Comments on the IESO…

Comments on the IESO Pathways to Decarbonization Report
In response to the questions raised in the IESO Pathways to Decarbonization, I propose that answering them in reverse order would be the best way to highlight my comments as they stem from the same concerns. The root concern is the lack of integrated planning of electrical and thermal infrastructures and the lack of awareness of how integrated thermal infrastructure could accelerate decarbonization of the electricity system in a more adaptable and resilient way and at a lower societal cost.
8. Do you have any additional feedback on the IESO’s “no-regret” recommendations?

The “no regret” recommendation does not deal with the largest product of thermal electric, including nuclear, generation – that being heat. Modest design changes could make the heat useful for space heating through existing and future thermal energy networks more commonly known as district heating systems. A powerful “no regret” policy would be that all new thermal electric generation, including nuclear, be capable of operating in a CHP (combined heat and power or cogeneration) mode. In most instances this would mean that steam turbines be designed and manufactured with extraction ports that could produce useful heat. In addition, space would be allocated in generating stations to add connecting piping and heat exchangers for the provision of useful heat when the station is not operating in an all electricity output or full condensing mode. The connecting piping need not be installed right away, but could be added when heating loads materialize. The additional cost would be marginal and no more than about 5%. Since the heat product power output would be at least equal to the electric product, the impact on overall energy availability would be significant. For instance, heat rejected from the Pickering Nuclear Generating Station (PNGS) is about equal to the heat demand of the Greater Toronto Area (GTA) and there has been a feasibility study to verify this in 1995.

There are over 40 nuclear CHP generating stations coupled with district heating systems around the world.

