THE PROPOSED CLEAN ELECTRICITY STANDARD

Comments by the Coalition of Concerned Manufacturers and Businesses of Canada

April 15, 2022

by Robert Lyman and Parker Gallant

On March 8, 2022, the government of Canada published a document entitled, “A Clean Electricity Standard in Support of a net zero electricity sector”. The stated purpose of this document was “to send a clear signal that the Government of Canada intends to move forward with regulations to achieve a net-zero electricity system by 2035; to outline considerations related to this objective; and to solicit comments from Canadians regarding the scope and design of the CES”.

The Coalition of Concerned Manufacturers and Businesses of Canada (hereafter referred to as “the Coalition”) is a not-for-profit association that represents small- and medium-sized manufacturers and other businesses in Canada.  The goal of the Coalition is to advance policies that promote economic growth and retain good jobs in Canada. 

General Comments

Much of the current public discussion concerning future energy transitions is based on speculation about the timing, cost, and pace of commercialisation of new technologies. It would seem more prudent to base one’s judgments on what has actually happened in past energy transitions rather than try and predict the future.

The period from scientific discovery to widespread commercialisation of technologies has been much longer than is currently estimated by advocates of rapid decarbonisation. None of the steps in the innovation pathway – research, discovery, testing, demonstration, initial market development or widespread commercialisation – operates according to a fixed or predictable schedule.

Professor Vaclav Smil of the University of Manitoba, perhaps the world’s foremost expert on energy transitions, has argued that past transitions have been slow, painstaking and hard to predict. Existing technologies, both for generation and consumption of electricity, have a lot of inertia. Smil observes that the changes in technology and infrastructure required to decarbonise the world in a few decades as a ‘grand delusion’.

The proposed CES seems premised on the view that, in the face of high market costs and barriers, governments can force the pace of change and retain the support of the electorate in doing so. Outside of the centrally planned economies, however, no government has attempted to prescribe the timelines for commercialisation of new technologies or the dates by which a large share of society’s needs must be met by a new technology. ‘Picking winners’ may be an increasingly popular aspect of national industrial policy (despite its history of failures), but a prudent government should be hesitant about committing billions of taxpayers’ dollars to technologies that are not ready and cannot compete without permanent subsidies.

Those who pursue the net zero goal will be confronted with the reality that hydrocarbons are nature’s most efficient embodiment of primary energy. The combination of high energy density, abundance, stability, safety, portability, safe storage and affordability is unmatched by any other source of energy. Governments cannot wish those advantages away.

The electricity sector offers good examples of the immense barriers to net zero. Just meeting the additional generation requirements needed to power proposed conversion to electric vehicles would require a major expansion in the electricity generation capacity across Canada, sometimes estimated as the addition of 10,000 megawatts of capacity from today’s levels. The provinces of New Brunswick, Nova Scotia, Saskatchewan and Alberta still have coal fired capacity collectively totalling over 9,000 MW which will also require replacement, adding considerable additional costs.

The two largest power projects being built in Canada today, Site C in British Columbia and Muskrat Falls in Labrador, have a combined design capacity of 1,944 megawatts. To meet just the additional EV-related  power demand, at least eight more projects of the same size would have to be built. It generally takes at least 15 to 20 years to bring such a project to production in Canada. There are none even being contemplated at this time.

Central to the vision on which the proposed CEP is based is the thesis that in future Canada must rely primarily on wind and solar power generation for incremental supply, notwithstanding that these sources are intermittent and frequently unreliable.

The Issue of Costs

The discussion paper presents the transformation of Canada’s electrical energy system from one which is predominately reliant on low- or zero-carbon dioxide emissions to one that has virtually no carbon dioxide emissions as though it can be accomplished at low cost. Indeed, considerations of cost seem barely to enter into the presentation of facts, which is a highly unrealistic approach.

