Comment ID: 210823 Otter…

Comment ID: 210823

Otter Creek wind project, EB 013-1043 August 21, 2017 IS THERE JUSTIFICATION FOR THE OTTER CREEK WIND PROJECT? On July 7, 2016, the Approvals Branch of the MOECC started the process of a technical review and public comment period because they've decided that the REA application documents can be “deemed complete”. Any technical evaluation and public comment period that does not include a review of the Ontario electricity requirements and a cost/benefit analysis for the Otter Creek project is incomplete. Ontario has what Minister Thibeault has publicly described as a “robust” electricity generating capacity for the next 10 years. To rephrase Minister Thibeault comments more clearly, Ontario has a significant surplus of electricity generation and will have a surplus for at least the next 10 years. Three recent reports illustrate the impact of this surplus on the province's electricity sector. 1. COUNCIL FOR CLEAN AND RELIABLE ENERGY REPORT The recent report by the non-profit Council for Clean and Reliable Energy [1] emphasizes that the province's ongoing commitment to approving and deploying wind projects has had, and will continue to have, a negative impact on our electricity sector, and recommends that the province reconsider this commitment. The report's summary states: “The characteristics of intermittent wind generation are very different from the patterns of electricity demand. With most of Ontario’s wind farms in southwestern Ontario, only 11 per cent of wind generation output is available at the Quebec border. The existing interties are already capable of handling up to six times more intermittent wind energy than in 2015. The reason more wind-based transactions do not happen, despite available intertie capacity, is evident from the price signals: there is already so much intermittent wind generation in the Great Lakes region that demand is over supplied, prices are collapsing and generation must be curtailed. The province should reconsider its 2013 commitment to ongoing deployment of wind resources as these challenges will increase if Ontario proceeds to double wind capacity to the projected ~6,500 MW.” [1] http://www.thinkingpower.ca/commentary.cfm 2. ONTARIO SOCIETY OF PROFESSIONAL ENGINEERS REPORT The March, 2017 report Ontario Society of Professional Engineers (OSPE), titled: “Ontario's Energy Dilemma, Reducing Emissions at an Affordable Cost” [2] has used the IESO data to calculate the amount of electricity curtailment in 2016. The OSPE study shows that, in 2016, the province curtailed 4.7 Terawatt-hours of hydroelectric power, an increase of 48% over 2015. The report also shows the the province curtailed 2.2 Terawatt-hours of wind power in 2016, an increase of 214% over 2015. [2] https://www.ospe.on.ca/public/documents/presentations/Ontario_Energy_Dilemma_Mar_2017.pdf Since the wind project developers are still paid for their curtailed power, at a slightly lower price from the contract price, the wind developers were paid over $250,000,000, directly out of our pockets, to not produce power that was not needed in 2016. 3. THE 2017 CURTAILMENT DATA The entire output from the Otter Creek project in one year, assuming an operating capacity of 35% of nameplate, would be about 153,000 MWh. A recent review of 2017 curtailment data from the Independent Electricity System Operator's (IESO) public database was undertaken by industry analyst Scott Luft. [3] [3] https://morecoldair.wordpress.com/2017/05/24/8-ignominious-ontario-electricity-records/ According to Mr. Luft's analysis of the IESO data, four of the first 20 weeks in 2017, (weeks 14, 15, 18 and 20), EACH had more electricity curtailment than the Otter Creek wind project can produce in an ENTIRE YEAR. SUMMARY COMMENTS Ontario curtailed 4.7 Terawatt-hours of electricity generation, which includes 2.2 Terawatt-hours (2,200,000 MWh) of that curtailed wind generation, in 2016. Under the current contract conditions, the wind generators were paid about $250,000,000 not to produce those 2.2 Terawatt-hours of electricity that were not needed. During the first 20 weeks of 2017, there have been 4 weeks where the IESO curtailed more electricity than the Otter Creek project can produce in an ENTIRE year. The Otter Creek generating capacity is not required at this time. It's output would be completely superfluous to the province's requirements for several more years. The Otter Creek project would have a negative impact on the financial health of the electricity sector by adding to the amount of wind generation that requires curtailment; or by increasing the surplus electricity exported to other jurisdictions at a significant loss. The Otter Creek proponents' desire for profit, convenience and expediency should not preclude a decision that is in the best interests of the public. RECOMMENDATION: Defer any REA approval for Otter Creek until such time that a proper technical evaluation and a full cost/benefit have been completed; and, this project's generating capacity is actually required.