Solar Krafte Utilities Inc - Stirling Solar Project August 21, 2018 - Decision 23323-D01-2018 - Alberta Utilities Commission
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Decision 23323-D01-2018 Solar Krafte Utilities Inc. Stirling Solar Project August 21, 2018
Alberta Utilities Commission
Decision 23323-D01-2018
Solar Krafte Utilities Inc.
Stirling Solar Project
Proceeding 23323
Application 23323-A001
August 21, 2018
Published by the:
Alberta Utilities Commission
Eau Claire Tower, 1400, 600 Third Avenue S.W.
Calgary, Alberta
T2P 0G5
Telephone: 403-592-8845
Fax: 403-592-4406
Website: www.auc.ab.caAlberta Utilities Commission
Calgary, Alberta
Decision 23323-D01-2018
Solar Krafte Utilities Inc. Proceeding 23323
Stirling Solar Project Application 23323-A001
1 Decision summary
1. In this decision, the Alberta Utilities Commission must decide whether to approve an
application from Solar Krafte Utilities Inc. to construct and operate a power plant designated as
the Stirling Solar Project. After consideration of the record of the proceeding, and for the reasons
outlined in this decision, the Commission finds that approval of the project is in the public
interest having regard to the social, economic, and other effects of the project, including its effect
on the environment.
2 Introduction
2. Solar Krafte Utilities Inc. (Solar Krafte) filed an application with the AUC for an
approval to construct and operate a 17.4-megawatt (MW) alternating-current solar photovoltaic
power plant in the County of Warner, approximately 1.6 kilometres east of the village of Stirling,
pursuant to Section 11 of the Hydro and Electric Energy Act. This application was registered on
February 8, 2018, as Application 23323-A001.
3. Solar Krafte later confirmed in an information response that it was also applying for a
connection order to connect the power plant to the electrical distribution system, pursuant to
Section 18 of the Hydro and Electric Energy Act.1
4. On May 14, 2018, the Commission issued a notice of application. The notice was sent
directly to potentially affected stakeholders within 2,000 metres of the project, published in the
Taber Times, the West Wind Weekly News and the Bow Island Commentator newspapers, and
made available on the AUC website. No submissions were received in response to the notice of
application.
3 Application
5. The application was prepared and submitted on the basis of generic equipment because
Solar Krafte had not finalized the specific make and model of the solar photovoltaic panels or the
inverters and transfer stations at the time the application was filed. Solar Krafte stated that the
design reference case for the project used 174,200 thin-film solar photovoltaic panels with a
nominal rating of 120 watts direct-current each and nine inverter and transfer stations with a
nominal rating of 3,000 kilovolt-ampere each.
1
Exhibit 23323-X0022, Information Response (Round 1).
Decision 23323-D01-2018 (August 21, 2018) • 1Stirling Solar Project Solar Krafte Utilities Inc.
6. On July 6, 2018, Solar Krafte provided the finalized make, model and quantity of the
equipment proposed for the project. Solar Krafte stated that the project would consist of 62,964
Canadian Solar CS3U-340P solar photovoltaic panels each with a nominal rating of 340 watts
direct-current. The project would also include three SMA UPR5500-EV-US transformers each
coupled with two SMA SC-2750-EV-US inverters as well as one SMA MV Block 2750 US-2.0
transformer coupled with one SMA SC-2750-EV-US inverter. The total generating capability of
the project would be 17.4 MW.
7. Solar Krafte stated that the project would be sited approximately 1.6 kilometres east of
the village of Stirling in the County of Warner on approximately 152 acres of privately owned,
agricultural land.2 The legal land location of the proposed project is in the southwest quarter of
Section 27, Township 6, Range 19, west of the Fourth Meridian.
8. Solar Krafte stated that the project would be interconnected to FortisAlberta Inc.’s
distribution system through one 25-kilovolt distribution feeder originating from
AltaLink Management Ltd.’s (AltaLink) Stirling 67S Substation. The point of interconnection
would be located in the southwest quarter of Section 27, Township 6, Range 19, west of the
Fourth Meridian.
