Hydro policy generates confusion

John Spears
The Toronto Star
July 22, 2000

Well, something is going to happen to change the way Ontario residents and businesses buy their electricity.

Only a few nagging issues remain to be resolved – such as how much residents and businesses will pay for electricity, and whether they’ll be better or worse off.

The past month hasn’t made it any easier to figure out.

In short order:

Energy Minister Jim Wilson blasted municipal utilities for trying to hike rates too much. He then introduced Bill 100, to “prohibit municipalities from taking windfall profits” from their local hydros.

Wilson also announced a delay in opening the competitive electricity market – which will allow electricity customers to buy power from any generator or broker that can offer an attractive price. The market had been scheduled to open in November. Wilson said the delay would be up to six months. Shortly afterward, Premier Mike Harris said it could be nine months.

Reacting to Wilson’s statements, the Ontario Energy Board blocked an application for a 6 per cent interim rate increase from Toronto Hydro.

Ontario Power Generation – one of the pieces into which the old Ontario Hydro was split – leased the Bruce nuclear generating station to British Energy PLC for 18 years.

Meanwhile, the Ontario Cabinet has quietly extended special, low electricity rates to a clutch of businesses who had enjoyed special deals with Ontario Hydro. They’ll continue to enjoy lower rates for up to four years. Wilson’s office refuses to release a list of the businesses getting the special break. Pressure for rates to go up, instead of down, is contrary to the promises that a competitive electricity market would benefit consumers.

If Ontario politicians and consumers are bewildered and frustrated they’re not alone: Rates in the U.S. zoomed this week as deregulated utilities charged higher prices in peak demand periods.

Jan Carr has watched the electricity issue for many years. Vice-president of consultants Acres International Ltd., he served on a special committee whose recommendations led to the competitive market we’re moving toward.

Carr said in an interview that the province seems to be losing its focus as it hits the inevitable bumps in the transition from the old monopoly run by Ontario Hydro to the new competitive market.

“That transition could be managed,” Carr said. “We seem to have stopped focusing on managing the transition, and are focusing on eliminating the transition instead.”

Terminology surrounding the new market also is confusing. It’s often referred to as deregulation of the electricity market.

That’s not really the case: All transmission and distribution rates must still be approved by the Ontario Energy Board.

But local utilities are now set up like private corporations, trying to earn a return on their assets. And the old Ontario Hydro has been broken up, with its transmission grid, known as Hydro One, separated from its generating side, called Ontario Power Generation.

“Re-regulation is probably a better word,” said Paul Calder of Canadian Bond Rating Service, which issued an analysis this week.

Some of the political rhetoric has also implied that the market is moving toward privatization of the electricity system.

Certainly, the long-term lease of the Bruce nuclear plant put operation of a major facility in the hands of a private company. But a provincial corporation remains the owner – and will ultimately be responsible for decommissioning and clean-up costs.

Moreover, the biggest buyer of local utilities, which own the wires that carry power to homes and businesses, has been Hydro One – whose sole shareholder is the Ontario government.

In these circumstances, private investors aren’t likely to put money into the electricity sector because they don’t know the rules, said Carr.

For example, Bill 100 seems in its wording to limit the rates of utilities owned by municipalities – but not private companies. But no one is quite sure.

“Clearly if you’re in the private sector and you’re thinking of investing in the industry, you’re sure as hell not going to invest until that little wrinkle is sorted out,” said Carr. “And that won’t happen until the fall.”

A spokesperson for Wilson, who is on vacation, didn’t lay the uncertainty to rest.

No private sector firms control municipal utilities, he noted, which is why the legislation refers to the public sector. But private firms could still face controls.

“If new owners didn’t see the long term benefits of keeping rates reasonable, the minister retains the option of intervening,” he said.

Calder also cites political uncertainty for keeping private buyers out of the market.

“They’re on the sidelines already, and this probably keeps them there even more firmly.”

Calder’s analysis shows a clear winner: Hydro One. It has already snapped up 40, mostly smaller, local utilities and has bids in for another 80.

It has a huge advantage over private investors, Calder said. The province has slapped a 33 per cent transfer tax on any municipal utility sold to a private sector firm or fund. Hydro One is exempt from that tax.

That “effectively renders Hydro One the prime candidate” to buy up local utilities, his report states. But it flags a danger: Given the lack of a real market Hydro One may overpay.

In tandem with Bill 100, Wilson has instructed the energy board to give “primacy” to the interests of customers when it determines rates.

That seems to limit the return that utilities can earn on their assets, Carr pointed out.

“The utility has to borrow money and find equity,” said Carr. “They’re going to be in a very awkward position to do that if they’re not allowed to earn a return on equity.”

Moreover, municipal utilities now in effect have to pay provincial tax on income. Taking on debt cuts their tax exposure, and is a common private sector financing strategy. But Wilson is flaying the local utilities, oddly, for acting like private sector firms. Dale Richmond, who runs the $35 billion Ontario Municipal Employees Retirement System (OMERS) pension fund, is on record saying he knows of utilities that have sought private investment, but failed to attract any because of the uncertainty.

OMERS owns 10 per cent of Mississauga Hydro, but plans to merge the utility with a clutch of other 905 area-code utilities have stalled in the uncertain climate.

Peter Dyne of the Consumers Association of Canada said that preventing utilities from generating a satisfactory return may violate the intent of laws governing corporate behaviour.

It also violates the rules of economic logic, he argued.

Earning a satisfactory rate of return is the incentive for businesses to operate efficiently, he said.

If the utilities are thwarted from earning their targeted rates of return, what incentives do they have to operate at maximum efficiency? he asked.

Tom Adams of Energy Probe argues that encouraging utilities to incorporate and seek a higher rate of return for their municipal shareholder-owners was bound to create pressure for higher rates.

Dyne said that there will be some thorny issues for the regulator to sort out even in defining rates of return.

For example, many municipalities require developers to pay extra so cables can be buried in new subdivisions. That creates a higher asset value for the utility.

Should utilities be allowed to earn a return on those “contributed assets?” Dyne asked. If so, they’ll have to raise rates.

Toronto city councillor Jack Layton, who is vice-chair of Toronto Hydro, is furious with the mixed signals from the province. Toronto Hydro felt the sting of the new policies when the energy board denied its rate increase on the basis of Wilson’s order.

Layton sees a bias toward privatization.

“If we’re a publicly owned business they won’t let us have a return on our investment. Only if we’re a privately owned business,” Layton said in an interview.

“They’re trying to accomplish the privatization that we refused to enact.”

Whether or not privatization is the ultimate agenda is hard to say.

But Carr – who had a hand in shaping the policy – said competition doesn’t have to mean privatization.

“What is needed is competition,” he said. “The fundamental thing is to create choice. When customers have choices and they vote with their pocketbook, then the industry will go in the direction people want it to go.”

If municipally owned utilities can do better than private ones, there’s no reason to intervene, Carr said. Wilson is right to blow the whistle on municipalities that suck dividends out of their electrical utilities to fund recreation programs,he said.

But he said Wilson should stay out of the fray if a city borrows responsibly against its hydro utility to fund capital improvements to other assets, such as roads or transit systems.

“I would prefer the minister tell them what to do with the money, rather than tell them how much money they may have, which is what they are now doing,” said Carr.

Energy Probe has urged competition in the marketplace, but Adams said recent provincial actions are subverting a true market.

By allowing the selected businesses to maintain special preferential rates for the next four years, for example, the province forces Ontario Power Generation Inc. to charge its other customers higher rates to make up the difference.

Wilson’s office notes that Bill 100 is a temporary measure, expiring in 2003.

Adams said that is precisely the problem. Changes are under way – but Bill 100 means their effects won’t be apparent for three years.

“We consider that to be immoral,” he said. “It conceals from consumers the magnitude of the impact they’re going to suffer.”

Adams also rejects the notion that higher electricity bills necessarily lead to conservation.

The current policies are driving up the cost of delivering power – not the cost of the energy itself, Adams said.

The cost of running a wire to a conservation-minded household is the same as running a wire to a household of energy hogs, Adams said. Driving up the cost of energy equally for both households does nothing to reward the household that uses less electricity.

 

Posted in Reforming Ontario's Local Electrical Distribution Sector | Leave a comment

British Energy taking over Bruce Nuclear

Michael Petrou
National Post
July 12, 2000

British Energy PLC, Britain’s biggest electricity producer, is taking over Ontario’s Bruce nuclear power station in a lease arrangement with Ontario Power Generation Inc. in a deal worth as much as $3.5-billion over 43 years.

