3.2. Extending the amount of time into the future, and thus the number, of new unabated gas plants that will benefit from less stringent EoPL provisions is bad.

Under the Draft CERs, any gas plant that begins operation before 1 January 2025 would be able to operate unabated for a period defined as its “End of Prescribed Life” (“EoPL”).  The EoPL would be 20 years from the date that it starts to operate or 2035, whichever is longer.

The Public Update states,

Consideration is being given to allowing units that have substantial investment and work underway but are unable to commission by January 1, 2025 to make use of the EoPL provisions provided they start selling electricity to the grid by a future date to be determined. The duration of these units’ prescribed lives would be shortened commensurate with their delay in commissioning past 2025 so that such units would become subject to a regulated annual emissions limit no later than a unit commissioned by January 1, 2025. This would avoid adverse impacts on investment decisions that have already been made.^[81]  [Emphasis added.]

Exactly what will be the “future date to be determined?  Without knowing that, citizens, even those with expertise in GHG emissions from gas plants and the operation of the electricity grid, cannot determine, and thereafter comment upon, the impact of the extension of the commissioning deadline to some unknown date beyond 1 January 2025.

In its submission to the consultation on the Draft CERs in Canada Gazette I, the AESO stated:  “Large-scale dispatchable generation investment is at risk due to investor uncertainty created by the draft CER and impracticable 2025 deadline.”^[82]

That is absurd.  If there is a need for electricity from gas plants, the market will fill that need.  If that electricity must come from gas plants from which their GHG emissions are abated by CCS, the market will fill that need, at whatever cost the market will bear.  Both the need and the cost will be heavily influenced by how much of the need can be filled by clean renewable generation.

For Alberta, Wikipedia currently lists two gas plants, each having a capacity of 450 MW, and one gas plant having a capacity of 1360 MW that are scheduled to be commissioned in 2024.  Wikipedia also lists one gas plant having a capacity of 100 MW scheduled to be commissioned in “202x”.^[83]

For Ontario, Wikipedia currently lists one gas plant of any real significance, with a capacity of 280 as being under construction, with no commissioning date given.^[84]  However, Capital Power is in the process of constructing a 100 MW gas plant near Windsor,^[85] which appears to be the gas plant expansion approved by Windsor City Council in January 2023.^[86] The IESO has also signed a contract with a gas plant operator to increase the capacity of the Brighton Beach gas plant from 45 MW to 584 MW.  That increase will probably not be operational until after 1 January 2025. ^[86.5]

While it might be somewhat objectionable that this relatively small number of new plants might be permitted to make use of the EoPL provisions if the date is moved from, say 1 January 2025, to 1 January 2026, there is a much more dangerous possibility, which would be completely unacceptable, and which we must work strenuously in our submissions to ensure that it does not transpire.

In Ontario, through its E-LT Procurement and its LT1 Procurement the IESO is seeking the construction of 1,500 MW of new gas capacity.^[87]   In its 15 December 2022 Pathways to Decarbonation, published on 15 December 2022, the IESO states its intention to have this 1,500 of new gas plant generation commissioned by the end of 2027.^[88]  It is doing so by offering an “Early COD [Commercial Operation Date] Payment Multiplier” that offers higher payments for gas plants that are commissioned, i.e. commence commercial operation, by 31 December 2027 and an even higher COD Payment Multiplier for gas plants that commence commercial operation by 31 May 2027.^[89]

CBC News summarized the situation this way:

The province’s current call for new sources of electricity allows for up to 1,500 megawatts from natural gas-powered facilities. To put that in context: that’s the same capacity as Ontario’s biggest hydroelectric dam, the Sir Adam Beck II Generating Station near Niagara Falls.

Once the new facilities are operating — expected to happen by 2027 — Ontario could put a moratorium on building new gas plants for electricity, the IESO reported last fall.  But the agency says the province can’t completely phase out the use of natural gas in the electricity  system until 2050.^[90]

It would be hard to over-emphasize the significance of this 1,500 MW of new gas plant capacity that they IESO wants to be operating by the end of 2027, as it pertains to the proposal in the Public Update to extend the deadline for making use of the EoPL beyond 1 January 2025 to “a future date to be determined”.  While having only 4,883 MW of installed wind turbine capacity and only 478 MW of installed solar capacity, Ontario currently has an installed capacity of 10,470 MW from gas plants and oil plants (while oil does not appear to figure prominently in the mix, the IESO has lumped them together as “gas/oil”),^[91] the IESO wants to have another 1,500 of gas plant capacity operational by the end of December 2027.  That is a 14% increase from current gas capacity.  That additional gas capacity will also represent over 30% of current wind capacity.

