Energy Evolution: Ottawa’s Renewable Energy Strategy
Environmental Stewardship Advisory Committee comments on draft V.4.6 2017.10.13
ESAC appreciates this opportunity to comment on this municipal initiative; climate change is directly correlated with energy use, and action to reduce consumption and to supply the remaining demand with green power, green fuel & green heat must be an over-arching priority for Ottawa. Council structured its advisory committees to provide strategic operational advice, and we trust that civic leaders appreciate the input that is possible if consultation is done proactively and at the earliest stage possible. We look forward to more consultation as this process evolves.
Our comments are divided into: general observations on the overall environmental context of the report; and specific comments where page number relevant text are cited for reference.
GENERAL OBSERVATIONS
Efficiency of energy use (both negawatts negatherms) and conservation are far more important than production of energy from any source, and the primary focus of this process should have been on demand reduction. We have concerns that undue attention has been placed on new-better-greener sources,rather than to a strategy for overall reduction which would have a direct immediate impact on any discussion of subsequent need for supply.
The document ignores the critical role of electricity storage, which is critical for non-dispatchable renewable energy sources such as solar PV wind. Time Of Use rates underscore the timing differential between generation and consumption, and the implications for peak demand are ignored or minimized. For example, solar PV generates no power during peak winter TOU periods, so any supply (centralized grid or decentralized) must have backup. Whatever form of storage (battery, flywheel, capacitor, compressed air, pumped hydro, etc) is considered, this is a key (and potentially expensive) component for any future of electricity.
The report does not quantify end-use applications, which is essential before any measures can be considered to reduce demand or amend supply. For example, 89% of all energy in homes and 74% in C-I facilities is consumed for temperature load, and is responsible for virtually all the carbon emissions. Temperature load is 30% of ALL energy in these two sectors. Simply estimating the quantity of each fuel source, without an indication of how it is used (and how it can be improved), is largely meaningless for selection of actions.
If citizens are to understand any of this discussion, nomenclature must use “kilowatt-hours” and NOT “terrajoules”. The latter is correct terminology but it is incomprehensible to anyone not directly involved in energy issues; its use will constrain any effective communication of the goals of Energy Evolution and harm its positive objectives.
There will be opportunities to identify prioritize more actions during phase 2, but this first phase could include the use of small-scale generation or the feasibility of home assessments to install solar panels for electricity or heat.
There is virtually no mention of municipal financing mechanisms such as local improvement charges on property title (p28 of the case study at examines Halifax’s Solar City project) or other financing mechanisms used in other cities, such as PACE.
The report does not address any of the unintended consequences discussed in the Energy Evolution process and in other fora, such as the need for more nuclear reactors to generate fuel for EVs, the need for high-voltage transmission lines to import electricity, significant distribution problems within HOL territory, etc.
If Ottawa is to achieve the ambitious GHG reduction targets set by higher levels of government, the City needs to radically reduce emissions from existing new construction, and ensure land-use planning proposals support GHG pollution reductions in line with these targets. This is largely dependent on updates to provincial building codes, planning act and other regulations on land-use planning, but the City should strongly advocate for measures that will allow it to ensure that local development is compatible with a low-carbon pathway. We are encouraged that this is included as one of the actions under the District Energy section, but it is something that should be done on an ongoing basis,rather than rely on developers to do this on their own.
Electricity in ON constitutes 15% of all consumption; electricity is acarrier –it is not a primary source of energy. Depending on fuel, electricity can reduce carbon content, but it must be recognizedthat 60% of current grid capacity is from nuclear reactors (low carbon but not renewable).
While many residents understand the threat posed by climate change and the need to transition to a low-carbon climate-resilient economy, this report makes little mention of the impact which actions could have on job retention or job creation. All employment predictions cite the positive job impact of new technologies and the potential for skills training, a contribution that should not be overlooked in any renewable energy plan. ThisCity has the advantage of hosting many institutions which offerprograms to train workers in many of the fields required to achieve a renewable energy vision. Addressing the implications of jobs is important; failure to do so risks alienating a portion of the population for whom increasing renewable energy or lowering carbon emissions is not a priority.
There is no recognition of the dramatic increase in space cooling demand; this end use has registered the largest percentage increase of all energy applications and has significant implications under a warming climate and peak TOU demand for electricity.
The City is exploring a possible partnership with the federal government on the latter’s desire to green the district energy connections for downtown buildings; it should explore more partnership opportunities with the federal provincial governments, and consider becoming a demonstration hub when implementing any new technologies.
