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National Energy Board 

Reasons for Decision 

British Columbia Hydro 

and Power Authority 


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vue ape ON re 
ty Uh So” 

June 1989 

Electricity Exports 


p on 

National Energy Board 

Reasons for Decision 

In the Matter of an Application Under 
the National Energy Board Act 


British Columbia Hydro and Power Authority 


June 1989 

© Minister of Supply and Services Canada 1989 

Cat. No. NE 22-1/1989-5E 
ISBN 0-662-17105-5 

This report is published separately 
in both official languages. 

Copies are available on request from: 

Regulatory Support Office 
National Energy Board 
473 Albert Street 

Ottawa, Canada 

K1A 0E5 

(613) 998-7204 

Printed in Canada 

Ce rapport est publié séparément 
dans les deux langues officielles. 

Exemplaires disponibles auprés du: 

Bureau du soutien de la réglementation 
Office national de l’énergie 

473, rue Albert 

Ottawa (Canada) 

K1A 0E5 

(613) 998-7204 

Imprimé au Canada 


Recital and Appearances 

IN THE MATTER OF the National Energy Board Act and the Regulations made thereunder; 


IN THE MATTER OF an application by the British Columbia Hydro and Power Authority to 
vary the term of Licence EL-162 pursuant to subsection 21(1) of the National Energy Board 
Act. Filed with the Board under File Number 1923-B7-7. 

HEARD at Vancouver, B.C. on 6 and 7 March 1989. 

J.-G. Fredette 
A.B. Gilmour 
. D.B. Smith 
K.C. MacKenzie 
P.D. Feldberg 

E.C. Eddy 
J.W. Fraser 

A. Hulbert 

D. Caldwell 
B. Mueller 

K.C. McAllister 
J.E. Miltimore 

G. Podersky-Cannon 
G. Wilson 

G.R. Bing 

J.M. Black 

I.G. Waddell, M.P. 
P. Graham 

D.G. Bacon 

A.R. Androsoff 

« D.Tremblay-Lamer 

Presiding Member 


British Columbia Hydro and Power Authority 
Alcan Aluminum Limited 

BC Gas Inc. 

City of Port Moody 

ISCA Management Ltd. 

Judicial Action 
Kootenay Okanagan Electric Consumers Association 

Liberal Party of British Columbia 

On his own behalf 

On his own behalf 

Port Moody/Coquitlam 

Society Promoting Environmental Conservation 
TransAlta Utilities Corporation 

Westcoast Energy Inc. 

