Closing Statement from TREE and RCM Regarding the
Need for and Alternatives to Wuskwatim Advancement
June 8, 2004
The purpose of our intervention
Time to Respect Earth’s Ecosystems (TREE) and Resource Conservation Manitoba (RCM) are non-government organizations committed to the advancement of a more sustainable society in which our planet’s natural endowments of living and non-living systems and resources are valued, respected and conserved. Recognizing that this natural legacy is finite and subject to degradation and depletion, we promote eco-efficiency – improving the ratio of social benefits to environmental harms and resource depletion – as an essential pillar of a sustainable society.
In our presentation on May 13th, we argued that concern for the environment and long-run sustainability generate a social imperative first for energy conservation and efficiency measures and second for least-impact generation options.
We also noted that Canada’s standing, relative to other OECD countries, in per capita energy consumption (27th out of 29, ranked from lowest to highest) and energy efficiency (28th out of 29, ranked from least to most energy used per dollar of GDP) indicates that we are global energy hogs. Canada’s energy use is 50% higher than countries with similar climates, namely Sweden. [1] These figures intensify the conservation imperative and pose the question: To what extent is our socio-economic climate well adapted to promote energy conservation?
High energy usage should provide a powerful incentive and opportunity for energy conservation, but we concluded on the basis of our experience in the 2002 Manitoba Hydro rate hearing before the PUB that Manitoba’s poor showing is not simply owing to our physical climate and geography. Rather it is attributable in part to perverse economic incentives, inadequate conservation investments and regulations, and policy failures. To simplify somewhat, as a society, instead of looking at our high usage and asking, How can we achieve the same social benefits more efficiently, with less energy consumption?, we have asked instead, How can we keep rates low? To do this, we have been prepared to divert great sums of Manitoba’s wealth in the form of foregone taxes and allocation of export earnings to subsidize domestic energy rates. Indeed, part of the Wuskwatim justification is to be able to maintain that subsidy in order to keep rates low.[2] Because low rates to consumers have trumped and, to some extent, replaced energy efficiency goals, it is no wonder that Canada’s energy profile has continued to worsen relative to other OECD countries.
Despite the above shortcomings in application, we note more optimistically that in Manitoba the social imperative to conserve is enshrined in the Manitoba Hydro Act and the Sustainable Development Act, as we discuss in the next section. Thus TREE and RCM have intervened in these hearings in response to the social imperative and legal requirement to prioritize conservation and least impact generation alternatives. Our determination to intervene was strengthened by consideration of Canada and Manitoba’s poor showing in global comparisons and the failures in resource pricing and energy policies to promote conservation.
A legal framework for our intervention[3]
Section 2 of The Manitoba Hydro Act, which provides the legal foundation for Manitoba Hydro, declares that:
The purposes and objects of this Act are to provide for the continuance of a supply of power adequate for the needs of the province, and to engage in and to promote economy and efficiency in the development, generation, transmission, distribution, supply and end-use of power . . . . [underlining added]
And Section 2 of The Sustainable Development Act states that:
The purpose of this Act is to create a framework through which sustainable development will be implemented in the provincial public sector and promoted in private industry and in society generally. [underlining added]
Section 1 of the Act specifies that a “provincial public sector organization” means . . .
a board, commission, association, or similar body whether incorporated or unincorporated, all the members of which, or all the members of the board of management, board of directors or other governing boards, of which are appointed by an Act of the Legislature or by the Lieutenant Governor in Council, to which this Act has been made applicable by regulation; [underlining added]
The Sustainable Development Act, therefore, clearly applies not only to Manitoba Hydro, but also to the Public Utilities Board and the Clean Environment Commission.
Appended to The Sustainable Development Act are principles and guidelines of sustainable development (Schedules A and B of the Act). Particularly relevant to the examination of alternatives to Wuskwatim in the current hearing is the first of the guidelines:
1 Efficient Use of Resources - which means
(a) encouraging and facilitating development and application of systems for proper resource pricing, demand management and resource allocation together with incentives to encourage efficient use of resources; and
(b) employing full-cost accounting to provide better information for decision makers.[4]
The Stewardship principle expresses the notion of planning for the long run and promoting intergenerational equity:
2(1) The economy, the environment, human health and social well-being should be managed for the equal benefit of present and future generations.