9. Solar Krafte stated that the project would be sited on land adjacent to AltaLink’s
Stirling 67S Substation. Solar Krafte stated that the area surrounding the project is a mix of
irrigated and dry cultivated farmland adjacent to Stirling 67S Substation, a commercial truck and
tractor lot, and four single-family homes. The surrounding area to the west is municipally zoned
as UF (Urban Fringe) and the property to the north is municipally zoned AG (Extensive
Agriculture).
10. Solar Krafte initially submitted its application without a renewable energy referral report
issued by Alberta Environment and Parks (AEP). Rule 007: Applications for Power Plants,
Substations, Transmission Lines, Industrial System Designations and Hydro Developments states
that an application must include this report. Solar Krafte submitted a referral report from AEP on
April 4, 2018. The report concluded that the project would pose a moderate risk to wildlife and
wildlife habitat based on deficient surveys, types of mitigation proposed and planned project
siting. AEP made several recommendations to better mitigate the environmental impacts of the
project and stated that the risk ranking could be adjusted pending the results of further wildlife
surveys.
11. Solar Krafte submitted an updated wildlife assessment report prepared by
Basin Environmental Ltd. Wildlife which addressed AEP’s concerns. In consultation with AEP’s
regional wildlife biologist, specific surveys were recommended to target potential species at risk.
The report concluded that potential impacts to wildlife and species at risk would be low and
potential habitat loss would be minimal. To minimize risk to wildlife during construction and
operation, additional mitigation measures were proposed. The report stated that a qualified
environmental professional would be on-site to monitor construction of the project to ensure that
the mitigation measures and all applicable environmental laws and regulations are followed.
12. To determine the effectiveness of the mitigation measures and to identify any ongoing
impacts or risks to wildlife, the report stated that wildlife biologists would conduct
2
Exhibit 23323-X0001, Rule 007 Application (Stirling Solar Project), PDF page 4.
2 • Decision 23323-D01-2018 (August 21, 2018)Stirling Solar Project Solar Krafte Utilities Inc.
post-construction monitoring for a minimum of three years following the project’s
in-service date. Bird and bat carcass surveys would be conducted on an annual basis to document
mortalities and to determine the need for consultation with AEP Wildlife Management
(AEP WM) and any additional mitigation of facility operations, if necessary.
13. Solar Krafte submitted an updated environmental protection plan (EPP) report and an
updated post-construction monitoring and mitigation plan (PCMMP) on July 6, 2018.3 The report
outlined updated environmental mitigation commitments including those to address the
requirements and recommendations provided by AEP in its referral report. Solar Krafte stated
that it would further revise the PCMMP and EPP, if necessary, following AEP WM’s review of
the updated reports and receipt of an updated renewable energy referral report from AEP WM.4
14. On August 3, 2018, Solar Krafte submitted to the AUC a letter from AEP WM
(the amendment letter) containing an amendment to AEP WM’s renewable energy referral report
for the project. AEP WM advised that it had reviewed the project’s updated July 2018 wildlife
assessment addendum report and determined that the updated wildlife surveys were conducted
using the correct protocols and no significant risks to wildlife were identified.5 Therefore,
AEP WM stated in its amendment letter that it has downgraded the risk ranking for the project
from moderate to low based on the proposed solar power plant’s siting and the wildlife
mitigation and commitments made by Solar Krafte.6
15. Solar Krafte stated that it had applied to the County of Warner for a development permit
to construct the project, and that a development hearing took place before the county’s planning
committee. Solar Krafte stated that there was no public opposition to the project and a
development permit was issued for the project. Solar Krafte stated that no appeal was lodged
against the project and its permit became effective on September 12, 2017.
16. Solar Krafte stated that the proposed weed and agricultural pest control mitigation
measures for the project would be developed in consultation with the County of Warner’s
Agricultural Service Board, an agrologist and with the County of Warner’s agricultural
fieldsman. Solar Krafte confirmed that the resulting proposed weed and agricultural pest control
mitigation measures recommended for the project would be discussed with interested adjacent
agricultural landowners.7
17. Solar Krafte stated that the proposed mitigation measures to control dust and wind
erosion would be developed in consultation with the county and submitted prior to the start of
grading or construction activities.