National Energy Board 

Table of Contents 

Recital and Appearances ...........cccecscscccscscecscscceccncesscnssseneneseasscnsssessesnseesssaenenenserecenes i 
Abbreviations © cic. cicocsce ccc nececos (seat ened ae eee tee eae cs SRS ose eithe ca Dale ys wislge tietsiseles eve 06 ce eermremeeeM ili 
1s .Background).%. iis wos loeht- etal ee Be ed EIS BER ER EL TS Es ated de i 
2. The Applicant  ...0..00edsccncedeestu ses te ice ReenOne aturde cides Vr aera tortie ripe domecser oven tne= ve eaaetencs 2, 
3. The Application .......::.00c0:<¢ofevanyoveesscst eens eee eee eens cote ag 2 oe Ble sere ce un ese eee Me 3 
A. Intervenor’s Motion icc eeic este arnt ee ee eo a eee datniete des vite sods nae Cee sem eure areata 4 
4.1 Motion to Request Federal Department of the: 
Environment Participation inithe Wearing 9) .--...1....ceses ce sere eee acas ceccen eee oneare 4 
4.2: Disposition of Motions 22.5 .crcsec Se eet ccee tec ee cocoa y onde red ceavnetencenaen aie <n tacea eee 4 
5 The Evidence wien cet natant ces sons 0a OR n ee ere re Oe Eee Rte eee reas Fae Cerne et ee ee 5 
5-1 Generation Capacity Surplus “ee g oe wteces acerca nes care oe 5 
5.2. Energy Capability Surplus) :2.../ctsgracecce oot tana oes ces eee ees ieer sn soem a aeerenerteaes 5 
5:3; Alcan's Requirements 4: scccahossseer sees cosa scan Co caer see ace a saee eee ne anc rr at ee 5 
5 Aa Role Gf Burrard coc. cote et a eee ae ican naan ee es esi er epee ieee ne 5 
5 All aintegrated Systema yc pertetce tag ck reise sa ocue eh auccnac stents masa onne ant ae eee 5 
5 POVeSVSlemr OUP POri am ee eter on ke tteee hee aelcc sar niccunauie be cwodsatesteeatenres tenn reams 5 
54:38 System LoadinpiOrder, occ. aa. stead hee eee sone eee eens oe ee 6 
5.5. Environmental Issucsememimrcerer cet rein ert trees sec ss here cancuenacreen tect aati teem 6 
5:5. lL eRequisite Provincial Permitsies. ose eon ces dots e cases ee eee eee ee ee 6 
5.5:2 ° .-Ambient Air Qualityarexcrs oer cree ret Sette aot ew ee cae daetec nate acenece tee aa eee 6 
5.6.32 Burrard: bmissionvianacementc. <9 scseeson ee eee ene ee eee 6 
5.5.4 Intervenors’ Concerns/Applicant’s Responses ................0ceececcescessecceseescecs i 
5.5.5 Environmental Impacts of Hydraulic Generation ..................cececceeeceeeeeees Z. 
5.5.6 Federal Standards and Guidelinesa 7... - ince. scenes eens cece tee ee eee 8 
6, - Disposition stesso Jo cawak von bee eat tae cs oa APO en ek Se EER CRE Oe ne 9 
G1 Surplus ooh 0F See ok ee ae Ee eee ora ee a ee 9 
6.1.1 Impact of Burrard’s Availability and 
Alcan’s Requirements scot ies tena eee reed en cbs sn ere 9 
6:12". sExportof Firm:Capacityandinerpy ee... .csciscsse seta 0ccck. cs See 9 
6.2* Environmental Issues eco vst ac eee ee ee ok ese oe eee 9 
6.2.1 ProvinetaltPermitsysye2G Woosh eee isd sca dee sven Aen ee 9 
6:2;2° “Air Quality and burrard: oinceestecosses toe ecc a. tesco enns teen ee 10 
6:2:3alivdraulic Operations i ere eee eae eee 10 
6.2.4 - Federal Standards aridiGuidelines (et... 5. ccs. .cce.0c0ce one cc sno ccc. eee 10 
to The. Board's Findings ....3.: sie... died Bes Aas ee eras to oaeeaes oe 11 
1. Map of B.C. Hydro’s Main Generation and Transmission Facilities ..............cececesees 13 
2. B.C. Hydro Estimated Dependable Capacity, Peak Demand and Surplus 
for each month of the Licence Extension’ <4...) 4s. eee 14 
3. B.C. Hydro Estimated Dependable and Average Streamflow Capability, 
Demand and Surplus for each month of the Licence Extension ...............ceceeeceeeeeees 15 

4. Amending Order A0-3-EL-162 


Units of Measurement 



B.C. Hydro or 
the Applicant 





Port Moody 





kilometre (1000 metres) 
kilovolt (1000 volts) 

kilowatt hour (1000 watt hours) 
gigawatt hour (1 000 000 kW.h) 
megawatt (1000 kilowatts) 

megawatt hour (1000 kW.h) 

National Energy Board Act 
Alcan Aluminum Limited 
Air Quality Index 

National Energy Board 

British Columbia Hydro and Power Authority 

Bonneville Power Administration 
Burrard Plant 
Cominco Limited 

Kootenay Okanagan Electric 
Consumers Association 

Greater Vancouver Regional District 

nitrogen oxides 

City of Port Moody 

Seattle City Light 

Society Promoting Environmental Conservation 
TransAlta Utilities Corporation 

West Kootenay Power and Light Company, Limited 

Digitized by the Internet Archive 
in 2023 with funding from 
University of Toronto 

Chapter 1 

In December 1983 the British Columbia Hydro and 
Power Authority applied to the National Energy 
Board, in part, for a licence to export firm power 
and energy to the United States for periods of up 
to six years. Following a public hearing in March 
1984, the Board issued firm export licence EL-162 
to B.C. Hydro in July 1984. Licence EL-162 was 
issued for only a four-year period because of the 
uncertainties the Board perceived in respect of the 
firm power requirements of Alcan Aluminum 
Limited in the years 1988-89 and 1989-90. The 
Board was not satisfied at the time it issued the 
licence that there would be firm power and energy 
surplus to reasonably foreseeable Canadian 
requirements in the years 1988-89 and 1989-90 if 
Alcan’s planned smelter expansion at Kitimat was 
to proceed without a corresponding expansion of 
Alcan’s generating facilities. 