Canadians’ experience with efforts to reduce greenhouse gas emissions from electricity systems in Ontario and Alberta have already revealed the significant economy-damaging costs of seeking to increase reliance on wind, solar and biomass energy. In Ontario, electricity rates for consumers doubled over the past decade and, according to the Ontario Auditor General, the cost of the move to increased wind and solar energy will be $90 billion over the life of the existing contracts.

Those who have studied the experience of other countries that have sought to increase reliance on renewable energy sources for electricity generation have found consistent patterns. These efforts bring about large increases in the actual prices that must be paid for electricity by consumers and businesses. Further, the price increases grow and accelerate as the percentage of electricity generated from intermittent renewables increases. This is due to the need for large and increasing amounts of costly backup and storage – things that are not needed at all in conventional hydrocarbons-based systems. Jurisdictions that increased generation from renewables up to as high as 30 per cent to total electricity supply have seen an approximate tripling in the price of electricity to ratepayers, except where a large portion of the increased costs is off-loaded to taxpayers.

In the remainder of these comments, the Coalition will address four specific aspects of the proposed CES:

• The paper’s treatment of energy technology pathways
• The paper’s proposal to minimize use of natural gas-fired generation
• The cost of bulk electricity storage
• Issues related to transmission

Technology Generation Pathways

The concept of technology is touted in the discussion paper as a way to achieve “net-zero” electricity for which wind turbines (onshore and offshore), solar (photovoltaic and concentrated), hydro and nuclear are considered to be zero emissions! It goes on to claim: “low and non-emitting generation technologies are becoming more cost-competitive, the pace of low-carbon electricity deployment must accelerate for Canada to reach NZ2035”.

The paper also opines favourably on possible energy sources under development such as SMR (small modular reactors), hydrogen fuel cells and carbon capture as zero emission. It also favours biomass (cogeneration and simple cycle) ahead of any form of natural gas generation. 

Biomass:  The treatment of biomass as low emissions flies in the face of reports from the UK where one of the world’s largest biomass power plants (DRAX)1. ranks third in the EU for emissions (if they were counted) and also received more than £800m in subsidies.

Solar photovoltaic is also a questionable source of energy in Canada (weak winter solar) and where it has been developed has cost more than estimated and produced considerably less power than forecast.  The larger projects started on the Nevada deserts have had many problems and the State 2. is dependent for over 60% of its electricity needs on natural gas plants. It would also need storage which would add considerably to its costs.

SMR technology is in process in many locations around the world but to date only a small number are operating, with Russia’s Akademik Lomonosov,3. the world’s first floating nuclear power plant which began operation in May 2020 producing energy from two 35 MW SMRs. China’s Huaneng Group Co.’s 200-megawatt unit 1 reactor at Shidao Bay is now feeding power to the grid in Shandong province, the China Nuclear Energy Association 4. said in a December 2021 article. Other SMRs are under construction or in the licensing stage in Argentina, Canada, China, Russia, South Korea and the United States of America.  SMR, dependent on costs, appears to be a possible “net-zero” energy source before several others but is unlikely to meet the targets committed to by the Canadian Federal Government at COP26.

Wind and solar are touted as playing a “key role”in reducing the electricity sector’s emissions but it will be very costly as demonstrated in Ontario5. where prices more than doubled in less than 10 years as they rose to represent over 15 per cent of capacity but generated only 9 per cent of demand, often when not needed. It must be recognized they receive “first-to-the-grid” rights meaning clean hydro is spilled and clean nuclear is steamed off to maintain grid stability and ratepayers are saddled with those costs in addition to what is paid to wind and solar developers. Due to their unreliable and intermittent nature they require backup from natural gas generation and ratepayers are saddled with that cost too.