Availability of funds is an obvious limitation on any ambition to convert to low-carbon renewable energy sources, and the report briefly mentions a green debenture framework that the City will explain in Q4 this year. There was no explanation of what this will entail and how it is connected to the actions identified, and the level of support for green bonds will have a corresponding impact on the level of action. For example, will individuals be able to invest in community projects, or will bonds be available only to the primary market (large investors)? We trust that subsequent reports will disclose more information on this topic, if only to raise preliminary awareness and interest among the affected community.
This report makes no mention of communication plans to widely promote its recommended actions. There is a high need to inform engage the community so they understand the rationale behind this “energy evolution” and to understand the opportunities associated with energy efficiency and local production of renewable energy.
The report makes no link to the myriad of activities underway in Canada around the world to implement “smart cities” which can backbone off a low-carbon economy.
Governance is an important aspect of this report; more details are required.
This draft contains few timelines for identified actions. Without clear deadlines milestones, it will be difficult to track measure the outcomes of priority actions. There is also a need to explain what will happen to the identified actions after the current term of Council ends.
There is no cost analysis of options suggested in this report; we assume this will be included in future iterations and in follow-up action plans. The method of accounting should be clarified at the earliest stage possible, so citizens know if costs are based on lifecycle or first cost, and how all externalities of energy production, distribution, consumption, disposal carbon will be quantified.
The following comments refer to specific sections of the draft report.
p8transform Ottawa into a thriving city powered by clean, renewable energy.
increasing renewable energy generation and energy conservation and efficiency efforts will inevitably have the net effect of reducing GHG’s.
“Powered” shows a bias towards electricity and excludes temperature + motive energy end use applications. Only 15% of energy consumption is electricity, and has the lowest carbon content of all energy options. It excludes GreenHeat (mainly biomass) which is a significant portion of Ottawa’s non-valorized energy consumption.
p8significant amount of funding currently available through federal provincial programs to support municipal energy initiatives, opportunity to submit competitive project applications before these programs expire.
Is appendix 2 a comprehensive list of all eligible funding sources?
p9in 2015, Ottawans consumed 114,000 TJ of energy at a total cost of $3 billion. Natural gas was the most consumed type of energy (39%) followed by electricity (28%). Despite hydropower facilities, only 5% of the city’s total energy consumption is generated or supplied from local, renewable sources.
These data vary significantly from the Office of Energy Efficiency and provide no substantiation; OEE estimates 178,000 TJ (50 billion kWh/a) with $5 billion leaving the community to import these energies.
p9Although Phase 1 focuses primarily on renewable energy generation opportunities, many of the proposed Phase 1 actions include opportunities to promote energy efficiency in buildings transportation sector.
There is no mention of production of renewable energy temperature energy from biomass, solar thermal, NetZeroPlus heat pumps, etc.
p11 Ottawa has the good fortune to be the primary shareholder in Hydro Ottawa includingEnergy Ottawa Inc.
Council has no operational or policy jurisdiction over HOL or Energy Ottawa; it repeatedly claims that it cannot direct HOL/EO to comply with municipal policies. Clarification on this governance issue is critical.
p13many benefits of developing a renewable energy strategy including economic development opportunities, job creation, energy security, climate change mitigation, legislative requirements, access to funding.
Other benefits include public health, consumer comfort, avoiding transportation of fuels (pipelines), decreased risk of terrorism, decentralized production, resiliency, and many more.
p14In Ontario, businesses are already working within a framework of limited emission allowances as a result of the provincial Cap and Trade program.
Ottawa likely will never produce sufficient local supply to participate in carbon pooling, but it could aggregate carbon credits from production of renewable thermal energy.
p14Green Energy Act, adopted in 2009, has helped to ensure that many of these jobs are located in Ontario.
In light of the WTO ruling and cancellation of the Samsung agreement, this positive point should be deleted.
p15According to NRCan, the largest solar-power installations built in Canada to date are all located in ON
Absolute size is not a good measure for decentralized generation technologies; that is a basic criticism of large centralized plant.
p21The role of the City
The City has always said it cannot require planning measures (solar access laws; siting covenants; etc) because it does not have the legal power under provincial law.
p21City also plays a key role in bringing community stakeholders together to facilitate discussions foster collaboration in planning strategizing integrated approaches to achieve long term energy sustainability goals. Through education and civic engagement, the City has a responsibility to communicate the basis for and the pathways to take towards a long term sustainable energy future.
