|Posted by Winnipeg Chapter on April 23, 2018 at 10:35 PM|
About the NEB MMTP Hearings and Chapter
The Council of Canadians - Winnipeg Chapter is an Intervenor in the National Energy Board hearings on Manitoba Hydro’s proposed Manitoba-Minnesota Transmission Project.
Photo by Ken Harasym
The MMTP would be “500 kV alternating current international power line (IPL) extending from Manitoba Hydro’s Dorsey Converter Station in Manitoba to the international boundary between Manitoba and Minnesota (Dorsey IPL). The Dorsey IPL will connect with the Great Northern Transmission Line, a new 500 kV transmission line in the United States.” NEB Project Description
The Chapter is concerned about many issues when it comes to Manitoba Hydro, including hydro justice for northern communities, the environmental devastation resulting from Hydro’s control of waterways in Manitoba, and the urgent need to transition away from fossil fuels.
As Intervenors in the MMTP hearings, we chose to focus on two specific problems that are relevant to the proposal: 1) Cathodic protection and 2) Transition.
There is a very specific process that must be followed for Intervenors and the Applicant (in this case, Manitoba Hydro) during an NEB hearing. The Information Request is the primary method for expressing concerns and asking questions about a project.
Once Manitoba Hydro replies to the Information Request, the Intervenor can either accept Hydro’s response or can take the next step by filing a Motion to Compel Full and Adequate Response.
The Motion to Compel gives the reasons why the Intervenor is not satisfied with Hydro’s answers and asks the NEB to compel Hydro to take action.
The detailed and fully referenced Information Requests and all responses are part of the public record on the NEB Regulatory Documents website.
Information Request Overview
In our first Information Request, we asked Manitoba Hydro to clarify what they are doing to maintain cathodic protection for nearby pipelines, railways, and other infrastructure. We were satisfied with Hydro’s response and are not taking any further action.
Our second Information Request addressed Manitoba Hydro’s role in helping the province meet our obligations under the Paris Climate Accord.
We took the position that using surplus hydroelectricity to facilitate transition could be more economically feasible and have better environmental and socio-economic outcomes than using it to raise revenue through locked-in export sales.
This is a time of rapid and disruptive change in energy technology and economics. Electric vehicles, solar power, wind power, and storage batteries are becoming more accessible and affordable every day, at a pace far beyond expectations. It doesn’t make sense to plan within the limitations of an older framework that is quickly disappearing.
Manitoba’s Green Plan, Canada’s Framework on Climate Change, and the MMTP
In the 2017 Made-in- Manitoba Climate and Green Plan, Manitoba laid out its commitment to decarbonization through electrification. This strategy is an effective way to reduce emissions and meet climate change targets while strengthening and diversifying our economy. Under the Pan‑Canadian Framework on Clean Growth and Climate Change, all provinces are obligated to work cooperatively towards climate solutions. The Framework commits provinces and the federal government to direct more funding towards increasing the mode share of public transit and other energy efficient modes of transportation.
Advances in battery storage technology and the concurrent drop in prices will make electric cars, trucks, and public transit buses viable much sooner than could have been predicted only a few years ago. If the province follows through on its Green Plan and Framework commitments, there would be a market here in Manitoba and in the rest of Canada for all the “surplus” hydroelectricity produced. Under those circumstances, the MMTP export line could become no longer economically viable.
Facilitating decarbonisation through electrification within Canada
“The Canadian Energy Strategy is intended to strengthen the collaboration of provinces and territories in the transition to a low-carbon economy. It proposes ‘pan-Canadian, regional, and bilateral agreements’ on electricity transmission. It is likely that Manitoba would benefit in multiple ways from the success of such agreements.”
Our specific Requests to Manitoba Hydro
1) Estimate and explain how much increased electricity would be required for decarbonization through electrification for each of the following:
a. Electrifying all urban transit buses in Manitoba assuming presently planned fleet growth and replacement by purchasing only electric buses starting in 2020.
b. Electrifying all urban transit buses in Manitoba assuming greatly accelerated fleet growth to meet climate emissions targets (purchasing only electric buses starting in 2020).
c. Electrifying other buses and heavy trucks, with 100% of new vehicles sold being electric or plug in hybrid by 2025.
d. Electrifying other buses and heavy trucks, with 100% of new vehicles sold being electric or plug in hybrid by 2030.
e. Electrifying cars and light trucks, with 100% of new vehicles sold being electric or plug in hybrid by 2025.
f. Electrifying cars and light trucks, with 100% of new vehicles sold being electric or plug in hybrid by 2030.
g. Electrifying the main rail lines through Manitoba for both passenger and freight transportation by 2025.
2) Estimate and explain how much less electricity would be required for decarbonization through electrification if 90% of federal and provincial urban road expansion budgets were re-allocated to public transit and other forms of active transportation beginning in 2018.
3) Estimate and explain how much increased electricity would be required for decarbonization through electrification for each of the following:
a. Cancelling all planned expansions of the Manitoba natural gas distribution system, to be replaced with programs to decarbonize these areas through electrification and energy efficiency.
b. Eliminating fossil fuel burning for water and space heating (except emergency back up) in new buildings starting in 2020.
c. Retrofitting 5% of all existing publicly owned buildings per year that burn fossil fuels for water and space heating to electric space and water heat (except emergency back up) starting in 2019.
d. Retrofitting 2% of all existing privately owned buildings per year that burn fossil fuels for water and space heating to electric space and water heat (except emergency back up) starting in 2019.
4) Estimate and explain how much increased electricity would be required for both moderately aggressive and very aggressive programs of decarbonization through electrification in the commercial / industrial sectors in Manitoba.
5) Explain the results of efforts to negotiate bilateral, regional and/or pan-Canadian agreements on electricity transmission in the context of Canadian and provincial commitments to reduce greenhouse gas pollution. For example, is increased electricity transmission and trade with Ontario a near term possibility?
Manitoba Hydro’s response
“Manitoba Hydro stands by its answers to this IR.
The questions ask for information on various alternative scenarios which are not within the scope of the NEB hearing. These scenarios are not “alternatives” to meeting the needs of the project that are explained in Section 3.1.3 of the Application. They are also not “alternatives” as defined in Section 4.5 of the NEB Electricity Filing Manual - “functionally different ways of meeting the need and purpose of the project, or are other technically, economically, socially and environmentally feasible means of fulfilling the project”.
Further, and in the alternative, Manitoba Hydro does not have access to the third party information that would be required to do the analyses requested.”
The Chapter can either accept Manitoba Hydro’s inadequate and dismissive reply, or it can reply for a final time. We are preparing our reply now. After that process is complete, we have a brief window to present written evidence, followed by the oral portion of the hearing where (if we choose) a Chapter representative can briefly speak and ask and answer questions.
Are you interested in transit, transition, and climate solutions? Please complete a brief survey to let us know where you stand.
Contributor: Mary Robinson - Council of Canadians Winnipeg Chapter Chair