18. Solar Krafte received a letter of non-objection from NAV CANADA on April 9, 2018.8
19. A glare analysis for observation points near the project site was conducted by
Solas Energy Consulting Inc. (Solas). The report stated that solar photovoltaic panels typically
reflect up to 10 per cent of the light hitting the panels, but that this can be reduced by applying an
3
Exhibit 23323-X0056 and Exhibit 23323-X0057.
4
Exhibit 23323-X0035, Information Response (Round 2), PDF page 5.
5
Exhibit 23323-X0065, AEP WM Amendment Letter, PDF pages 2-3.
6
Exhibit 23232-X0065, AEP WM Amendment Letter, PDF page 3.
7
Exhibit 23323-X0041, Information Response (Round 2), PDF page 8.
8
NAV CANADA is the company that owns and operates Canada’s civil air navigation service and is responsible
for communicating aviation safety aspects related to structures such as wind turbines.
Decision 23323-D01-2018 (August 21, 2018) • 3Stirling Solar Project Solar Krafte Utilities Inc.
anti-reflective coating to the panels. Solas explained that it conducted a glare analysis at eight
points surrounding the project to account for residences, points along roads adjacent to the
project and highway intersections in the area. Solas modelled a worst-case glare scenario,
specifying smooth glass without an anti-reflective coating. Solas concluded that the project
would not produce glare at any hazard level at any of the measured points and that these results
would not differ between crystalline and thin-film solar photovoltaic panels.9
20. A noise impact assessment (NIA) for the project was conducted by FDI Acoustics Inc.
(FDI) using the base case reference.10 The reference case for the NIA modelled six Sungrow
SG3000HV inverter/transformer pairs for the inverter and transformer stations because it would
be the most likely choice for the power plant. Subsequent to three information requests,
Solar Krafte submitted an updated noise impact assessment summary form11 based on the final
project layout of four SMA inverter/transformer locations. The noise impact assessment
summary form indicated that with the revised project layout and equipment, the predicted sound
levels at the most impacted residence would be 51.0 dBA Leq daytime and 45.7 dBA Leq
nighttime; compliant with the daytime permissible sound level (PSL) of 55 dBA Leq but above
the nighttime PSL of 45.0 dBA Leq.
21. In response to a fourth round of information requests, FDI provided additional
clarification and information for the proposed project. FDI stated that the predicted exceedance
of the nighttime PSL at Residence R3 is due to the conservative approach used in the noise
modelling of AltaLink’s Stirling 67S Substation, which assumed a steady state sound power
level with all cooling fans operating continually. However, cooling fans on transformers operate
in response to required load, so the cooling fans will not run continually in actual operation. FDI
further provided both the predicted cumulative nighttime sound levels for the proposed power
plant and for the Stirling 67S Substation based on the substation operating without cooling fans,
an operating condition known as oil natural air natural (ONAN). In addition, FDI provided the
results from the comprehensive sound survey for the AltaLink Stirling 67S Substation 12
completed at Residence R3 by SLR Consulting (Canada) Ltd. showed compliance of the
Stirling 67S Substation with an isolated nighttime sound level of 33.4 dBA Leq.
22. In the fourth round of information responses, Solar Krafte submitted revised tables for its
noise impact assessment summary form using the finalized equipment based on ONAN sound
power levels.13 The revised results assuming the operating condition of ONAN showed that the
cumulative predicted sound levels of the proposed power plant and the Stirling 67S Substation
complied with the daytime and nighttime PSLs of Rule 012: Noise Control, with the cumulative
nighttime sound levels predicted at 40.9 dBA Leq and 41.2 dBA Leq respectively. The predicted
noise contribution alone is 30.6 dBA.
23. FDI summarized that “due to the nature of the timing, variability and duration of the
regulated facilities acoustic environment, the predicted sound levels from the solar project
sources, the general impression is that the project will comply at all residences with the
Stirling 67S Substation primarily operating in ONAN mode and the solar project operating
9
Exhibit 23323-X0027, Attachment 5 – Solas Energy Consulting Inc. Memorandum.
10
Exhibit 23323-X0031, Attachment 9 – Revised FDI Acoustics Noise Impact Assessment.
11
Exhibit 23323-X0063, Attachment 3 – Revised Noise Impact Assessment Summary Form.
12
Exhibit 23323-X0042, Attachment 1 – SLR Substation Audible Noise Study.
