Electricity Filing Manual – Chapter 4 – Project Description and Engineering
- 4.1 Project Location
- 4.2 Project Components and Activities
- 4.3 Impacts to the Bulk Power System
- 4.4 Other Required Approvals and Project Schedule
- 4.5 Alternatives
This chapter describes the information an applicant needs to file with the CER with respect to describing the IPL project, including all project components, activities and related undertakings, their location and the project schedule.
4.1 Project Location
The application includes a complete description of where the project and its components are located.
1. Provide a description of, and maps that show, at an appropriate scale:
- the terminal points and international boundary crossover point;
- the route, facility sites and any proposed ancillary facilities;
- land use features which the IPL is to cross;
- constraints that restrict the preferred route or location of facilities or project components;
- the power line outside Canada; and
- the location of project components and related undertakings.
Describe the width of the right of way proposed and the reasons why that width was selected.
Constraints that restrict the preferred route or location of facilities or project components include environmental, socio-economic, and land or resource use factors, including general land tenure; current land uses, zoning and land use plans; the nearest residences and communities; and unique or major physical features.
For some information, line drawings or site plans may be more appropriate.
The CER encourages applicants to include key Global Positioning System (GPS) locations, where available, as part of their spatial information submissions, particularly for the project endpoints, boundary crossover point and main IPL route locator points.
4.2 Project Components and Activities
4.2.1 Engineering Design Details
The application provides a description of the physical design, operational details and lifecycle activities of the proposed project, with sufficient detail to:
- identify project design features and procedures that will ensure the safe, secure and reliable operation of the proposed facilities;
- identify potential project related interactions with the environment; and
- identify project design features and practices that will mitigate adverse environmental and socio-economic effects.
1. The application shall identify and describe all project components, activities and related undertakings (e.g., conductors, substation components, access roads including temporary and permanent bridges, construction camps, temporary work space, etc.), including, but not limited to:
- the voltage level;
- the number and size of conductors;
- a description of the tower or other structures that will provide physical support for the international power line; and
- a single-line diagram identifying all the facilities that constitute the international power line.
2. The application should include a description of how the project will be carried out.
3. Provide a description of any facilities to be constructed by others which are required to accommodate the proposed facilities including temporary facilities.
4. Describe other permits, licenses, or authorizations that will be required before part or all of the project can proceed.
CER-regulated facilities are to be safe and secure. They are also to be built and operated in a manner that respects the rights of those affected. In general, the information listed above is required in order for the Commission to ascertain that the electrical design and operation of the project, if it were built, would meet these goals.
The project description should address:
- what the project is, including:
- a complete list and thorough description of the project components, activities and, any related undertakings (i.e., any additional components or activities required for the project to proceed, such as temporary work space, means of access including temporary and permanent bridges, etc.);
- a description of replacements or expansions of physical works and activities that are anticipated over the life of the project; and
- preliminary drawings if available.
- how the project will be carried out, including:
- a thorough description of how project activities (e.g., clearing, blasting, tower foundations, tower raising, stringing, watercourse crossings, inspection, monitoring programs, testing, etc.) would be carried out during the construction and operations phases; and
- the anticipated workforce (i.e., person days and skills required for construction and operations activities).
The above requirements generally assume that the project is of overhead construction. If the project is of underground construction, in whole or in part, substitute information should be provided as appropriate (e.g., trenching or conduit details and construction information versus information on tower structures).
The single-line diagram identifying all the facilities that constitute the international power line should include information detailing the line’s connection to substation facilities in Canada. The diagram should clearly delineate what substation components form part of the line versus substation components forming part of the host Canadian power system. Components to be identified should include equipment and structures such as busbar, transformers, breakers, switches, air breaks, reactive compensation components, protective relaying and metering equipment, etc.
4.2.2 Engineering Design Philosophy
The application provides sufficient description of the applicable codes, standards and regulations and any engineering details with respect to any special design challenges, to demonstrate that the proposed facilities will be safe, secure and reliable.
1. The application should clearly indicate all primary codes and standards, including the version and date of issue, that will be followed in the design and material selection for each element of the applied-for facility, subject to the following:
- where there is a choice in the code or standard selected, provide a brief reason why the referenced code or standard is considered appropriate, and
- where there is no industry-recognized code or standard, provide brief reasoning why the proposed course of action would be taken with respect to affected design and material selections.
2. The application should clearly indicate that the project will comply with applicable company design and operations manuals and confirm that, in turn, these manuals comply with the codes and standards for the project. As well applicants are expected to keep the latest versions of these manuals available for CER audit and file copies upon request.
- The information listed above is desired in order for the Commission to ascertain that the electrical design and operation of the project, if it were built, would be safe and secure and perceived as being so. To this end the application should demonstrate that the project would not be inconsistent with current generally accepted industry practice and procedure for similar facilities built and operated under similar circumstances and conditions elsewhere, preferably in Canada.
- Where no clearly applicable industry-recognized code or standards exist, the use of good engineering practice is recognized, respected and expected. However, to the extent possible, a course of action proposed as a consequence of doing so should be clearly traceable back to established code, standards or engineering principles.
4.3 Impacts to the Bulk Power System
The application provides sufficient information to identify and justify the effects of the proposed project on the safe operation, security and reliability of the existing and projected power system it would become a part of.