The Board also found in its July 1984 Decision 
that there was uncertainty about the availability 
of energy from the Burrard natural gas-fired ther- 
mal plant because B.C. Hydro did not have all the 
requisite provincial environmental permits to oper- 
ate the plant. For these reasons, the Board was not 
prepared at the time to give any credit for supply, 
reserve, or surplus of capacity or energy that 
might be generated at Burrard during normal 

B.C. Hydro applied on 12 February 1988 for a 

review of the Board’s July 1984 decision which 
restricted the export of energy generated at the 

EH-1-89 Electricity Export 


Burrard plant to emergency situations either in 
Canada or the United States, testing, or for opera- 
tional reasons. In May 1988 the Board found that, 
because B.C. Hydro had obtained the requisite pro- 
vincial environmental approvals to _ operate 
Burrard, that is, to generate power for use in 
Canada or for export, the environmental impact of 
operation for export would be within the criteria 
imposed by provincial authorizations. In conduct- 
ing its review of the July 1984 decision, the Board 
sought the views of the parties of record to the 
original proceedings. The operation of Burrard was 
examined through a comparison of the provincial 
permits with the applicable federal standards and 
guidelines. The Board was satisfied that the opera- 
tion of Burrard was in compliance with the appli- 
cable federal and provincial requirements and that 
the provincial permitting process involved public 
participation with the right of interested parties to 
appeal. Consequently, the Board found that no fur- 
ther limitations on the use of Burrard need be 
imposed by conditions of the export licences and 
appropriate licence amendments reflecting this 
finding were issued. 

A public hearing, to extend B.C. Hydro’s Licence 
EL-162 to 30 September 1990, was held in 
Vancouver, British Columbia on 6 and 7 March 
1989. The Board issued its decision approving the 
extension of Licence EL-162, subject to Governor 
in Council approval, on 28 March 1989. This report 
sets out the Board’s Reasons for Decision on B.C. 
Hydro’s application. 

Chapter 2 

B.C. Hydro is a crown corporation operating in 
British Columbia. The company provides electrical 
service to most of the province, the main exception 
being the area served by West Kootenay Power 
and Light Company, Limited. The map included as 
Appendix 1 shows the main generation and trans- 
mission facilities of B.C. Hydro. 

B.C. Hydro’s system is interconnected in the north 
with the Alcan system at Kitimat, in the east with 
the system of TransAlta Utilities Corporation, in 
the southeast with the systems of Cominco Limited 
and WKPL, and in the south with the system of 
the Bonneville Power Administration. Bonneville 
is an agency of the United States Government, 
with extensive generation and transmission facili- 
ties in the Pacific Northwest area of the United 

The Applicant 

There are four international power lines connect- 
ing the B.C. Hydro and Cominco systems to the 
Bonneville system. Two 500-kV lines cross the 
international boundary at Douglas, British 
Columbia, near Vancouver, and two 230-kV lines 
cross the border at Nelway, British Columbia. In 
addition, B.C. Hydro owns an international power 
line that supplies the isolated distribution system 
of Puget Sound Power and Light Company in the 
Point Roberts area of the state of Washington. 

The export of power over these international power 
lines is authorized by Licences EL-162, EL-163 
and EL-164. The licences were issued to the 
Applicant by the National Energy Board in July 
1984. Licences EL-163 and EL-164 will expire on 
30 September 1990, whereas EL-162 was dated to 
expire on 30 September 1988 

EH-1-89 Electricity Export 

Chapter 3 

By an application dated 10 August 1988, B.C. 
Hydro applied to the Board for an extension to 
Licence EL-162. The Board decided’ on 
15 September 1988 that it would treat the applica- 
tion as an application for review pursuant to sub- 
section 21(1) of the National Energy Board Act to 
vary Licence EL-162 and issued AO-2-EL-162 
extending the licence for six months to allow time 
for the review. The Board subsequently decided on 
27 October 1988 to hold a public hearing to obtain 
the evidence and views of all interested parties on 
the application. 

Board’s Explanatory Note 

The Board first informed the public of its intention 
to hold a hearing through the publication, in 
November 1988, of a notice of an impending hear- 
ing. The notice stated that the issues to be 
addressed at the public hearing would be con- 
tained in the Board’s hearing order to be issued at 
a later date. Hearing Order EH-1-89, issued on 
16 January 1989, stated that the Board wished to 
ascertain whether the supply, demand and surplus 

EH-1-89 Electricity Export 

The Application 

position of B.C. Hydro could permit the continued 
export of up to 2000 megawatts of firm power and 
6000 gigawatt hours of energy per year until 
30 September 1990, including the specific consider- 
ation of: 

i) The extent to which B.C. Hydro intends to 
depend on the supply of Burrard to export 
firm power; 

ii) The effects, if any, of the requirements of 
Alcan Aluminum Limited on the demand of 
B.C. Hydro; 

iii) The environmental impact of generating the 
power proposed to be exported under this 
licence; and 

iv) The status of the requisite provincial permits 
to operate the Burrard generating station. 

