RE: ERO number 025-0660…

RE: ERO number 025-0660 Greenstone Transmission Line

The Northwest Energy Task Force (NW ETF) a committee of the Northwestern Ontario Municipal Association is pleased to provide the Ontario Energy Board with our knowledge and opinion on the Greenstone Transmission Line.

By way of background, the NW ETF (formerly the Common Voice Northwest Energy Task Force) has been in existence since 2003. We have evaluated the energy needs and situations in Northwestern Ontario since then. From time to time we have been intervenors in a number of Ontario Energy Board applications related to aspects of the energy supply for the region.

Specifically, we identified the lack of electrical capacity in the Greenstone area, both within the municipality and the neighbouring First Nations. We advocated both directly and through the Northwestern Ontario Municipal Association, along with the Municipality of Greenstone, for the construction of a new transmission line to serve the area.

In February 2011 NOMA raised the following issues regarding the Greenstone area in relation to the then newly released Province’s Long Term Energy (Nov 2010)

1. “Instability ,Instability, unreliability and lack of capacity in the service to the Municipality of Greenstone
2. Lack of capacity at the Longlac TS to provide for service to the mines that will be developed in and around Greenstone and the Ring of Fire
3. Lack of capacity in a zone located between the Ring of Fire/Longlac TS and the City of Thunder Bay and immediate area to support the construction and operation of a 340 MW chromite processing facility
4. Lack of inclusion in the Plan for a proposed transmission line to connect the Nipigon area with the proposed Little Jackfish generation project and a proposed 100 MW Windfarm on the eastern side of Lake Nipigon.
5. Lack of inclusion in the Plan for the construction of the Little Jackfish Generation Project
6. Lack of inclusion in the Plan for the construction of a line to supply power to the Junior Lake & Miminiska Lake mining properties north of Lake Nipigon and east of Pickle Lake”

Collectively we received no support over 14 years for the construction of a new transmission line and subsequently, the new Greenstone Gold mine chose to construct 7 gas fired generators on their property, serving their needs but not sharing power with the area. This decision was the result of the failure of two separate Ontario Governments to modify the allocation of costs policy for the construction of new transmission lines. Greenstone Gold was being forced to pay for 100% of a new line connecting to the East-West Tie bulk transmission line and it was cheaper for them to build their own gas fired generating facility.

Therefore the NW Energy Task Force welcomes and supports the recent initiative to begin serious planning for a new transmission line to serve the Greenstone area, remote communities utilizing diesel generation and future mining and economic development.

We also congratulate and thank the initiative led by Aroland First Nation along with its First Nation partners Animbiigoo Zaagi’igan Anishinaabek, Ginoogaming First Nation, Biinjitiwaabik Zaaging Anishinaabek, Bingwi Neyaashi Anishinaabek, Long Lake #58 First Nation and Red Rock Indian Band on their leadership in this matter.

The following are the key aspects of our input into this process:

A) We strongly support an Order in Council that would, “subject to fulfillment of applicable consultation obligations, including Duty to Consult and receiving required approvals, declare the following transmission project, recommended to be in-service by 2032, to be a priority project under s. 96.1 (1) of the Ontario Energy Board Act, 1998 (OEBA)”:

B) We also strongly support the Government of Ontario proposal, “to direct the OEB, pursuant to s. 28.6.1 of the OEBA, to amend Hydro One’s transmitter licence, as the First Nation consortium’s identified preferred transmitter, to require it to undertake development work and seek all necessary approvals to construct the transmission project listed above.”

C) The first phase of the line should be constructed up to the Aroland First Nation and Nakina area as well as being relatively parallel to the existing highway 11 and the existing radial transmission line.

This is important because all of the involved area is poised for growth as a result of the opening of Greenstone Gold and the impending development of other mines.

D) While we recognize that the plan calls for a transmission line with the capacity for two circuits, only one will be initially installed. It is the view of the NW Energy Task Force that it will be more efficient and cost effective to install both circuits during the initial construction period. Such an approach is consistent with the Ontario Government’s policy of accelerating development towards the expansion of industrial activity throughout the north and the removal of any barriers that may delay development. It will also cost less in today’s dollars than the inflated cost in the future including the mobilization costs etc.

We have been advised by the IESO with regards to the preliminary analysis of the North of Dryden Addendum study that the cost to add a second circuit after the initial construction will double the cost of the installation.

E) It is essential that major transformer facilities be located at key junctions along the new line. This will include Geraldton, Beardmore and Nakina. This approach will facilitate and speed the development of mines and community growth along the new transmission line. It will also facilitate the connection to the potential Little Jackfish Hydro-electric generation dam.

It is essential that every effort be made to expedite the planning and development of the strategically important line, which under normal circumstances takes between 5 and 7 years. Specifically, we will be requesting that the following steps be undertaken by the responsible entity.

A) Exempt the line from the Leave to Construct requirements.

B) Assigning the line to the Ontario Class Environmental Assessment process, which according to the Energy for Generations Integrated Plan, will reduce the time required by one to two years.