Decision 25690-D01-2020 (Corrigenda)
Barlow Solar Park Ltd.
Corrigenda to Decision 25690-D01-2020
Barlow Solar Park
November 16, 2020
Alberta Utilities Commission Decision 25690-D01-2020 (Corrigenda) Barlow Solar Park Ltd. Barlow Solar Park Proceeding 25690 Application 25690-A001
November 16, 2020
Published by the: Alberta Utilities Commission Eau Claire Tower, 1400, 600 Third Avenue S.W. Calgary, Alberta T2P 0G5
Telephone: 310-4AUC (in Alberta) 1-833-511-4AUC (outside Alberta) Fax: 403-592-4406 Website: www.auc.ab.ca
Alberta Utilities Commission Calgary, Alberta
Decision 25690-D01-2020 (Corrigenda) Barlow Solar Park Ltd. Proceeding 25690 Barlow Solar Park Application 25690-A001
1. On October 14, 2020, the Alberta Utilities Commission issued Decision 25690-D01-20201 approving the application from Barlow Solar Park Ltd. to construct and operate a 27-megawatt solar power plant, designated as the Barlow Solar Park, in the city of Calgary (the project).
2. In Decision 25690-D01-2020, the Commission included a condition of approval related to Rule 033: Post approval Monitoring Requirements for Wind and Solar Power Plants. The condition was imposed in error because Alberta Environment and Parks did not prepare a renewable energy referral report for the project given its specific circumstances and it neither required nor recommended post-construction monitoring.
3. Decision 25690-D01-2020 also stated in error that ENMAX Power Corporation had “… confirmed its willingness to connect the power plant to ENMAX’s 25-kilovolt electric distribution system provided that Barlow Solar can demonstrate compliance with applicable rules, standards and ENMAX’s interconnection requirements.” No connection voltage was stipulated by ENMAX.
4. Section 48.3 of Rule 001: Rules of Practice, states that “[t]he Commission may issue a Corrigenda decision to correct an error in a decision or order that is not in the nature of a typographical, spelling, calculation error or other similar type of error.”
5. Decision 25690-D01-2020 has been amended to remove the Rule 033 condition as well as the specific reference to ENMAX’s 25-kilovolt distribution system.
Dated on November 16, 2020.
Alberta Utilities Commission
(original signed by)
Carolyn Hutniak Commission Member
1 Decision 25690-D01-2020: Barlow Solar Park Ltd. – Barlow Solar Park, Proceeding 25690, Application 25690-A001, October 14, 2020.
Decision 25690-D01-2020 (Corrigenda) (November 16, 2020) 1
Decision 25690-D01-2020
Barlow Solar Park Ltd.
Barlow Solar Park
October 14, 2020
Alberta Utilities Commission Decision 25690-D01-2020 Barlow Solar Park Ltd. Barlow Solar Park Proceeding 25690 Application 25690-A001
October 14, 2020
Published by the: Alberta Utilities Commission Eau Claire Tower 1400, 600 Third Avenue S.W. Calgary, Alberta T2P 0G5
Telephone: 310-4AUC (310-4282) in Alberta 1-833-511-4AUC (1-833-511-4282) outside Alberta Email: [email protected] Website: www.auc.ab.ca
The Commission may, within 30 days of the date of this decision and without notice, correct typographical, spelling and calculation errors and other similar types of errors and post the corrected decision on its website.
Contents
1 Decision summary ...... 1
2 Introduction ...... 1
3 Discussion ...... 1
4 Findings ...... 4
5 Decision ...... 6
Appendix A – Summary of Commission conditions of approval ...... 7
List of figures
Figure 1: Barlow Solar Park location ...... 2
Decision 25690-D01-2020 (October 14, 2020) i
Alberta Utilities Commission Calgary, Alberta
Decision 25690-D01-2020 Barlow Solar Park Ltd. Proceeding 25690 Barlow Solar Park Application 25690-A001
1 Decision summary
1. In this decision, the Alberta Utilities Commission considers whether to approve an application from Barlow Solar Park Ltd. (Barlow Solar) to construct and operate a 27-megawatt solar power plant in the city of Calgary, designated as the Barlow Solar Park, and to connect the power plant to the Alberta Interconnected Electric System, (collectively, the 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. On June 25, 2020, Barlow Solar filed an application with the AUC seeking approval for the project pursuant to sections 11 and 18 of the Hydro and Electric Energy Act.
3. The Commission issued a notice of application for the project and received one statement of intent to participate from Randy Cusson. For the reasons expressed in its September 8, 2020 ruling, the Commission denied standing to Mr. Cusson and determined that it would not hold a public hearing to further consider his concerns.
