When Can Bitcoin Mining Count as Circular Energy Policy?

Industrial symbiosis already examines interfirm resource exchange, coordination and the conditions under which exchanges develop. Chertow (2007, 12–15) distinguishes bilateral precursors from a fuller network under her stated heuristic, treats contracts as one route to resource security, and identifies operational, financial and behavioural barriers across organizations. A mine selling heat to one recipient need not satisfy every definition of industrial symbiosis. More fundamentally, the physical existence of an exchange does not establish its environmental value. Calling a project circular should leave those distinctions visible.

Demand-response evaluation already separates the quantity used to settle a participant’s payment from programme impact and planning estimates. Goldberg and Agnew (2013, 4–15, 41–47, 56–59) explain why baselines, operating rules and the purpose of evaluation shape the result. This paper inherits that separation. It adds no new measurement theory by requiring a baseline or refusing to infer system benefit from a payment.

The present comparison instead connects these existing problems to admission, competing operating commitments and exit for the same load. A provincial instrument can make a mine interruptible without identifying the recipient who loses heat during interruption. A heat contract can make delivery valuable to that recipient while leaving connection or backup exposure with another party. Whether the obligations fit together is a different question from whether each arrangement is individually intelligible. It requires following the rights to call, refuse, substitute and terminate across the actual parties.

A stipulated winter interruption makes the distinction concrete. Assume a mine exports useful heat, the grid operator exercises a valid curtailment right, and the recipient needs heat throughout the event. Curtailment can meet the grid contract while causing a shortfall under the heat relationship. Storage, backup or replacement supply may preserve the recipient’s service; their capacity, cost and emissions then belong in the comparison. Another arrangement might give heat priority and therefore offer less firm electrical flexibility. These are alternative allocations of a conflicting commitment, rather than two benefits that can be added at their full standalone values.

Ordinary industrial contracts and demand-response programmes may already allocate these exposures successfully. That is the strongest rival account and a possible favourable finding. Public admission and tariff decisions enter that allocation alongside private contracts. Following them together identifies where an asserted benefit still lacks a recipient, operative duty or party bearing exit costs. Computing need not create a novel kind of interdependence for those assignments to require examination.

A generation mix describes supply over a period. It cannot identify the resources responding to an additional facility at each operating hour. A new load can induce generation, alter imports or exports, require network capacity or displace another prospective user. The assessment therefore needs an explicit alternative: no connection, another use of the capacity, or the same computational service supplied elsewhere. Each answers a different policy question.

A low annual grid intensity can provide useful context without proving that incremental demand is consequence-free. Conversely, a high historical average cannot be assigned to every future operating hour. Project emissions need a declared temporal model and assumptions about system response. Contractual renewable procurement should be reported separately from the physical effects attributed to it.

This distinction also changes the assessment of flexibility. Reducing an existing load during scarcity can help the system. Adding a load and paying it to cease consuming does not automatically improve the system relative to never adding it. A project can still create economic or operational value, but the no-project comparison belongs alongside the within-project dispatch comparison.

Technical interruptibility becomes a service when another party can call on a specified reduction and evaluate delivery. The relevant arrangement defines the baseline, nominated capacity, notice, duration, telemetry, performance measurement, settlement and consequences of failure. Price-responsive shutdown can also affect system demand; it is a different arrangement from an operator’s contractual dispatch right.

Event records should show nominated and delivered reductions, response time, availability, duration, rebound and failures. A tariff can establish the right to demand performance without establishing that performance occurred. Payments likewise establish a financial transfer rather than its net reliability value.

Heat recovery requires a recipient with a use for heat of the available temperature, timing and location. Rack-level capture, heat exported from a facility and useful heat accepted by a recipient have different boundaries. A percentage called heat-recovery efficiency is uninterpretable until its numerator, denominator and boundary are stated.

The comparison should identify the heat source displaced and include network losses, heat-pump and pumping electricity, backup and seasonal rejection. Recovered computing heat may replace a fossil-fuel boiler, a heat pump or no existing supply at all. Those alternatives produce different energy and emissions results. A delivered-heat ledger can establish a bounded reuse contribution without establishing a whole-system environmental benefit.

The heat ledger must also account for the interruption conflict described above. Backup supply, storage, notification and contractual priority determine whether electrical flexibility creates costs in the heat system. Counting curtailed electricity and displaced heating separately without coordinating those boundaries risks overstating the combined benefit.

A heat network or interconnection can outlive a mining operation. The institutional question extends to asset ownership, maintenance, replacement heat, decommissioning and stranded costs. A durable agreement should specify who measures delivery, who may interrupt it and who pays when the relationship ends. These assignments connect a facility’s mobile equipment to the longer commitments of its public and private counterparties.

The approved 2026 Electricity Rates define Rate CB for covered annual contracts with at least 50 kW of installed capacity dedicated to cryptographic use applied to blockchains. Under the Hydro-Québec-customer provisions, supply is non-firm. Article 7.9 permits reduction to 5% of the highest real power demand recorded during the relevant rolling twelve monthly periods for up to 300 hours in a rate year, with two hours' notice; consumption above the limit during curtailment is billed at $1.038/kWh. The separate municipal-system provisions have their own terms (Hydro-Québec 2026a, ch. 7, arts. 7.1, 7.9, 7.13).

