Letter to Alberta Electrical System Operator and Altalink
Posted: November 20, 2010
Like many individual residents and landowners in the area, the Livingstone Landowners Group has very recently been made aware of Altalink plans to seek approvals and construct a new high voltage transmission line connecting the existing north-south line in the Maycroft/Burmis region to the Fidler sub-station near Summerview – currently referred to as the “Fidler to Chapel Rock Transmission Project” as it is currently referred to.
“The Livingstone Landowners Group (LLG) is a non-profit, community based organization formed to provide and a collective voice for our members and other interested landowners and residents in the Livingstone – North Cowley/Lundbreck area. LLG’s purpose is to ensure that proposed industrial activity is compatible with existing uses and conservation of this environment, and that adverse impacts are minimized or avoided wherever possible. We believe that citizens and residents of the area have a fundamental right to be involved in determination of their own future, and to protect features of this landscape and community that are unique and irreplaceable.
“It is in this context that we write to you to indicate serious concerns regarding the lack or absence of public consultations to-date, the need for this project, and the apparent intent of the AESO and Altalink to simply bypass consultation on needs and community interests by moving directly to consideration of specific routing proposals. We consider it entirely premature, and are strongly opposed to any consideration of specific routes, design features, and alternatives, until there has been full disclosure, meaningful public consultations, and open discussion and assessment of need for the project in any of its versions. To our knowledge, none of those have occurred to-date.
“The questions and comments following are in no intended order of priority; each has been raised by numerous individuals. We would ask that you reply to each of these issues in writing, following which we will hopefully be in a position to engage with you in more informed and constructive dialogue.
Needs Justification, Criteria, and Cost Responsibilities:
- What need has been demonstrated or determined by either AESO or Altalink for this project? Please detail what consultations with general taxpayers and consumers in this area have occurred, who conducted them, what the outcome of those consultations was, and how they were incorporated into the current proposals.
- Has needs assessment and analysis to-date been internal only to AESO and Altalink, or have other industry, third party interests, or regulatory agencies been involved? If the latter, please indicate those.
- What criteria and time frames are applied to needs assessment and determination for this or similar projects – by each of AESO, Altalink, and other regulators?
- To what degree is AESO and/or Altalink needs assessment based on in-province demand versus export opportunities, local generation and transmission requirements versus provincial forecasts? If analysis is combined, can the weighting of these factors be segregated?
- If approved, how will the project be funded? What portion, if any, of the costs of this or similar projects are paid, or expected by AESO or Altalink to be paid, by general taxpayers or energy consumers?
Process and Timelines:
- Please detail on a step-by-step basis the process anticipated or required by Altalink for this type of project - from concept to needs analysis and determination, planning and design, community consultations, hearings, engineering, and construction.
- What are the timelines anticipated or required for each stage of the process? How flexible or variable are these timelines, depending on factors arising throughout?
- What stage or stages of this particular project are currently underway, and which, if any, have in your view been completed?
Project Management, Consultation, and Disclosure:
- Please provide names, positions, and contacts for AESO and Altalink management representatives who have been or will be responsible for overall planning and coordination of the proposed project.
- Please provide similar information for operational staff and any outside consultants who have been or will be responsible for particular studies, design, community liaison, etc. associated with the project.
- What are AES’s general policies on consultation with interested residents, landowners, and community or public interest organizations? What are Altalink’s policies with respect to the same matters?
- What policies do each of AESO and Altalink have governing public disclosure of planning, consultation, and other information gathered in relation to the project? Will relevant information be provided to residents or their representatives on request or only at hearing?
- What funding is available through AESO, Altalink and/or regulatory agencies for interested or affected residents, landowners, and community interest organizations to engage directly or be represented by legal counsel or others in the consultation and regulatory processes?
- What steps will Altalink consider and/or undertake to ensure collective and consistent information is provided to all interested parties prior to any commitments being made, and to avoid misinformation or misunderstandings potentially dividing the community or pitting “neighbour against neighbour” as the process unfolds?
Authorities and Authorizations:
- In addition to the AESO, what governing and regulatory authorities have been or will be involved in assessment, review, and approval/rejection of any aspects of the project? For example, what responsibilities, if any, do the provincial departments of Sustainable Resource Development, or Environment have regarding matters within their normal sphere of authority?
- What, if any, submissions have been made or approvals received for any parts of the project to-date, and from which authority? What, if any, submissions are imminent, and to which authority?
- At what stage or stages of this or similar projects, are AESO or other agencies able or required to conduct public hearings?
- Are comprehensive environmental or other assessments required for all or particular parts of the project? How will terms of reference be developed for those, and will there be opportunity for citizen participation therein?
- How are this and other similar project proposals being coordinated with and incorporated into the pending regional land-use plans ? What needs or criteria, if any, justify moving decisions on this particular project ahead of the regional planning exercise?
We appreciate that the questions above are relatively extensive and will take a reasonable amount of time for your representatives to prepare adequate responses. We are also sure, however, that you will appreciate that the information requested is simply baseline information that should be available collectively and to every interested or potentially affected party. It cannot be provided through any number of individual conversations at “open houses” or similar forums. Without written information and a much more structured process - involving the community from project inception onward, not at some arbitrary or imagined midway point - a balanced and well-informed community dialogue on project proposals simply cannot occur.
“We look forward to your early response. Please feel free to contact me if you wish additional clarification prior to sending a more formal response.”