Carbon capture utilization and storage (CCUS) is a major part of the discussion paper.  Based on the following excerpt however it seems to be viewed as temporary: “Over time, however, natural gas coupled with CCUS will increasingly be in competition with other emerging options that are both non-emitting and flexible in the roles they can play in electricity systems.” The issue of CCUS has gained interest from the Government of Alberta 6. and six major oil patch participants who are seeking “carbon capture credits” to assist in recovering some of the costs. While Canada is a leader in the development of CCUS the costs involved will be billions of dollars. Those costs will add considerably to electricity generation costs from flexible fossil fuels required to back up intermittent and unreliable wind and solar generation.  A report from June 2020 from Rutgers University 7. stated: “The analysis suggests coal-sourced CO2 emissions can be stored in this region at a cost of $52–$60 ton−1 , whereas the cost to store emissions from natural-gas-fired plants ranges from approximately $80 to $90.”  Note the foregoing are US dollars and those costs will be added to each kWh delivered. Transferring part of these costs from emitters to taxpayers through the use of investment tax credits for CCUS will not reduce the cost to society.

Hydrogen blending with natural gas will raise consumer costs and risk public health while barely reducing emissions, a US think-tank 9. reported in a March 30, 2022 article. It goes on to state “A blend of 20% green hydrogen in natural gas would raise fuel costs for heating and cooking by a factor of two to four, as renewable H₂ is currently six to 14 times more expensive than fossil gas, the study explains. Green hydrogen prices would have to fall by roughly an order of magnitude to achieve parity with the price of natural gas for use in buildings.”  The “Discussion Paper” suggests “releasing the Hydrogen Strategy for Canada to position Canada as a world-leading producer, user and exporter of clean hydrogen, and associated technologies”.  It appears once again the blending of hydrogen and natural gas would further drive up the cost of electricity should this be cast as another regulation.

Natural Gas

Natural gas has long been favoured as a clean, efficient, plentiful and affordable source of energy supply for multiple uses. In absolute terms, natural gas is the fastest growing source of supply for energy consumers, and through the use of liquification one of the fastest growing sources of international energy trade. In the United States, the increasing domestic supply of natural gas and its affordability have allowed the US to convert a large amount of previously coal-fired electricity generation to the lower cost and cleaner fuel.

In Canada, natural gas is used both for reliable base-load power generation and a back-up source to help cope with the serious problems of intermittency that plague wind and solar generation sources that have been used for political reasons. According to Canada’s Emissions Inventory, published by Environment and Climate Change Canada, in 2019 natural gas fired generating plants produced 46,100 GWh of electricity, 8 per cent of Canada’s total, and emitted 22 megatonnes of carbon dioxide equivalent, 32 per cent of the emissions from power generation. This, however, is only illustrative of how extremely low greenhouse gas emissions already are from electricity generation in Canada. Emissions from natural-gas generated power are only 3 per cent of Canada’s total emissions.

Increasingly, natural gas electricity generation in most provinces will come to represent a backup source produced from plants constructed a decade or more ago. The Independent Electricity Systems Operator of Ontario (IESO) recently completed a study to determine the feasibility and cost of phasing out natural gas generation by 2030. The findings of that study are very relevant to the federal government’s consideration of the Proposed Clean Electricity Standard. These included the following:

• Gas generation offers a set of services, including quick response time and assured availability, that keep the grid reliable and help balance the variability of wind and solar.
• Completely phasing out gas generation by 2030 would lead to blackouts.
• Replacing gas generation in Ontario by 2030 would require more than $27 billion to install new sources of supply and upgrade transmission infrastructure. This translates into a 60 per cent, or $100 per month, increase in the average monthly residential bill.
• There are many other practical considerations that make a 2030 phase-out impossible, including the time that it takes to plan, get regulatory approvals for, and build new infrastructure and non-availability of storage as an alternative. Those impediments are likely to last well beyond 2030.

The IESO report did not address the fact that many natural gas generation facilities, including those operated by private firms (i.e. the so-called non-utility generators, or NUGs), while often signed to 20-year contracts, generally operate for much longer than that. In fact, it is not surprising to see them operating under 40-year contracts. The premature cancellation of these contracts could cost well over $600 million, which would also be added to consumers’ bills.

Anyone considering the termination of existing contracts across Canada and the construction of new generation, transmission and storage facilities to replace the services now provided by natural gas-fired generators would have to take these factors into account.

