Rule 007: Applications for Power Plants, Substations, Transmission Lines, Industrial System Designations and Hydro Developments

The Commission is interested in stakeholder feedback for requirements regarding end-of-life management for renewable energy operations. The draft changes to Rule 007 include the addition of the following two requirements:

• Submit a copy of the renewable energy operations conservation and reclamation plan (REO C&R Plan) prepared pursuant to the Conservation and Reclamation Directive for Renewable Energy Operations.
• Describe how the operator intends to ensure sufficient funds will be available at the project's end of life to cover the costs of decommissioning and reclamation activities. 
  

The Commission is interested in stakeholder feedback of the draft requirement for emergency response plans for power plants. The draft changes to Rule 007 include the addition of the following requirements:

·  Confirm whether the applicant has or will have an emergency response plan for the proposed power plant prior to operation. If no, please explain why an emergency response plan is not required.

·  If yes, please summarize the following:

o  The site-specific risks that were identified.

o  Any emergency mitigation measures that may be implemented.

o  Any site monitoring and communication protocols that may be put into place.

·  Identify the local responders and authorities that have been contacted or notified to date and those that remain to be contacted or notified. Describe any requirements or feedback received as a result of the consultation and notifications.

The Commission is interested in stakeholder feedback of the draft requirement for time extension applications for power plants. The draft changes to Rule 007 include the addition of the following requirements:

TE1)  Identify the sections of the Hydro and Electric Energy Act and Hydro and Electric Energy Regulation under which the application is made.

TE2)  Provide a list of the existing approvals for facilities affected.

TE3)  Provide a list of the original approvals for the affected facilities and describe the history of time extension approvals.

TE4)  Provide construction details including clarification whether construction has or will begin prior to the expiry date of the approval and the reason why the construction completion date will not be met.

TE5)  If construction will not have begun prior to the expiry date of the approval, a new noise impact assessment is required under Section 1.5 of Rule 012: Noise Control if one or more of the following conditions is satisfied:

(a)  The most affected dwelling(s) have changed; or

(b)  There are new energy-related facilities that may influence sound levels at dwellings located within 1.5 kilometres of the proposed facility boundary.

TE6)  Confirm that a participant involvement program in accordance with Appendix A1 of Rule 007 has been updated and provide details.

TE7)  If potentially directly and adversely affected persons raised any concerns, describe how the concerns were dealt with or will be dealt with.

TE8)  Provide mailing labels for stakeholders who had been notified as part of the participant involvement program. (If mailing labels were not used, i.e. in the case of a postal code drop, please provide details).

TE9)  Identify any new stakeholders that were not part of the original application.

TE10)  For a time extension to a solar or wind power plant approval, the application shall include:

(a)  Confirmation that the renewable energy referral report remains valid. If not, an updated renewable energy referral report from AEP Wildlife Management should be submitted or, alternatively, the proposed schedule should be outlined to ensure that the referral report is maintained as current until the project is constructed.

(b)  Confirmation that the project’s wildlife surveys remain current and do not require updating.

TE11)  For a time extension to a power plant approval that is not solar or wind power, the application shall include confirmation that the project does not require a wildlife survey or that the project’s wildlife surveys remain current and do not require updating.

TE12)  Confirm that the project can and will be constructed as approved and that no changes to the approved equipment are being contemplated. For projects that do not have major components of the power generating equipment selected, clarify whether the equipment has been selected or clarify when the equipment will be selected.

TE13)  For projects where a system access service request is required and has already been submitted to the AESO, provide an approved change proposal to confirm that the preferred transmission connection is still valid. If system access service request has not yet been granted, please provide an update on the status of the request.

TE14)  If the project is to be connected to the distribution system and a connection order was granted in the original application, confirm that the distribution system owner has no concerns with the new construction completion date.

The Commission is interested in stakeholder feedback regarding notification and the participant involvement program application requirements.

The following table summarizes the notification radii based on the type, size and location of the power plant. The proposed changes to the notification radii are in bold.

