We want to thank the…

We want to thank the Ministry for affording Hydrostor the opportunity to submit feedback. Hydrostor has a number of comments; we have split them into comments that are related to general Compressed Air Energy Storage (CAES) feedback and comments specific to the proposed changes. They are split separately in this document for clarity.

General Items

The following are some general CAES storage comments with regards to provincial regulation.

1.The proposed legislation covers CAES in salt caverns and porous formations accessed via a well. Hydrostor has developed technology using hard rock mines that would remain in a position of regulatory uncertainty following the proposed updates coming into effect. Hydrostor believes there is a strong likelihood that the next significant CAES project proposed in Ontario will be proposed in a hard rock mine, resulting in a repeated review process. 2.The proposed legislation (rightly) does not define the required environmental assessment process. Hydrostor is taking this opportunity to provide the Province with feedback regarding the EA process. Any potential project that triggers an EA could force CAES into an individual EA. Due to the pace of change in the energy storage industry, an individual EA would result in very challenging project economics and could kill the investment on CAES projects in Ontario. It is Hydrostor’s opinion that the Province of Ontario should work with relevant stakeholders to establish a class EA process for CAES projects. Hydrostor would be a willing participant in the process. 3.Hydrostor would prefer to see specific timing for MNRF to respond to technical submissions.

Specific Items

The following are some comments specific to the proposed regulatory changes:

4.The proposed regulation limits MNRF’s responsibility at the “top” of the Emergency Shut-Down Valve (ESDV). Hydrostor agrees with this demarcation point between MNRF and other bodies (TSSA). In the judgment of Hydrostor’s engineers, the ESDV must be capable of receiving signal from the SCADA system for the entire plant (portions beyond the current demarcation point) in order to safely isolate the well from certain potential plant-side emergencies. Hydrostor would like to see language that permits proponents to provide this information without requiring them to supply the entire plant’s P&ID. This would put intellectual property at risk to FIPPA exposure and would therefore limit the information the proponent might be willing to provide to the MNRF, making it more challenging for MNRF’s technical reviewers to confirm all of an ESDV’s functionality. 5.Generally around the discussion of intellectual property, Hydrostor believes the MNRF should include specific language that allows a proponent to designate certain documents for submission as protected from FIPPA release. This is for issues of public safety (certain elements in a large CAES facility could be targeted for terrorism) and intellectual property protection to maintain Ontario’s lead in CAES technology. 6.The examiner requirement is presently listed as a Class IV hydrocarbon examiner. Hydrostor would prefer to see a Class III examiner, consistent with solution mining as the requirement. Functionally, these projects in salt formations are very similar to a solution mine with an air pad. 7.Under section 19 of 245/97 there is a requirement for plugging a well within 12 months after it is taken out of use. Hydrostor would like there to be language that permits a well to stay open if a proposed CAES project is under consideration for the well and/or language that distinctly permits the re-opening of a previously plugged well for future CAES operation, subject to appropriate testing and technical review. 8.It is understood that there is intent to use CSA Z341 as a guidance document/standard. Hydrostor believes that each CAES project is somewhat unique and the proponent should be permitted to supply a determination of which elements of CSA Z341 are applicable to the project, provided a person qualified to make the determination has signed off on the proposal. 9.The proposed notification requirements require a fixed radius (750 m of any proposed well and also from the boundary of the storage cavern when projected on the surface. Hydrostor believes this number to be arbitrary – some ground conditions may justify a larger radius, and some may justify a smaller radius. We would prefer to see the notification radius set as 750 m or some other distance that is determined to be appropriate by a qualified person examining the geomechanical risks of the local ground conditions. 10.Hydrostor believes the proposed 90 day consultation period to be too long. 60 days is more appropriate with maintaining effective project timelines while still affording public the opportunity to provide input. 11.The operating standards refer to the “corrosive nature of compressed air”. Hydrostor agrees that corrosion prevention and planning appropriate to the proposed working fluid should be conducted, but explicitly calling out compressed air storage as corrosive in nature is inappropriate and may be used by individuals or parties wishing to compromise a project in the public’s eye.

[Original Comment ID: 211394]