13
Exhibit 23323-X0066, Information Response (Round 4), PDF page 7.
4 • Decision 23323-D01-2018 (August 21, 2018)Stirling Solar Project Solar Krafte Utilities Inc.
primarily during daylight hours.”14 Solar Krafte agreed to complete another compliance survey
following approval and construction of the Stirling Solar Project should a complaint arise from a
residence.15
24. The project was granted Historical Resources Act clearance on September 1, 2017.
25. With respect to its participant involvement program, Solar Krafte stated that it notified all
landowners and residents within 2,000 metres of the project boundary about the project and
consulted with residents within 800 metres of the project boundary. Solar Krafte stated that a
project-specific information package was mailed to residents on June 7, 2017, and a project
update package was mailed out on November 27, 2017. An open house was held on
June 24, 2017. Solar Krafte also notified other interested parties about the project, including
government agencies and industrial stakeholders and businesses, as required by Rule 007.
Solar Krafte confirmed that stakeholders were informed of both types of solar photovoltaic
panels that could be used for the project.16
26. Solar Krafte stated that during the notification process, stakeholders had questions
regarding the project including visual impact and aesthetics, glare from the solar panels, noise,
siting considerations, weed control, and loss of farmland. Stakeholders also questioned whether
new transmission infrastructure would be needed and whether the project is dependent on
government subsidies.
27. Solar Krafte stated that it agreed to plant trees and pay for the maintenance of the trees to
serve as a visual screening for three neighbouring homes to the project. Further, Solar Krafte
indicated that it agreed to implement and pay for chloride and lignosulfonate oilings along the
gravelled public roads that access the project site from Highway 4 and run north and south along
Range Road 193. Solar Krafte stated that it responded to all questions and concerns, fulfilled all
commitments to landowners and residents, and will continue to provide general project updates.17
28. Solar Krafte stated that there are no outstanding concerns or issues regarding the project.
Solar Krafte stated that it would continue its engagement with stakeholders throughout the
application process, pre-construction, construction and operation activities.
29. In its application update, Solar Krafte stated that construction would begin on or
around September 15, 2018, and that the expected in-service date would be March 30, 2019.
Solar Krafte stated that the power plant would have an operational lifespan of approximately
25 years.
4 Findings
30. The Commission has reviewed the application and has determined that the technical,
siting, environmental and noise information requirements for the power plant have been met.
31. The Commission finds that Solar Krafte’s participant involvement program for the
project satisfies the requirements of Rule 007 and there are no outstanding public or industry
14
Exhibit 23323-X0066, Information Response (Round 4), PDF page 5.
15
Exhibit 23323-X0063, Attachment 3 – Revised Noise Impact Assessment Summary Form.
16
Exhibit 23323-X0022, Information Response (Round 1), PDF page 4.
17
Exhibit 23323-X0001, Rule 007 Application (Stirling Solar Project), PDF page 19.
Decision 23323-D01-2018 (August 21, 2018) • 5Stirling Solar Project Solar Krafte Utilities Inc. objections or concerns. In addition, the Commission notes that no parties responded to the notice of application. 32. The Commission notes that the noise impact assessment predicted the worst-case scenario for noise levels from AltaLink’s Stirling 67S Substation with all fans operating continually at the most impacted residence, Residence R3. The Commission considers the results of the 2016 comprehensive sound level survey to be representative of the Stirling 67S Substation’s actual noise level contributions at Residence R3 and demonstrated the conservative nature of the assumptions of the sound power levels used for the Stirling 67S Substation. In making this determination, the Commission notes that the Stirling 67S Substation is a significant contributor to the sound levels at Residence R3. Based on the revised predicted sound levels using the results of the comprehensive sound level survey, the Commission finds that the predicted cumulative sound level of the proposed solar power plant complies with the daytime and nighttime PSLs at Residence R3 and fulfils the requirements set out in Rule 012. 33. The Commission accepts that Solar Krafte will implement the mitigation measures identified in the current version of the project’s environmental protection plan and the wildlife assessment report addendum reviewed by AEP and found to reduce the project risk. 34. AEP has provided approval for reduced setbacks and/or alternative mitigation in the project’s renewable energy referral report and the amendment letter, as well as approval under the Water Act. The Commission accepts Solar Krafte’s commitment that the siting of the project’s infrastructure will meet all AEP’s recommended minimum setbacks from wetlands and watercourses, and also that siting, construction and operation of the project’s infrastructure will meet all of AEP’s recommended setbacks for high disturbance level activities from any wildlife habitat features. 