Included in the list of parties directly served with 
the hearing order were the parties of record to the 
original proceedings held under Order EH-1-84 

Chapter 4 

4.1 Motion to Request Federal 
Department of the Environment 
Participation in the Hearing 

Mr. Ian Waddell, the Member of Parliament for 
Port Moody/Coquitlam, submitted that the Board 
did not have the resources to properly consider 
whether there would be detrimental environmen- 
tal impacts to Canada resulting from electrical 
exports that might be made under the extended 
term of Licence EL-162. Mr. Waddell further sub- 
mitted that, as intervenors such as volunteer and 
charitable organizations are limited in resources, 
the Board should ask the federal Department of 
the Environment to intervene in the hearing 
because a fair hearing would not be possible with- 
out that department’s expertise and resources. 

Intervenor’s Motion 

The Society Promoting Environmental Conserva- 
tion, the Kootenay Okanagan Electric Consumer 
Association, the City of Port Moody and two inter- 
venors representing themselves supported the 
motion. The Applicant opposed the motion. 

4.2 Disposition of Motion 

The Board reminded all parties that the hearing 
would consider evidence on all matters, including 
the environment. The Board stated that it recog- 
nized the government’s recent establishment of 
environmental matters as a priority and that, in 
its review, the Board would re-examine the facts 
and determine if current environmental require- 
ments and norms are being met. The Board further 
stated that it had the expertise to assess and test 
the validity of evidence presented at the hearing. 
Consequently, the Board denied the motion. 

EH-1-89 Electricity Export 

Chapter 5 

5.1 Generation Capacity Surplus 

The Applicant’s estimates of dependable power 
capacity, peak demand and surplus power are 
summarized in Appendix 2. In calculating the sur- 
plus capacity available for export, B.C. Hydro 
excluded supplies from Burrard because it lacked a 
firm gas supply. B.C. Hydro did not include either 
the demand of Alcan or any supply it might pro- 
vide in the calculations of surplus for the reasons 
detailed in Section 5.3. The supply and demand 
balances take into account the Applicant’s own 
load, plus its firm commitments to West Kootenay 
Power and Light, Limited, transfers to Seattle City 
Light under the Skagit River Treaty as well as a 
capacity reserve credit reflecting B.C. Hydro’s 500- 
kV interconnection with Alberta. Appendix 2 
shows that the surplus capacity over the licence 
extension period ranges from a monthly low of 
261 MW to a monthly high of 2000 MW. 

5.2 Energy Capability Surplus 

The Applicant’s estimates of monthly energy capa- 
bility, loads and surplus, under probable load 
growth assumptions for both dependable and aver- 
age streamflow conditions, are summarized in 
Appendix 3. The evidence showed that, under both 
dependable and average streamflow conditions for 
any consecutive 12 months of the period April 1989 
to September 1990, B.C. Hydro surpluses exceed 
the 6000 GW.h export quantity permitted under 
Licence EL-162. The Burrard station is included in 
the calculation of available energy under both 
dependable and average streamflows, as are trans- 
fers to WKPL and SCL. 

The evidence shows hydraulic surpluses under 
average streamflows, but none, under dependable 
conditions. Transfers to Alcan are excluded for the 
reasons detailed in Section 5.3. 

EH-1-89 Electricity Export 

The Evidence 

5.3 Alcan’s Requirements 

As previously mentioned, the issuance in 1984 of a 
firm export licence (EL-162), limited to a four-year 
term, reflected, in part, the Board’s concern that 
Aican might place additional firm load require- 
ments on the Applicant in the years 1988-89 and 
1989-90. Alcan, as an intervenor in the present 
proceedings, stated that, barring emergencies, it 
did not anticipate purchasing any power from B.C. 
Hydro in the period covered by the export applica- 
tion and that, on the contrary, Alcan expected to 
have power available for sale to the Applicant until 
at least 30 September 1990. The Applicant stated 
that it is negotiating with Alcan to purchase part 
or all of Alcan’s firm surplus. 

5.4 Role of Burrard 

5.4.1 Integrated System 

The Applicant stated that the source of B.C. 
Hydro’s exports will be from the integrated gener- 
ating system of which the 912-MW Burrard station 
is a part. Because Burrard is a high-cost generat- 
ing station it is used only when required. The 
annual Burrard capability of 5520 GW.h comprises 
3430 GW.h generated from off-peak gas purchases, 
while the remaining 2090 GW.h comes from gas 
purchased at regular market prices. Supply can 
also be supplemented by purchases from Alcan and 

Currently, 450 MW of the Burrard station’s units 
are operated as synchronous condensers to lend 
stability to B.C. Hydro’s transmission system. 

