Commentary for ERO …

Commentary for ERO (Environmental Registry of Ontario) number 013-3800
Amendments to the Renewable Energy Approvals Regulation
(Ontario Regulation 359/09)

November 5, 2018

Issue 1. There has never been a business case analysis for renewable energy projects.

Ontario’s former Auditor-General, Jim McCarter, and the current Auditor-General, Bonnie Lysyk, have pointed pointed this out since Mr. McCarter’s 2011 annual report.

In his 2011 annual report, Mr. McCarter stated:

“Because the ministerial directions were quite specific about what was to be done, both the Ministry and the OPA directed their energies to implementing the Minister’s requested actions as quickly as possible. As a result, no comprehensive business-case evaluation was done to objectively evaluate the impacts of the billion-dollar commitment. Such an evaluation would typically include assessing the prospective economic and environmental effects of such a massive investment in renewable energy on future electricity prices, direct and indirect job creation or losses, greenhouse gas emissions, and other variables.”

In her 2015 report, Ms. Lysyk stated:

“Compared to other types of energy resources, renewables like wind and solar tend to contribute less than their installed capacity during peak- demand periods; wind and solar energy are not always reliable because wind and sunshine are intermittent by nature.”

The intermittent nature of wind and solar, and their inability to deliver any substantive quantity of electricity during peak demand is evident in the Independent Electricity System Operator’s (IESO) current 18 month forecast[1] covering the period from October 2018 to March 2020. The IESO has forecasted wind’s availability at only 14% of installed capacity, and solar at 10% of installed capacity, during peak demand periods.

Reference [1]. http://www.ieso.ca/en/Sector-Participants/IESO-News/2018/09/IESO-releas…

Recommendation 1:
Any review and amendments to the Renewable Energy Approvals process should include a requirement for project proponents to provide a detailed, and audited, life-cycle financial analysis.

The financial analysis should take into consideration the capability to deliver electricity during peak demand periods, and any financial implications for producing electricity out-of-phase with demand.; i.e. cost of backup generation, etc.

Recommendation 2:
The IESO should have full discretion to make the most financially responsible decisions in sourcing electricity from any generator.

Issue 2: No full life-cycle environment analysis for renewable energy projects.

There has been growing interest in electricity storage projects in Ontario and other parts of the world.

One type of storage project in particular that should have careful scrutiny is lithium-ion battery storage due to the impact of the extraction and refinement of the raw materials used in the manufacture of these batteries.

The design of lithium-ion batteries, currently in use for electric vehicles and in large scale energy storage, require metals such as lithium, cobalt, and nickel, as well as the mineral graphite, an allotropic form of carbon. The major source for these materials are in countries like Australia and Chile for lithium; China and India for graphite; and the Congo, New Caledonia and China for cobalt. [2]

Reference [2]. Ben McLellan, Honorary Senior Research Fellow, Kyoto University
Politically charged: do you know where your batteries come from?
http://theconversation.com/politically-charged-do-you-know-where-your-b…

The mining, refining, manufacture and disposal of the currently available lithium-ion batteries carries significant environmental costs and risks.

The Arthur D. Little (ADL) consulting firm published a report[3] comparing the full life-cycle environmental impact of battery engine electric vehicles (BEV) versus internal combustion engine vehicles (ICEV).

Reference [3]. John W. Brennan, Timothy E. Barder, Ph.D. Arthur D. Little
Battery Electric Vehicles vs. Internal Combustion Engine Vehicles
http://www.adlittle.com.tr/sites/default/files/viewpoints/ADL_BEVs_vs_I…

The ADL consulting group found that a reduction in greenhouse gas emission from BED vehicles over ICEV vehicles (between 19% to 23% depending on the size of the vehicle) comes at a cost of increased toxicity and adverse health effects as a “secondary environmental impact:

From the ADL executive summary:

“Secondary Environmental Impacts – BEVs generate a host of secondary environmental impacts greater than those of ICEVs. A 2015 BEV generates enough toxicity over a vehicle’s lifetime to cause an impact to human life equivalent to 20 days of life lost to death or disability,[*] whereas a 2015 ICEV generates enough toxicity to impact the average human life by only 6 days. The differential in secondary environmental impacts will widen for new vehicles in 2025, with BEVs producing even higher levels of human toxicity potential.

[*] The authors’ describe human life equivalent as: “Measured in disability adjusted life years (DALYs), a comprehensive metric defined by the National Institutes of Health as “the total number of years lost to illness, disability, or premature death within a given population.”

The ADL report includes the following comments:

“Once the types of pollution generated by the US power grid are taken into account (e.g. tailings from coal power plants), BEVs generate twice as much human toxicity potential for the In-Use portion of a vehicle’s environmental lifecycle compared to the In-Use portion of an ICEV (see Figure 18).”

“The In-Use portion of ICEV lifecycle accounted for 34.5% of the human toxicity generated by the vehicle, while the In-Use portion of BEV lifecycle only accounted for 19% of the human health impact caused by the vehicle. The largest portion of impact for the BEV came from manufacturing, accounting for 44% to 45% (depending on the type of battery used) of the vehicle’s total human toxicity impact, with the battery replacement accounting for an additional 30% to 31%.”

“Across all of the other secondary environmental impacts ADL measured – except for FFDP (fossil fuel depletion potential, i.e. the impact of using fossil fuels) – the BEV performed similarly or worse than the ICEV. BEVs generated more than twice as much freshwater toxicity potential and BEVs were responsible for nearly twice as much mineral depletion, owing to the use of heavy metals in the manufacturing process for BEVs (see Appendix D for greater detail). Nonetheless, neither BEV manufacturing nor ICEV manufacturing poses a threat to the global supply of mineral resources.”

“All other secondary environmental measures pale in comparison with the potential impact BEVs have on human health. Because human toxicity potential is distributed differently across a vehicle’s lifetime, the decision to drive a BEV instead of an ICEV essentially shifts the damage to human life caused by car ownership, from a relatively small impact more localized to the vehicle in the case of an ICEV, to a relatively large impact localized to the mineral mine tailings in the case of a BEV. For the American driver, the decision becomes a trade-off between generating small amounts of pollution in one’s local community (or driving region) versus generating comparatively large amounts of pollution in regions where mining and manufacturing occur.”

Recommendation 3: All energy project proponents should be required to submit a full life-cycle environmental analysis including impact on the natural environment, endangered and species at risk, human health, and social impacts. This analysis should include the sourcing of raw materials, manufacturing, operations and decommissioning of the proposed project. This analysis should not be limited to impacts in Ontario and Canada, but should include all jurisdictions where raw materials are sourced and refined, and where components are manufactured.