The Bruce Power Partnership, which is 95% owned by British Energy, will make an initial payment of $625-million, to be made in three installments of $400-million, $112.5-million and $112.5-million.

Annual payments, estimated to begin at $150-million in 2002, will continue until 2018, with an option to extend for 25 more years.

The deal is part of an agreement by Ontario Power Generation to reduce its generating capacity to no more than 35% of that available to the province 10 years after the market is privatized.

“We’re delighted,” David Gilchrist, executive vice-president of finance at Bruce Power, said yesterday. “We think it’s a significant milestone in the liberalization of the electricity market, which is going to be of enormous benefit to the Ontario energy consumer.”

Ron Osborne, president and chief executive officer of Ontario Power Generation, said the arrangement will result in more choice and lower prices for energy consumers.

“It’s a good (deal) for the customers because of the acceleration of the introduction of competition,” he said. “It’s important to the shareholder, to the province.”

The Association of Major Power Consumers in Ontario, an organization representing resource, manufacturing and processing industries, supports the deal.

“It will inject new thinking and efficiencies into the Bruce nuclear fleet, and introduce an important new competitor to Ontario Power Generation,” Arthur Dickinson, president of AMPCO, said in a statement.

But yesterday’s announcement prompted harsh criticism from environmental groups and Ontario’s Liberal opposition.

Under terms of the agreement, the British company will not be responsible for future liabilities, including waste storage and disposal, and decommissioning of the station.

These costs will be absorbed by Ontario Power Generation and will be paid for through the yearly lease. Norman Rubin, director of nuclear research at Energy Probe, an environmental advocacy group, said Bruce Power is leasing the plant to avoid future responsibility for cleanup and decommissioning costs.

“When it’s over, they can say, ‘Here, it’s toxic, it’s carcinogenic, it costs millions of dollars to clean up, and it’s yours,’ ” Mr. Rubin said. “We get to keep the garbage.”

Dominic Agostino, chief party whip for the provincial Liberal Party, said future liabilities “could ultimately be disastrous for people in this province.”

But president Ron Osborne remains confident Ontario Power Generation has struck a safe deal.

“We believe our estimates are more than conservative,” he said. “There’s more than enough funds to cover this.”

Posted in Power Generation in Ontario | Leave a comment

Harris revolution’s power failure

Terence Corcoran
National Post
June 29, 2000

One of the little mysteries of the Canadian Alliance leadership race is the belief that the Harris Tories in Ontario offer a blueprint for national policy and good government. Preston Manning, Tom Long and Stockwell Day genuflect at the mention of Mike Harris and his Common Sense Revolution. As this is written, Harris cabinet ministers, backroom operators and fund-raising wizards are lining up behind the Alliance, the assumption being that Ontario’s Conservatives, along with Ralph Klein’s Alberta Tories, are natural political allies who share objectives and philosophies with the Canadian Alliance.

It may come as a surprise to some, but the Harris revolution, mostly myth right from the beginning, is now down to a few wheezing talking points on the subject of tax cuts. On any other policy issue — health care, education, privatization, municipal affairs — the Harris government has no reform agenda to speak of. The Walkerton water tragedy, while not of its making, has only further paralyzed a government that has no intellectual capital of its own to fall back on.

Nowhere is this core vacancy more obvious than in the turmoil within Ontario’s electric power industry. Originally scheduled to open a pioneering power market next November, complete with competition at the consumer level, the industry is now on the brink of chaos. Over the past couple of weeks, the government has postponed introduction of a widely advertised power trading system for at least six months; issued directives to a regulator reversing its own legislation; tabled new legislation that puts many cities at financial risk; stalled the privatization of parts of the industry; and in the process risked driving private capital out of the market.

Calls are out for the resignation of the province’s energy minister and former health minister, Jim Wilson. The mayor of Toronto’s biggest suburb, Mississauga, accused the minister of bungling and called for his removal. “The new legislation introduced this week clearly indicates that the minister misled the public of Ontario and in fact his own government. This minister has made a mess of Health and now he is making a mess of Energy. Not a very good track record for a government that prides itself on being efficient and organized. This latest action by the minister is a disgrace.”

The mayor of Mississauga, herself a long-time Tory, is prone to flights of hyperbole, but in this case she has her feet on the ground. Under legislation, Ontario cities were given authority to convert local electricity distribution utilities into profit-making corporations. The half-baked plan produced predictable problems, but now — too late — the government is trying to reverse the legislation. Mississauga, Toronto and others face hundreds of millions in losses and other difficulties.

Tom Adams, a veteran Ontario power industry watcher, says Mr. Wilson has undermined the fairness and integrity of the whole system. The province needs a new energy minister — and a premier who will “give the energy portfolio the attention it deserves.”

Whether more attention from a government lacking in reform ideas will solve the problem is debatable. The power mess is the result of a spineless unwillingness to adopt key reforms needed to break up the province’s bankrupt Ontario Hydro power monopoly and create a dynamic, competitive marketplace. Instead, the old monopoly has been carved up into several monopolies — a big power generating company, a big transmission company and a big market operator. At the same time, the $39-billion in debt left behind by the old Ontario Hydro sits unattended.

This is not the handiwork of a government steeped in radical reform and guided by much in the way of economic principle. Not one privatization has taken place. Many deals have been talked about, including the leasing of a nuclear plant to British Energy, but the government now appears to have a moratorium on privatizations, if not an outright fear of them. In a recent speech to industry reps, Mr. Wilson said the financing of the nuclear power deal had been halted because of a “messaging” problem surrounding privatization in the wake of Walkerton.

The reason Walkerton now looms so large within the Harris revolution is that the government has spent all this time in power and never once formulated a meaningful set of principles. Failure to set out privatization objectives and plans has left it at the mercy of critics. When the left pounced on Walkerton as a product of privatization, the Harris revolutionaries could do nothing but run for cover. A cabinet that cannot muster the conviction to privatize liquor sales cannot be expected to defend itself against critics of privatized municipal services.

In short, inside the Harris revolution, the lights are out. Based on its track record, the Alliance hopefuls would do better to look elsewhere for a coherent model of a national revolution from the right.

 

Posted in Reforming Ontario's Local Electrical Distribution Sector | Leave a comment

Energy Probe’s comments to the AECB on the Environmental Assessment of the Pickering A Restart

Norman Rubin

June 29, 2000

Dear Sirs:

Following are Energy Probe’s comments to the Canadian Nuclear Safety Commission(1) on Ontario Power Generation’s Draft Submission to AECB entitled “Environmental Assessment Report, Pickering A Return to Service”, dated April 2000.

As in our earlier comments of December 1, 1999, on AECB’s draft “Scope of Assessment” for this project, we divide our comments into two general categories: Process Concerns and Substantive Concerns.

While it may be tempting for AECB/CNSC to focus primarily on the so-called Substantive Concerns – as appears to have occurred with our earlier comments – we would urge you to avoid that temptation. As discussed below, we believe our Process Concerns are more fundamental and therefore more important than our Substantive Concerns. Specifically, we believe that proper resolution of our Process Concerns is probably both a necessary and a sufficient condition for the proper resolution of our Substantive Concerns. Moreover, it is our submission that the federal law under which this exercise is being undertaken – the Canadian Environmental Assessment Act – not only permits AECB/CNSC to resolve most if not all of our Process Concerns properly, but seems to require that you do so.

A. Process Concerns:

Unfortunately, our process concerns have increased both in number and severity since those earlier comments, and partly as the result of your agency’s actions and inactions since we submitted those comments.

1. Modern, democratic, open regulation cannot be, and is not, done inside a “black box”. Our earlier comments on AECB’s draft “Scope of Assessment” for this project highlighted the following request – in fact, it was the second sentence in a five-page document:

As always, we would appreciate receiving reasons for AECB’s decisions to accept or reject these recommendations.

We note that AECB has on at least one previous occasion(2) produced a “reasons for decision” document, and thereby joined the post-1980 world of modern, open regulators in democratic societies. Unfortunately, the receipt and consideration of public comments on your draft “Scope of Assessment” for this enormous and important project was not such an occasion, and your final “Scope of Assessment” for this project was issued without comment. Any of the parties, including Energy Probe, who took the trouble to comment on your draft were essentially left to hold the draft and final documents “up to the light” to guess whether our comments had been dealt with, considered extensively but rejected, misunderstood, laughed at, or lost in the mail.(3) If – speaking totally hypothetically – a regulatory agency and its staff viewed public concerns, public values, and public comments as a nuisance rather than an essential step toward arriving at a wise decision, such treatment of public comment could be expected to minimize the nuisance.