3 Discussion
4. Barlow Solar stated that the project would be located on previously disturbed land within the city of Calgary, west of Barlow Trail S.E. and north of 114th Avenue S.E., on the southeast quarter of Section 16, Township 23, Range 29, west of the Fourth Meridian, as shown in the map below.
Decision 25690-D01-2020 (October 14, 2020) 1 Barlow Solar Park Barlow Solar Park Ltd.
Figure 1: Barlow Solar Park location
5. The project would consist of approximately 100,000 solar panels grouped into approximately 1,500 rack-mounted fixed-tilt solar panel tables, 10 inverters, five transformer stations with medium voltage step-up transformers, a collector system, an on-site electrical building, an access road, a small area for construction or temporary laydown and storage, and a perimeter fence. Barlow Solar stated it had not yet finalized the specifics of the solar photovoltaic panels, the inverters and transfer stations or the final layout. The power plant would have a gross generation capability of 27 megawatts.
6. Barlow Solar filed a letter from ENMAX Power Corporation wherein ENMAX confirmed its willingness to connect the power plant to ENMAX’s distribution system provided that Barlow Solar can demonstrate compliance with applicable rules, standards and ENMAX’s interconnection requirements.1
7. Barlow Solar submitted a glare analysis report for the project prepared by Stantec Consulting Ltd. Stantec’s assessment considered the potential for glare impacts from the solar park on nearby receptors along Deerfoot Trail S.E, Barlow Trail S.E., 114th Avenue S.E. and flight paths to and from Calgary International Airport. Stantec predicted that Barlow Trail S.E., 114th Avenue S.E. and the flight paths would not experience any glare. Stantec identified two observation points along Deerfoot Trail S.E. that could receive up to 1,665 minutes of yellow-grade solar glare per year.2 However, Stantec concluded that due to the existence of buildings between the solar park and Deerfoot Trail S.E, the fact that drivers on Deerfoot Trail S.E. are at a lower elevation than the solar park and that there would be a perimeter fence surrounding the solar park, the potential for yellow-grade glare would be extremely low. Further, any glare would be far from the observer’s centre of vision and could be mitigated. Stantec
1 Exhibit 25690-X0027, Appendix1_EPC_Letter_Interconnection_Agreement_BarlowSolar_20200916. 2 Exhibit 25690-X0018, Glare Analysis, PDF page 15, Table 9.
Decision 25690-D01-2020 (October 14, 2020) 2 Barlow Solar Park Barlow Solar Park Ltd.
concluded that the solar park would pose a negligible potential for hazardous glare conditions for all the receptors it assessed.
8. Barlow Solar stated that the solar panels would have anti-reflective coating and any glare issues caused by the project could be addressed by selectively adjusting the angle of the solar panels on the southernmost row of the solar park or by installing screening within the project boundary.
9. Barlow Solar retained Stantec to prepare an environmental evaluation of the project (the environmental evaluation). The environmental evaluation stated that the project has been developed in accordance with the South Saskatchewan Regional Plan and is not located within any of the conservation areas or provincial recreation areas established in the plan.3 The environmental evaluation concluded that the potential adverse effects of the project can be mitigated with the implementation of the project-specific mitigation measures outlined in the environmental evaluation along with industry best management practices and that the residual adverse effects of the project are expected to be not significant.
10. Alberta Environment and Parks (AEP) determined that because the project would be located within an urban area, the Wildlife Directive for Alberta Solar Energy Projects (the directive) is not applicable and accordingly, a renewable energy referral report was not required. 4 Although the directive does not apply to the project, Barlow Solar stated that it consulted with AEP throughout the design phase of the project and voluntarily applied the standards and best management practices of the directive to the project, where practical.