2(2) Manitobans are caretakers of the economy, the environment, human health and social well-being for the benefit of present and future generations.
2(3) Today's decisions are to be balanced with tomorrow's effects.
The principle of Global Responsibility directs that
7 Manitobans should think globally when acting locally, recognizing that there is economic, ecological and social interdependence among provinces and nations, and working cooperatively, within Canada and internationally, to integrate economic, environmental, human health and social factors in decision-making while developing comprehensive and equitable solutions to problems.
Together, these three principles imply that Manitoba Hydro’s energy planning should be developed against a backdrop of global long-run energy scenarios that include analyses of resource availability, limits and constraints; environmental loadings and impacts; and socio-economic consequences of alternative paths that can be taken. Planning should identify the preferred sustainable futures to which the utility can contribute. Efficiency improvements will be a primary component of any preferred path.
Because ever-rising trends in energy consumption and production cause incremental harms and face global limits, a sustainable scenario must contemplate the leveling of and possible decline in available energy and thus in aggregate customer consumption. Hence we argued in our May 13 testimony that it is not too soon for Manitoba Hydro to sketch an end-game for the province once the hydro-electric potential of the Nelson is fully installed. Indeed 3,700 MW of the existing Nelson River capacity came on line in the short space of 16 years from 1974 to 1990[5]. A similar building binge, such as is currently contemplated by Manitoba Hydro and the provincial government, could come close to completing the job in a comparably short time.
For these reasons, alternative resource plans are to be assessed for their sustainability and eco-efficiency, i.e. achieving the greatest long-run human benefits with the least degradation of resources and the environment, both locally and globally. We also believe that conservation alternatives hold the best prospects for long-run economic stimulation and jobs and the improvement of Manitobans’ homes, institutions and businesses.
Summary of TREE/RCM evidence, observations and conclusions
To develop our intervention, we engaged Torrie Smith Associates (TSA) to help us with the analysis of Manitoba Hydro’s case for advancing Wuskwatim through a consideration of the need for and alternatives to the project (NFAAT). In particular we wondered if a case could be made that more aggressive DSM programs and policies combined with distributed generation, including non-utility generation, might provide a viable alternative to Nisichawayasihk and Manitoba Hydro’s Wuskwatim advancement project that would better satisfy the principles of sustainability. We also provided evidence from our 2002 intervention before the PUB on Manitoba Hydro rates.
Below, under several headings, we summarize our evidence, further observations, comments and conclusions in point form. We examine in turn: (1) NFAAT analysis and sustainability, (2) Load forecasting, (3) DSM and NUG analysis and programming, (4) Alternatives to Wuskwatim, and (5) Perverse incentives and subsidies.
NFAAT analysis and sustainability
· Regardless of possible future energy requirements of Manitobans, Wuskwatim advancement is not needed at this time for domestic power supply, as indeed MH acknowledges.
· The “Need” for Wuskwatim advancement (as defined by MH and NCN) is to maintain, in the face of rising domestic consumption, sufficient electricity surplus to domestic use to supply the “estimated on-peak export market” of 10,500 GW.hours.
· Thus an NFAAT analysis of Wuskwatim advancement should examine, compare, and evaluate in some depth alternative portfolios containing conservation and generation options capable of meeting this need, some of which include Wuskwatim and some not.
· “Manitoba Hydro interprets ‘alternatives to’ to involve a demonstration that the project is more beneficial than other projects either similar in nature or significantly different but in all cases serving to meet the same need….”[6]
· Yet Manitoba Hydro has neither defined nor analyzed alternatives to Wuskwatim Advancement in its NFAAT filing and subsequent responses.[7]
· Sensitivity analyses to show that Wuskwatim is still viable under a range of assumptions is not a substitute for an NFAAT analysis that shows it is a preferred option or part of a preferred portfolio (TSA Feb. 10, p. 7).