Once again, we urge AECB/CNSC in the present instance to issue, along with your final EA or reference to the Minister, a Reasons for Decision document that summarizes public comments and responds to them. We hereby consent to have Energy Probe’s name attached to our comments in that document.

2. Wisdom cannot reliably achieved while standing on one foot. Given the extremely tight schedule AECB staff were operating under – in the order of a week or two between the deadline for public comment on the draft document and the scheduled issuance of the final document – it is perhaps understandable that it was essentially impossible to produce a Reasons for Decision document. But that absurdly tight schedule, and the continuing absurdly tight schedule of this entire review, is itself a barrier to modern, democratic, open regulation, and to wise decision-making on important matters of great public concern. It also interferes with AECB/CNSC’s duty to ensure that justice is not only done, but is perceived to be done – i.e., the AECB’s quick production of a final document in response to extensive public comments gives the appearance that those comments were not carefully considered, or that the final document was at least partly prepared before the comments were received. This appearance is obviously not in the best interest of AECB/CNSC, or of good governance in our society, and should be actively opposed.

We understand that the review schedule is largely under the control of AECB/CNSC, and we urge you to allow time for volunteer and non-profit groups to review, think about, discuss, and comment on the extensive, complicated, and important information involved in this process. We also urge you to allow time for AECB/CNSC to consider such comments carefully, and to document and explain that consideration.

While we would expect OPG to be impatient about the restart of a large facility like Pickering A, we urge AECB/CNSC to resist or overrule OPG’s predictable impatience. We also understand that OPG’s schedule for the Pickering A restart has slipped somewhat during this process (and not as a result of it), and that its estimated costs have risen, decreasing whatever societal desirability and business-case benefit the restart may have originally had. In other words, whatever perceived urgency may have been attached to this project should have lessened in the past year. Having clearly made multi-billion-dollar mistakes in building these reactors in the first place, Canada and Ontario should not rush to make more.

3. These decisions must be made in a full Environmental Assessment Panel Review and not by AECB/CNSC. And there must be a full assessment of need and alternatives. We will not repeat here our earlier comments on these three process concerns, made in sections A.2, A.3 and A.4 of our December 1, 1999 submission.

We do note, however, that since that submission was made, the City of Toronto and the City of Pickering have both issued unanimous resolutions calling for a full Environmental Assessment Panel Review of this decision. Whether AECB/CNSC is or is not an ideal and omniscient regulator whose decisions are consistently based on truth and wisdom, the awkward position of AECB/CNSC as “Responsible Authority” (essentially proponent-claimant, judge, and jury in one) – coupled with AECB/CNSC’s inability to harmonize public and local values to its own and its perceived closeness to nuclear-industry views on many areas of public concern – has created a problem in decision-making and governance that cries out for an independent review. We urge AECB/CNSC to trigger a full Environmental Assessment Panel Review of this EA and this project.

We note the discussion of the Panel Review option in AECB’s Final Scope of Assessment Document:

3.2 Options for Other Types of Assessment under CEAA

Section 25 of the CEAA provides the AECB with the ability, at any time during the assessment, to request the Minister of the Environment to refer the project to a federal review panel.

. . .

A request for referral to a review panel would be made if the AECB were to conclude that it is uncertain whether the project is likely to cause significant adverse environmental effects, taking into account the proposed mitigation measures or if public concerns warrant it. The AECB will continue to review the project in relation to these criteria periodically during the screening process. (p. A-2)

Regardless of AECB/CNSC’s views on the aforementioned issues of “likelihood” and “significance”, we believe that it is undeniable that public concerns warrant a request for referral of this project to a review panel.

We also understand that it is within the provisions of the CEAA for a federal review panel (though not a screening review) to assess the need for, and alternatives to, a project – an assessment that is sorely needed in this case.

B. Substantive Concerns:

Given time and resource constraints, and given our process concerns, we have only conducted a very cursory review of the approximately 1250 pages in the primary documents submitted by OPG(4). As a result we will only comment briefly on a select few topics. Please do not take our silence on any issue as support or acceptance of OPG’s draft submission. We reserve the right to review and comment on any part of this document in any forum in the future, regardless of its inclusion or exclusion in these comments. Indeed, we look forward to the opportunity to reexamine and comment on these matters before our requested and anticipated Environmental Assessment Panel Review.

We note as well that the draft document (though not by any means an adequate basis for making the decision to pursue this project) contains passages that apparently achieve a new and higher standard in nuclear-industry discourse on environmental matters. Indeed, even those sections selected for criticism below because of statements and omissions that are false, biased, or misleading, seem to this author to contain some concessions to truth that did not appear in OPG, Ontario Hydro, AECL, or even AECB documents a short time ago. We look forward to praising these passages more specifically before an Environmental Assessment Panel Review.

1. The combined effects of aging and obsolescence have still not been adequately addressed: We will not repeat our December comments on the subject, note B. 6. But we do note that the issue was incorporated in the AECB’s final “Scope of Assessment”, as follows:

6.3 Description of the Project

. . .

General Information, Design Characteristics and Normal Operations:

. . .

the key operational components of the plant (following completion of current upgrade work), including a discussion of component age and wear issues where relevant to future environmental performance and reliability; [emphasis added]

Indeed, OPG’s draft EA acknowledges this particular concern as a “key concern” for the public, on p. 5-24 : “There is concern about the safety of old nuclear reactors. Is PNGS-A worth refurbishing?” This key concern is supposedly dealt with in section 4. But section 4 apparently does not contain any of the words “age”, “aging”, or “wear”, or any appearance of the letter-string “obsole”. It would appear that OPG has responded to this key (and rational) public concern with only the following unsatisfying platitudes: “The PNGS-A plant has been operating safely for 28 years. Safety is OPG’s number one priority for staff, the community and the environment. If PNGS-A were not safe, it would not be returned to service.” Clearly, it’s time for a Panel Review!

2. OPG seems to think that toxins and eco-toxins have no impact if they go off-site! The following passage may need no further comment – except to hope that it has as little basis in Environment Assessment law as it has in logic:

4.4.1.6 Heavy Water Recovery and Re-use

. . .

The off-site effects associated with the processing and storage of radioactive wastes and tritiated heavy water are regulate [sic] through the respective licenses of the facilities involved and are outside the scope of assessment. (p. 4-22)

We look forward to debating this issue before an independent Panel Review.

3. Impacts must be quantified and judged acceptable, and not just legal: We will not duplicate our comments from December 1999 on this topic (section B.3). But we note that AECB’s Final “Scope of Assessment” addressed these concerns in several places, including as follows:

6.6.1 Assessment of Effects Caused by the Project

. . .

It may be relevant, but not sufficient to only assert that an effect is, for example, less than a specific government guideline level without describing the effect in quantitative or qualitative terms. The likely effects should be described before the criteria for judging significance are applied . . .

But OPG’s draft submission seems to honour this requirement in the breach. For example, the discussion of radioactive dose to humans (individuals and populations) does not provide any quantitative estimate of health risks, but instead compares them to regulatory criteria, arcane definitions of de minimis doses, unavoidable doses from the environment, and other less relevant quantities. One example out of many:

10.2 Potential Health Effects Associated with Radioactivity

Likely effects associated with radiation exposure have been addressed in Section 7.2.1. The following provides a summary of the estimated radiation doses to workers and general public as a result of the project. The estimated radiation doses are compared with the regulatory dose limits established by the AECB and with the variation in natural background radiation levels in Ontario. [p. 10-3]

The referenced Section 7.2.1 is no better, in our submission.

4. The passages on the health risks of radiation are biased and misleading (though we’ve seen worse!): For one example out of many:

F-7.0 REGULATORY ISSUES

. . .

Linear Non-Threshold (LNT) Model

. . .