11. Barlow Solar stated that the project is located on top of capped phosphogypsum stacks in an area of industrial development, and the site avoids proximity to known wildlife habitat. It submitted that the project would not disturb the integrity of the phosphogypsum stacks and no excavation would occur within the phosphogypsum stack area.5 It also stated that there are no wetlands within the project disturbance area and mitigation would be implemented during project activity to protect surrounding wetland conditions from indirect effects such as siltation.6
12. Barlow Solar contacted AEP to determine whether an amendment to the existing Environmental Protection and Enhancement Act approval for phosphogypsum stack number 1 would be required for the project site. AEP indicated that an amendment to the Environmental Protection and Enhancement Act approval would not be required. Barlow Solar also provided a letter from AEP indicating that an environmental impact assessment would not be required for the project.7
13. Barlow Solar stated that the mitigation measures proposed in the environmental evaluation would comply with all pertinent environmental-based provincial and federal legislation, acts, and guidelines. It further stated that these mitigation measures would be incorporated into a project-specific environmental protection plan which would be completed prior to the start of construction.8
3 Exhibit 25690-X0006, Attachment_6_Barlow_environmental_evaluation, PDF page 18. 4 Exhibit 25690-X0005, Attachment_4_Barlow DP Solar AEP-WM Urban Letter 2019-11-22. 5 Exhibit 25690-X0006, Attachment_6_Barlow_environmental_evaluation, PDF page 7. 6 Exhibit 25690-X0006, Attachment_6_Barlow_environmental_evaluation, PDF page 34. 7 Exhibit 25690-X0009, Attachment_9_noEPEA_EIA, PDF pages 1-3. 8 Exhibit 25690-X0006, Attachment_6_Barlow_environmental_evaluation, PDF page 5.
Decision 25690-D01-2020 (October 14, 2020) 3 Barlow Solar Park Barlow Solar Park Ltd.
14. Barlow Solar stated that conservation, reclamation and decommissioning activities would be implemented in alignment with AEP’s Conservation and Reclamation Directive for Renewable Energy Operations. Barlow Solar also stated that it would develop a conservation and reclamation plan for the project which would be submitted to the AUC once complete, and that it would conduct a pre-disturbance site assessment prior to the start of construction.9
15. Barlow Solar submitted a noise impact assessment (NIA) for the project to address the requirements of Rule 012: Noise Control. The NIA indicated that the predicted cumulative sound levels for the most affected receptor would be 46.4 decibels A-weighted (dBA) nighttime and 56.0 dBA daytime.10 Barlow Solar submitted that the project is predicted to meet the Rule 012 permissible sound levels.
16. A participant involvement program was conducted pursuant to Rule 007: Applications for Power Plants, Substations, Transmission Lines, Industrial System Designations and Hydro Developments by BRITT Land & Engagement on behalf of Barlow Solar. Barlow Solar stated that the program included consultation with stakeholders within 800 metres of the project and notification to stakeholders within 2,000 metres of the project. Barlow Solar also stated that at the time of filing the application, all outstanding questions and concerns had been addressed.
17. Barlow Solar stated that it consulted with The City of Calgary with respect to its emergency response plan and that the plan would be communicated to local fire responders during construction and operation of the power plant.
18. Barlow Solar stated that construction would begin as early as July of 2021 and be completed by December of 2021.
4 Findings
19. The Commission is considering the application under sections 11 and 18 of the Hydro and Electric Energy Act. In accordance with Section 17 of the Alberta Utilities Commission Act, the Commission must assess whether the project is in the public interest, having regard to its social, economic and environmental effects. The Commission must also decide if an applicant has met the requirements of Rule 007 and Rule 012.
20. The Commission has reviewed the application and has determined that the technical, siting, emissions, environmental and noise aspects of the project meet the Commission’s requirements. The Commission is satisfied that Barlow Solar conducted its participant involvement program in accordance with Rule 007.
21. The Commission finds that the NIA submitted by Barlow Solar in support of the application fulfills the requirements of Rule 012. Based on the results of the NIA, the Commission is satisfied that the project will likely comply with the permissible sound levels established in accordance with Rule 012.
9 Exhibit 25690-X0017, Response to AUC IR1-001 to 007, PDF page 11. 10 Exhibit 25690-X0011, Attachment_7_Barlow_Solar_NIA.
Decision 25690-D01-2020 (October 14, 2020) 4 Barlow Solar Park Barlow Solar Park Ltd.
22. The Commission has reviewed the environmental evaluation, including the proposed mitigation measures, and considers that Barlow Solar’s application addresses all the environmental information requirements of Rule 007. The Commission accepts the environmental evaluation’s conclusion that the potential adverse effects of the project can be mitigated with the implementation of the project-specific mitigation measures outlined in the environmental evaluation along with industry best management practices and that the potential environmental effects of the project would be “not significant.”
23. The Commission notes that AEP did not prepare a renewable energy referral report for this project, given its location within Calgary city limits and that the directive does not apply to projects in urban areas. The AEP project review letter states that AEP supports the siting and development of solar projects within urban areas because urban solar projects have limited impact to wildlife and wildlife habitat, have reduced requirements for transmission infrastructure, and reduce development pressure in locations with higher quality wildlife habitat.11
24. The Commission is satisfied that with diligent implementation of the mitigation measures outlined in the environmental evaluation and adherence to commitments made by Barlow Solar, including its commitment to apply the standards and best management practices of the directive for the project where practical, the identified environmental effects of the project can be mitigated to an acceptable degree.
