BC Hydro’s 2024 Call for Power: Unique Opportunities Ahead for the Renewable Sector in BC
Author: Rachelle Lynne-Davies, P.Eng.
British Columbia Hydro and Power Authority (“BC Hydro”), the main electricity distributor in British Columbia, has recently announced its 2024 Call for Power. This initiative is a Request for Proposals (RFP) aimed at acquiring clean or renewable energy to meet the province’s future needs. BC Hydro indicated that this will be the first of a series of calls for power, with the next expected to be in 2026 and approximately every two years following. The volume and timing of future calls will be determined through BC Hydro’s long-term resource-planning process and subject to review by the BC Utilities Commission.
Three key dates that must be met to ensure a Proponent’s participation in this RFP are:
- CEAP IR* Pre-Submission deadline – April 19, 2024;
- CEAP IR* Submissions Date (incl deposit**) – May 21, 2024; and
- Closing Date (Proposal Submission Deadline) – September 16, 2024.
*CEAP IR – Competitive Electricity Acquisition Process Interconnection Request
**CEAP IR deposit ($15,000) and Interconnection Feasibility Study deposit ($15,000)
Emerging Needs and Procurement Targets
The emerging needs that the province is facing are detailed in the 2021 Integrated Resource Plan (IRP), a 20-year-long forward-looking document that aims to identify emerging needs within the provincial grid. The document compares existing and committed resources against the forecast of future customer needs by creating a Base Resource Plan and several Contingency Resource Plans. It balances the price of the assets with the greenhouse gas emissions and impact on the water and land.
One of the key targets set in the IRP is the acquisition of approximately 3,000 GWh/year of additional energy as early as late fall 2028, which aligns with the Call for Power’s expected commercial operation date between 2028 and 2031. The projects that are constructed as a result of the Call for Power will be instrumental in achieving the targets set out in the IRP.
The IRP also emphasizes the importance of diversifying the energy mix with a focus on clean or renewable resources. This is reflected in the Call for Power, which is open to all types of clean or renewable energy technologies. By encouraging a diverse range of solutions, BC Hydro aims to create a more resilient and sustainable energy system. The following figure illustrates the emerging system energy needs identified in the Base Resource Plan and various contingency plans as denoted by the different line types. The amount of energy that future resources will cover can be seen in green, showing the important role these resources will play in ensuring there is sufficient energy to supply the grid starting in the late 2020s.
Similarly, on the system capacity side of the grid, some scenarios in the IRP such as the accelerated electrification scenario identify potential needs of nearly 800 MW in fiscal 2032 driven by increasing demand for electricity on the province’s South Coast. It is expected that these needs will be gradually solved via the introduction of new generating assets coupled with battery energy storage systems. The impact that growing electrification could have on the grid is illustrated in the figure below.
Eligible Technologies
This ambitious RFP seeks to procure all types of clean or renewable energy technologies. This includes but is not limited to, wind, solar, hydro, and bioenergy that are between 40 and 200 MW in size. The RFP is open to “proven” renewable energy technologies that are readily available in commercial markets and in commercial use, and this is defined as technologies that have at least three projects that are operating successfully. The procurement is seeking new builds only, with projects that are phased, including uprates, replacements, or modifications to any generating equipment that currently operates or has operated in the past considered not eligible.
Project Location
These projects are to be located anywhere in the province except in Fort Nelson, areas where BC Hydro does not have grid coverage, or otherwise inaccessible areas where BC Hydro would be required to transmit energy through another out-of-province jurisdiction to the Lower Mainland.
This requirement ensures that the projects are feasible from a logistical and technical perspective. It also ensures that the projects can effectively contribute to the province’s energy grid without incurring excessive transmission costs or technical challenges.
However, the RFP does allow for indirect interconnections. This includes connections through private or third-party transmission lines or utility companies other than BC Hydro. This provision opens up more areas of the province for potential projects at the expense of higher interconnection costs. It allows for greater flexibility in choosing project locations, which can be particularly beneficial for projects involving renewable energy sources like wind or solar, which may be location dependent.
First Nations Involvement
The requirement for First Nations equity ownership is a significant and unique aspect of the RFP. It reflects BC Hydro’s commitment to fostering partnerships with First Nations communities and promoting their active participation in the province’s energy sector.
Under this requirement, one or more First Nations in whose territory the project is located must hold a minimum of 25% equity ownership in the entity owning and controlling the generating assets. This means that First Nations communities have a direct stake in the projects, sharing in the benefits and returns that these projects generate. Proposals that do not confirm a minimum 25% First Nations equity ownership are disqualified from the Call for Power.
A Structured Approach to Bid Management
Give your team a competitive advantage with a dedicated resource managing your bid submission. A single point of contact and expert in the solicitation requirements will streamline your bid submission and alleviate your development team’s time.
It is critical that your team remains focused on the multitude of tasks relating to project development to ensure that your project is designed strategically and maintains its proposed timelines. Renewable energy procurements tend to have complex criteria, both pass/fail and rated criteria, which will ultimately rank your project along with the bid price. It is critical to strategically present your bid submission in a way that minimizes the bid price, while meeting the minimum thresholds and maximizing the rated criteria.
Compass will support your development team as the bid manager to dissect the complex procurement documents and distill its parts into an RFP tracker tool, highlight long lead time items, get your entire team on the same page with a kick-off call, set internal deadlines, get ahead of complexities or contradictions by submitting questions, advise on strategically maximizing scoring, draft templates/content, and performing quality control on all drafted content.
Why Compass Energy Consulting?
Our consulting services can provide valuable assistance to independent power producers and stakeholders in navigating the RFP process by dissecting the relevant documents and ensuring that all requirements are understood and met.