. . . Overall, the advice of the ACRP [390] which suggests the continued use of LNT for regulatory purposes seems prudent with the caveat that, at low doses and dose rates, there is a possibility of no (excess) risk. (p. F-16)

In the field of pollution and public health, the calculation of doses that correspond to acceptably low risk levels — i.e., lifetime risks on the order of 1 fatal cancer per million — can never be directly proven correct, but must be calculated by extrapolation with mathematical models. That is the basis of (for example) drinking water objectives for carcinogenic chemicals, and it must also be the basis for comparable limits and standards for radioactive substances. It is technically true in both cases that science cannot prove beyond reasonable doubt that such small exposures actually cause cancer; it is equally true in both cases that science cannot prove beyond reasonable doubt that such small exposures don’t cause much more cancer than the model indicates. Indeed, if the model is the best fit to the evidence (as the linear risk model is to the radiation-cancer data for most forms of radiation and cancer), then it is equally likely that the truth is above the model as below it.

It is biased and misleading to mention one half of an essentially symmetrical uncertainty band, without mentioning the other half. Since the other half is of great public concern, we need an independent Panel Review.

We also look forward to debating, before an independent Panel Review, the significance of the observed excess in childhood leukemia mortality around the Pickering and Bruce Nuclear Generating Stations. Since AECB has taken one extreme view on this controversy, AECB/CNSC staff may be expected to take the opposite side of that debate. We like our chances – but only if there is an independent Panel Review.

5. The calculation of population collective dose is important, but the discussion of population collective dose is absurd.

In calculating the human health impacts of a toxic facility that emits toxic pollution, one obviously meaningful measure is the total amount of harm – e.g., the total estimated human health risk – the facility’s toxic emissions will cause. For Pickering-A’s radioactive emissions to air and water, these collective population health risks could be calculated from an estimate of the population collective radiation dose caused by Pickering-A’s emissions. Unfortunately, the passage where OPG might have presented that figure reads as follows:

7.2.1.7 Likely Effects on the General Public

. . .

Population Collective Dose

Radioactive dose can also be assessed through the estimation of the radiological dose received by a population living within approximately 50 km of the facility. The dose to a typical member of this population will be lower than the doses to the critical group member since the typical receptor will usually be exposed to lower concentrations and have average consumption characteristics when compared to a critical receptor. The population collective dose is the sum of radiological doses received by the individuals and provides a measure of facility performance. Although not required to do so by the AECB, OPG has continued to estimate, and report, the population collective dose for PNGS.

It is arbitrary, self-serving, and unworthy for OPG to stop calculating “population collective dose” 50 km from the source of its pollution. Perhaps if OPG were going to eliminate radioisotopes with half-lives over an hour or two, it would be reasonable(5) – but OPG has made no such commitment. Pickering’s radioactive noble gas and tritium emissions to the atmosphere circle the globe many times and expose most of the world’s population and their children and their children, throughout their lifetimes, to incremental doses of radiation – admittedly very small ones. OPG’s tritium emissions to the Great Lakes are now apparently responsible for at least half of the tritium exposure for the large population – in Canada and the U.S. – consuming water from Lakes Huron, Erie, and Ontario(6).

Integrating those individually tiny (and admittedly uncertain) estimated health risks with that enormous population put at risk would create an estimate of “total population dose” and “total population health risk”. Judgments of the significance or the acceptability of that integrated figure would depend strongly on human values – i.e., on the biases and environmental “religion” of the individuals making the judgments. But the math should be done before arguments and judgments are made about the significance or the acceptability of those estimated impacts.

Indeed, much of the nuclear debate – including matters that impact directly on the significance or the acceptability of Pickering-A’s environmental impacts – hinges on similar human values. A nuclear reactor complex like Pickering A is arguably the most toxic human-made facility on earth. In other words, a standard calculation of the integrated toxicity of Pickering-A’s contents or its annual output of toxins(7) would, we believe, produce a higher result than a similar calculation at any other human-made facility. Many Canadians react strongly negatively to toxic, ecotoxic, carcinogenic technologies like nuclear power, and wish they were phased out in favour of more benign technologies. On the other hand, the vast majority of Pickering-A’s toxic materials are contained in engineered structures for now, and may (or may not) be effectively contained in engineered structures for the many millennia during which some of them will remain toxic.(8) The remainder are emitted to the environment, a practice that is justified by AECB/CNSC-approved calculations that focus only on the impacts of immediate exposure to the immediately adjacent population, and apply “acceptable risk” values that would not be considered acceptable in other regulatory arenas.

Canadians who support nuclear power – like the AECB/CNSC and its licensees – tend to focus on the engineered containment systems for the enormous quantity of poison, rather than on the poison itselfor the residual probability that much of it will escape.(9) Canadians who oppose or question nuclear power tend to focus on the latter and discount the importance of the former. These values conflicts cause significant public concern and controversy, which should be examined and partly resolved in an independent panel review.

Sincerely yours,

Norman Rubin

Director, Nuclear Research

and Senior Policy Analyst

1. The Atomic Energy Control Board, Canada’s federal nuclear regulator and the “Responsible Authority” for this Environmental Assessment, has recently been recreated under new legislation and renamed the Canadian Nuclear Safety Commission. We will generally refer to this agency in this document as “AECB/CNSC”, unless the context is clearly historical. Ontario Power Generation (“OPG”) is itself one of the successor organizations to Ontario Hydro, and owns and operates the generating stations formerly owned by Ontario Hydro, including Pickering A.

2. The occasion was the issuance of the Regulatory Guide G-129, The Requirement to Keep All Exposures as Low as Reasonably Achievable, and was in response to public comments on the earlier Consultative Document C-129. Energy Probe had included the following request in its comments on C-129. dated November 30, 1994:

In the past, AECB has not issued detailed responses, comments, or Reasons for Decision in response to public comments on Consultative Documents — an omission that has received criticism from several public stakeholders, including Energy Probe. At various times in the past, AECB staff have indicated their intention to change this policy, at least in certain cases. We hereby request that these comments not vanish into the usual void, but that AECB issue, along with its final Regulatory Document, Reasons for Decision that summarize public comments and respond to them. We hereby consent to have Energy Probe’s name attached to these comments in that document.

3. Our own “holding the documents up to the light” exercise suggests that our comments in section B.1, B.3, and B.6 were received with favour and at least partly reflected in the final document; our comments in section B.5 were expressly rejected; and the remaining six were either lost in the mail, or at least “vanished into the usual void”.

4. We note with great approval the fact that OPG and its consultant Golder Associates has chosen to freely circulate the draft EA document in digital form, on a CD-ROM. Unfortunately, the (.pdf) files as widely distributed were in “locked” form, which did not permit public commenters to quote from the files by the usual “cut-and-paste” procedure. When I phoned Golder Associates staff on this matter, they quickly received OPG’s approval to send me a second CD-ROM, with “unlocked” files, and promptly did so. I acknowledge their cooperation in this matter, but regret the fact that most recipients of the CD-ROM were unable to quote from the distributed files without re-typing the passages in question – an anachronistic nuisance in year 2000.

5. A wind speed of 25 km/hr is extremely common in Southern Ontario – perhaps one day per month on average – while one of 50 km/hr is encountered perhaps a few days per month on average. Pickering-A’s radioactive plume would exit the 50-km radius roughly two hours after release in the former wind conditions, and roughly one hour after release in the latter.

6. For example, Ontario Hydro’s and OPG’s annual radioactivity surveys typically find mid-lake or “background” tritium levels of approximately 9 Bq/L in Lakes Huron and Ontario far from the Bruce, Pickering, and Darlington nuclear complexes, but levels of approximately 4 Bq/L in “control” lakes without CANDU reactors. Although the 9 Bq/L tritium level in Lakes Huron and Ontario (and the presumably similar level in Lake Erie) are apparently 50% or more attributable to the environmental impacts from its nuclear stations, OPG typically subtracts that number from the higher levels near Bruce, Pickering, and Darlington in calculating the stations’ dose to the “critical group” and the local population! We assume, but have not verified, that the same mistake has been made in the calculations in the draft EA.

7. Such a calculation could quantify the volume of drinking water needed to dilute the contents to a level corresponding to a standardized drinking water standard, including levels of carcinogens at a one-in-a-million lifetime risk of excess cancer. The more common method – to calculate the volume of drinking water needed to dilute the contents to a level corresponding to actual drinking water standards – seriously underestimates the toxicity of radioactive materials, because drinking water standards routinely allow hundreds or thousands of times higher cancer risks from radioactive carcinogens than from non-radioactive carcinogens. AECB has consistently been part of a polluter-led coalition to preserve that regulatory double standard.

