Documents
January 18, 2006
Mr. John Zych
Board Secretary
Ontario Energy Board
P.O. Box 2319
2300 Yonge Street
Toronto, Ontario
M4P 1E4
BY E-MAIL
re: CanWEA Response to File EB-2005-0528
Dear Mr. Zych,
The Canadian Wind Energy Association represents over 230 companies, including manufacturers of wind turbines and components, wind energy project developers, and service providers to the wind energy industry.
In times of low wind, or during maintenance, a wind turbine will consume a small amount of power to run computers, communications, hydraulics, yaw motors, heaters and radiator fans. When a turbine is generating, its power curve (or rated output) is net of power consumption, so it does not draw power from the grid at that time. Commercial scale wind turbines produce power 70-80% of the time, with output ranging from a small amount to the full rated capacity of the turbine. A typical wind turbine will produce 100 times more power than it consumes in a given month. Its consumption and peak load are very small. A 1.8 MW turbine may have peak load of 27kW, with a resting consumption of as low as 5 kW. Wind turbines are principally suppliers of power to the system, and any consumption is purely incidental. As such, wind turbines are not typical demand customers and should not be treated as other loads.
Accordingly, CanWEA strongly supports the interim rates proposed in the rate application (EB-2005-0528) because it is sound policy, and believes it is especially important that this measure be implemented in order to accommodate the upcoming Standard Offer Program currently being developed by the Ontario Power Authority. This proposal would eliminate the basic monthly charge for 27.6 and 44kV lines ($40-$250/mo), but leave in place the demand charges as well as the volume based usage charges for power consumed.
CanWEA supports this rate application for the following reasons:
* Electricity generated by a wind project on a distribution feeder is mostly consumed on that feeder, or adjacent feeders, thus reducing the line losses of power that would otherwise have come from the transmission system. This reduction in line losses is passed on to consumers, and any increase in their rates due to loss of revenue from the monthly charge is more than offset by line loss reductions. Line losses in rural Ontario average 9% (27.6 kV system), and so saving even part of these losses results in considerable savings for consumers.
* The revenue loss to the utility is miniscule - $160,000 annually. But the cost savings for the rate payer may well exceed this.
* Under the Distribution System Code, connection capital costs, including the cost to study the connection, are paid for by the Generator. Hydro One has no incremental capital deployed to accommodate Generators connected to the distribution system. Any demand charge should be purely to pay for the power consumed.
* Distribution connected projects utilize existing infrastructure, as an alternative to larger transmission connected generation. There is no need to add new transmission capacity to accommodate projects connected to existing distribution feeders.
* Distribution connected projects, where the power is consumed locally, reduces the utilization of the transmission system, reducing costs. Excess utilization of the transmission system can cause its premature failure, leading to costly upgrades.
The CanWEA member who initiated the request for this change on behalf of all CanWEA members, Glen Estill of Sky Generation, began discussions with Hydro One on the current discriminatory tariff in Jan 2004. Because of the length of time it has taken Hydro One to act to correct this tariff, and to partially compensate the pioneers in the Distributed Generation market, we propose that the change be imposed retroactively to Jan 1, 2005.
We thank you for your attention to this matter and we look forward to your response.
Yours sincerely,
Robert Hornung, President
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