5.4.2 System Support 

The Applicant stated that the domestic load had 
grown to a point where, very shortly, hydraulic 
capability would not be able to fully supply the 
firm domestic load. At that point the firm energy 

capability of Burrard would be required to supple- 
ment the hydraulic system. 

In addition, the evidence showed that at this time 
the principal roles for Burrard are as follows: 

- emergency back-up during outages; 

- emergency supply in poor water years; 

- voltage support for the Vancouver area; and 

- system back-up should new projects be delayed. 

5.4.3 System Loading Order 

The Applicant’s evidence showed that, in loading 
its system, resources are allocated on the basis of 
cost. The Burrard station, because of the relatively 
high costs associated with its operation, is one of 
the last stations loaded. However, the witness for 
B.C. Hydro stated that, because the use of Burrard 
is dependent upon the cost of energy available 
from other sources, it is not necessarily the last 
station loaded onto the system and that the cost of 
supply from Alcan or Alberta may vary the actual 
loading order. 

Thus, exports, if any, would first be made from 
hydraulic surpluses on the B.C. Hydro system 
before other sources of supply such as Alcan, 
Alberta coal or gas-fired generation, or additional 
energy available from the Burrard station at appli- 
cable peak gas prices would be utilized. The wit- 
ness for B.C. Hydro stated that exports from any 
particular source would be dependent upon market 

5.5 Environmental Issues 

5.5.1 Requisite Provincial Permits 

The evidence showed that, under the British 
Columbia Waste Management Act, B.C. Hydro 
requires two environmental permits for the use of 
the Burrard plant. The first is an effluent permit 
(PE-7178) which was issued in 1985 and does not 
require renewal. That permit sets limits for cooling 
water discharge temperatures, discharge volumes 
and miscellaneous wastes from the Burrard plant 
as well as the monitoring of Burrard Inlet in the 
vicinity of the plant. 

The second permit required is an air emission per- 
mit (VA-330) issued by the Director of the Greater 
Vancouver Regional District specifying air emis- 
sion limits. This permit provides for the curtail- 

ment of the operation of Burrard in the event of 
poor ambient air quality. All permits issued by the 
GVRD require periodic renewal. B.C. Hydro had 
applied to the GVRD for an extension of the air 
emission permit beyond its expiry date of 30 April 
1989. The GVRD permitting process is a public 

There is also a Provincial Energy Removal 
Certificate in effect which allows energy to be 
exported until 30 September 1990. 

5.5.2 Ambient Air Quality 

B.C. Hydro’s evidence showed that the GVRD oper- 
ates an air quality monitoring network to provide 
continuous measurement of air pollution levels in 
the Greater Vancouver area. The GVRD evaluates 
the regional air quality using provincial criteria 
which are consistent with air quality objectives 
established by the federal Department of the 
Environment. The federal objectives define the lev- 
els of contaminant concentration as Maximum 
Desirable, Maximum Acceptable and Maximum 

The index pollutants measured are sulphur diox- 
ide, carbon monoxide, nitrogen oxides, ozone and 
suspended particulates. There is also a short-term 
daily air quality index (AQI) calculated from cur- 
rent hourly air quality measurements of the gase- 
ous index pollutants. 

The Applicant’s evidence indicates that, for the 
most part, air quality in the Greater Vancouver 
Region meets the federal air quality objectives. 
Measurements exceeding objectives occur infre- 
quently and are associated with poor atmospheric 
dispersion during the fall and winter and with the 
occurrence of photochemical episodes in the 

B.C. Hydro’s evidence showed that the GVRD and 
the provincial government have entered into a two- 
stage air management planning project. Stage one, 
scheduled for completion in mid-1989, will identify 
air quality problems and general air management 
needs while stage two will assess future emission 
control strategies and procedures to achieve goals. 

5.5.3 Burrard Emissions Management 
The Applicant’s evidence showed that the opera- 

tion of Burrard is currently regulated by an ambi- 

EH-1-89 Electricity Export 

ent control regime based on nitrogen dioxide meas- 
ured in the vicinity of the plant. Through the ambi- 
ent air control program, the operation of Burrard 
is curtailed when the GVRD AQI index reaches 50, 
a limit equal to the federal Maximum Acceptable 
quideline. Combustion modification techniques 
have resulted in a 40 percent reduction in the of 
emission of nitrogen oxides and studies are contin- 
uing to investigate additional emission reduction 
with the objective of making Burrard the cleanest 
plant of its type in North America. 

