Concerns and Opposition to Ontario Pumped Storage Project

As a permanent resident of Meaford with an extensive technical background, I am writing to express my strong opposition to the proposed TC Energy (TCE) Ontario Pumped Storage (OPS) Hydropower project. I have many concerns about this associated IPD and project.

Although I agree that Ontario needs more energy storage capacity, this project is an inadequate, misguided solution. The OPS proposal is sole-sourced and has not been submitted to the IESO Long-Term Request for Proposal (LT RFP) to compete with other energy storage companies and technologies.

There is nothing in the Initial Project Description (IPD) that supports any confidence this project should proceed further. For such a lengthy IPD, there is minimal information and supporting engineering data/calculations about the actual project. This IPD seems to be intentionally vague.

Pumped storage is not electricity generation. It stores energy from electrical generation and then re-generates it with a significant output loss.   

There hasn’t been an open-loop pumped storage project (PSP) built in North America since 1973 (Ludington PSP) and there are good reasons for this. Open-loop PSP’s are environmentally damaging, have high capital costs and are geographically dependent, due to the height differential required between the upper and lower reservoirs. Most more modern PSP’s worldwide are closed-loop designs located in remote areas.

It is true that pumped storage projects currently account for the majority of worldwide energy storage but this dominance will be eclipsed in the future. China is investing in alternative energy storage technologies, such as lithium-ion battery energy storage systems (BESSs), a first-ever sodium-ion grid-scale BESS, gravity storage and compressed air storage. Goldman Sachs Research predicts China will require about 520 gigawatts of energy storage. More than three-fourths of that storage will come from batteries.

I have many concerns about the potential negative impacts and issues associated with this Ontario Pumped Storage (OPS) Hydropower Project. These are not covered adequately in this IPD. My major concerns are:

Environmental Impact

The proposed Ontario Pumped Storage Hydropower project would be located on an active military base with currently unknown levels and types of UXO’s and contaminants on site. Also, the Meaford military base is located on unstable, permeable shale.

The OPS project could cause significant environmental damage to the Niagara Escarpment and Georgian Bay. It could threaten 34 at-risk land species on the base, many aquatic species, municipal water supplies and the local tourist industry.

Reservoir construction and tunneling on the Meaford training base can create significant traffic, noise and release CO2 and other pollutants. Unexploded ordnance (UXO’s) is another problem. Even with modern screen upgrades, the Ludington, Michigan PSP operation still has massive fish kills caused by its pump/turbines and the OPS won’t be significantly different.

In the first decade of operation, the Ludington, Michigan PSP killed approximately 150 million fish every year, when drawn through the pump/turbines. An environmental lawsuit settlement mandated use of a four-kilometre net to protect fish. The Director of Environmental Compliance at Consumers Energy (the Ludington PSP operator), told The Narwhal “The net is 91 per cent effective in saving fish greater than five inches”.

This still allows 9% of the larger fish to enter the turbines and what about the millions of fish 5 inches and under? These fish are the juvenile future generations of mature fish and several mature species of bait fish. Both groups provide a food base for larger fish. The OPS would have an outflow rate of about 1/3 the flow of the Niagara Horseshoe Falls. It’s impossible to block a significant amount of fish and sediment from transiting through the inlets/outlets and pump/turbines without severely restricting flow.

Previous sampling methods in wells have determined limit exceedances but local deep core sampling has not been reported, raising concerns about toxins residing in deep layers. As an example, all forms of mercury, including dissolved, organic, and methylmercury, would be released during excavation. Deep core sampling needs to be performed before this project commences to measure toxic substances that have leached deep beyond soil and well water levels.

Contaminants, fish biohazard, turbidity and extreme turbulent flow-induced underwater noise, etc. entering Georgian Bay through construction activities and plant operation could threaten fish habitat, fish reproduction, a fisheries industry, and the drinking water quality for thousands of people around Georgian Bay.

Also, in the IPD there is no mention of the associated transmission line construction environmental effects, such as tree loss, habitat destruction and increased defoliant contamination.