8. The values-laden conflict over the safety and acceptability of the Canadian government’s plan to “dispose” of nuclear spent fuel deep underground was recently revealed in depth at the federal Environmental Assessment hearing on that subject. Among other conclusions, that independent panel review rejected AECB’s recommendations on the acceptability of the concept, and on the next steps toward “disposal”. The panel also made extensive recommendations for reform of the AECB, most of which have not been implemented.

9. AECB has always taken this view. For example, it has never even required nuclear-reactor owners to estimate the total toxicity contained, or produced, in their facilities. And emissions are tracked and “regulated” primarily with measures that credit all dilution to the point of impingement, as if AECB believed that “the solution to pollution is dilution”. The point of impingement is always based on human receptors, as if other species have no value.

Posted in Nuclear Plant Security | Leave a comment

Credibility meltdown

Thomas Adams and Michael Hilson
National Post
June 14, 2000

Ontario’s plans to freeze electricity distribution rates could lead to regulatory chaos — nothing new to the province’s electric market reform. But it is not too late for the government to fix the situation.

Instead of depoliticizing Ontario’s electricity sector and protecting the authority and independence of its regulator, the province is going in the opposite direction. The result? The government has disgraced the Ontario Energy Board — once a superb regulator — and replaced it with arbitrary cabinet dictates, creating chaos in the marketplace.

Tomorrow, Toronto Hydro, the largest of the municipally owned distribution utilities, is scheduled to appear before the Ontario Energy Board to ask for a rate increase of 58%, or $128 a year, for the service it provides residential customers. Mississauga wants a 79% increase, or $107 per year, for its residential customers. On average, Ontario’s municipal utilities seek rate hikes that will raise the overall bills that consumers see by 10% to 15% a year from this increase alone.

The response of Jim Wilson, Ontario’s Energy Minister, has been panic. Last week, he issued a directive to the Energy Board opposing the rate increases. Today, he is expected to introduce emergency legislation to enforce rate freezes. If he does, chaos could ensue. Not that chaos is a stranger to the government’s electricity restructuring.

For the last year, Mr. Wilson has been pressing the municipalities to merge their utilities to make them efficient, all the while boasting of rate cuts to come. To encourage the municipalities to merge their utilities, he passed legislation in 1998 that declared Ontario municipalities to be owners of the 250-odd municipal utilities, ordered the utilities to be corporatized and told the Energy Board to regulate them as ordinary commercial utilities. At the same time, by stripping the Energy Board of its independence, the board became subject to political pressure.

The rate increases occurred because the Energy Board accepted the advice of its American experts, who likely had never seen debt-free utilities flush with more than $1-billion in cash. The U.S. experts convinced the board that the utilities’ equity should be transferred to municipalities. Notwithstanding that this equity had all been contributed by electricity ratepayers, the board — lobbied by the municipalities — required them to charge ratepayers again, with interest, for these assets, valued at approximately $6-billion. This decision, made in January of this year, inevitably produces much higher rates. Those higher rates, in turn, inflate the value of the utilities to their owners and potential investors. Utilities and investors have been jumping though the merger hoop, expecting the regulator-approved rate increases. Dozens of deals have been struck, many more are in the works, and untold contractual commitments have been made.

While the Energy Board was determining the rate formula last year, provincial government officials sat quietly. Municipal utilities egged the Energy Board on. Toronto Hydro, using smoke and mirrors, has since been trying to make the elephant-sized rate increases appear small.

Mr. Wilson’s rate freeze — if he can make it stick for any length of time — throws all the financial calculations out the window. Those who risked their cash based on Energy Board-approved rate projections may get singed, even though they followed the government’s dictates to the letter. For example, Hydro Mississauga, Ontario’s second-largest distributor, followed the government’s lead in good faith and refinanced itself but now may get caught offside on the resulting bank covenants. One potential consequence is that the utilities’ assets may be seized.

The Energy Board is now in an awkward position. The municipal utilities’ requests for whopping rate increases appear to generally comply with the Energy Board’s own order. Assigning liability in the event of financial disputes will provide lawyers with a field day.

Within weeks, or perhaps even days, we will get either uncalled for rate increases that will undermine the whole electricity restructuring process, or litigation from investors such as pension funds who had once trusted the process and had responded to Mr. Harris’ efforts to improve Ontario’s investment climate. The reputation of the Ontario Energy Board, which, guided by its questionable interpretation of provincial energy policy, decided to impose the rate increase, may never recover.

It is not too late for the government to remedy the situation. Despite the government’s litany of errors to date, an easy, fair solution to the rate increase problem is readily available. The government should allow the rate increases to go through. But, to leave consumers whole, Mr. Harris should slap a windfall profits tax on municipal governments to recover their excess profits — at least $7-billion province-wide.

Mr. Harris can then use the proceeds of the windfall tax to reduce debt retirement taxes in the electricity bill, a leftover from Ontario Hydro’s debts and stranded nuclear waste liabilities. That would virtually eliminate the province’s own electricity tax on consumers, now called the Debt Retirement Charge, which the government announced late last week. Most consumers would see higher distribution charges but their ultimate bills would be unaffected.

Posted in Reforming Ontario's Local Electrical Distribution Sector | Leave a comment

`So complicated it makes your head hurt’

John Spears
Toronto Star
June 4, 2000

CONFUSED BY the door-to-door salespeople trying to sign you up to natural gas contracts? Just wait until the electricity peddlers hit the streets.

Starting in November, you will be able to buy your electricity from independent suppliers, just the way you can buy your gas from an independent supplier instead of Enbridge Inc., the former Consumers Gas.

You will pay the supplier for the cost of the actual energy you use. A separate charge will show the cost of delivering the electricity from the generator to your community and then distributing it locally.

That much is clear.

What’s not so clear is how to make an intelligent decision about an electricity supplier, let alone how to tell after the fact whether you chose well or not.

“This damn thing is so complicated it makes your head hurt,” says Tom Adams of Energy Probe, which favours competition in principle but is unhappy with the current situation.

Until the murk clears, beware.

Retailers must abide by a code of conduct drafted with the help of the Ontario Energy Board. But lack of reliable information is a problem at the moment.

Peter Dyne, who has been tracking electricity deregulation for the Consumers’ Association of Canada (Ontario), offers this simple advice. Sign nothing until more is known about the new electricity market. Right now, there are more questions than answers.

It’s tough to compare rates.

You can keep getting your electricity from your local utility, rather than signing a long-term contract with an independent supplier. The difference is that the independent retailer will probably offer a guaranteed rate over a long term. (The independent could also offer energy conservation incentives, or Air Miles.) Your local utility’s rate may vary year to year.

Ideally, you would want to know the difference between today’s price and the long-term price the independent retailer is offering. But the starting price that local utilities can charge – to be known as the “standard supply charge” and regulated by the Ontario Energy Board – isn’t known yet.

Reliable information about the new system is difficult to come by. A call centre operated by the Ontario Energy Marketing Association to answer questions about electricity and gas marketing was shut down this spring. Yet some energy marketers are still giving out pamphlets advising customers to call the association with questions.

The Star tried several other consumer information call lines with varying degrees of success.

Some of the worst information came on a line operated by Ontario’s energy ministry after The Star asked for an explanation of the new electricity system. Part of the exchange went like this:

Call centre: “They’ve decided to open up the market to private retailers. What that means is, private retailers will be purchasing electricity from the government and selling it to the public at various rates.”

The Star: “They’re buying it from the government?”

Call centre: “They are buying from, yes, the Ontario, yeah, the government.”

The Star: “The retailers are buying it from the government? Electricity from the government?”

Call centre: “And they’re selling it to us.”

In fact, retailers will be able to buy electricity from whomever they want. The hope is that more generating companies will spring up. Although the dominant generator in the province will continue to be Ontario Power Generation, the publicly owned generating arm of the former Ontario Hydro, it is not a government department.

The call centre was also unable to tell The Star how much of the electricity bill is made up of the energy cost, which is open to competition, and how much is the delivery charge, which will be the same for everyone.

“I’ve had that question all day today,” said the call centre worker. “However, I have not been given details on the the monetary breakdown. I couldn’t tell you. Neither could I give you details on the rates. I have no idea what the rates are, what they will be.” (It seems the energy part of the bill will make up between 40 per cent and 50 per cent of total, depending on whom you ask.)

The ministry call centre ultimately referred The Star to a call centre operated by the Ontario Energy Board, which had accurate information.

The private companies have trouble telling you about their products.