35. Following completion of the post-construction wildlife monitoring program, the Commission expects that Solar Krafte will promptly notify AEP WM of the discovery of any provincial or federal threatened or endangered species carcasses that may be attributable to the project and that might be observed near project infrastructure during operation and maintenance activities. 36. The Commission accepts that Solar Krafte will control weeds and plant diseases as described in the application and in accordance with the Weed Control Act and the Agricultural Pests Act. 37. If any changes are made to the siting of the project infrastructure, the construction schedule, or the proposed wildlife mitigation measures, or if any increases are made to the project footprint, from what was reviewed as being acceptable in AEP WM’s wildlife renewable energy referral report, the Commission expects that Solar Krafte will submit these changes to AEP WM for further review to ensure wildlife and wildlife habitat are protected. 38. Solar Krafte is required to comply with all applicable requirements for conservation and reclamation of the project site under the Environmental Protection and Enhancement Act at the end of the project’s life, including the requirement to obtain a reclamation certificate. However, if for any reason at the time of decommissioning there are no statutory reclamation requirements in place for solar electric power generating facilities, The Commission directs Solar Krafte to submit a reclamation plan to AEP and to the Commission for review and approval. 6 • Decision 23323-D01-2018 (August 21, 2018)
Stirling Solar Project Solar Krafte Utilities Inc.
39. In making its decision on the application, the Commission also had regard for
Solar Krafte’s commitment to implement mitigation measures to address the environmental
impact concerns raised by AEP in its renewable energy referral report. Given these
commitments, and taking into account the project’s location on previously disturbed lands, the
Commission is satisfied that the project is likely to have minimal adverse impacts on the
environment and to area residents. The Commission is also satisfied that if such impacts were to
occur, they could be mitigated to an acceptable degree.
40. Regarding solar glare, the Commission accepts as reasonable the findings of the Solas
report that the project would not produce glare at any hazard level at any of the measured points
surrounding the project including residences, points along roads adjacent to the project and
highway intersections in the area.
41. Having regard to the foregoing, the Commission approves the project with the following
conditions:
Solar Krafte shall abide by any requirements and commitments outlined in AEP WM’s
renewable energy referral report and its amendment letter and in the final version of the
post-construction wildlife monitoring and mitigation plan developed for the project. As
necessary, Solar Krafte shall continue to consult with AEP WM throughout construction
and operation of the project.
Solar Krafte shall complete a minimum of three years of post-construction monitoring
and submit the results of the surveys yearly to AEP WM and the Commission.
42. Based on the foregoing and subject to the above-noted conditions, the Commission
considers the project to be in the public interest in accordance with Section 17 of the
Alberta Utilities Commission Act.
5 Decision
43. Pursuant to Section 11 of the Hydro and Electric Energy Act, the Commission approves
the application and grants Solar Krafte the approval set out in Appendix 1 –
Approval 23323-D02-2018 – August 21, 2018. (Appendix 1 will be distributed separately).
44. Pursuant to Section 18 of the Hydro and Electric Energy Act, the Commission approves
the interconnection and grants Solar Krafte the connection order set out in
Appendix 2 – Connection Order 23323-D03-2018 – August 21, 2018. (Appendix 2 will be
distributed separately).
Dated on August 21, 2018.
Alberta Utilities Commission
(original signed by)
Tracee Collins
Commission Member
Decision 23323-D01-2018 (August 21, 2018) • 7Stirling Solar Project Solar Krafte Utilities Inc. Appendix A – Summary of Commission directions with required deliverables This section is provided for the convenience of readers. In the event of any difference between the directions in this section and those in the main body of the decision, the wording in the main body of the decision shall prevail. 1. Solar Krafte shall complete a minimum of three years of post-construction monitoring for the project and submit the results of the surveys yearly to AEP WM and the Commission. This direction will be a condition of Power Plant Approval 23323-D02-2018. 8 • Decision 23323-D01-2018 (August 21, 2018)
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