Palmer’s Submission to the Submission

This is part #2 of a 2-part posting.  Part #1 covers the original OSPE Submission.

William Palmer is a Professional Engineer who accepted an early leave from paid employment to be able to apply his skills and knowledge (he maintains his professional credentials) to issues facing his neighbours.   Last month the OSPE (Ontario Society of Profession Engineers) issued a draft submission for the Ontario Ministry of Energy with some recommendations on how to handle Ontario’s growing Surplus Base load Generation (SBG) problem.  The OSPE draft called for submissions on the draft and Bill answered their call.  His submission is a very powerfully written indictment of Ontario’s wind energy program and its oversight.

His submission runs 9 pages of which about 7 pages are well-written text, suitable for the general reader, along with 2 pages of charts that illustrate the points he makes in the text.  Go ahead, take 30 minutes, read it for yourself.

In my reading of it, his submission makes 7 general points and all of them are important enough that I’ll go through them one-by-one.  But my short summaries pale in comparison with what Palmer wrote.  You really ought to read it to get a full sense of his outrage.  Here they are:

  1. The OSPE trivializes the health impacts to the neighbors.
  2. The OSPE refrains from stating the obvious problem that the politicians, with their ministerial directives, are making bad decisions.
  3. The OSPE emphasis on nuclear steam bypass is ethically unacceptable.
  4. Wind production does not match demand.
  5. The OSPE understates the economic consequences.
  6. The OSPE trivializes the difficulty of implementing electrical storage.
  7. The OSPE doesn’t concern itself with Who Pays? and How Much?.

1) Health – Palmer notes that “Engineers in Ontario are bound by a code of ethics that demands making “reasonable provision for the safeguarding of life, health or property of a person who may be affected by the work for which the practitioner is responsible” and yet the work of the report as drafted fails to recognize that the inappropriate placement of wind turbines has not only an impact on the electrical grid, but also on human health and safety.”  He then goes on to note that just because the Ontario government has abdicated its obligations to provide a healthy environment for its citizens does not cancel an engineer’s obligations.

2) Directives.  The professional engineers who work for the Ministry of Energy have been “unwilling” to tell the Minister that his directives were mistakes and the OSPE has the obligation to “…tell the emperor that he is not wearing any clothes!”  In his words: “The OSPE report needs to be forceful in stating that it is not technically feasible to integrate this level of intermittent and non-dispatchable generation into the Ontario grid within 6 years while still maintaining “reliable and efficient operation.””

3) Steam Bypass.  The OSPE is too casual with its recommendation that this practice become a normal operating procedure.  Palmer has first-hand experience with steam bypass and “as one who has stood beside the discharge valves as they strained against their anchors dumping hundreds of kilograms of steam at 4000 kPA (250 degrees celsius) into the condenser” he doesn’t think it is a good idea to do it unnecessarily, preferring to see wind derated (engineer-talk for turned off) rather than routinely having a base load nuclear plant take actions that do have some level of risk.  He goes into the financial costs of this (it ends up costing $310 per MW-hr) and concludes “For the OSPE report to casually suggest such ongoing operation is ethically unacceptable.”

4) Load Mismatch.  The OSPE submission does mention the mismatch, where wind production tends to be highest when demand is lowest, but Palmer doesn’t think they treat this fact with enough emphasis.  “Are Engineers who have studied reality not obliged to point out the mismatch?

5) Economic Consequences.  Palmer provides 3 examples of how wind energy sharply raises the costs and that the OSPE downplays those consequnces.  In the third of his three examples (involving steam bypass) he states “redesigning the existing nuclear fleet within 6 years is unrealistic – and why, so we can still pay it to back off and pay wind, when it is available? For goodness sakes, why not just run the lower cost non greenhouse emitting nuclear, if you are going to build it anyhow, and have it?

6) Storage.  The OSPE draft presented several schemes for storing electricity, but Palmer states that some of them are so nonsensical that maybe the OSPE should have vetted them better.  One of those schemes was to have more electric cars.  Palmer: “The OSPE needs to at least do the rudimentary calculations to see if what the report offers as alternatives are actually feasible, and what the economic cost would be. Even if we look at larger battery pack capabilities, do we really think that it would be economically responsible to suggest  replacing the entire Ontario vehicle fleet in 6 years to be ready for 2018?

7) Who pays?  Palmer thinks the OSPE should have noted that electricity prices are already up more than the government projected, and are slated to go up even more.  “The OSPE should be taking advantage of this report to identify that the projected electricity price increase predicted by the Ontario Long Term Energy Plan (2010) that predicts an electricity price increase of 46% over 5 years and doubling in 20 years is perhaps just a tad under estimated – it has already gone up 80% in the last 3 years, even before most of the costs come on stream!”  He displays the chart below with the total cost of off-peak electricity to the ratepayer over the last 3 years to drive home just how expensive this entire experiment will be.  Parker Gallant also wrote about this increasingly expensive experiment.He concludes with the following:

I have attempted from a high level to identify that there are significant concerns with the OSPE draft, that call for a re-working of it before submission to the Ministry of Energy. The integration of wind turbines into the electrical grid and the impact of such decisions on:

  • public safety and health, and environmental effects
  • economic impacts on the Ontario economy
  • the integrity of the Ontario electricity system

have not been fully addressed by the OSPE draft as it exists.


Palmer’s Submission to the Submission

Original OSPE Draft Submission

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