Capital Cost Impact

Hydro-electric mega-projects have a history of huge cost overruns. The current OPS capital cost projection of $7B is about 3 years old. By project completion, the cost of this project will exceed $10B and may reach $14B+. That will not include the cost of transmission lines, etc. The enormous cost of this project will ultimately be borne by Ontario taxpayers and electricity ratepayers’ surcharges. 

As an example, the Snowy 2.0 Pumped Storage project in Australia had an initial projected capital cost of $2B AUS when it was announced in 2017. By 2025, the cost projection had increased to $12B AUS (6 times). This year, the cost projection is expected to reach $20B AUS and the project is currently only about 70% completed.

Another example is TC Energy’s own Coastal GasLink pipeline in British Columbia. The cost was estimated to be $6.2B in 2018. The final cost was about $14.5B.

Meanwhile, the cost of grid-scale battery energy storage is decreasing rapidly. BloombergNEF recently stated that grid-scale battery costs are currently at their lowest and by 2030, the cost will be about 25% less.

Design issues

Design specifications on this proposed project in the IPD are almost non-existent and vague. At best, the component descriptions are merely an overview.

The reservoir is a major safety concern and yet there is only an overview of the construction that lacks any supporting documentation. The reservoir description does indicate that the ring dam will be constructed mainly of excavated earth and rock material. This ring dam construction would be similar to the Taum Sauk pumped storage plant that breached in 2005.

In the IPD, there is no mention that the design of the inlet/outlet ports is based on the Ashbridges Bay sewage treatment plant design. The Ashbridges Bay flow is only outflow while pumped storage is bi-directional. The flow rate of Ashbridges Bay is only about 1/17 of the outflow of the OPS project. The outflow flow rate of the TCE OPS would be about 1/3 of the flow rate of the Niagara Horseshoe Falls and yet no design experience, studies or supporting data for this design have been released to the public by TC Energy.

Construction Issues

The Snowy 2.0 Pumped Storage project had a number of construction issues that have delayed progress and caused huge cost overruns. Some of these problems were due to geological issues, toxic gas, tunnel boring machine issues and sinkholes.

Ontario Pumped Storage construction could have many similar problems due to Meaford military base geology and contamination issues.

In the IPD, it is stated that this proposed pumped storage project will take 5-1/2 years to complete after approval. A battery energy storage plant can be built in 2-3 years and at about half the cost of an equivalent capacity pumped storage plant. 

Disruption to Military Operations

Construction activities and base infrastructure relocation would disrupt and/or defer military training activities. The MP for this area has already expressed his concerns about this matter in the House of Commons.

Now, it has been announced that the 4^th Canadian Division Training Centre has been renamed and is expecting 30% more trainees in the near future and may build 60 dwellings for staff and trainees.

Safety Issues

Approximately 300+ farms, permanent homes, cottages and 1,000+ people are located below the proposed OPS 375-acre reservoir. The dam will be mainly constructed of earth and rock. If this 20 meter high above-ground reservoir ring dam breaches (historically, many dams have), the property damage and loss of life would be catastrophic.

Property owners in the reservoir impact zone have been informed that insurance coverage for dam failure damage will not be offered. It is hard to believe that it is even legal for this reservoir construction to take place.

Even if a dam is correctly engineered, dam failure can be caused by extreme environmental conditions, poor construction practices, human error, sabotage, terrorism or even wars.

On December 14, 2005, the upper reservoir ring dam at the Taum Sauk, Missouri pumped storage plant overfilled due to a construction error, resulting in a dam failure and flooding of 600 acres of a state park. There were no fatalities as no one was in the impact zone at the time, however, damage was estimated at about $1B.

Pumped Storage Efficiency, Energy and Revenue Loss

Superior efficiency, short-term construction times and less environmental impact are battery storage advantages.

A Tesla Megapack battery unit has a 91% round-trip efficiency compared to TCE’s 72% round-trip efficiency claim (stated in the 2020 Navigant report funded by TCE) for the OPS project. The TCE claim doesn’t include long bi-directional transmission line losses that a battery energy storage plant wouldn’t have, if located close to the grid. These transmission line losses could lower the Ontario PS total efficiency down to 67% or less.