Storage

Battery Storage is only cited once in the Discussion Paper in the following context: “leveraging Canada’s competitive advantage in mining to build the Canadian battery and critical mineral supply chains”.  The foregoing suggests the author(s) do not regard it as a means to significantly support the electricity sector, perhaps due to its high costs.  A report from June 2021 by the US NREL 8. (National Renewable Energy Laboratory) estimated the cost as; “(e.g., a $300/kWh, 4-hour battery would have a power capacity cost of $1200/kW).” That translates to a cost of U.S.$1.2 million for just 1 MW (megawatt) of storage for 4 hours and if done to any scale would drive up electricity prices.

No jurisdiction has yet succeeded in getting the percentage of its electricity generated from intermittent renewables past 50 per cent on an annualized basis. As the reliance on renewables increases, the grid operator must rely more on coal or natural gas-fueled backup power, and where these are prohibited, on some form of storage, most likely from large batteries. The cost of batteries is high and increases with the period of time for which storage is required, and whether the storage is needed only to balance daily or seasonal variations in demand

The cost of batteries sufficient to power a jurisdiction of millions of people would be enormous. In jurisdictions where a calculation has been made, the costs of the batteries exceeds the full annual GDP of the jurisdiction, and implies an increase in the price of electricity by a factor of 15 or more. For example, according to a study by Roger Andrews[1], the total amount of storage needed to provide secure supply in California amounts to about 25,000 GWh per year, more than a full month’s current rate of usage. Even assuming a substantial reduction in current battery prices, the cost of that would be in the range of US $5 trillion. And these batteries would need to be replaced regularly. Ken Gregory[2], a Canadian engineer, has assessed the cost of electrifying the United States economy without hydrocarbon-based generation, including the cost of battery backup. Simply to meet 2020 demand for 31 days would require storage that would cost $77.4 trillion, almost four times current US annual GDP.

Bulk electricity battery storage is hopelessly insufficient, no matter the cost. David Wojick, a Virginia-based Ph.D. in the logic and philosophy of science, explains this well in his article “California secretly struggles with renewables” (January 19, 2021).

Here is an excerpt:

“California has hooked up a grid battery system that is almost ten times bigger than the previous world record holder, but when it comes to making renewables reliable it is so small it might as well not exist. The new battery array is rated at a storage capacity of 1,200 megawatt hours (MWh); easily eclipsing the record holding 129 MWh Australian system built by Tesla a few years ago. However, California peaks at a whopping 42,000 MW. If that happened on a hot, low wind night this supposedly big battery would keep the lights on for just 1.7 minutes (that’s 103 seconds). This is truly a trivial amount of storage…Barely time to find the flashlight, right? “This one reportedly utilizes more than 4,500 stacked battery racks, each of which contains 22 individual battery modules. That is 99,000 separate modules that have to be made to work well together. Imagine hooking up 99,000 electric cars and you begin to get the picture.”

Large-scale battery storage of electricity is still an infant industry, with enormous costs and technological risks, It is foolish in the extreme for Canada to commit to a pattern of electricity generation dependent on large-scale batteries for security of supply.

[1] Roger Andrews, The cost of wind and solar power: batteries included. Energy Matters, November 22, 2018

[2] Ken Gregory. The Cost of Net-Zero-Electrification of the USA. Friends of Science. December 20, 2021

Transmission Costs

The Discussion Paper notes; “Achieving net-zero electricity will require coordinated efforts. Provinces and territories hold jurisdiction over electricity planning and operation, while the federal government holds jurisdiction over emissions reduction regulations, interprovincial transmission projects, and international commitments, among others.” 

What the foregoing infers is either conflict or agreement will occur between the two parties as to how to achieve “net-zero electricity” which will obviously depend on projected outcomes and the current generation sources in each province/territory. 