Type	Size	Location	Notification radius	Personal consultation
solar and battery	< 1 MW	urban	first row of occupied properties	N/A
		rural	800 metres	N/A
	1 - <10 MW	urban	first row of occupied properties	first row of occupied properties
		rural	800 metres	N/A
	≥ 10 MW	urban or rural	800 metres	400 metres
wind	< 1 MW	urban	first row of occupied properties	N/A
		rural	1,500 metres	N/A
	1 - <10 MW	urban	first row of occupied properties	first row of occupied properties
		rural	1,500 metres	N/A
	≥ 10 MW	urban or rural	1,500 metres	800 metres
thermal and other	< 1 MW	urban	first row of occupied properties	N/A
		rural	1,500 metres	N/A
	1 - <10 MW	urban	first row of occupied properties	first row of occupied properties
		rural	1,500 metres	N/A
	≥ 10 MW	urban or rural	2,000 metres	800 metres

The Commission is interested in stakeholder feedback of the draft requirement for solar glare impact assessment for solar power plants. The draft changes to Rule 007 include the addition of the following requirements:

Receptors

PPA)  Complete a solar glare impact assessment when receptors are located within 800 metres from the boundary of the project. Receptors include:

·  owned or rented dwellings^[1]

·  offices or similar workplaces

PPB)  If yellow graded or higher solar glare at a receptor is predicted to be at or less than 30 minutes per day and 30 hours per year at all of the receptors assessed, complete and submit a solar glare impact assessment summary form.

Note: The Commission is seeking stakeholder feedback on information that should be included in the solar glare impact assessment summary form, a draft form is available in consultation documents.

PPC)  If yellow graded or higher solar glare is predicted at a receptor for more than 30 minutes per day or 30 hours per year at any of the receptors assessed, the applicant must prepare and submit a solar glare impact assessment report and, where applicable, the report should include proposed measures to mitigate the solar glare for any affected receptor.

PPD)  Provide the solar glare impact assessment report, including any proposed mitigation measures, to the owner(s) or resident(s) of the receptor(s) affected. The applicant must submit a summary of discussions with the owner or resident and describe any outstanding concerns that the owner or resident may have.

Transportation

PPE)  Complete a solar glare assessment that predicts the solar glare at:

·  Critical points at highways and roads, where there is a line of sight to the front of the photovoltaic (PV) panel and the angle between the PV array and line of sight is less than 15 degrees.

·  Critical points at railways if there is a line of sight to the front of the PV panel and the angle between the PV array and line of sight is less than 15 degrees.

PPF)  If the solar glare impact assessment completed for PPE predicts solar glare at any of the receptors assessed, submit the solar glare impact assessment report, including any proposed mitigation measures, to Alberta Transportation and the county in which the project would be located. Submit a summary of discussions with the stakeholders and describe any outstanding concerns that they may have.

Aerodromes

PPG)  Complete a solar glare assessment that predicts the solar glare at runways, flight paths and air traffic control towers within three kilometres from the boundary of the project and within +/- 15 degrees between the PV arrays and the field of view from the control tower.

PPH)  If the solar glare impact assessment completed for PPG predicts solar glare at any of the receptors assessed, the applicant must submit the solar glare impact assessment report, including any proposed mitigation measures, to the owner of the airport, heliport or runway. The applicant must submit a summary of discussions with the stakeholders and describe any outstanding concerns that they may have. 

The Commission is interested in stakeholder feedback regarding shadow flicker requirements. The draft changes to Rule 007 include the addition of the following requirements:

PPA)  Complete a shadow flicker impact assessment that predicts the shadow flicker at any of the following receptors within 1.5 kilometres from the centre point of the tower of the closest wind turbine:

·  owned or rented dwellings[1]

·  offices or similar workplaces

PPB)  The shadow flicker impact assessment should assess theoretical shadow flicker and must include the following equipment-specific input parameters:

·  blade chord thickness

·  blade diameter

·  hub height

·  blade pass frequency

It must also include the following environmental input parameters:

·  minimum sun angle of three degrees

·  properties in relation to the turbine up to and including 50 degree latitude at 130 degrees either side of north

·  properties in relation to the turbine up to and including 55 degree latitude at 135 degrees either side of north

·  properties in relation to the turbine up to and including 60 degree latitude at 140 degrees either side of north

PPC)  If the shadow flicker impact assessment predicts that shadow flicker will occur at or less than 30 minutes per day and 30 hours per year at all of the receptors assessed, submit a shadow flicker impact assessment summary form. 