In the IPD, TC Energy claims a 1,000 MW output level for 11 hours from a reservoir with 26,000 cubic meters of water capacity, a 10,000 MWh electrical capacity and 174 meters of head height.

Firstly, it’s mathematically impossible to output 1,000 MW of power for 11 hours with a 10,000 MWh capacity. The output would have to be derated to 910 MW to achieve this goal.

Secondly, using TCE’s round-trip efficiency claim of 72%, 174 meters of head height and a standard power formula, the reservoir could only supply 8,860 MWh of energy capacity from the 26,000 cubic metres of water in the OPS reservoir. To obtain a 10,000 MWh capacity, an efficiency of 81.3% would be required. Again, TCE is altering numbers to make this project look better.

Another point is that the IPD doesn’t mention transmission line losses. The OPS will require    bi-directional, long transmission lines with a calculated efficiency loss of about 5%-6%. The OPS will have a total efficiency of 67%. As a battery facility can be built close to an existing distribution line there will only be about a 2% loss.

For the claimed 10,000 MWh capacity, the proposed OPS plant would require 14,925 MWh of input at 67%. The wasted energy is 4,925 MWh.

A 10,000 MWh capacity Megapack battery plant would require 11,236 MWh of input at 89%. The wasted energy is 1,236 MWh. The difference in wasted energy between the two plants is 3,689 MWh = 3,689,000 kWh.

At the average Ontario household electrical consumption of 26 kWh per day, the wasted energy difference between the two technologies could power 340,628 houses during a 10-hour output cycle.

At the average rate of $0.141 per kWh, the retail revenue loss would be $520,149 per day and $190M per year. The revenue loss over the expected 50-year plant operation would be $9.5B.

Emergence of Better Alternative Energy Storage Technologies

Many battery energy storage technologies are emerging or in current use. Some of these are lithium-ion, lithium-iron, iron-air, sodium-ion, sodium solid-state, redox flow and liquid metal batteries. Electric vehicle owners mainly charge their EV’s during off-peak rate hours, at the same time as the OPS would fill its reservoir. Other viable energy storage technologies are gravity storage, compressed air storage, flywheel storage, hydrogen production, thermal storage and high density closed-loop pumped storage.

The claim that a grid-scale battery energy storage system (BESS) has a 4-hour duration limit is false. Several 8-hour BESS facilities are currently planned or in operation in Australia. By 2030, 8-hour battery systems are projected to be cheaper than pumped hydro for long-duration storage due to falling costs and higher round-trip efficiency.

Obsolescence

Within a few years, the Ontario Pumped Storage (OPS) Hydropower project could become obsolete. Pumped storage technological advancement has reached its peak, while alternative energy storage development and deployment is rapidly advancing. Even lithium-ion batteries may be replaced for grid-scale energy storage within a few years.

Peak to off-peak price differential flattening due to the increase in EV’s, and 24-hour AI, cryptocurrency and manufacturing facilities could make this project economically unviable.

Lack of Transparency and No Clear Plan

In spite of the TCE claims of much “public engagement” in this IPD, there has not been any real engagement with the public. Any public information meeting information has been vague and incomplete. Knowledgeable questions about the project have been ignored or deflected by TCE. People have even been told by a local TCE representative that TC Energy will provide information to the public “when the project is approved”. It appears that the only real engagement is with politicians behind closed doors.

There is currently no clear plan behind this project. Technical details are vague and unsubstantiated. Since this proposal’s inception, claims, numbers and specifications have been altered to enhance the project’s appeal to the public.

Lack of Experience and Dubious Track Record

TCE has no experience with pumped storage projects and has a dubious track record with its own pipeline projects. According to the organization Violation Tracker, TC Energy and its subsidiaries have been given 53 environmental, safety, and competition related violation fines since 2000.

Lack of Liability

There is no mention of TC Energy’s liability for damages in this IPD and it appears that it falls under DND’s responsibility. This means Canadian taxpayers will be responsible for any harm and cleanup expenses.