7. The IESO’s Pathways Study suggest that significant transmission capacity will be needed to help balance intermittent sources of electricity (e.g., wind and solar) and to ensure cost-effective supply can be delivered to meet growing demands from electrification and economic growth.
A major driver of the requirement for increased transmission capacity is the expectation of urban heating adopting electrification through air source heat pumps (ASHPs) to displace gas space heating in buildings. ASHPs have a COP (coefficient of performance) of about 1 during cold winter weather. If non-electric sources are adapted, particularly but not limited to, nuclear CHP plants, much of this increase could be significantly reduced or eliminated. Energy conservation measures in buildings at cost effective levels of demand reduction could further improve this as well as other non GHG emitting sources within urban areas.
Toronto Hydro suggested that an upgrade to transmission and distribution would cost in the order of $2000/kW. That would be as much as $12 billion. This could be avoided by a district heating network to supply the GTA heating load. The lesson is similar for other urban areas if future nuclear SMRs or MMRs are distributed near urban centres.
Importantly, the cost of urban district heating is similar to that for transmission and distribution system upgrades and so the cost would be similar but the cost of new generation could be avoided. At $8 million a MW of installed capacity, the avoided cost just to electrify GTA heating would be in the order of $48 billion.
7. The IESO’s Pathways Study includes a scenario for over 650 MW of new large hydroelectric capacity to meet system needs in 2050.
A recently released assessment estimates that there may be potential to develop 3,000 to 4,000 megawatts of new hydroelectric generation capacity in northern Ontario and 1,000 megawatts in southern Ontario.
What are your thoughts on the potential for development of new hydroelectric generation in Ontario by private-, Indigenous- and government-owned developers?
While the capital costs for hydroelectric generation may be higher than nuclear, wind, solar, and natural gas, do you support investing in large scale hydroelectric assets that may operate for over a hundred years?
Space heating has many options of which district heating would allow the use of many other non GHG emitting or renewable sources of thermal energy. Using such sources and avoiding electricity based heating (other than ground source heat pumps where building sites permit) electricity load could be significantly reduced and the hydro capacity, its cost and impact on the land could be avoided. More detailed analysis would confirm this.
6. The IESO’s Pathways Study recommends greater investment in new non-emitting supply, including energy efficiency programs.
Following the end of the current 2021-2024 energy efficiency framework how could energy efficiency programs be enhanced to help meet electricity system needs and how should this programming be targeted to better address changing system needs as Ontario’s demand forecast and electrification levels grow?
Aggressive efficiency programs are the foundation of any decarbonization approach. However, the cost of really deep retrofit to buildings can be very expensive. The largest efficiency measure available to the electricity sector is the conversion of thermal electric generation (including nuclear) where all currently rejected cooling water could be rejected at a higher temperature and used for space heating through district heating systems. Thus, making heat useful from thermal electric plants is the largest efficiency option available to IESO and would be at a much lower cost as noted under 7 above.
5. The IESO’s Pathways Study recommends that for a zero-emissions grid by 2050, investment and innovation in hydrogen (or other low-carbon fuels) capacity could be required to replace the flexibility that natural gas currently provides the electricity system.
Do you have any comments or concerns regarding the development and adoption of hydrogen or other low-carbon fuels for use in electricity generation? What are your thoughts on balancing the need for investments in these emerging technologies and potential cost increases for electricity consumers?
Innovation in hydrogen or other low carbon fuels is speculative and expensive. Renewable natural gas might only amount to about 5% of current natural gas supplies and hence is not a major option. However, Nuclear CHP plants could be designed to supply heat as well as power with minor modifications and would be capable of supplying both heat and electricity or electricity only. In such an arrangement, large thermal energy storage (TES) could store heat so that if full electricity production is required, then heat loads could be met from stored heat. This way, instead of using natural gas turbines (even with new fuels), nuclear or other thermal electric plants could switch to full electric production in times of peak load.
Furthermore large TES units could be used to receive surplus wind or solar (or any surplus) power and store it as heat. TES is, at large scale, about 1/200th of the cost of batteries, does not have the site requirements for pumped storage and it can be located so as to minimize both thermal and electricity transmission lines.
4. The IESO’s Pathways Study highlights emerging investment needs in new electricity infrastructure due to increasing electricity demand over the outlook of the study. The IESO pathway assessment illustrates a system designed to meet projected demand peaks almost three times the size of today by 2050, at an estimated capital cost of $375 billion to $425 billion, in addition to the current system and committed procurements. Please see supporting materials for illustrative charts on capacity factor and cost by resource type.
Are you concerned with potential cost impacts associated with the investments needed? Do you have any specific ideas on how to reduce costs of new clean electricity infrastructure?
I am very concerned about the impact of the requirement for new zero GHG electricity infrastructure (generation and distribution) because it might be largely avoided. The recent OSPE study suggests that peak demand may increase to double or triple current peak demand largely due to electrification of heating buildings. In urban areas, district heating using, where possible, heat from new or refurbished CHP units would largely eliminate the need for expanded electricity capacity. The focus could be on the refurbishing of existing units and the design of replacement generation as CHP generators. This requires the integrated planning, design and operation of thermal and electricity grids and the progressive transformation of natural gas infrastructure to thermal distribution infrastructure. All using existing and well demonstrated technology and creating new business opportunities for a transformed natural gas industry. Such a strategy would greatly reduce the expenditures proposed above; technically and economically feasible only requiring new integrated thinking and planning.
3. The IESO’s Pathways Study shows that natural gas-fired generation will need to continue to play an important role in the system for reliability in the short to medium term. The IESO’s assessment shows that most of the projected Ontario demand in 2035 can be met with the build out of non-emitting sources, but some natural gas will still be required to address local needs and provide the services necessary to operate the system reliably.
Do you believe additional investment in clean energy resources should be made in the short term to reduce the energy production of natural gas plants, even if this will increase costs to the electricity system and ratepayers? What are your expectations for the total cost of energy to customers (i.e., electricity and other fuels) as a result of electrification and fuel switching?
If a strategy of electrification and fuel switching is adhered to, electricity rates can be expected to increase. The OSPE report suggests that the increase could be as much as triple the current electricity rates. By avoiding electrification and adopting district heating and thermal energy storage, the above costs could be largely avoided and the use of natural gas peaking plants largely avoided. Furthermore, the generation of revenue from heat from nuclear and other CHP plants could help reduce rather than increase costs.
2. The IESO’s Pathways Study recommends beginning work on planning and siting for new resources like new long-lived energy storage (e.g., pump storage), nuclear generation and waterpower facilities.
What are your expectations for early engagement and public or Indigenous consultations regarding the planning and siting of new generation and storage facilities?
Before doing any of the above, start doing the integrated planning of thermal, electricity and natural gas systems. The potential to avoid significant disruption and expense is real and there are integrated options available as noted in answers to the previous (reverse order) questions.
1. The IESO’s Pathways Study recommends streamlining regulatory, approval and permitting processes, citing that it can take five to 10 years to site new clean generation and transmission infrastructure.
What are your thoughts on the appropriate regulatory requirements to achieve accelerated infrastructure buildout? Do you have specific ideas on how to streamline these processes?
By focusing on the integrated planning, design and operation of electricity generation and the requirement that all thermal electric generation by CHP and the creation of district heating networks, the requirement for new generation and transmission/distribution system infrastructure would be largely reduced or, in some instances, eliminated. Furthermore, if the public saw that IESO was determined to increase generation efficiency, more rapidly reduce GHGs and lower the costs of electricity service, public and political support would be strong and the planning and permitting would become much simpler and the public more supportive.
Recommendations:
1. Integrate the planning, design, and operation of all energy utilities – electricity, thermal and natural gas - to develop integrated solutions that are more efficient and less costly.
2. Conduct integrated think tanks and do the necessary studies to confirm the above.
3. Make all new or refurbished thermal electric power generation as CHP units that are “retrofit ready” and can operate as electric only until thermal loads are assembled and connected.
4. IESO should acknowledge and advocate the above new approach to integrated systems and commit to working with the other utilities in an integrated fashion.
5. Encourage or support the gas utilities to transform, at least in urban areas, to thermal/district heating utilities or to cooperate with communities to create thermal infrastructure.
6. Support the planning design and construction of strategically located and sized thermal energy storage units to minimize thermal and electric peaks.
7. Given the characteristics of new SMRs and MMRs, encourage the siting of new generation that is closer to electricity and thermal loads to make more efficient and less costly energy infrastructure.
8. For refurbished or new CHP units, initially charge for heat a rate that will offset losses in electricity output. This low cost of production of thermal energy (about 1/6 to 1/14 the cost of electricity production) would allow for the construction of district heating and thermal energy storage infrastructure. Once thermal energy infrastructure is established, new higher rates can be negotiated so that revenues to generators increases and there is the possibility of lowering electricity rates.
Closing remark:
Don’t believe me! Assemble a team of suitable experts and verify. You will be very pleasantly surprised.