· In the most recent Manitoba Hydro Rebuttal of TREE/RCM’s interrogatory responses, there is considerable new information and analysis, but there is nothing new in the thinking or approach to the NFAAT question. No alternative strategies for meeting the objective of Wuskwatim Advancement are identified or analyzed, except to the extent the Rebuttal does contain comments on the one alternative to Wuskwatim that was put before the CEC, namely the TREE/RCM illustrative scenario.
· The identification and comparative analysis (including risk analysis) of such alternatives should be an important element of Manitoba Hydro’s investment planning strategy, as well as the basis for the analysis of the need for and alternatives to Wuskwatim Advancement. What is needed is a proactive and thoughtful approach to the market, focused on the horizon, driven by the principles of sustainable development, and informed by a deep understanding of the business and technological possibilities on the demand side.
Comment:
We believe that this critique is essentially correct and is confirmed by the Econalysis testimony that MH failed to conduct an analysis of alternative portfolios, as described by the BC Utilities Commission. To these points we would add the importance of linking NFAAT analysis to principles of sustainability.
· Manitoba Hydro’s planning, investments, and operations are, by law, subject to the principles and guidelines of conservation and sustainability, as elaborated above, so the NFAAT analysis should be well-grounded in these principles and guidelines.
Ø In particular, an NFAAT analysis accompanied by a sustainability analysis should include longer range energy scenarios that address limits to global energy supplies, limits to Manitoba’s hydroelectric capacity, and transitions from increasing energy consumption and production trends to a more sustainable containment of consumption within long-run sustainable supplies.
Ø Manitoba Hydro conceives of Wuskwatim as the first in a series of dams to provide a succession of construction employment opportunities, which could rapidly use up remaining sites with hydroelectric potential on the Burntwood and Nelson rivers. Thus it is not too soon to ask Hydro to provide an end-game analysis for energy supply and demand when the feasible and economic potential is exhausted. The continuous growth in energy production and consumption is not a sustainable trajectory.
· Likewise the CEC review of Manitoba’s planning and investment proposals are, by law, subject to the same principles and guidelines of sustainability.
· Hence, while the export of power is contemplated in the Manitoba Hydro Act, provision of power for export must adhere to the principles of sustainability.
Ø The case for export would be stronger if the power were to be sold into jurisdictions likewise committed to sustainability, including adherence to the Kyoto protocol for GHG reduction. Otherwise there is a concern that the exported power might be incremental to unsustainable fossil fuel generation rather than displacing it.
Ø Likewise the case for export would be stronger if Manitoba Hydro’s increased export capacity was to be used to firm wind generation. Otherwise there is a concern that the exported power might displace wind generation in export markets rather than supporting this relatively low-impact technology. However the operational design of Wuskwatim precludes significant storage, and thus firming capacity, at this site.
Ø In addition, the case for providing socio-economic benefits to Manitoba through export earnings would be stronger were the export earnings not to be used to subsidize the wastage of energy in Manitoba, which the current rate design and cost allocation methods encourage. For example, the largest customers pay only 1.975 cents/kw.h for incremental energy consumed as long as it does not add to demand (http://www.hydro.mb.ca/your_service/er_monthly_rates.shtml#generallarge). This is far from the marginal cost of new generation and transmission and of export earnings foregone and less than a third of the 6.15 cents/kw.h at which Manitoba Hydro values DSM savings.
Load forecasting
· Manitoba Hydro adopts a forecasting approach to planning, which extrapolates the future on the basis of high level econometric trends, as opposed to a scenario approach based on end-use analyses under varying assumptions about changing relationships between trends and end-use variables. The very term “load forecasting” reflects the passive approach to electricity demand (something to be forecast, like the weather) that characterizes the traditional utility business culture.
· Ideally, load forecasting should be based upon scenario analyses with an end-use model. The electricity market is in a very dynamic state, and once stable relations between demographic and economic activity and electricity demand are changing rapidly. Business planning for sustainable development requires thinking about alternative futures -- backcasting rather than forecasting -- as a central element of investment planning strategies.
· The latter approach is to be preferred because it is less deterministic, provides a richer understanding of the factors affecting energy consumption and can guide energy service opportunities and DSM interventions.