These provisions allocate a dispatch right and a financial consequence. They provide a concrete institutional basis for evaluating flexibility, while supplying no event-performance result. Such a result would need calls, baselines, delivered reductions, exceptions and rebound. A non-firm connection also requires a heat recipient to plan for interruption if that facility supplies heat.

The proposed price reset occupies a different evidentiary category. Hydro-Québec’s February release announced an average 19.5-cent/kWh proposal. The October capture of docket R-4333-2026 lists procedural decisions, revised proposed text and hearing transcripts through 9 October, rather than a listed final merits approval. The June 29 English tariff exhibit remains a proposal. Neither a requested November commencement nor a hearing establishes an approved replacement rate (Hydro-Québec 2026b; Hydro-Québec Distribution 2026; Régie de l’énergie 2026a, 2026b).

The relevant object is consequently the combination of an existing service obligation and a pending redesign. The captured docket supports that bounded statement, without guaranteeing that no subsequent filing or decision exists elsewhere.

Section 21.1 of the Utilities Commission Act authorizes regulations governing cryptocurrency electricity service. The Cryptocurrency Power Regulation, last amended 20 October 2025 in the captured consolidation, prohibits the authority, BC Hydro, supplying service to defined new projects (British Columbia 2024, 2025).

A new high-voltage project would receive supply at 60 kV or higher and lacked the specified facilities-study agreement before 28 December 2022. The two low-voltage categories concern requests of at least 2.5 MW at 12.5 kV or 5 MW at 25 kV without the earlier design deposit. The rule also addresses specified preliminary service steps and agreements. Its thresholds and grandfathering boundaries matter to who is excluded.

This instrument allocates access to electricity before a project can demonstrate an ongoing service relationship. It establishes no universal prohibition on existing, smaller or off-grid activity and no finding about every facility’s environmental performance. Whether it changes total mining load, moves projects elsewhere or preserves capacity for more valuable uses requires facility and connection evidence beyond the regulation.

The AUC’s power-plant guidance states that all new power plants, including those serving cryptocurrency mining, require approval from 25 April 2022, with requirements varying by capacity. On-site generation therefore needs its own approval analysis (Alberta Utilities Commission n.d.).

AESO’s June 2026 guide expressly includes digital-asset mining in its data-centre scope. It says the operator reviews transmission-connected facilities regardless of size to determine applicable requirements and mitigations. Applicable ISO rules, reliability standards and project-specific functional specifications take precedence over conflicting guidance. The guide addresses the operation of a connected load rather than certifying its circularity (Alberta Electric System Operator 2026, 1–4).

The updated large-load page adds an important allocation boundary. AESO reports Phase 1 complete and 1,200 MW of interim connection capacity allocated to executed load contracts: 970 MW for GLDC and 230 MW for Keephills Phase I. It places other requests in Phase 2 and describes work on a longer-term framework. These are reported contractual allocations, without proof of energized load, mining activity or delivered grid service at either project. AESO separately warns that staged energization dates are outside dates rather than firm expected in-service dates (Alberta Electric System Operator n.d.-a, n.d.-b).

The comparison therefore cannot describe Alberta as simply open or unregulated. Nor can an examination of these selected official materials establish the absence of every other restriction. It identifies general approvals, technical requirements and an evolving capacity-allocation process.

The CER page retrieved in October still reports Alberta’s 2022 annual electricity-generation intensity of 470 g CO₂e/kWh, preceding the June 2024 coal phase-out. The new response is byte-identical to the recovered July capture. Retrieval freshness does not change the measurement year or make that figure a marginal factor for a new mine (Canada Energy Regulator 2026).

Section 4 of the Requests for Service Regulation, M.R. 68/2025, directs Manitoba Hydro to deny a service request where the proposed power use is directly or indirectly related to cryptocurrency mining. It came into force on 1 September 2025. The October capture retains that rule; the earlier temporary pause cannot substitute for it (Manitoba 2025).

Two Acts assented on 1 June 2026 describe possible alternatives. Chapter 17 would authorize a cryptocurrency curtailable-power programme, subject to Lieutenant Governor in Council approval. Chapter 32 would establish customer-class and intensive-use levy provisions. The captured Hydro Act consolidation, current to 15 October, lists chapter 17 and Part 1 of chapter 32 as not yet proclaimed. The separate Tax Administration consolidation, also current to 15 October, lists chapter 32 Part 2, which contains the levy, as not yet proclaimed (Manitoba 2026a–d).

Royal assent makes each an enacted statute; it does not activate provisions expressly dependent on proclamation. A possible future programme also requires the further approvals and terms specified by the statute. The present documentary comparison therefore rests on the denial rule, while treating curtailment and levy provisions as uncommenced institutional possibilities.