One example is referenced as the “Atlantic Loop” project which aims to transmit hydro power from Muskrat and Churchill Falls (both located in Labrador) to other Atlantic regions, principally Nova Scotia which has 8 coal fired plants that federal regulations says they must close by 2030.  No doubt Nova Scotia would be happy to replace those coal plants with hydro power but what cost would Quebec, Newfoundland and Labrador charge for that power? The other consideration is that Quebec is a winter peaking province so has little surplus energy available during that period meaning little or no generation from Churchill Falls. 

To top things off, Muskrat Falls is way over budget, having ballooned from an estimated $7.2 billion to $13.1 billion. The Federal 10. government stepped in to provide up to $5.2 billion with $1 billion of that as a loan guarantee and another $1 billion for transmission costs.  The latter $1 billion is 20 per cent of the estimated cost of the Atlantic Loop which in late January 2022 Intergovernmental Affairs Minister Dominic LeBlanc said his Ministry required more information before they could “justify a federal investment”. 

Based on the comments in the Discussion Paper it appears the government is prepared now to “justify” that investment as it states: “The ‘Atlantic Loop’ project is an example of collaboration to bring clean power to where it’s needed in Eastern Canada. The Government of Canada and the Canada Infrastructure Bank are currently collaborating with provinces and regional partners to advance this intertie project, which could greatly reduce emissions and maintain electricity affordability in the Atlantic region.” So, Nova Scotians should now wonder what will the cost be for the power combined with the costs of the transmission.  Will the cost of electricity be truly affordable? To top things off, GE 11. (who supplied the turbines) has been having problems with the software for the LIL (Labrador Island-link) slated to bring power to the Northeast Avalon.   

High voltage transmission projects vary in terms of costs per kilometer. As one example the 301-kilometer Eastern Alberta Transmission Line 12. completed several years ago cost $1.8 billion or about $6 million per kilometer.  Two major power lines under construction in northwestern Ontario are estimated to cost much less!  Those are the East-West Tie Line, 13. a 450-kilometre line stretching from Wawa to Thunder Bay, at a cost of $777 million makes its projected cost per kilometer $1.7 million. The other project is the 1,800 kilometer Wataynikaneyap Power 14. line serving many small indigenous communities on its route.  In total it will serve 15,000 people for a total cost of $1.9 billion or just over $1 million per kilometer and $126.6K per person and over $500K for a family of four.   

An article in the Financial Post on March 31, 2022 penned by Francis Bradley, CEO of Electricity Canada titled “The clock is ticking on Canada’s electricity grid” 15. stated “Under net-zero, Canada will stop its reliance on fossil fuels by mid-century. However, by the government’s own estimation, to do so Canada will need two to three times the amount of electricity it produces now in order to decarbonize other sectors of the economy.”  The article went on to note: “Transmission lines — the big power lines that move electricity long distances — are hugely complicated to survey and then build. Even making sure the electricity infrastructure on your street is ready for the increased load will take years of investment.”  Mr. Bradley went on to say; “Decarbonizing Canada’s economy by 2050 will be a herculean task. Decarbonizing the electricity system in less than half that time will be doubly so. If either is to have any chance of succeeding, the electricity industry will need to do more, faster, as Prime Minister Trudeau has said. But that also works the other way. The countdown clock is ticking. And we’re still waiting for vital leadership.”

What the above illustrates is that just the costs associated with ensuring the transmission lines delivering the “clean green” renewable energy will require significant upgrades costing billions of dollars.  Those costs coupled with those associated with the desire to eliminate fossil fuel generation will drive up power costs for families and businesses. It will affect the provinces of Nova Scotia, Alberta and Saskatchewan to a much greater degree due to their current use of fossil fuels in the generation of their electricity needs.

The foregoing suggests costs in the tens of billions of dollars which in turn will damage Canada’s ability to attract new business, it’s related capital and will decimate the economy and drive-up unemployment levels. 

