By Andrea McDowell
Before the RFP
The long-awaited Request for Qualifications (“RFQ”) for the new Large Renewables Process (“LRP”) in Ontario is finally here, and developers are gearing up for their September 4th submissions. The Ontario Power Authority (“OPA”) then plans to notify qualified applicants by November 4th, and release the next steps in the process around November 4-11.
But wait! Those two months are best spent preparing for the next phase.
The RFQ document specifies timelines that will be allowed to developers between contract award and Commerical Operation Date (“COD”). Waterpower projects will receive eight years; on-shore wind receives four; and all other renewable project types receive three years to complete their projects through to operations. Under the initial Feed in Tariff (“FIT”) process, it took many developers three years just to submit their Renewable Energy Approval (“REA”) Application to the Ministry of the Environment and Climate Change (“MOE”). Three or four years is not a lot of time to go through the entire process, receive an approval, wait out any appeals, construct the project and connect it to the grid. Any delays would be costly.
Fortunately, there is work that can be done prior to and during the Request for Proposals (“RFP”) process in order to streamline the projects and ensure that they proceed as efficiently as possible, once contracts are awarded. This work does not need to be extensive or time consuming, and can save a lot of time and money down the road.
1. Public Consultation prep: What is your public consultation strategy? Who will you need to talk to? What local groups are likely to be for and against your project? Where do local politicians stand?
Do you have a policy in place for how you will interact with participants in your public consultation process? Is there a system to track and log your consultation and communication efforts?
Consultation is a priority issue for the Ontario government and the OPA for renewable projects going forward. You can get yourself ahead of the game by investing a little time and money now into properly structuring your consultation program and testing the waters.
2. Noise and Odour Receptors: Since vacant lots will count as receptors, do you know where the property boundaries are? Have you identified where vacant lot receptors should be placed?
Finding out late in the game that a vacant lot noise or odour receptor will necessitate a change to your project layout could cause a delay of a year or more to your COD, if field work needs to be completed for the new design. The more you can do now to determine project layout constraints, the better position you will be in later.
3. Natural Heritage: Are there any natural heritage features in the area known to be significant? If so, how will you incorporate them into your project design?
Most significant natural heritage features can be mitigated through the Environmental Impact Study, but not all. Significant wetlands and certain types of significant wildlife habitat often require changes to project layouts in order to ensure protection of the feature. While most of these will be uncovered during the Evaluation of Significance phase, knowledge of any known significant features will help you in your project planning process.
4. Have you done a preliminary database review for Cultural Heritage, Archaeological, or Radiocommunications resources?
While cultural heritage and archaeological resources do not often require layout changes, mitigation measures can alter your schedule and construction costs. If it is possible to identify known issues in advance, you can incorporate that into your project planning.
Radiocommunications infrastructure, while it is not a required part of the REA process as it is under federal jurisdiction, can have a significant impact on project costs and layout if not properly accounted for. A database search will allow you to identify towers and pathways fairly early in the process and avoid unworkable layouts.
5. What is your planned schedule? How does it compare with the experience of other developers who have gone through this process? How much space do you have for surprises?
Surprises will happen. Significant habitats will be found where you least want them; there will be a blizzard on the day of your final public meeting; your archaeological field work will be flooded out and need to wait until spring. Some leeway in the schedule to protect your COD and accommodate the unpredictable is your best bet to ensuring a successful REA process.
A year can go by in the blink of an eye when developing a renewable project, particularly when dealing with seasonal field work requirements and weather conditions. Any cost-effective work done now to better define the project and the eventual scope of work after contract award will be money well spent.