Note: The Commission is seeking stakeholder feedback on information that should be included in the shadow flicker impact assessment summary form, a draft form is available in consultation documents.

PPD)  If the shadow flicker impact assessment predicts that shadow flicker will occur for more than 30 minutes per day or 30 hours per year at any of the receptors assessed, submit a shadow flicker impact assessment report and, where applicable, the report should include proposed measures to mitigate the shadow flicker for any affected receptor. 

PPE)  Provide the shadow flicker impact assessment report including the proposed mitigation measures to the owner(s) or resident(s) of the receptor(s) affected. Submit a summary of discussions with the owner or resident and describe any outstanding concerns that the owner or resident may have.

The Commission is interested in stakeholder feedback regarding information required for all battery storage facilities. The draft changes to Rule 007 include the addition of the following requirements:

If the battery storage project is intended to operate as a transmission facility, a needs identification document application by the AESO is also required. Information required for a needs identification document application can be found in Section 6.

An applicant shall provide information required under Section 3.2 wherever applicable, and in addition:

BS1)  Indicate what the proposed battery facility is designed for and the function it serves.

BS2)  Provide the nameplate capacity and storage capacity of the project.

BS3)  Describe where the proposed battery facility is charged from and discharged to.

BS4)  Describe all discussions held with the AESO, Transmission Facility Owner, and/or Distribution Facility Owner regarding the interconnection of the proposed battery facility, including any concerns indicated and solutions proposed.

BS5)  Provide a single-line diagram for the project including the metering points for the proposed project.

BS6)  Describe the recycling plan for the energy storage system at the end of life.

BS7)  Provide an overview of the operator’s planned conservation, decommissioning and reclamation activities during construction and operation and at the end of the project’s operational life.

BS8)  Describe how the operator intends to ensure sufficient funds will be available at theproject’s end of life to cover the costs of decommissioning and reclamation activities.

BS9)  Provide information required under Section 5 if a connection order is sought.

During previous consultation, parties recommended that the buildable area concept should likely evolve into a “maximum impact scenario,” but did not elaborate on what this should entail. The AUC is interested in better understanding the maximum impact scenario proposed by stakeholders.

The Commission is interested in better understanding the maximum impact scenario proposed by stakeholders. In particular, the Commission invites parties to:

• Define the maximum impact scenario, including the specific parameters to be assessed under a maximum impact scenario application and provide rationale for including the parameters.
• Describe the potential requirements for a maximum impact scenario application, where changes in technology selection or site layout are made following receipt of an approval.
• Comment on the flexibility needed to accommodate rapidly evolving technology and changes to site layout, including any proposed changes to sections 3.4.2 and 3.4.3 of Rule 007.
• Suggest the point in time prior to construction that an applicant must confirm the selected technology, the finalized project layout, and that the project will not increase the impacts beyond those described in the application and approved by the Commission.
• Describe the circumstances that would trigger an amendment application, for example if the impacts increase from what was approved.

The Commission proposes the following changes to clarify requirements related to Nav Canada and Transport Canada submissions for renewable projects:

PP7) For solar and wind power plants, confirm that a land use proposal submission form has been or will be submitted to Nav Canada. For wind power plants, confirm that an aeronautical assessment form for obstruction evaluation and a final drawing of the wind turbine locations will be submitted to Transport Canada at least 90 days prior to the start of construction. 

The Commission considers that a reorganization of the information requirements in Rule 007 may provide further clarity to stakeholders, may reduce the time required for an applicant to prepare an application and may reduce information requests. The Commission is interested in receiving additional feedback on ways Rule 007 could be organized more effectively to make it easier to understand and to use. The Commission invites parties to comment on the pros and cons of the current organization of Rule 007 (or specifically with respect to power plant requirements) and whether reorganization is worth pursuing, given that it would involve further consultation.