Needs Identification Application, Transmission Lines
In this decision, the AUC approved a needs identification document (“NID”) application from the Alberta Electric System Operator (AESO”) and facility applications from EPCOR Distribution & Transmission Inc. (“EDTI”) to construct and operate an 11-kilometre-long, 72-kilovolt transmission line and to alter the Poundmaker, Meadowlark and Garneau substations in west Edmonton (the “Project”).
The AUC received more than 100 statements of intent to participate from stakeholders objecting to EDTI’s facility applications. Four groups of interveners formed, filed evidence and participated in the oral hearing. Some individuals also participated in the hearing, along with the Consumers’ Coalition of Alberta (“CCA”), which objected to the AESO’s NID application.
The AUC noted that these applications triggered the following legislative provisions:
approval of the need for expansion or enhancement to the Alberta Interconnected Electric System (“AIES”), pursuant to Section 34 of the Electric Utilities Act (“EUA”), and
a permit to construct and a licence to operate a transmission facility, pursuant to sections 14 and 15 of the Hydro and Electric Energy Act.
The AESO prepared its NID application in response to a system access service request (“SASR”) submitted by EDTI to reliably serve the growing demand for electricity in the west Edmonton area.
The AESO directed EDTI to apply with the AUC for the facilities to meet the need identified and to assist the AESO in conducting a participant involvement program for its NID application.
AESO Decision to File One NID Application for Two Developments
The AUC noted that the AESO’s preferred transmission solution was comprised of two transmission developments:
the replacement of three transformers with higher capacity transformers at Garneau Substation (the “Garneau Upgrades”), to respond to the load at risk in the event of a contingency to any of the three Garneau transformers; and
the proposed 72-kV transmission line from Meadowlark to Poundmaker, and alterations to Meadowlark and Poundmaker substations, to respond to all the other contingencies.
While the AESO filed these two developments in one NID application, the AUC viewed them as distinct and separable. Based on the amount of load at risk and likelihood of unsupplied load, among other factors, it was also evident that the need for the Meadowlark to Poundmaker transmission line was more urgent than the Garneau Upgrades.
The AUC found that in this case, filing both developments under one NID was appropriate. However, the AUC outlined its concern regarding the potential for a less urgent project to become accelerated by being attached to a more urgent one. It noted that it would have greatly assisted the AUC if EDTI had considered these as separate projects and assessed the level of urgency of each development on a stand-alone basis.
Notwithstanding its concerns, the AUC found that while the Garneau Upgrades were less urgent than the Meadowlark to Poundmaker transmission line development, they were nonetheless required and that moving forward with both transmission developments was warranted.
Probabilistic Assessment and Cost-benefit Analysis
The CCA’s expert filed cost-benefit analyses, which the AUC found informative. This evidence generally assisted the AUC’s understanding of how the risks identified correlated with the costs of the Project and provided helpful context into the level of urgency of the need for the proposed solution’s two developments.
However, the AUC agreed with the AESO and EDTI that calculating initial inputs was beyond the scope of a single NID proceeding. The AUC noted that it saw significant value in the AESO’s initiative regarding probabilistic analysis and cost-benefit analysis in 2020.
Need for Transmission Development
The AUC was satisfied that the need for the Meadowlark to Poundmaker transmission line was clear and urgent. The evidence demonstrated that the project would resolve several different contingencies that, if left unaddressed, could result in a significant amount of load that EDTI would be unable to serve, potentially including critical loads such as hospitals, police stations, and the LRT.
While the AUC found there was a need at Garneau, the urgency of that need was less obvious. Unlike the levels of unsupplied load related to the Meadowlark to Poundmaker transmission line development, the amount of load at risk at Garneau did not appear to be as significant.
University of Alberta
In the AUC’s view, it was important for EDTI and the AESO to assess the system under an N-G-1 scenario, where the University of Alberta’s generation was assumed at zero. While the AUC acknowledged this scenario is unlikely, it was important for EDTI and the AESO to understand those consequences
The AUC noted that as the AESO moves forward with its initiative on probabilistic assessment, the manner in which distribution-connected generation is incorporated into planning studies would be an important factor to consider. The AUC recognized that distribution-connected generation is increasing in the province, and while that generation may not be as reliable as large-scale, traditional transmission-connected generation, it would be unwise to completely discount the contributions that these facilities can make to reliability in all cases.