We offer support in multiple steps of the procurement process, including undertaking the Competitive Electricity Acquisition Process Interconnection Request (CEAP IR), a required process for proponents who wish to interconnect their proposed project to BC Hydro’s integrated system.
Founded in 2011, Compass has been providing regulatory and compliance support to the renewable energy marketplace throughout Canada and the Northeastern U.S. for over a decade. Our team of consultants help developers participate and win in some of the largest procurements, like NYSERDA’s Tier 1 REC RFP and Ontario’s Long-Term Procurements.
Please reach out to Rachelle Lynne-Davies at rachelle@compassenergyconsulting.ca or 416-803-6945 to discuss further.
Penalty for Non-Compliance Could Be 50% of the ITC
Author: Rachelle Lynne-Davies, P.Eng.
The third in a series of ITC blogs from Compass Energy Consulting
- Making Sense of the Federal ITC Legislation
- Making Sense of the Federal ITC Labour Requirements
- Penalty for Non-Compliance Could Be 50% of the ITC — This Blog
Where the incentive claimant claims the regular tax credit rate of 30%, but it is determined that the labour requirements are not met, there are financial penalties incurred by the incentive claimant which will be added to the tax payable for the installation taxation year. It is important to note that the financial penalties are significantly different whether or not gross negligence is determined to have caused the non-compliance.
Assuming gross negligence was not a factor, non-compliance with the prevailing wage requirement results in a financial penalty equivalent to $20 for each day in the installation tax year that a covered worker was not paid the prevailing wage.
EXAMPLE
Let’s assume it was determined that the incentive claimant that claimed the regular tax credit rate for the installation tax year did not pay 75 covered workers the correct prevailing wage for their labour hours on-site for a period of 6 months from Jan 1 , 2024 to June 30, 2024.
The financial penalty equivalent to $20 x 126 working days x 75 covered workers = CAD $189,000 would be added as tax payable for the installation tax year. It is important to note that the incentive claimant’s eligibility for the regular tax credit rate of 30% is not affected by this marginal non-compliance.
Again assuming gross negligence was not a factor, non-compliance with the apprenticeship requirement results in a financial penalty for the claim year equal to the following: $50 x (A – B), where A is the total number of hours of labour required to be performed by apprentices registered in a Red Seal trade for the installation tax year, and B is the total number of actual hours performed by apprentices.
EXAMPLE
Let’s assume it was determined that the incentive claimant that claimed the regular tax credit rate for the installation tax year did not meet the 10% apprenticeship requirement. The target apprenticeship percentage was 10,000 hours but only 9,455 hours were performed. For clarity, there were no applicable laws or clauses of an eligible collective agreement that prevented the incentive claimant from meeting the 10% apprenticeship requirement.
The financial penalty equivalent to $50 x (10,000 – 9,455) = CAD $27,250 would be added as tax payable for the installation tax year. Again, it is important to note that the incentive claimant’s eligibility for the regular tax credit rate of 30% is not affected by this marginal non-compliance.
If it is determined by the Minister that the non-compliance was known or the result of gross negligence, the financial penalties are more severe. The incentive claimant will not be eligible for the regular tax credit rate and will only be entitled to not more than the reduced tax credit rate of 20%. Additionally, the incentive claimant is liable to a penalty for the claim year equal to the following: 50% x (A – B), where A is the amount of tax credit claimed at the regular tax credit rate, and B is the amount of tax credit that the incentive claimant would be entitled to claim at the reduced tax credit rate. This penalty amounts to 5% of the total tax credit amount expected through the Clean Tech ITC at the regular tax credit rate. Together, the financial penalties sum to 50% of the original expected refundable tax credit.
EXAMPLE
For a 100MW wind farm located in Saskatchewan, which has eligible capital costs of CAD $200 million, the expected Clean Tech ITC at the regular tax credit rate is expected to be CAD $60 million.
Assuming the regular tax credit rate was claimed, but the Minister determined that non-compliance was the result of gross negligence, the taxpayer would only be eligible for the reduced tax credit rate, a reduction of $20 million and an additional financial penalty of $10 million for gross negligence could be applied. This is a total financial penalty of $30 million, or 50% of the original expected ITC.
Financial penalties for non-compliance should be avoided altogether. A structured compliance plan will set a strong foundation to ensure you are able to realize the full value of the ITC without risk of claw backs due to non-compliance.
The Need for Compliance Management Support
It would be detrimental to project stakeholders to incur additional financial penalties for non-compliance whether it is gross negligence or an honest mistake. Mismanagement of the compliance activities to meet the labour requirements is an avoidable error.
The labour and apprenticeship requirements give rise to the need for compliance planning, monitoring, and data management of evidence.
Why Compass Energy Consulting?
Founded in 2011, Compass has been providing regulatory and compliance support to the renewable energy marketplace throughout Canada and the Northeastern U.S. for over a decade. Compass’ founders helped to design some of the largest Domestic Content compliance obligations for renewable energy procurements, like those found in Ontario’s Feed-in Tariff program, and our team of consultants help developers participate and win in some of the largest procurements, like NYSERDA’s Tier 1 REC RFP.
Compass is uniquely positioned to provide a turn-key compliance, monitoring, and audit service due to our experience providing these types of services to over 200 MW of projects under Ontario’s Feed-in Tariff 1 and 2 Domestic Content compliance regime. Our compliance assessments were provided for project owners but importantly were relied upon by project lenders to ensure projects satisfied this critical and binary contractual obligation.
Compass Energy Consulting is your insurance policy for your ITC. Feel free to reach out to me at rachelle@compassenergyconsulting.ca to discuss further.
Check Out Our Other Blogs in the ITC Series
- Making Sense of the Federal ITC Legislation
- Making Sense of the Federal ITC Labour Requirements
- Penalty for Non-Compliance Could Be 50% of the ITC — This Blog