Direct Energy Marketing Ltd. is already asking customers to sign five-year contracts in a plan called the “Electricity Price Protection Discount Program.” The price will be 5 per cent less than the price of electricity charged by the local utility, guaranteed for five years.

The choice is like choosing a mortgage: You can take a floating rate that will probably cost less in the beginning, or lock in for five years.

Should you want to get out of the contract, it’s expensive, as outlined in some very fine print. The company says the current price of electricity is 6.46 cents a kilowatt hour in Toronto. If you want out after, say, three years, Direct Energy would estimate how much power you would have used for the remainder of your contract and charge you 1.5 cents a kilowatt hour for that electricity. That’s the equivalent of 23 per cent of your bill.

For the average household using 12,000 kilowatt hours a year, that comes to $180 for each year remaining in the contract.

Direct Energy, too, operates a call centre. The operator there initially misinformed The Star about the price of escaping the contract. He said the customer would have to pay the full amount for the electricity remaining on the bill – a condition that applies to commercial, not residential, customers.

A customer who gets into a disagreement with a supplier can call the Ontario Energy Board, which may sort out minor disputes based on misunderstanding. For more serious disputes the board has contracted with a private firm, Consumer Expressions, to run a dispute resolution service.

Until more generators hit the market, the supply of electricity will be dominated by Ontario Power Generation, which produces about 85 per cent of Ontario’s power. If all the retailers buy from one wholesaler and pay exactly the same transmission and distribution charges, it may be hard for them to offer different packages.

Ontario’s new energy rules call for Ontario Power Generation to sell 4,000 megawatts of generating capacity – about 40 per cent – within 42 months of this Nov. 1. Within 10 years, the new company is supposed to supply no more than 35 per cent of electricity, giving retailers lots of room to wheel and deal.

But since no one knows who will buy the generating capacity and on what terms, or what new suppliers will be building generators, it’s tough to predict what will happen to wholesale prices.

Adams at Energy Probe complains that Ontario Power Generation, because it is owned by the province, will be able to borrow more cheaply than rivals can, gaining a built-in advantage. On the distribution side, some local utilities are raising their rates. Toronto Hydro has applied for a rate increase, which will offset savings consumers might get on energy supply.

Toronto Hydro vice-president Blair Peberdy acknowledges the industry has some work to do in getting reliable information to the public, especially with the Nov. 1 competition date approaching.

With so many unknowns, some critics are questioning the whole idea.

“How much effort is it worth going to, when it’s only a few dollars a month difference?” wonders John Todd, an economist and director of the Ontario Energy Marketers Association.

“Nobody’s really asking the question: How much is it costing to make the transition and what’s the benefit?”

Posted in Reforming Ontario's Local Electrical Distribution Sector | Leave a comment

Energy Probe corrects the record: Toronto Hydro misleads its consumers

Tom Adams
Energy Probe
June 1, 2000

 

Toronto Hydro is about to impose shocking rate increases on its consumers. Residential consumers using the average amount of electricity for the residential class will see distribution rates rise by 39% initially and 58% once the increase is fully implemented in 2001. Residential consumers who use a small amount of electricity–typical of consumers in bachelor apartments or conservation conscious consumers–will see an increase of 48% initially. Some small businesses will see an initial increase of 868%. Toronto Hydro has posted on its web site a Q&A series providing its explanation of the increases. In this posting, Energy Probe has taken the text of that statement verbatim and commented on it. Energy Probe’s comments, written by Tom Adams, Executive Director, are in bold.

Toronto Hydro-Electric System Limited Rate Proposal:

Questions and Answers for Customers
May 03, 2000

 

Q:Why does Toronto Hydro-Electric System Limited need a rate increase?

A:The increase is a “one time adjustment”
Wrong. This is not a “one time adjustment” but a stealthy increase in rates over a span of years. Both the Ontario Energy Board (OEB), which is the regulator of the distribution companies, and Toronto Hydro prefer a slow phase-in of the increase to avoid the negative public reaction associated with a rate shock. However, the phase-in does not protect consumers since consumers are forced to be involuntary borrowers from Toronto Hydro, funding the foregone profits in an interest bearing account for later recovery from consumers. You can get more information on this deferred increase and involuntary borrowing mechanism directly from the OEB decision

(www.oeb.gov.on.ca March 15, 2000 – The Board’s Electricity Distribution Rate Handbook, SECTION 5.5.2 Deferred MBRR) that reflects the changes to the marketplace.
Wrong again. The rate increase is due to the OEB’s interpretation of the Ontario government energy policies and bill 35. Relying on the same policies and legislation upon which to base its opinion, Energy Probe considers the increases completely unnecessary. For more information see http://www.energyprobe.org/energyprobe/index.cfm

Municipal utilities have incorporated and must now pay taxes like other corporations in Ontario.
Wrong. The rate increase discussed in this press release has nothing to do with taxes payable to the Ontario government.

We must also provide a financial return to our shareholder, The “shareholder”, meaning the Municipal government, did not invest a dime in Toronto Hydro. Consumers, not the city, invested the funds and consumers should get the financial return from historic investments by consumers. fund capital construction programs in excess of $100 million this year, and invest in new information systems technology that will enable us to operate in the new competitive marketplace.

 

Q:Why are rates changing now?

A:Under The Energy Competition Act 1998, Toronto Hydro-Electric System Limited is required to apply to the Ontario Energy Board (OEB) for new rates. This year, the application must be received by May 1 for consideration over the following two months.

Q:When will rates go up?

A:Subject to OEB approval, the new rates will go into effect on July 1, 2000.

Q:How much will the rate increase cost the average residential customer?

A:The average residential customer using 1,000 kilowatt-hours of electricity per month will have a rate increase of $7.20 per month.
This represents a 39% increase in the distribution rates. By the time Toronto Hydro has completed the phased increase, distribution rates for the average residence will be 58% higher than now. Toronto Hydro prefers to report its rate increase on a fully diluted basis–for residential customers it claims the increase is only 8.7% initially and 13% when fully implemented. Because distribution costs are only 20% of the current bill, the non-distribution portions of your bill dilute the impact of Toronto Hydro’s huge increases.

Q:How will water heater energy rates be affected?

 

A:Water heater energy rates will increase the same amount as electricity rates, but because two old water heater rates are being harmonized into one, some customers will pay a little more and some a little less.

 

Q:Will rates be the same across the amalgamated utility?

A:As of July 1, all residential rates will be the same. All commercial rates will be the same within each of the various commercial rate classes.
Some small business customers in Scarborough will see a distribution rate increase of 868% or about $455.00/month.

Q:When did electricity rates increase last?

A:Our last increase was in 1993. Electricity rates across Toronto have stayed the same or declined since 1994. This increase, our first in seven years, takes rates only two percent higher than they were in 1993.
The main reason why rates in “Toronto” are lower now, before the planned increase, than in 1993 was cost shifting to lower cost regions amalgamated into the megacity. Most customers in York, and Scarborough have already seen huge increases.

Q:Should we expect regular rate increases?

A:The current rate has been designed to cover anticipated costs through 2001, which means that at the present time, we don’t anticipate another rate change until at least 2002. However, there will be changes to the way rates are separated and presented on your bill when the market opens, which is expected to be in November, 2000.

Q:How is the deregulated market expected to affect future rates?

A:We expect electricity prices to come down when the competitive market has been in operation for a while. In the United States, average electricity prices have fallen every year since 1996, when wholesale competition was introduced. What we’re going through this year is the effect of electricity rates having fallen for several years
This statement is incorrect. Rates are rising because the OEB thought the increases were “just and reasonable”. The government imposed rate freeze on Ontario Hydro, initiated in 1993, is completely unrelated to the impending distribution rate increase. combined with some initial start-up costs for the amalgamated Toronto Hydro.

Q:What impact has utility amalgamation had on electricity rates?

A:Amalgamation significantly reduced costs, and therefore pressure on electricity rates. Customers in the amalgamated cities around Toronto got rate increases. It has enabled us to achieve efficiencies that have resulted in cost savings of approximately $60 million since 1998. Although these savings are significant and they can help us mitigate rate increases, they don’t allow us to avoid them altogether.

Q:Has the outstanding debt of the former Ontario Hydro had an impact on rates?

