BCSE comments on Hydrogen Ready Power Plant Project

The proponent offers the use of hydrogen as a fuel as an expectation for the future.  If the project is moved ahead for further review, a schedule for the use of hydrogen should become a commitment and requirement for approval.

If the project is moved froward for further review there must be consideration and analysis of the carbon intensity of the use of hydrogen as a fuel in a blend with natural gas.  This will determine the extent to which the project will impair the carbon-intensity of the Ontario electricity grid.  We recommend that the carbon intensity of the Ontario electricity grid not be impaired.

If the project is moved forward, we recommend that further review must include an analysis of LCOE.  This will permit an objective comparison to other technologies for generating electricity.  It will also allow the final review to assess the economic impact on user rates.

If the proposed project is not rejected during this stage, then the Bowman Centre for Sustainable Energy recommends any approval to be contingent on a commitment by the proponent to schedule the use of hydrogen as a fuel, that the carbon intensity of the electricity generated by the proponent not impair the carbon intensity of the Ontario grid, and that the proponent demonstrate that the LCOE contributes to the affordability of user rates.