There is a papertrail of the City’s desire to NOT encourage efficiency or green production which would have avoided the need for a $75m high-voltage transmission line to bring nuclear electricity into South Nepean. That recent episode is at odds with the above statement and should serve as a case study of action to avoid.
p26Corporate Electric Vehicle Charging Station Policy
There is no mention of the implications of charging EVs during peak TOU periods. If all passenger cars in ON switched to EV status at current charging capacity current mileage driven, the province would need four more nuclear reactors (or many solar panels) to produce the requisite fuel.
p31Energy Consumption in Ottawa (2015)
These data do not correlate with OEE data. There is no mention of biomass which is a significant fuel in the largest rural city in Canada. Electricity is not a source of energy ... it is a pure sine-wave carrier. There is no mention of end-use applications.
p32only a small fraction of energy consumed in Ottawa is generated from local renewable sources. Of 114,000 TJ in 2015, 5% was generated within the geographic boundary. The remaining 95% was imported, which means Ottawa is reliant on and vulnerable to decisions made in domestic international energy markets.
There is no quantification of GreenHeat (thermal) technologies which produce a significant portion of local energy. It should be noted that the outflow of 95% to import energy imposes a negative cashflow on the City and residents.
p32Ottawans sent $2.5 billion in energy expenditures to companies not located within city. Of $3.0 billion spent annually on energy, only 17% or $510 million remains in the community as revenue for local businesses.
Cost estimates do not correlate with OEE data.
Does this mean that 5 HOL dams and 1,000 solar roofs generate $500m of electricity a year?
p40Solar, Wind and Water Power
Despite having more rural farm land in its 2,800 km2 boundary than any other city, Ottawa has not a single wind turbine. NRCan maps show our resource potential to be similar to Kingston and, even if generation costs more than other areas due to lower wind speeds, a price increment is partly offset by lower transmission costs due to proximity of load. There was no representative of any wind energy association or company on the Energy Evolution process, and it remains a mystery as to why wind turbines are so opposed.
p40solar power represents the greatest opportunity forrenewable electricity generation in Ottawa.
This report does not address storage, without which solar PV is seriously handicapped.
p412,300 buildings with 6.85 million m2 of roof potentially suitable for commercial solar power systems. Solar installations could add 1 GW of local renewable generation, providing electricity to power 150,000 homes.
If you are suggesting that solar PV should be used for direct replacement of baseboard electric heat, that is a major flaw in assumption. Solar PV is matched to CI demand profile, but many CI facilities do not operate on weekends - what happens to PV output at that time. Solar panels do not generate any electricity during peak TOU winter periods; where does the electricity come from during those periods? There is no mention of solar PV or solar thermal for space or water heating.
p42Build an 11 MW solar park at the Trail Road Waste Facility
In 2014, the Environmental Advisory Committee tabled detailed recommendations for action by Energy Ottawa when it applied for a FIT application at the Trail site. On the basis of that failed proposal, more rationale is required to justify this suggestion.
p42Spotlight on Virtual Net-Metering for Renewable Electricity.
This tool could remove the onsite generation limits in the current provincial net-metering framework. More examples are needed where this has been implemented.
p45 Biogasinjected into the natural gas grid as pipeline-grade renewable natural gas.
The Canadian Gas Association says 5% of biogas qualifies the fuel as “renewable natural gas” although 5% of car fuel is ethanol (not called renewable gasoline) and 6% of grid electricity is wind/solar (not called renewable nuclear) and co-firing with biomass was never labeled as renewable coal. Higher levels of government accept this term, but it should not be encouraged at city level due to its potential to confuse the market with true renewables.
p50Heat pumps are devices that move heat from one place to another. In air source, the heat pump draws heat from outside air; in ground source, heat is pulled from ground using an intermediary liquid such as glycol or water. Ground source are the most efficient but have higher capital costs. Some space is required for installation and in high density areas, there might not be enough heat source available to satisfy all the areas heating requirements.
Heat pumps “produce” renewable energy, in the same way as solar panels or wind turbines. GSHP do not use glycol or water; the medium is diluted denatured ethanol. Systems also provide space cooling, which combustion fuels do not. The co-efficient of performance for ASHP is 2.5 which drops once ambient temperature dips below -10oC; minimum COP for GSHP is 3.2; most are 4 and can reach 7. Where footprint is a limiting factor, vertical boreholes are drilled; the only system which has been constrained by insufficient resource is the Museum of Canadian History, which uses all the thermal energy in the Ottawa River and made it impossible for the War Museum to tap into the same source of energy. ASHP and GSHP are not similar and should not be included in the same discussion.
p51they present an opportunity to displace up to 20% of Ottawa’s heating fuels by 2050.
Conventional backup heat is usually required by an ASHP during peak TOU periods, so their effectiveness is limited. The GeoExchangeTM Coalition terminated dealer training which now is offered by the International Ground Source Heat Pump Association.
p52Seek opportunities to expand rebate programs for ASHP. These could include all fossil heating fuels (natural gas, propane, fuel oil) and could include retrofits and new builds.