A:The cost of paying Ontario Hydro’s stranded debt has been built into the rate structure for many years now. That situation hasn’t changed at all, so it’s not a major factor in the current rate proposal.
This statement is true but that is the tragedy. The distribution increase, if it funded our historic debts and nuclear waste liabilities, would have been legitimate. Instead, the increase is just providing a new revenue stream to fund government. Since this money is coming to municipalities as a windfall, we are very concerned that municipal government’s will not be accountable for the beneficial use of the funds.

Q:Will the rate increase affect the look of my hydro bill?

A:No it won’t. The bill was recently redesigned as required by the OEB to illustrate the different components of your electricity costs and that won’t change. Because your new bill shows “unbundled” charges, it allows you to make clear comparisons between different retail suppliers who may be seeking your business. The unbundled bill gives you a tool that will help you choose a retailer in the coming deregulated market.

Q:What is unbundling?

A:Toronto Hydro-Electric System Limited presently buys energy and transmission services on behalf of its customers. Up until last year, the charges for these services were bundled together and shown with your energy charge as one single charge. In preparation for deregulation, these charges have now been stated separately on your bill to help you track your usage and make better energy management decisions. That’s why your bill shows separate listings for the energy, distribution, transmission, and customer charges.
The customer charge is also a distribution charge. To find your total distribution cost, that is the total amount of your bill caused by Toronto Hydro, sum the customer charge and the “distribution” charge.

Q:What is an energy charge?

A:The energy charge covers the cost of producing electricity, which can vary on an hourly basis. In an open market, electricity will be treated as a commodity and will be priced on a per kWh basis. This is the portion of your bill that will be subject to competition.

Q:What is a transmission charge?

A:Transmission is the cost of designing, building and maintaining the transmission system that carries electricity from generating stations to municipalities. Because transmission lines are very expensive, it’s most efficient to have one single, regulated provider. For now, that provider is Ontario Hydro Services Company, whose rates are regulated by the Ontario Energy Board.

Q:What is a distribution charge?

A:Distribution refers to the cost of designing, building and maintaining the distribution system, which connects your home or business to the rest of the electricity transmission and generation system. Like transmission lines, distribution wires are also very expensive. Toronto Hydro-Electric System Limited will continue to perform distribution services under regulation of the Ontario Energy Board.

Q:What is a customer charge?

A:The customer charge includes such fixed costs as meter reading and billing which remain constant, no matter how much electricity you use each month. Since these costs don’t vary with usage, the customer charge is a fixed monthly amount. This charge is regulated by the Ontario Energy Board.

Energy Probe’s concluding remarks: Consumers in Toronto have been overcharged for distribution services due to the past inefficiency of Toronto Hydro. Toronto Hydro should be getting more efficient and therefore distribution rates should be going down, not up.

 

In its application for the rate increase to the OEB, Toronto Hydro (referring to itself here a TH-Electrical System) makes the following statement:

 

1.4.25 TH-Electric System recognizes that customers may experience come confusion trying to understand the changes to their rates and the resultant impacts to their bills. The Applicant understands the importance of an effective communication plan to explain these changes and notes the OEB’s direction in paragraph 3.2.11 on the Decision requiring “…the utility to inform and explain the rate changes as well as the reasons thereof.”

 

Energy Probe encourages the reader to consider this statement for themselves.

 

Posted in Reforming Ontario's Local Electrical Distribution Sector | Leave a comment

Ins and outs of hydro hike

Ellen Roseman
The Toronto Star
May 29, 2000

LAST FEBRUARY, the Ontario Energy Board gave municipal utilities the go-ahead to raise distribution prices as part of the province’s restructuring of the electricity market.

So, it’s no surprise that utilities are now applying for price increases.

Last week, Toronto Hydro-Electric System Ltd. released details of its plan to increase the average residential customer’s bill by 13 per cent.

To lessen the impact, the municipal utility wants to phase in the increase over two years, starting with an 8.7 per cent increase on July 1.

Toronto Hydro has 650,000 customers and supplies one- quarter of Ontario’s electricity. Toronto Hydro is the largest municipal utility in Canada and supplies power to the economic hub of the country.

For business customers, the average rate increase is 5.3 per cent in the first year. But some will be hit harder as Toronto Hydro harmonizes rates across the six former utilities amalgamated into one.

This is alarming news for Toronto businesses, already reeling from large property tax hikes resulting from changes in the province’s assessment system. Many cannot survive if forced to pay more for electricity, too.

Here’s a guide to Toronto Hydro’s proposed rate increase.

Q What is the distribution price?

A Distribution makes up 10 to 20 per cent of your electricity bill.

Toronto Hydro breaks it out into two components: the distribution charge (which varies with volume) and the customer charge (which is fixed).

On my own Toronto Hydro bill, which covers the two-month period to May 17, the distribution and customer charges add up to $45 of the $224.59 total. That’s exactly 20 per cent.

“In general,” the utility says, “smaller volume consumers in any class will experience the greatest rate increases on a percentage basis as the level of the customer charge is increased.”

Some businesses were never charged a fixed monthly fee (in Scarborough, for example), so their increases will be much higher than average.

Q Why are distribution prices going up July 1, when electricity restructuring begins in November?

A The province gave municipalities the option of operating their utilities on a for-profit basis.

Incorporation was intended to lead to mergers and consolidation. Ontario has 257 municipal utilities, compared with 25 in all the rest of Canada.

Toronto Hydro incorporated itself a year ago and assumed more debt in its capital structure. (Before, the utility operated virtually debt-free.) It now needs more revenue to pay interest on the debt to the city of Toronto.

The utility also wants to earn a commercial rate of return. Last year, Toronto Hydro’s return on equity was 1.28 per cent.

The energy board ruled in February that municipal utilities can earn up to 9.88 per cent.

Toronto Hydro says it can’t wait until November to raise rates. Making things worse, the utility plans to apply the higher price to the entire consumption on bills issued after July 1, even if that consumption occurred before that date. This unfairness is unavoidable, the utility says. Prorating customers’ bills to reflect electricity consumed before and after July 1 is “unjustifiably expensive” and not a viable option.

Q What is the impact of Toronto Hydro’s plan to split the increases over two years?

A While promoted as a benefit, the phase-in will actually cost customers more in the end.

The difference between the phased-in amount and the maximum allowable rate under the energy board’s formula will be recovered, with interest, in later years.

Tom Adams, executive director of Energy Probe, a Toronto advocacy group, says the deferral (with interest) means the public will be borrowing money from Toronto Hydro.

“There’s no indication that the utility intends to disclose to customers how much money they involuntarily borrow,” Adams says.

Q Can the government do anything to stop this rate increase?

A As part of the provincial restructuring plan, the energy board regulates distribution prices charged by municipal electric utilities.

The board gave newly incorporated utilities the freedom to raise rates by adopting a formula allowing them to move to a commercial return.

The only matter in dispute is whether Toronto Hydro is entitled to the maximum return of 9.88 per cent or something smaller. The utility has tried to alleviate that concern by phasing in price increases over two years.

Bottom line: Customers will pay more for electricity in an age of choice, despite Ontario Energy Minister Jim Wilson’s protests that price increases were not inevitable.

 

Posted in Reforming Ontario's Local Electrical Distribution Sector | Leave a comment

Canada’s nuclear nabob’s try to turn green

Norman Rubin

May 20, 2000

For decades, nuclear power has been a promising industry. First, it promised electricity too cheap to meter, and nuclear-powered cars and airplanes. Later, it promised safe, reliable and economic electricity. Today, those promises are hard to make with a straight face, and even harder to keep: More than one-third of Canada’s billion-dollar Candu reactors have stopped producing any electricity (or income), and the unsupportable debt created by Candu reactors has far surpassed $10-billion, not including the additional nuclear billions in the federal debt.

So today, the nuclear industry has taken to promising environmentally friendly energy, and promising to help Canada meet its commitment to reduce greenhouse gas emissions under the 1997 international Kyoto agreement. As David Torgerson, Atomic Energy of Canada Ltd. (AECL) vice-president, recently told a Senate committee: “We believe quite strongly that Candu is a key to meeting the Kyoto targets.”

That promise has already been adopted by Canada’s reactor sales force — led by Prime Minister Jean Chretien. It has also been spread widely by U.S. officials. Ambassador John B. Ritch III, the U.S. representative to the United Nations Organizations in Vienna, told a conference earlier this year: “Only one technology on our horizon — advanced nuclear reactors — offers a realistic promise of contributing substantially to the world’s burgeoning need for large base-load power production without exacerbating the hazards of environmental contamination and catastrophic climate change.”

