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February 28, 2023
The recent Request for Proposals launched by Ontario’s Independent Electricity System Operator (IESO) resulted in interest by companies proposing new Battery Energy Storage Systems or BESS.
BESS is a relatively new technology and is currently being touted as an answer to wind power’s Big Problem of Intermittency (together with its other Big Problems of non-recyclable components and dependency on weather). Some of the proposals submitted were to be attached to existing solar or wind power generation installations.
The wind and solar lobbyist the Canadian Renewable Energy Association or CanREA (formerly CanWEA) actively promotes battery storage as an adjunct to wind power and says battery storage is key to multiplying Canada’s wind power fleet. CanREA has even added “storage” to its corporate banner.
Are we ready? No.
However, even the influential lobbyist points to concerns. First, there is a need to develop technical requirements for connecting and operating battery storage facilities CanREA says in its document, Laying the Foundation: “In many jurisdictions, the technical details may be included in the operating documents of the crownowned utility. However, there are other elements, such as the scope of safety and environmental reviews, that will need legislated descriptions or will need to be included in the regulatory documents of the relevant ministry or government department.” (Page 10)
And, CanREA says, regulating authorities may need to get ready for BESS and develop new competencies: “In most jurisdictions, the mandate and/or rules of the regulating authority (for example the Alberta Utilities Commission) may need to be enhanced. Regulatory authorities will need sufficient expertise to fairly evaluate proposed energy-storage installations.”
Where public meetings, required by the IESO as part of the submission process, took place and were publicized,* it is clear that some communities at least were not completely unaware of the risks posed by BESS.
Prince Edward County citizens actively engaged in review of several BESS proposals, including one for a 250 megawatt installation. Their concerns were so well founded that the municipal council voted against approval of the facility, because of the risk of fire, environmental noise, and loss of valuable farmland.
Concerns were expressed in other communities too, including Arran-Elderslie in Ontario. The Mayor said this about fact-finding on battery storage: “township officials tried to gather information on battery storage projects from provincial agencies and officials while attending a recent Rural Ontario Municipal Association conference in Toronto, ‘but the information is fairly sparse’, Mayor Marriott told the Sarnia Observer.
“People aren’t even quite aware of what it is,” the mayor added.
We looked and asked
Based on these reports and inquiries from our community group coalition members, Wind Concerns Ontario conducted a review of news about battery storage system incidents, community concerns, and the current regulatory environment in Ontario.
Our conclusions were that there is a lot of work to be done to answer citizen questions and provide reassurance. In specific:
- Standards needed for emergencies – As BESS technology is relatively new, standards are rapidly changing in response to emergency situations encountered. Even projects developed by companies with extensive battery experience have experienced serious emergency situations.
- Not enough information – The requirements for submissions to the IESO and to municipalities when requesting support for the project include few, if any, details on the actual project. The process appears to assume that once a company is awarded an IESO contract based largely on price, it will then proceed to develop the real proposal which will be submitted into an undefined permitting process or processes. Based on information submitted, it is not clear how the IESO will be able to distinguish between proposals with higher prices because they meet high standards for development and those with lower prices because the proposal includes the minimal safety standards.
- Renewable energy or not? – BESS systems are neither defined as a Renewable Energy project by Regulation 359/09, nor are they included in the list of excluded projects. The intention may be to omit further provincial review of these projects and to proceed directly to the municipal permitting process but this would be a recipe for substantial delay as the building officials in each host municipality (many of which are small rural municipalities) individually develop the expertise needed to assess and approve these projects.
- Safety regulations? – While Ontario Hydro has defined setbacks from BESS installations to protect their infrastructure, there are no setbacks for BESS installations established in Regulation 359/09 to protect other buildings and activities. Similarly, there are no noise standards for these systems which could create a new enforcement challenge for Ministry of Environment, Conservation and Parks field staff.
- Potential for support to be withdrawn – As the submissions to municipalities have included minimal information, there is potential for municipalities to rescind their support resolution once they learn the risks associated with these projects and the municipal resources that will be potentially required to deal with emergency situations.
The IESO is expected to launch another, larger Request for Proposals later this year, and more BESS proposals are likely.
The WCO report is here:
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