1. The application shall provide:
- the total export and import power transfer capabilities, with and without the proposed international power line, of the local Canadian power system to which the proposed project will interconnect, and of the non-Canadian power system that the international power line will connect to, stating the criteria for those capabilities;
- the proposed international power line’s power transfer capability for sustained transmission of power under winter and summer conditions, and the criteria for the stated power transfer capability;
- a description of the reliability standards to which the IPL will be subject during operation;
- a copy of:
- each interconnection agreement that relates to the construction of the international power line, and
- any other agreement between the applicant and the owner or the operator of the power line outside Canada that relates to the construction and operation of the international power line and the power line outside Canada;
- confirmation ensuring compliance with the North American Electricity Reliability Corporation (NERC) reliability standards, as applicable.
- Applicants should review the General Order for Electricity Reliability Standards (Appendix 1) for guidance on the CER’s expectations regarding reliability standards.
- The information listed above is required in order to ascertain that the presence, timing, design and operation of the project, if it were built, would respect others’ right to expect safe and reliable electrical service from the power system in its existing and projected future forms. It should also assist in ascertaining that the project, if it were built, would not compromise or jeopardize the power system’s physical security. To this end the application must demonstrate that the project has or will acquire all approvals required for it from provincial governments or other appropriate authorities.
- Where the project would be considered to form part of the bulk power system, the application for the project should provide the details of the international power line’s review, studies and recommendations by the appropriate element(s) of governing electric system reliability organization(s), such as the Regional Reliability Organization(s) of the NERC. This could be provided in the form of copies of appropriate documents, such as study reports, issued by such organizations with respect to the project.
- It is the expectation of the CER that applicants will comply with the most current version of reliability standards those are developed by a standards development authority, for example NERC, that is recognized in a province during the design, construction, and operation of the proposed facility. Applicants should confirm their commitment to the Commission.
4.4 Other Required Approvals and Project Schedule
The application includes information on other regulatory approvals and processes and the project schedule.
- a description of provincial approvals that are required for the power line in Canada including,
- a description of the review process for each provincial approval including any public engagement component,
- the status of each review process and the schedule for the completion of any outstanding reviews, and
- a copy of any provincial approvals already obtained;
- a description of the approvals that are required to be obtained, from the appropriate authorities for the power line outside Canada;
- for permit applications, the identity of the designated provincial regulatory agency;
- a schedule showing the projected dates for the start and completion of construction of the international power line and the power line outside Canada; and
- the expected in-service date.
The CER requires information regarding the status of all approvals or authorizations both inside and outside Canada. This is in order to reasonably assure the Commission that there are no issues before other regulators that would prevent or delay either the construction or use of the applied-for facilities. Updates on status may also be provided after an application has been submitted. The Commission will consider non-CER approvals that are filed with the application to the CER and will minimize, to the extent possible duplications in regulatory burden. It is therefore in the applicant’s interest to file non-CER approvals at the outset to improve regulatory efficiency.
While applicants may choose when to apply for their provincial and CER authorizations, applicants should be aware that the CER permit process is best suited for after the corresponding provincial review. Should an applicant choose to apply to the CER before, or at the same time as, applying to the provincial regulator, it will be especially important that project routing is as detailed as much as possible and that public engagement (on that specific route) is as complete as possible. Should an applicant’s project planning and engagement not be far enough advanced before applying to the CER this may result in a longer review process.
In the case of permit applications, section 250 of the CER Act requires that the applicant identify what provincial regulatory agency is designated for the oversight of the proposed IPL. This is an important requirement to ensure there is no regulatory gap in the jurisdiction of the IPL ultimately reverting to the province. Applicants may wish to be prudent in ensuring this issue is resolved prior to applying with the CER.
With respect to scheduling information, the project schedule should:
- include a breakdown of all major construction activities by sub-activities;
- identify any timing constraints or windows which the schedule must accommodate; and
- describe how any changes to schedule can affect the rest of the schedule and ultimately the project.
You should include a description of when proposed decommissioning and abandonment of the project might take place.
For elected certificates, you should also provide a schedule for operational activities, such as inspection, repair or maintenance.
FYI – Reminders...
Applicants applying under a Permit process should obtain provincial approvals prior to applying to the NEB for authorization of an IPL and identify the ongoing provincial regulator.
The application includes a description of the alternatives considered and the rationale for the options selected.
1. Describe other alternatives that were examined and the rationale for selecting the applied-for project over these other possible alternatives.
2. Describe and justify the selection of the proposed route and site, including a comparison of the alternatives using selection criteria.
3. Describe, where appropriate, any alternative designs and construction methods that were considered and the rationale for selecting the preferred design and construction methods.
Alternatives are functionally different ways of meeting the need and purpose of the project, or are other technically, economically, socially and environmentally feasible means of fulfilling the project. These could include an alternative:
- interconnection strategy;
- route or site;
- facility design; or
- construction methods, including different means of development, implementation and mitigation.
Selection Criteria for Alternatives
Different project, routing, design and construction alternatives should be summarized and compared using a suite of criteria that justifies and demonstrates how the proposed option was selected and why it is the best option.
When comparing project, routing, design or construction alternatives, you should elaborate on the following criteria, as appropriate:
- engineering design;
- economic feasibility or costs;
- effect on reliability and security of the existing host power system;
- demonstrated public concern;
- environmental and socio-economic constraints, benefits or potential effects; or
- regional concern from a cumulative effects standpoint.
The level of detail provided should be consistent with the scope of the project and any potential impacts on the stability and reliability of the host power system, other parties, and the environment.
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