To followers of the energy debate, the new emphasis is at its root a plea for continued taxpayer subsidies from an industry that can’t compete. The hope for subsidies arises from a footnote in the Kyoto accord known as the Clean Development Mechanism (CDM). According to the CDM, countries that fail to meet their agreed targets for emissions reductions under the Kyoto accord could get compensating credits by promoting “clean development” in other countries — development that at least theoretically reduces greenhouse gas emissions in a sustainable and “clean” way. Canada’s nuclear industry is basing its hopes for exporting reactors to the Third World on having them qualify for the valuable credits.

As the International Atomic Energy Agency’s Thomas Tisue explained to a Canadian Nuclear Society audience late last year, “The basic idea is easy to grasp: stimulate the use of nuclear power in developing countries through the CDM mechanism to simultaneously generate CO2 offset credits and promote sustainable development.” Because of its higher costs, he said, “nuclear would not be used by most developing countries in the absence of the CDM mechanism.”

Unfortunately for the industry, the promise that nuclear power is either sustainable or clean — or poses a practical or affordable way to lower greenhouse gas emissions — looks as empty as the industry’s earlier broken promises of cheap and reliable power:

– Canada’s nuclear industry has already generated a world-class collection of toxic trash, with virtually no funds set aside for cleaning up the mess. Ontario Hydro estimated recently that its own nuclear clean-up would cost $18.7-billion in today’s dollars. The entire clean-up fund now stands at $420-million. The rest will have to be raised in the future, since the first two decades of Ontario’s nuclear generation (like Quebec’s and New Brunswick’s) left no funds at all.

The totally unfunded radioactive waste mess of the federal Crown corporation, AECL, has been criticized by Canada’s auditor-general since 1995 as a violation of accepted accounting principles, not to mention the principles of sustainable or “clean” development.

– The industry’s waste-disposal plans — for unmonitored, irretrievable burial — have received only two public reviews, and neither supported them. In 1988, an all-party federal committee unanimously recommended a moratorium on reactor construction until the plans were improved. A second look — a nine-year federal review by an independent environmental assessment panel that finished in 1998 — unanimously judged the industry’s plans unacceptable, and produced a “hung jury” on their safety. The panel unanimously recommended that the industry not proceed with its preferred next step: selecting a site for burial.

– Although reactors emit extremely low levels of the greenhouse gases implicated in global climate change, virtually no serious plans to decrease emissions include building new reactors. Greater emissions cuts are available sooner and cheaper from a combination of efficiency gains in generation and consumption, and decentralized generation from natural gas (a low-emission fuel) and renewables. The Canadian government’s claims to CDM credits for exporting Candu reactors have accordingly been met with scorn from foreign governments and environmentalists alike.

– To the surprise of many non-experts, most major producers of nuclear power — including Ontario Power Generation (the new-generation successor to Ontario Hydro) and New Brunswick Electric Power, as well as generators in the United States, China, Eastern Europe and elsewhere — are also major coal burners and greenhouse gas emitters. Although they look like alternatives, coal power and nuclear power are really natural partners: Reactors produce constant or “base-load” power when they can run, while coal-fired stations can fire up to meet “peak” loads and keep the lights on whenever the reactors go down.

With all these developments sullying its latest repositioning as an environmental saviour, the nuclear industry should find its plea for ongoing subsidies a hard sell. But with the decision in the hands of a federal government that continues to spout the rhetoric of the nuclear industry all the way up to the prime minister, nothing can be ruled out.

Posted in Nuclear Economics, Nuclear Plant Security | Tagged | Leave a comment

Canada’s nuclear nabobs try to turn green

Norman Rubin
National Post
May 20, 2000

For decades, nuclear power has been a promising industry. First, it promised electricity too cheap to meter, and nuclear-powered cars and airplanes. Later, it promised safe, reliable and economic electricity. Today, those promises are hard to make with a straight face, and even harder to keep: More than one-third of Canada’s billion-dollar Candu reactors have stopped producing any electricity (or income), and the unsupportable debt created by Candu reactors has far surpassed $10-billion, not including the additional nuclear billions in the federal debt.

So today, the nuclear industry has taken to promising environmentally friendly energy, and promising to help Canada meet its commitment to reduce greenhouse gas emissions under the 1997 international Kyoto agreement. As David Torgerson, Atomic Energy of Canada Ltd. (AECL) vice-president, recently told a Senate committee: “We believe quite strongly that Candu is a key to meeting the Kyoto targets.”

That promise has already been adopted by Canada’s reactor sales force — led by Prime Minister Jean Chretien. It has also been spread widely by U.S. officials. Ambassador John B. Ritch III, the U.S. representative to the United Nations Organizations in Vienna, told a conference earlier this year: “Only one technology on our horizon — advanced nuclear reactors — offers a realistic promise of contributing substantially to the world’s burgeoning need for large base-load power production without exacerbating the hazards of environmental contamination and catastrophic climate change.”

To followers of the energy debate, the new emphasis is at its root a plea for continued taxpayer subsidies from an industry that can’t compete. The hope for subsidies arises from a footnote in the Kyoto accord known as the Clean Development Mechanism (CDM). According to the CDM, countries that fail to meet their agreed targets for emissions reductions under the Kyoto accord could get compensating credits by promoting “clean development” in other countries — development that at least theoretically reduces greenhouse gas emissions in a sustainable and “clean” way. Canada’s nuclear industry is basing its hopes for exporting reactors to the Third World on having them qualify for the valuable credits.

As the International Atomic Energy Agency’s Thomas Tisue explained to a Canadian Nuclear Society audience late last year, “The basic idea is easy to grasp: stimulate the use of nuclear power in developing countries through the CDM mechanism to simultaneously generate CO2 offset credits and promote sustainable development.” Because of its higher costs, he said, “nuclear would not be used by most developing countries in the absence of the CDM mechanism.”

Unfortunately for the industry, the promise that nuclear power is either sustainable or clean — or poses a practical or affordable way to lower greenhouse gas emissions — looks as empty as the industry’s earlier broken promises of cheap and reliable power:

– Canada’s nuclear industry has already generated a world-class collection of toxic trash, with virtually no funds set aside for cleaning up the mess. Ontario Hydro estimated recently that its own nuclear clean-up would cost $18.7-billion in today’s dollars. The entire clean-up fund now stands at $420-million. The rest will have to be raised in the future, since the first two decades of Ontario’s nuclear generation (like Quebec’s and New Brunswick’s) left no funds at all.

The totally unfunded radioactive waste mess of the federal Crown corporation, AECL, has been criticized by Canada’s auditor-general since 1995 as a violation of accepted accounting principles, not to mention the principles of sustainable or “clean” development.

– The industry’s waste-disposal plans — for unmonitored, irretrievable burial — have received only two public reviews, and neither supported them. In 1988, an all-party federal committee unanimously recommended a moratorium on reactor construction until the plans were improved. A second look — a nine-year federal review by an independent environmental assessment panel that finished in 1998 — unanimously judged the industry’s plans unacceptable, and produced a “hung jury” on their safety. The panel unanimously recommended that the industry not proceed with its preferred next step: selecting a site for burial.

– Although reactors emit extremely low levels of the greenhouse gases implicated in global climate change, virtually no serious plans to decrease emissions include building new reactors. Greater emissions cuts are available sooner and cheaper from a combination of efficiency gains in generation and consumption, and decentralized generation from natural gas (a low-emission fuel) and renewables. The Canadian government’s claims to CDM credits for exporting Candu reactors have accordingly been met with scorn from foreign governments and environmentalists alike.

– To the surprise of many non-experts, most major producers of nuclear power — including Ontario Power Generation (the new-generation successor to Ontario Hydro) and New Brunswick Electric Power, as well as generators in the United States, China, Eastern Europe and elsewhere — are also major coal burners and greenhouse gas emitters. Although they look like alternatives, coal power and nuclear power are really natural partners: Reactors produce constant or “base-load” power when they can run, while coal-fired stations can fire up to meet “peak” loads and keep the lights on whenever the reactors go down.

With all these developments sullying its latest repositioning as an environmental saviour, the nuclear industry should find its plea for ongoing subsidies a hard sell. But with the decision in the hands of a federal government that continues to spout the rhetoric of the nuclear industry all the way up to the prime minister, nothing can be ruled out.

 

Posted in Nuclear Economics | Tagged | Leave a comment