Battery Energy Storage System Recommendations by Ontario Federation of Agriculture

Over the next few years, the Ontario government has directed the Electricity System Operator (IESO) to complete the transition to a zero-emissions electricity system. This will require phasing out natural gas-fired power stations. To replace the quick-start and system-balancing attributes of gas-fired plants, the IESO will rely on battery energy storage systems (BESS).

By 2050, Ontario also plans to expand the electricity grid to meet the higher electrification of large energy-consuming sectors, including transportation, manufacturing, water heating, and building envelope heating. All additional capacity will use renewable energy (RE) sources, including solar and wind. This intermittent RE requires a BESS element to make energy available for the durations needed to become committed market participants.

BESS is any technology or process that captures energy when unnecessary and stores it for later use, eventually discharging it. Technologies include Batteries, Capacitors, Pumped Hydro, Flywheel, Compression, Gravity, and Demand Response (commercial and industrial processes).

Several types of BESS can deliver the scale of energy required by the IESO for the duration. To date, all proposals submitted for IESO consideration use Lithium-ion Phosphate batteries. Although lithium-ion batteries are considered safe technology and the risk of a fire in a utility-scale BESS is low, the degree of impact of such events is high.

There have been and will continue to be multiple proposals, presentations to local governments, and public engagements by companies vying for various transmission system connection points. OFA developed what we view to be fair and practical considerations aimed at supporting affected rural and farming communities. Our hope is that agencies that procure and license these facilities adopt prudent recommendations that all Ontario’s energy regulators accommodate Ontario’s buildout of clean, reliable grid systems while ensuring due attention is afforded to the communities that host BESS and RE facilities needed to reach 2050 electrification demand.

Summary of OFA Recommendations:

• Proponents of Battery Energy Storage Systems in Ontario must ensure robust fire and safety risk management. This includes training for fire services, financial preparedness for emergencies, and installing automated fire prevention and suppression systems.
• The text discusses the regulatory framework for BESS in the U.S. and Canada, emphasizing the importance of compliance with Underwriters Laboratory (UL) and National Fire Prevention Association (NFPA) standards to mitigate risks such as thermal runaway events. It highlights the separation of codes between the U.S. and Canada and urges the Ontario Energy Board (OEB) to review its codes to include energy storage regulations. Recommendations include adopting specific UL and NFPA codes in iOntario’s regulations and ensuring compliance with updated standards as technology evolves.
• Modular outdoor BESS may bypass local building permits if they adhere to recognized standards. The Ontario Federation of Agriculture advocates for project proponents and owners to collaborate with qualified professionals to ensure compliance with safety codes and regularly maintain the systems. Guide to Environmental Approval Requirements (GEAR) indicates that BESS are classified as non-designated Class A resource types and do not require an Environmental Assessment. However, due to the potential for significant environmental impacts from failures, there is a call for enhanced oversight of utility-scale BESS.
• The OFA supports efforts to assess procurement processes considering environmental impacts and community support. They recommend prioritizing commercial and industrial lands for energy infrastructure to protect prime agricultural areas.
• Hydro One has identified the need for increased setback requirements for BESS near transmission lines to protect critical infrastructure and the public. The new guidelines propose significantly larger setbacks than the existing NFPA 855 standard, emphasizing safety and damage mitigation. OFA recommends that regulatory bodies adopt these stricter requirements to safeguard agricultural and residential areas while supporting future energy infrastructure development.

Read the complete resource at the source (Ontario Federation of Agriculture)