+ RMA Rural Municipalities
of Alberta

Resolution 23-22F

Small Scale Generation Regulation – Interconnection Challenges

Date:
November 9, 2022
Expiry Date:
December 1, 2025
Active Status:
Active
Sponsors:
MD of Taber
District:
1 - Foothills-Little Bow
Year:
2022
Convention:
Fall
Category:
Energy
Status:
Intent Not Met
Vote Results:
Carried
Preamble:

WHEREAS Alberta’s Micro-generation Regulation was implemented in January 2008 to allow individuals to generate electricity for their personal use while providing excess electricity to the grid; and

WHEREAS when the Micro-generation Regulation was passed, the Alberta Utilities Commission implemented Rule 24 to simplify approvals, interconnection and operating agreements between micro-generation customers and wire owners (utility companies); and

WHEREAS due to the effectiveness of Rule 24, the Alberta’s micro-generation program has been very successful, resulting in the installation of 8,163 solar energy systems with a combined generation capacity of 122.6 Megawatt (MW) as of May 2022; and

WHEREAS the development of utility scale solar projects has greatly accelerated in Alberta with 18 projects totalling 892 MW of generation capacity completed between December 2017 and May 2022; and

WHEREAS the utility scale solar projects under development in Alberta require an average of 2.6 hectares of land per MW of solar generation capacity and average 130.5 hectares per project; and

WHEREAS the rapid pace of development of these projects is resulting in an increasing demand for land that is needed for agricultural production; and

WHEREAS the Small Scale Generation Regulation (SSGR) is a regulatory framework established in Alberta for the purpose of facilitating distribution-connected alternative and renewable generation sized to supply electricity to the grid; and

WHEREAS according to the Government of Alberta, the SSGR was created to fill a gap between micro-generation and large utility-scale renewable energy projects, to make it “easier for communities to develop their own renewable energy projects” and to provide a framework for community generation to enable individuals or local organizations to partner on small-scale renewable energy projects such as wind, biomass, hydro or solar that provide community benefits.4; and

WHEREAS the “community generation” designation within the SSGR includes a requirement to demonstrate the benefits a community receives from generation projects, such as revenues, local jobs, training opportunities, new social programs or new infrastructure; and

WHEREAS there are currently more than 170,000 inactive (suspended, abandoned or orphaned) oil and gas leases in Alberta and these leases occupy more than 133,000 hectares of land that is not available for other purposes;

Operative Clause:

THEREFORE, BE IT RESOLVED that the Rural Municipalities of Alberta advocate to the Government of Alberta to apply distribution and transmission connection timelines and study exemptions that are currently provided to micro-generation projects under Alberta Utility Commission Rule 24 to community generation projects under five Megawatts.

Member Background:

In January 2020, the MD of Taber applied for funding through the Municipal Community Generation Challenge, a competitive program of the Municipal Climate Change Action Centre (MCCAC).  On February 11, 2020, the MD of Taber received confirmation from the MCCAC that they were successful in their application to test the newly passed Small Scale Generation Regulation (SSGR) to develop two one-Megawatt (MW) distribution connected solar projects on abandoned oil and gas lease sites. The MCCAC provided $2.1 million dollars to the MD of Taber and their participating project partners to complete this work.

Although there are suggested timelines for electrical distribution companies to provide connection for community generation (CG) projects, those timelines were not respected. Furthermore, the transmission provider in the area required time consuming and expensive connection studies for any electricity that may have ultimately ended up entering their substations. Through the Alberta micro-generation program, for projects up to five MW in size, the distribution company is required to provide connection within legislated and enforceable timelines. Micro-generation proponents are also exempt from having to undertake and pay for transmission connection studies that are required for the SSGR/CG projects. Since micro-generation and SSGR/CG solar projects of the same size have very similar impacts on power flow within the utility grid, there is no technical reason for the large disparity in the cost of interconnection studies or approval timelines.

This initiative, if implemented successful, identified several objectives:

  • Increase distributed solar generation to support seasonal irrigation power requirements
  • Conserve land for agriculture
  • Accelerate oilfield reclamation
  • Energy storage to supplement wind and solar
  • Employment and economic diversification
  • Generate revenue for the municipality and three irrigation districts

If the Government of Alberta wishes to see broad scale adoption of the SSGR and repurposing of inactive oil and gas leases to solar generation, there must be additional consideration for ease of connection to the distribution and transmission grids.

RMA Background:

RMA has no active resolutions directly related to this issue.

Government Response:

Affordability and Utilities

Government of Alberta recognizes that small-scale power generation creates jobs, diversifies our economy, and provides opportunities for increased distributed generation that can preserve agricultural land. Requirements for small-scale generation are set out in the Small Scale Generation Regulation under the Electric Utilities Act.

This regulation is intended to enable small scale electricity generation from renewable and alternative sources to supply electric energy to the grid or to an isolated community and provides for the establishment of a default market participant for these projects in order to minimize barriers associated with connecting to the electricity market.

The intent of micro-generation, on the other hand, is to enable behind-the-meter self-supply for Albertans to offset all, or a portion, of their own annual electrical load by generating electricity from renewable or alternative energy sources. The approval and connection obligations in place for small-scale generation projects are the same as those for other distributed generation projects and are intended to ensure the safe and reliable operation of our electricity grid.

Amendments to the Small Scale Generation Regulation to implement enforceable distribution and transmission interconnection timelines and provide study exemptions to projects under five megawatts are not being actively considered at this time. However, the Ministry of Affordability and Utilities is aware of the concerns raised in Resolution 23-22F and will consider this feedback in future reviews of the regulation. Government regularly reviews the policies and regulations governing the electricity sector to ensure their efficiency and effectiveness.

Development:

The Ministry of Affordability and Utilities recognizes the benefits that small scale power generation brings to communities, through job creation and the preservation of prime agricultural land. The approval processes and procedures currently in place are linked to the safe and reliable use of the electricity grid. However, it is not clear whether the exemptions would create unsafe transmission from a generator project under five megawatts.

As the Ministry is not actively working on auditing the processes and creating a more streamlined approach to small scale generation, the RMA assigns this a status of Intent Not Met.

Provincial Ministries:
Energy
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