coal plants and backstop wind and solar generators, while meeting new consumer demand.

After consulting with power companies and investors, the AESO concluded in late 2016 the electricity market couldn't attract enough investment to build the needed power generation under the current model.

The AESO said at the time investors were concerned their revenues would be uncertain once new plants are running. It recommended what's known as a capacity market, which compensates power generators for having the ability to produce electricity, even when they're not producing it.

In other words, producers would collect revenue for selling electricity into the grid and, separately, for having the capacity to produce power as a backstop, ensuring the lights stay on. Power generators would use this second source of income to help cover plant construction costs.

Clark said the complex system introduces unnecessary costs, which he believes would hurt consumers in the end. He said what's preventing investment in the power market is uncertainty over how the market will be structured in the future.

"What investors need to see in this market is price certainty, regulatory ease, and where the money they're putting into the marketplace is not at risk," he said.

"They can risk their own money, but if in fact the government comes in and changes the policy as it was doing, then money stayed away from the province."

Notley said a capacity market would not increase power bills but would avoid big price swings, with protections like a consumer price cap on power bills also debated, while bringing greener sources of energy into Alberta's grid.

"Moving back to the [deregulated] energy-only market would make a lot of money for a few people, and put consumers, both industrial and residential, at great risk."

Clark disagrees, citing Enmax's recent submissions to the Alberta Utilities Commission, in which the utility argues the proposed design of the capacity market is flawed.

In its submissions to the commission, which is considering the future of Alberta's power market, Enmax says the proposed system would overestimate the amount of generation capacity the province will need in the future. It says the calculation could result in Alberta procuring too much capacity.

The City of Calgary-owned utility says this could drive up costs by anywhere from $147 million to $849 million a year. It says a more conservative calculation of future electricity demand could avoid the extra expense.

An analysis by a Calgary energy consulting firm suggests a different feature of the proposed power market overhaul could also lead to a massive spike in costs.

EDC Associates, hired by the Consumers' Coalition of Alberta, argues the proposal to launch the new system in November 2021 may be premature, because it could bring in additional supplies of electricity before they're needed.

The consultant's report, also filed with the Alberta Utilities Commission, estimates the early launch date could require customers to pay 40 per cent more for electricity amid rising electricity prices in the province — potentially an extra $1.4 billion — in 2021/22.

"The target implementation date is politically driven by the previous government," said Duane Reid-Carlson, president of EDC Associates.

Reid-Carlson recommends delaying the launch date by several years and making another tweak: reducing the proposed target for system reliability, which would scale back the amount of power generation needed to backstop renewable sources.

"You could get a result in the capacity market that would give a similar cost to consumers that the [deregulated] energy-only market design would have done otherwise," he said.

"You could have a better risk profile associated with the capacity market that would serve consumers better through lower cost, lower price volatility, and it would serve generators better by giving them better access to capital at lower costs."

The UCP government did not respond to a request for comment.

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