5.5.4 Intervenor’s Concerns/Applicant’s 

The Board heard interventions at the hearing from 
SPEC, the ECA, the Liberal Party of British 
Columbia, Judicial Action, Mr. I.G. Waddell, M.P., 
and Messrs. Bing and Black who represented 
themselves. Others who had stated their intention 
to intervene did not participate at the hearing or 
were satisfied that their concerns were addressed 
through the GVRD air quality permit system. 

SPEC, ECA, Mr. Waddell, M.P., and Mr. Bing 
raised concerns about air quality, visual pollution 
and the emissions of nitrogen oxides, ozone, carbon 
monoxide and other trace emissions. The Liberal 
Party of British Columbia supported the applica- 
tion provided that the price of exports results in 
the people of British Columbia receiving the fullest 
value possible, due them by their ownership, while 
maintaining the long-term environmental integrity 
of the province. The party also believed the use of 
existing generating facilities in British Columbia 
should be maximized, prior to the construction of 
additional generation in the province. Mr. Black 
expressed his concerns about B.C. Hydro’s pre- 
building generation and exporting power from 
these facilities at prices below cost with the subse- 
quent transfer of the pre-building costs to domestic 
residential customers. Judicial Action stated that 
the energy exported could be better used for alter- 
native purposes to serve the people of British 
Columbia at affordable prices. 

SPEC stated the Burrard plant should be shut 
down sooner than required under the AQI because 
pollution readings generally keep rising even after 
a plant is shutdown during periods of atmospheric 
stagnation. Mr. Waddell, M.P., Mr. Bing and SPEC 
felt that Canadians pay a price in air quality deg- 

EH-1-89 Electricity Export 

radation and suffer from visual pollution each time 
Burrard is used for export purposes and that 
export commitments should be met without the 
use of Burrard. B.C. Hydro argued that the opera- 
tion of Burrard is regulated under its air emission 
permit which requires the curtailment of the oper- 
ation of Burrard whenever the GVRD Air Quality 
Index exceeds the federal Maximum Acceptable 

SPEC, ECA and Mr. Waddell, M.P., and Mr. Bing 
also expressed concerns over the contribution of 
Burrard to NOx emissions in the Vancouver 
Region and stated that NOx emissions lead to 
health, environmental and economic problems. 
However, B.C. Hydro’s environmental evidence 
showed that the operation of Burrard meets all 
current applicable federal and _ provincial 

In response to some of the intervenors’ concerns 
about ground level ozone impacts on health and 
agriculture, B.C. Hydro stated that the Burrard 
station was not a major contributor to ozone pro- 
duction and testified that it is developing control 
strategies to further minimize the impact of 
Burrard on ozone production. 

ECA and Mr. Waddell, M.P. voiced concerns about 
other emissions from Burrard such as carbon mon- 
oxide and hydrogen sulphide. B.C. Hydro’s witness 
testified that fuel combustion controls reduce the 
production of carbon monoxide and that carbon 
monoxide monitors are being installed at the plant 
to assist in the combustion control program. B.C. 
Hydro stated the contribution of Burrard emis- 
sions to sulphur compounds is very low because 
the gas supply for the plant is essentially sulphur- 

5.5.5 Environmental Impacts of 
Hydraulic Generation 

B.C. Hydro was questioned about any environmen- 
tal impacts due to exports resulting from hydraulic 
generation. The Applicant testified there had been 
no significant changes in its hydraulic generating 
system since the 1984 hearing and that environ- 
mental impacts of hydraulic generation will not 
change under the proposed extension of Licence 

5.5.6 Federal Standards and Guidelines 

Evidence was presented by B.C. Hydro which com- 
pared the operation of Burrard with the relevant 
federal environmental standards and guidelines. 

Federal standards establish limits on concentra- 
tions of pollutants in the ambient air. The evidence 
showed that B.C. Hydro’s requirement to curtail 
operations under the GVRD air emissions permit 
during the proposed licence extension period is a 
standard exceeding that of similar fossil fuel- 
burning plants in the region. B.C. Hydro’s evidence 
comparing Burrard with guidelines for new sta- 

tionary sources of fossil-fuel electricity generating 
plants showed that Burrard meets applicable fed- 
eral requirements. 

