BCSEA comments on BC Hydro's Integrated Resource Planning
For the benefit of members
BCSEA Policy Advisory
BC Hydro’s Integrated Electricity Plan open houses & invitation for public input
BCSEA encourages its members to attend BC Hydro's open houses on its Integrated Resource Plan. The IRP is being developed now, to be delivered to government this November or early December. It will set the course for BC Hydro's resource acquisition plans over the next 20 years (subject to periodic updates). Important issues that will be addressed in this plan:
· How much energy conservation should Hydro plan for, and how many generation resources should it acquire?
· Should BC Hydro build the Site C dam?
· How much should BC Hydro plan for and/or encourage electrification, particularly the switching of motor vehicles to electricity or the switching from fossil fuel heating to electric heat pumps for buildings?
· Should BC build generation for export?
· What new transmission lines should BC Hydro build in the next 30 years?
Dates and locations of BC Hydro open houses on the IRP:
· Victoria: Wednesday, March 9
· Campbell River: Thursday, March 10
· Vancouver, Tuesday, March 15
· Abbotsford: Wednesday, March 16
· Kamloops: Thursday, March 17
· Terrace: Tuesday, March 22
· Prince George: Wednesday, March 23
· Fort St. John: Thursday, March 24
· Vernon: Tuesday, March 29
· Castlegar: Wednesday, March 30
· Fort Nelson: Thursday, March 31
· Cranbrook: Thursday, April 7
For more information, see: bchydro.com/irp
Discussion of the questions that BC Hydro poses in the workbook for the open house sessions (needs to be read with the BC Hydro materials):
1. Energy conservation (a.k.a. demand-side management, or DSM):
BC Hydro question: “Please indicate your level of agreement with this greater conservation and efficiency approach. In developing your response, please consider the summary to the left, including the trade-offs and other factors that have been provided.”
BCSEA believes that energy conservation (DSM) should be the first choice to meet energy needs. DSM is estimated to cost around $40-$60/MWh, compared to BC Hydro’s benchmark of about $120/MWh for new supply-side power (based on the recent Clean Power Call).
Conservation has far fewer environmental impacts than supply-side resources (CLFs versus damming or diversion of rivers, etc.). Conservation is immune to power failures. Some DSM, such as upgrades to building envelope efficiency, represents virtually permanent improvements in energy performance, yielding benefits over many years and protecting customers from future power price shocks.
Above all, conservation is one of the best ways for homeowners to support efforts to reduce the greenhouse gas emissions that cause climate change. Reductions in electricity demand to heat homes or domestic hot water can make more electricity available for other uses that may reduce the need for fossil fuel generation. As well, many Hydro customers heat their homes with gas. Improvements to the efficiency of walls and windows will cut gas consumption and reduce greenhouse gas emissions.
We recommend giving strong support to this resource option.
In discussing DSM, BC Hydro highlights the risk that savings might not be achieved. We think this concern is over-stated. In a twenty-year planning horizon, with updates to the plan every two or three years, there will be ample opportunity to evaluate progress in achieving DSM savings and to take any required corrective action. BC Hydro should be urged to pursue the most ambitious conservation/DSM plan.
2.1 - 2.4. Evaluation of different resource portfolio options:
BC Hydro question: “Please indicate your level of agreement with Portfolio 1 – Renewable Mix ... Portfolio 2 – Renewable Mix with Site C ... Portfolio 3 – Renewable Mix with Site C and Gas-Fired Generation (within 93 per cent Clean Energy Act target).”
BCSEA believes that most of BC Hydro’s resource needs can and should be met with energy conservation, but there will also be need for supply-side resources, and we recommend that any such resources should come from renewable energy, with the least possible environmental impacts.
We are carefully considering whether the Site C dam would be needed in the future (e.g. if there is a large increase in demand for electricity from the electrification of BC's vehicle fleet), and whether the environmental harm of developing the dam (loss of agricultural land, harm to fisheries and wildlife habitat, greenhouse gas emissions from the reservoir) and other issues such as First Nations rights are sufficient to outweigh the benefits. To date, neither BC Hydro nor the government has addressed these concerns adequately, and we are concerned that the current environmental assessment process will not deal adequately with the question of the need and justification for Site C.
We do not support the construction of gas-fired generation – with or without carbon offsets – due to the associated greenhouse gas emissions, contributing to climate change.
3. Electrification:
BC Hydro question: “Please indicate your level of agreement with this approach to electrification that involves active promotion by BC Hydro. In developing your response, please consider the summary to the left, including as well as the trade-offs and other factors that have been provided.”
BCSEA strongly supports BC Hydro actively pursuing electrification where it can reduce greenhouse gas emissions. In particular, BC Hydro should actively pursue electrification:
· In remote areas where electricity generation is powered by diesel fuel;
· For the the BC vehicle fleet;
· To displace the use of fossil fuels for residential and commercial space and water hearing; and
· In industrial processes relying on fossil fuels for heat and power.
4. Transmission Planning:
BC Hydro question: “Please indicate your level of agreement with this proactive approach to transmission planning. In developing your response, please consider the summary to the left, including the trade-offs and other factors that have been provided.”
BCSEA supports the principle of developing a long-term plan for the development of BC’s transmission system. However, we are concerned that transmission developments have large impacts on the land base, affecting the environment, First Nations rights and other British Columbians. It is not clear that environmental, social and First Nations concerns will be adequately addressed. This is government’s responsibility; however, BC Hydro’s planning efforts here should be informed by known land use concerns.
5. Power Exports:
BC Hydro question: “Please indicate your level of agreement with this export approach. In developing your response, please consider the summary to the left, including the trade-offs and other factors that have been provided.”
BCSEA supports the gathering of information that could lead to a business case for building generation for export; however, we are also aware that there are big challenges to be overcome, mainly the high cost of developing new power versus the currently low spot market price for power. However, if these can be addressed, it is possible that the export of clean power could contribute to reductions in greenhouse gas emissions outside BC. If this can be achieved, it would be a good thing. BC Hydro should be concentrating more of its efforts on electrification than on developing export markets.