Political Interference and Lobbying

In spite of the IESO twice advising the Ontario Ministry of Energy that this project does not have sufficient economic value to the electricity ratepayers of Ontario, the Ministry still advances this project. In addition, The Ontario government has supplied 285 million dollars to an Alberta firm (TCE) with a market worth of $92B for “pre-development studies” that have not yet produced the assurance that a project of such magnitude and complexity would need.

On the Federal Government level, why has the DND been instructed to accommodate a commercial project on an active, contaminated military base in Meaford when training demand is increasing?

In addition, the local Meaford and Owen Sound Councils voted to declare the towns “conditional willing hosts” for the proposed OPS without any public referendum or formal consultations.

This is an indication to me and many other people that there is a large degree of political interference and lobbying associated with this OPS project.

Economic Benefits Claims

As for TC Energy’s claims of “Made in Ontario”, battery storage projects also create many job opportunities for Ontarians and use locally sourced construction materials, just as the Ontario Pumped Storage project would. Many supposed “local” suppliers of hydro-electric project equipment are divisions of or distributors for global corporations that manufacture overseas. The OPS would be using these suppliers as well.

Commissioned by TC Energy, the Canadian Centre for Economic Analysis (CANCEA) was tasked with making the case for the proposed Ontario Pumped Storage project. This "funded research" was carefully crafted to influence its audience, relying on a model that allows for  user-defined inputs, making the outcomes easily manipulated. The report presents data in ways that exaggerate the project’s benefits, thus painting a much rosier picture than reality. Most of the economic benefits claimed in the IPD are derived from this report.

In the IPD, TCE claims 41,000 jobs created by the OPS project. In the CANCEA report, the 41,000 “jobs” are actually people-years. This was calculated by multiplying the 820 claimed direct construction jobs by 50 years of OPS operation. As there will only be about 32 permanent operations jobs after construction, this claim is unfounded.

The CANCEA report claims that there will be a total of $6.8B in economic benefits to Ontario but if the project cost becomes $14B by completion, there could be a benefits deficit of $7.2B that Ontario taxpayers and ratepayers will be paying for.

Most of the construction jobs will be temporary jobs filled by non-local skilled union workers, working at different time periods over the course of the construction.

The Independent Electricity System Operator (IESO) has rejected TC Energy’s proposal at least twice, citing a lack of value and net economic benefit to Ontario energy consumers.

Negative Social Impact

Large capital construction projects associated with small towns have created several issues for the towns. A large influx of transient workers with high incomes can raise rents, home prices and commodity costs for locals. Crime tends to increase. There is an increased strain on local community services such as hospitals, schools, etc.

CO2 Emissions Reduction Claims

The IPD claims that the OPS will reduce CO2 emissions by 490 tons per year but it doesn’t mention that any gas generation plants will be closed. Total CO2 generated by this massive construction project is estimated by an expert to be about 1,224 tons. Even if the IPD claim of 490 tons is accurate, a battery energy storage facility of the same MWh capacity would achieve a greater CO2 reduction, due to less construction emissions and greater operating efficiency.        

Local Opposition to the OPS Project

Several thousand citizens have signed petitions to the federal government, voicing their opposition to the proposed TC Energy OPS project. Also, seven municipalities, several organizations and cottage associations have expressed their opposition in resolutions and statements.

In this modern world with many alternative grid-scale energy storage alternatives available, it is clear that this archaic proposed TC Energy Ontario Pumped Storage Hydropower project is unviable.

In addition to the project impacts and issues listed above, key design specifications, environmental impacts, mitigation measures, and supporting technical studies have not been disclosed or described sufficiently to the public or in this IPD. Up-to-date project cost estimates and associated ratepayer impacts and project funding details have also not been included.

In view of all of the IPD unaddressed issues and lack of information, I am requesting that this Ontario Pumped Storage Hydropower project IPD be rejected by the IAAC.

As mentioned by many, there several far better and less impactful energy storage technologies available to replace this open-loop pumped storage “dinosaur” that can threaten the pristine beauty of Georgian Bay and the surrounding area.

Mike McTaggart,                                                                                                                                                                                                              Meaford, Ontario