The operation of Burrard was also compared with 
the applicable provisions of the federal design 
phase code for new plants. The evidence showed 
that B.C. Hydro’s discharges under the provincial 
effluent permit conform to the relevant recommen- 
dations of the federal design phase code. As well, 
the provincial monitoring program under the efflu- 
ent permit conforms with the applicable provisions 
in the federal design phase code. 

EH-1-89 Electricity Export 

Chapter 6 

The Board has given consideration to all the evi- 
dence and submissions presented and has reached 
the following conclusions. 

6.1 Surplus 

To ascertain whether B.C. Hydro could export up 
to 2000 MW of firm power and up to 6000 GW.h 
energy-per year during the proposed licence exten- 
sion period, the Board examined B.C. Hydro’s esti- 
mated supply, demand and surplus position to 
30 September 1990. 

6.1.1 Impact of Burrard’s Availability 
and Alcan’s Requirements 

The Board is satisfied that its earlier concerns over 
the availability of energy from Burrard, which led 
the Board to not giving credit for supply, reserve or 
surplus for capacity or energy that might be gener- 
ated at Burrard, no longer exist. The Board notes 
the Applicant’s requirement for the Burrard plant 
for system support and to supplement its hydraulic 
generation system. Accordingly, the Board recog- 
nizes the possibility that any surplus available for 
export may include electricity generated at the 
Burrard plant. 

In addition the Board notes that Alcan’s require- 
ments up to 30 September 1990 can be met from 
Alcan’s own generation. Accordingly, the Board is 
satisfied that those requirements no longer need to 
be considered in the Board’s examination of 

6.1.2 Export of Firm Capacity and 

The Board finds that the Applicant’s estimates of 
capacity under dependable streamflows, and of 
energy capabilities under both dependable and 
average streamflows along with its estimates of 
firm commitments and probable load growth 
assumptions are reasonable. 

EH-1-89 Electricity Export 


With respect to the export of firm capacity, the 
Board notes that, in most months during the pro- 
posed export period, B.C. Hydro’s estimates of sur- 
plus capacity under dependable streamflows are 
less than 2000 MW. However, the Board is satis- 
fied that, in some months B.C. Hydro could export 
up to the requested 2000 MW and that, in other 
months, some surplus capacity is available for 
export. With respect to the export of firm energy, 
the Board is satisfied that B.C. Hydro could export 
up to 6000 GW.h in any consecutive 12-month 
period to 30 September 1990. 

The Board has taken into consideration interven- 
ors’ concerns about exports from Burrard and 
notes that the plant’s use for export purposes will 
largely be determined by the marketplace for elec- 
tricity and that its use for export will likely be 
minimal due to the high cost of Burrard genera- 
tion. The Board notes that firm export Licence 
EL-162 is conditioned to ensure there is a pre- 
mium charged for incremental production from 
Burrard and such a condition would continue to 
apply to any licence extension issued hereunder. 

6.2 Environmental Issues 

6.2.1 Provincial Permits 

The evidence submitted with the application shows 
that B.C. Hydro has all the necessary permits to 
operate Burrard to generate power for use in 
Canada or for export. These include an effluent 
permit, an amended air emission permit and an 
energy removal certificate. The Board is aware 
that the air emission permit is being reviewed by 
the GVRD and notes that B.C. Hydro will have to 
secure the appropriate renewal of the air emission 
permit before exports from Burrard generation can 
be made. The Board is satisfied that the GVRD 
permitting process addresses the appropriate tech- 
nical aspects of the air quality issue and involves 
public participation. 

6.2.2 Air Quality and Burrard 

The Board notes that the GVRD measures air pol- 
lution and controls the operation of Burrard based 
on a daily air quality index which is equivalent to 
the federal Maximum Acceptance Level and that 
the GVRD along with the provincial government 
are conducting a long-term air management study 
to assess future air control strategies. The Board 
accepts the Applicant’s undertaking to ensure that 
Burrard will conform to the air control strategies 
that will evolve. 

From its examination of the evidence, the Board 
concludes that the air quality in the Greater 
Vancouver Region complies with federal air quality 
objectives at most times and that measurements 
exceeding the objectives occur infrequently under 
adverse weather conditions. Because of the emis- 
sion controls imposed on the operation of Burrard 
by the GVRD, the Board is satisfied with the use of 
the Burrard plant to satisfy domestic or export 
requirements. The Board recognizes that to satisfy 
B.C. Hydro system requirements the Burrard 
plant may be operating while exports are taking 

The Board also notes the Applicant’s undertakings 
to minimize the impact of Burrard as a contributor 
to the production of ozone. The Board believes that 
intervenors’ concerns about the impact of Burrard 
air emissions on health and agriculture are being 


addressed by B.C. Hydro’s air emission reduction 
program, by its studies, to the extent that these 
may lead to further reduction of these emissions 
and by the GVRD’s air quality monitoring program 
under the air emission permit..The Board further 
notes the Applicant’s installation of monitoring 
devices to assist it in the control of gaseous emis- 
sions from the plant. 