25. The Commission notes that there are currently no public safety standards or regulations associated with solar glare that apply to the project. The Commission accepts the conclusion by Stantec in its glare analysis that glare from the solar park would not result in lasting health impacts on individuals, and that the glare potential at all defined observation points is predicted to be negligible. The Commission observes that Stantec’s conclusions are premised on anti-reflective coating being applied to the solar panels to limit solar glare.
26. The Commission notes that the glare analysis stated there are buildings between the solar park and Deerfoot Trail S.E. and that the solar park would be surrounded by a perimeter fence at an elevation higher than vehicles travelling on Deerfoot Trail S.E., which would decrease the amount of solar glare drivers could receive to a negligible amount. However, the Commission wishes to ensure that any deleterious glare associated with the project is addressed by Barlow Solar in a timely manner. Accordingly, the Commission imposes the following as conditions of approval:
a. Barlow Solar Park Ltd. shall use anti-reflective coating on the project’s solar panels.
b. Barlow Solar Park Ltd. shall file a report detailing any complaints or concerns it receives or is made aware of regarding solar glare from the project during its first year of operation, as well as Barlow Solar’s response to the complaint. Barlow Solar shall file this report no later than 13 months after the project becomes operational.
27. The Commission notes that Barlow Solar has not finalized its selection of inverters and panels for this project, nor finalized the project’s layout. Consequently, the Commission imposes the following as a condition of approval:
11 Exhibit 25690-X0005, Attachment_4_Barlow DP Solar AEP-WM Urban Letter 2019-11-22, PDF page 1.
Decision 25690-D01-2020 (October 14, 2020) 5 Barlow Solar Park Barlow Solar Park Ltd.
c. Once Barlow Solar Park Ltd. has made its final selection of equipment for the project, it must file a letter with the Commission that identifies the make, model, and quantity of the equipment and, if the equipment layout has changed, an updated site plan. This letter must also confirm that the finalized design of the project will not increase the land, noise and environmental impacts from what was approved by the Commission for the base reference case. This letter is to be filed no later than one month before construction is scheduled to begin.
28. The Commission notes that ENMAX did not express any concerns with the interconnection of the power plant and there are no outstanding public or industry concerns.
29. Based on the foregoing, the Commission considers the project to be in the public interest in accordance with Section 17 of the Alberta Utilities Commission Act.
5 Decision
30. Pursuant to Section 11 of the Hydro and Electric Energy Act, the Commission approves the Barlow Solar Park power plant application and grants Barlow Solar Park Ltd. the approval set out in Appendix 1 – Power Plant Approval 25690-D02-2020 – October 14, 2020.
31. Pursuant to Section 18 of the Hydro and Electric Energy Act, the Commission approves the interconnection application and grants Barlow Solar Park Ltd. the connection order set out in Appendix 2 – Connection Order 25690-D03-2020 – October 14, 2020.
32. The appendices will be distributed separately.
Dated on October 14, 2020.
Alberta Utilities Commission
(original signed by)
Carolyn Hutniak Commission Member
Decision 25690-D01-2020 (October 14, 2020) 6 Barlow Solar Park Barlow Solar Park Ltd.
Appendix A – Summary of Commission conditions of approval
This section is intended to provide a summary of all conditions of approval for the convenience of readers. In the event of any difference between the directions and conditions in this section and those in the main body of the decision, the wording in the main body of the decision shall prevail.
The following are conditions of Decision 25690-D01-2020 that require follow-up with the Commission, and will be tracked as conditions of Power Plant Approval 25690-D02-2020 using the AUC’s eFiling System:
• Barlow Solar Park Ltd. shall file a report detailing any complaints or concerns it receives or is made aware of regarding solar glare from the project during its first year of operation, as well as Barlow Solar’s response to the complaint. Barlow Solar shall file this report no later than 13 months after the project becomes operational.
• Once Barlow Solar Park Ltd. has made its final selection of equipment for the project, it must file a letter with the Commission that identifies the make, model, and quantity of the equipment and, if the equipment layout has changed, an updated site plan. This letter must also confirm that the finalized design of the project will not increase the land, noise and environmental impacts from what was approved by the Commission for the base reference case. This letter is to be filed no later than one month before construction is scheduled to begin.
The following is a condition of Decision 25690-D01-2020 that does not require follow-up with the Commission:
• Barlow Solar Park Ltd. shall use anti-reflective coating on the project’s solar panels.
Decision 25690-D01-2020 (October 14, 2020) 7