Conclusion

This analysis outlines the impossibilities of achieving the goals set by the Government of Canada within the proposed time frame.  Any push towards the unrealistic outcomes included in the planned government policies will badly damage the Canadian economy.  As well, they will lead to millions of Canadian households living in energy poverty, spending well over 10 per cent of disposable income on trying to stay warm in winter and cool in summer. It is no accident that Canadian government climate plans never include reputable, independent cost/benefit analyses, as to do so would reveal to Canadians just how unachievable and punitively costly the stated goals are. 

It is important to recognize Canada’s total emissions in 2019 (last reported year) were 20 Mt lower than China’s emissions increased in the two years between 2019 and 2021 during the pandemic. China’s emissions reported by the IEA (International Energy Agency) rose to over 11.9 billion tonnes which represents 33 per cent of total global emissions. China was also the only major economy to experience economic growth in both 2020 and 2021, questioning the often-cited claim that “the environment and the economy go hand in hand”.

Sensible, measurable policies to achieve tangible benefits to the environment are welcomed by the Coalition.  Unfortunately, the approach in the Clean Electricity Standard document does not qualify as either measurable or achievable.

1. https://atlantic.ctvnews.ca/ottawa-hands-n-l-5-2-billion-for-troubled-muskrat-falls-hydro-project-1.5526011
2. https://www.saltwire.com/atlantic-canada/business/muskrat-falls-power-in-march-2022-could-be-too-optimistic-according-to-pub-consultant-100661743/
3. https://www.transmissionhub.com/articles/transprojects/eastern-alberta-transmission-line
4. https://www.cbc.ca/news/canada/thunder-bay/thunder-bay-power-contracts-valard-1.5726667
5. https://www.cbc.ca/news/canada/thunder-bay/wataynikaneyap-power-proceeding-1.5340793
6. https://financialpost.com/opinion/francis-bradley-the-clock-is-ticking-on-canadas-electricity-grid https://news.sky.com/story/climate-change-draxs-renewable-energy-plant-is-uks-biggest-co2-emitter-analysis-claims-12428130
7. https://www.eia.gov/state/?sid=NV
8. https://world-nuclear-news.org/Articles/Russia-connects-floating-plant-to-grid
9. https://www.bnnbloomberg.ca/china-is-home-to-world-s-first-small-modular-nuclear-reactor-1.1698791
10. https://www.ieso.ca/en/Corporate-IESO/Media/Year-End-Data
11. https://financialpost.com/commodities/energy/oil-gas/oilpatch-looks-to-ottawa-for-carbon-capture-tax-credit-as-alberta-pushes-six-projects-forward
12. https://royalsocietypublishing.org/doi/pdf/10.1098/rsfs.2019.0065
13. https://www.nrel.gov/docs/fy21osti/79236.pdf
14. https://www.rechargenews.com/energy-transition/hydrogen-blending-will-raise-consumer-costs-and-risk-public-health-while-barely-reducing-emissions-us-think-tank/2-1-1193416

Other related observations

Peak emissions occurred in 2007 at 752 megatons and our population was 32.89 million so per capita emissions were 22.86 tons per person.

Emissions in 2019 (latest from Government of Canada) were 730 megatonnes and our population was 38.19 million so our per capita emissions were 19.11 tons per person a drop of 16.4%.

https://www.canada.ca/en/environment-climate-change/services/environmental-indicators/greenhouse-gas-emissions.html

Canada had wind capacity at the end of 2021 of 14,304 MW and 2,399 MW of solar which reputedly generated slightly less than 6% of total electricity of 647.7 TWh!  https://www.cer-rec.gc.ca/en/data-analysis/canada-energy-future/2020/results/index.html  From this “variable renewable energy (VRE) sources such as wind and solar. Figure R.21 shows that by 2050, total non-hydro renewable capacity in the Evolving Scenario is over triple 2018 levels. Total wind capacity rises to 40 GW and total solar capacity rises to 20 GW.” It also has a key uncertainty “Export market developments: Climate policies, fuel prices, electrification and power sector decarbonization in export markets could impact future projects and transmission intertie developments.”

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