6.2.3 Hydraulic Operations 

The Board is satisfied that the incremental envi- 
ronmental effects resulting from hydraulic exports 
under the proposed licence extension will be negli- 
gible since B.C. Hydro’s facilities and operations 
have not changed in any significant respect since 
the Board’s July 1984 decision. 

6.2.4 Federal Standards and Guidelines 

Although federal standards and guidelines relate 
to new plants, the Board examined the federal 
standards and guidelines and recognized them as a 
benchmark against which to evaluate the perfor- 
mance of Burrard. Based on its examination, the 
Board is satisfied that Burrard meets the applica- 
ble guidelines for ambient air pollution for new 
stationary generating sources. The Board also com- 
pared the operation of Burrard with federal design 
codes for new plants and is satisfied that provin- 
cial monitoring conforms with the applicable 
design codes. 

EH-1-89 Electricity Export 

Chapter 7 

EH-1-89 Electricity Export 

The Board’s Findings 

The Board has satisfied itself that the power and 
energy that may be exported are surplus to reason- 
ably foreseeable Canadian requirements and that 
the operation of Burrard will meet applicable fed- 
eral environmental standards and guidelines, and 
has considered all other matters that appear to be 
relevant. Accordingly, on 28 March 1989, the 
Board issued to B.C. Hydro, subject to Governor in 
Council approval, an extension to 30 September 
1990 of the continuing export of up to 2000 MW of 
power and up to 6000 GW.h of energy in any con- 
secutive 12 month period allowed under Licence 
EL-162. Amending Order A0-3-EL-162 is attached 
as Appendix 4. 

The foregoing constitutes our Reasons for Decision 
and decision in the matter of the present applica- 
tion of the British Columbia Hydro and Power 
Authority pursuant to Section 21 of the National 
Energy Board Act. 

A.B. Gilmour 

D.B. Smith 


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EH-1-89 Electricity Export 

Appendix II 

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EH-1-89 Electricity Export 


Appendix III 


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EH-1-89 Electricity Export 


Appendix IV 

IN THE MATTER OF the National Energy Board 
Act and the Regulations thereunder; and 

IN THE MATTER OF an application by the 
British Columbia Hydro and Power Authority 
(B.C. Hydro) pursuant to subsection 21(1) of the 
National Energy Board Act, to vary Licence 
EL-162; filed with the Board under File No. 1923- 

WHEREAS the National Energy Board has issued 
to B.C. Hydro Licence EL-162, as amended, for the 
exportation of firm power and energy at points on 
the international boundary between Canada and 
the United States of America; 

AND WHEREAS B.C. Hydro by an application 
dated 10 August 1988 has applied for an extension 
of Licence EL-162; 

AND WHEREAS the Board has issued an exten- 
sion to 30 March 1989 of Licence EL-162 to allow 
time for a review, pursuant to subsection 21(1) of 
the National Energy Board Act, for a further 
extension of Licence EL-162 to 30 September 1990; 

AND WHEREAS a public hearing for a review, has 
been held commencing on the 6th day of March, 
1989, in the City of Vancouver, in the Province of 
British Columbia, at which B.C. Hydro and all 
interested parties were heard; 


ORDER NO. AO-3-EL-162 

AND WHEREAS the requested amendment would 
not increase the total annual quantity of energy 
authorized for export under Licence EL-162. 

AND WHEREAS B.C. Hydro currently has posses- 
sion of the required environmental operating per- 
mits under the provincial Waste Management Act; 

AND WHEREAS B.C. Hydro has _ requested 
renewal of the Air Emission Permit expiring 30 
April 1989 from the provincial authorities; 

AND WHEREAS the Burrard Generating Station 
may not be operated without B.C. Hydro possess- 
ing all the required environmental operating 

IT IS ORDERED THAT Licence EL-162 be 
amended by revoking Condition 1 therefrom and 
substituting therefor the following: 

“1. The term of this licence shall commence on 
the date of revocation of Licence EL-128, and 
shall end on 30 September 1990.” 

Issued under subsection 21(2) of the National 

Energy Board Act, in the City of Ottawa, in the 

Province of Ontario, on 28 March 1989. 


Louise Meagher 

EH-1-89 Electricity Export 

i Lan i.