On December 6, 2011, the Government of Alberta announced the creation of an independent panel of experts to review plans for two high-voltage transmission lines between the Edmonton and Calgary regions. To view the news release, click here. The Critical Transmission Review Committee (CTRC) will deliver recommendations to the government by February 10, 2012.
To accomplish this task, the CTRC requested information from several stakeholders, including the AAMDC. Based on short timelines, the AAMDC used established positions and resolutions to form its submission. The main points communicated by the AAMDC to the CTRC include:
- The AAMDC does not have the technical expertise in-house to respond to questions surrounding the reasonableness of load and generation forecasts, or those surrounding the ability of the north-south transmission reinforcement plan to serve existing and new generators and load. Given the short timeframes for response, the AAMDC encouraged the committee to speak directly with affected rural municipalities who may have studied these technical aspects in more detail.
- The AAMDC understands that high voltage direct current (HVDC) technology requires a smaller footprint and right-of-way when compared to equivalent AC lines. This means it is possible to scale infrastructure for load increases without the same degree of footprint increase requirements, thus having a smaller impact on land owners along the right-of-way path.We view this as a positive aspect of the HVDC technology.
- The AAMDC understands the need to address issues of reliability and line losses in certain areas of the province. However, increased transmission costs resulting from the construction of these lines without sufficient benefit in the short and medium term will have negative economic impact on residents, institutional, commercial and industrial stakeholders. The AAMDC believes that the construction of the north-south transmission lines should be undertaken when short and medium-term benefits can be realized.Transmission infrastructure should not be overbuilt in excess, but should realize benefits in the nearer-term.To this end, the AAMDC believes that the provincial government should put all critical transmission projects on hold until a comprehensive cost benefit review is completed.
- The AAMDC’s concerns related to the Electric Statutes Amendment Act, 2009 centre on respect for property owners and power consumers. Landowner input must be sought in major decisions that will affect property rights, and critical transmission infrastructure definitely affects property rights.As such, cabinet power must never supersede the necessity of appropriate consultations with affected Albertans.
- In addition, the AAMDC is concerned with the potential ramifications of cabinet-approved critical transmission infrastructure as it relates to the cost of electricity to consumers.A detailed cost-benefit analysis must be done prior to the approval of transmission infrastructure.And, importantly, once a project is deemed to be worthwhile from a cost-benefit and future transmission capacity perspective, the costs must be monitored.To this end, the AAMDC reiterated its positions previously submitted to the Transmission Facilities Cost Monitoring Committee:
- The AAMDC is concerned that transmission facilities projects are exceeding initial estimate budgets by significant margins, and believes there is a need to improve cost estimate quality and accountability.
- While cost increases and scope changes may be justifiable in many instances, project approvals are based on cost estimates that are not representing final costs.As the party responsible for absorbing the cost increases, consumers are not being adequately represented in the approval processes.
- The AAMDC is supportive of the intent of the 6 recommendations outlined in the June 2011 report from the Transmission Facilities Cost Monitoring Committee.
- Further, the AAMDC recommends that competitive bidding processes be required for both the construction and the operations of transmission projects, regardless of boundaries.
The AAMDC’s main messaging in this submission to the CTRC was that the approval of all transmission projects (critical or otherwise) must consult with landowners, respect private property rights, undertake cost-benefit analysis, and control costs moving forward. Cabinet powers of approval must be designed to respect these important aspects of transmission infrastructure approval.
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