ECCC needs to reduce GHG emissions from electricity generation, not make things easy for profit-seeking gas plant operators and for systems operators who are actively resisting or avoiding employing their provinces’ enormous renewables potential.

Under no circumstances should Ontario be allowed to slip in and get the benefit of the EoPL provisions because it has “substantial investment and work underway but [is] unable to commission by January 1, 2025”.

We must not let this happen because the ECCC is not talking about “a future date to be determined”.

In our submissions, we must insist the only gas plants that should be able to make use of the EoPL provisions are those that are in fact able to commission by 1 January 2025.  Also, in any event, ECCC must not permit the “future date to be determined” to let the new 1,500 MW of gas plants that the IESO wants by 2027 to make use of the EoPL provisions.

By talking only about the cut-off date being only “a future date to be determined”, we have no idea how many new unabated gas plants might be commissioned before the cut-off date.

The Pembina Institute addressed this issue in its submission on the Draft CERs:

The CER must ensure that any electricity emissions in 2035 and beyond are addressed with credible, verifiable, additional and permanent offsets, in order to achieve a truly net-zero grid by 2035 that is credible to investors, Canadian citizens, companies with ESG goals, civil society, and the international community.^[92]

3.2.1.  Again, since GE Vernova says that 95% abatement from gas plants using CCS is already possible, there is no excuse in 2024, let alone 2025 or any time thereafter, for anyone to commission a gas plant that is either not abated using CCS or that cannot be made abated by using CCS by 2035

As discussed under the section on the proposal to extend the End of Prescribed Life (EoPL), GE Vernova, currently a subsidiary of the General Electric Corporation (although there might seen be a corporate “spin-off”)^[93],  is advertising equipment and processes that it states can reduce gas plant emissions by up to 95%:

GE Vernova’s carbon capture solutions are available.  Our financial services team can help develop a successful capital plan.  GE Vernova is a proven technology integrator, ready to support your decarbonization journey.^[94]

GE Vernova further states:

The U.S. Department of Energy awarded $5.7 million for a GE-led carbon capture technology integration project aiming to achieve 95% reduction of carbon emissions. The project includes collaboration with Southern Company, Linde, BASF, and Kiewit. We will develop a FEED study with advanced technology and control concepts to integrate Southern Company subsidiary Alabama Power’s James M. Barry Electric power plant with Linde’s Gen 2 carbon capture solution based on BASF’s OASE® blue gas treatment technology. This study will serve as a template for lowering carbon emissions for other 7F gas power plants worldwide.^[95]

In 2024, let alone 2025, there is excuse for anyone to commission a new gas plant that either is fully abated using CCS or that can be made fully abated using CCS well before 2035.

3.2.2  Suggestions for your submissions on extending the 1 January 2025 deadline

• The deadline for when gas plants must begin operation to benefit from the 20-year End of Prescribed Life exemption, thereby not having to meet the main performance standard by 2035, must not be extended beyond the current deadline of 1 January 2025.  There is no reason why anybody should commission a gas plant in 2024, let alone 2025 and beyond, that does not either have CCS abatement in place at the time of its commissioning or that cannot accommodate CCS abatement technology before 2035.
• Under no circumstances should the deadline for when gas plants must begin operation to benefit from the 20-year End of Prescribed Life exemption be extended until the end of 2027, which would let almost all of Ontario’s planned new gas plants be exempted from the core effect of the Clean Electricity Regulations.
• GHG abatement using Carbon Capture and Storage (“CCS”) is already feasible and available.  It will certainly be even more effective and more available by 2035.  No gas plant commencing operation after 1 January 2025 should be exempted from the rule to operate at or below the emissions intensity standard achievable through CCS at any point beyond 2035.