The AUC found the general question of whether and to what extent N-G-1 is appropriate for SASR-driven distribution reliability-based NIDs was too broad a question for this proceeding. Notwithstanding that, it made note of the following statement by the CCA’s expert:
[I]t’s almost bizarre that we have a large amount of generation right in the centre of this problem, and we are not having a relatively aggressive discussion with them, talking about every opportunity there is to firm up that generation in some way or to bring it to the table to avoid a very expensive project.
The AUC accepted the AESO’s evidence that Transmission Must Run (“TMR”) can only be used in areas with limited potential for load growth and that this was not the case in the Garneau area. Furthermore, the evidence indicated that the University of Alberta had no interest in providing emergency backup or in pursuing additional generation at this time.
The AESO’s Distribution Deficiency Report Author’s Guide, Distribution Load Shifting and EDTI Distribution Planning Criteria
The CCA argued that EDTI’s Distribution Deficiency Report (“DDR”) submitted to the AESO and filed as part of the NID application did not meet the requirement of the AESO’s DDR Author’s Guide because it did not include distribution-only options such as load shifting and distribution upgrades which might have resolved the need identified. In addition, the CCA said the report did not include a single-line diagram of EDTI’s distribution system or information about existing or new distribution feeders such as the maximum or spare capacity and submitted that the NID application should be considered technically deficient on this basis.
The AUC found that the AESO’s DDR Author’s Guide is a guideline and that the AESO has the discretion to determine what information has to be included in a DDR. The AUC was also satisfied that the AESO obtained and filed the necessary information to consider whether distribution alternatives were feasible or superior options through information requests and the hearing process.
The AUC found, however, that had EDTI provided a single-line diagram of its distribution system and information on the spare capacity of its feeders, this would have clearly and succinctly answered questions on the ability of EDTI to address the problems via load shifting, which would have saved time and resources of many of the parties involved.
The AUC noted that while EDTI’s practice of proactively shifting load allows it to get as close as possible to firm capacity at each area substation, it does not maximize overall area capacity. Under EDTI’s policy, a transformer contingency could occur at each and every area substation and no unsupplied load would occur. This achieves a level of reliability greater than N-1 as it does not properly account for capacity that could be provided by a nearby substation in the event of a contingency. Under the reliability criteria of other Distribution Facility Owners (“DFO(s)”), a point of delivery (“POD’s”) firm capacity would add capacity from adjacent substations. The amount of firm capacity would be limited by the amount of transformer capacity at nearby substations and by the amount of capacity on the feeders connecting the substations. The AUC found that EDTI’s POD loading criteria does not align with that of other DFOs and has the potential to unnecessarily accelerate transmission development.
There was some indication that EDTI would transfer load between substations in the event of a contingency, but it was less clear to what extent the AESO or EDTI planners accounted for the ability of operators to do so in determining that additional capacity was needed.
The AUC was satisfied that while there was adjacent and unused transformer capacity at Rossdale that could provide support to Garneau, there was no available capacity on the feeders that connect Rossdale and Garneau and, therefore, no way to utilize Rossdale’s available transformer capacity. To access that capacity, new distribution feeders would be required to be constructed. The AUC accepted EDTI’s evidence on the costs and technical issues associated with those alternatives and found that they were not superior to the proposed transmission development. Although the AUC was satisfied in this case that the transformer replacements were in the public interest, it expected that EDTI would review its POD loading criteria to assess how it can be more aligned with other DFOs, and specifically to account for the capability that adjacent feeders and substations can provide in the operational time frame.
The AUC noted that the lack of available feeder capacity might have been the reason the AESO or EDTI did not discuss load shifting as an option in a contingency. If that was the case, it was not clearly stated, and this option was not eliminated in EDTI’s DDR. The AUC noted that there is a level of overlap between the planning and operational horizons, and to completely separate them can only result in greater costs and inefficiencies.
The AUC advised against the practice of over-relying on transmission solutions and encouraged the AESO and DFOs to attempt to find innovative means to delay the need for transmission projects, where it is prudent and appropriate to do so. Importantly, in evaluating whether it is in the public interest to approve a transmission solution, the AUC requires a full analysis of what operational measures were considered and why such measures were eliminated in favour of new infrastructure as a solution.
Conclusion on NID Application
The AUC found that no interested person demonstrated that the AESO’s assessment of the need for proposed transmission upgrades in west Edmonton was technically deficient or that approval of the NID would not be in the public interest.
EDTI filed facility applications to:
Construct an 11 km 72-kV transmission line between the Poundmaker and Meadowlark substations. EDTI’s application included a preferred route and an alternate route for the proposed transmission line.
Construct a new fibre optic line between the existing Poundmaker and Meadowlark substations, using the proposed transmission line structures for the majority of its route.
Alter the existing Poundmaker Substation by adding one 240/72-kV, 100/133-MVA transformer, one 240-kV circuit breaker, and one 72-kV circuit breaker.
Alter the existing Meadowlark Substation, located in the community of Lynnwood, by adding two 72-kV circuit breakers.
Alter the existing Garneau Substation by replacing three 72/14.4-kV, 40-MVA transformers with three 72/14.4-kV, 60-MVA transformers.
The AUC recognized that many stakeholders had concerns about the participant involvement program for the proposed transmission line. However, the AUC was of the view that the participant involvement programs were sufficient to communicate to potentially affected parties the nature, details and potential impacts of the Project and gave parties an opportunity to ask questions and to express their concerns.
Visual and Property Impacts
Although the AUC recognized that the Project would change the viewscape along the preferred route, it found that visual impacts could be sufficiently mitigated.
The AUC found that the preferred route would result in the least impact on property values in terms of the overall project because a significant portion of the preferred route followed a transportation and utility corridor (“TUC”) as well as existing linear infrastructure such as Whitemud Drive. It found that property value impacts could be mitigated.
Electric and Magnetic Fields and Health / Safety
The AUC placed significant weight on the World Health Organization’s conclusion that, based on available research data, exposure to electromagnetic fields (“EMF”) is unlikely to constitute a serious health hazard. The AUC also placed weight on Health Canada’s conclusion that exposure to EMF from transmission lines is not a demonstrated cause of any long-term adverse effect on human or animal health.
The AUC found that there would be no material difference between the expected magnetic fields produced by an overhead versus an underground line at the nearest homes, schools, daycares, and playgrounds. It also accepted that the expected electric and magnetic fields produced by the proposed line, whether underground or overhead, will be very low and well below recognized standards, as noted by the expert witnesses for both the applicants and the interveners.
Environment and Noise
The AUC found that the environmental effects predicted for the project were consistent with transmission line development in the TUC and an urban setting. With the diligent application of proposed mitigation and monitoring measures, the environmental effects from construction and operation of the proposed transmission line will be adequately mitigated.
The AUC found that the proposed and existing substation facilities will comply with the requirements of Rule 012. It was also satisfied that the proposed transmission line will not be a significant source of audible noise.
Routing of Transmission Line
The AUC accepted EDTI’s evidence that the potential impacts associated with its proposed preferred and alternate routes were similar and reflected the highly developed urban area within which the Project was proposed. Each route used existing linear developments to minimize incremental impacts and was located primarily on public land. In particular, the AUC found that the preferred route’s use of the TUC for slightly less than one-half of its length was the primary consideration in its favour and that it was superior in this regard to the alternate route, which makes almost no use of the TUC.
The AUC noted the TUC is publicly-owned land that was created to provide a corridor within which utility infrastructure, including pipelines and transmission lines, could be grouped with other linear features. The TUC was, therefore, an obvious and superior routing choice for the proposed transmission line.
The AUC noted that the preferred and alternate routes were similar in length, and their cost estimates were almost identical.
For these reasons, the AUC found the preferred route will result in lower impacts than the alternate route.
The AUC approved the AESO NID application, and the applications to alter and operate the Poundmaker, Meadowlark, and Garneau substations. The AUC also approved applications to construct a transmission line and a fibre optic line and will issue permits and licences for the transmission line following the written consent of the Minister of Infrastructure regarding facilities in the TUC.