December 13, 2024 The…

The Toronto Region Board of Trade (the Board) appreciates the opportunity to provide feedback to support Ontario’s energy strategy and contribute to the government’s consultation on Ontario’s Affordable Energy Future: The Pressing Case for More Power. As one of North America’s largest chambers of commerce for Canada’s largest urban centre, the Board represents a diverse business community committed to advancing a competitive, reliable, and sustainable energy system. Input from the Board’s Energy & Climate Policy Committee, comprising leaders from Ontario’s primary energy companies, has informed this submission.

Planning for Growth

Ontario’s energy strategy must navigate the complexities of balancing affordability, reliability, and sustainability. These interconnected priorities are essential to meeting the needs of Ontario’s growing economy while preserving its leadership in clean energy innovation.

The Board emphasizes the importance of addressing policy contradictions that currently hinder investment and innovation. Streamlining permitting processes and preparing for potential shifts in federal policy, including changes to cleantech funding and investment tax credits, will help ensure that provincial and federal frameworks are harmonized to grow Ontario’s competitiveness.

Transmission planning remains an essential focus, particularly the lack of coordination between energy generation and transmission projects. “Last mile” transmission issues have created bottlenecks that delay energy delivery to critical areas. A centralized permitting coordinator and expedited approval processes are necessary to address these challenges and enable the rapid deployment of infrastructure. The Board has previously provided an unsolicited submission on this issue, which is attached for your reference.

Ontario’s energy mix must continue to diversify. While nuclear energy remains a cornerstone of the province’s clean energy leadership, natural gas and renewables such as geothermal and deep-water energy can further strengthen Ontario’s energy resilience on the path to net-zero. Additionally, the adoption of low-carbon fuels like renewable natural gas (RNG) and hydrogen presents significant opportunities for both decarbonization and economic growth.

Supporting clean technology adoption will require refined incentives that address both supply and demand. While there are numerous supply-side incentives, navigating them can be challenging for businesses. Complementing these efforts with demand-side incentives would align market needs with policy objectives, particularly in critical sectors such as the emerging electric vehicle (EV) manufacturing industry. Balancing market-driven solutions with targeted government interventions will help achieve broader electrification goals, including the expansion of critically needed housing and the electrification of transportation systems, all while maintaining cost-effectiveness.

Affordable and Reliable Energy

Affordability and reliability remain central to the evolution of Ontario’s energy system. Empowering households and businesses to manage energy use effectively will require ambitious energy efficiency programming delivered through the IESO, improved energy literacy resources, and simplified access to smart energy management tools. Expanding financial support for smart grids and distributed energy resources (DERs), such as on-site solar and battery storage systems, along with demonstration projects to de-risk investment in these technologies, will also encourage adoption, enhance grid resilience, and reduce costs for consumers.

Structural barriers that disincentivize first movers and early adopters of innovative technologies need to be addressed. Clear, predictable financial and regulatory frameworks are essential to mitigating risks and rewarding innovation. Successfully integrating DERs into the grid will necessitate standardized policies, stakeholder collaboration, and updated regulations to enable local distribution companies (LDCs) to expand their roles in grid operations and innovation.

The transition to a low-carbon future must also include robust investment in expanding public EV charging infrastructure and integrating vehicle-to-grid systems. Residential and workplace charging incentives will help close infrastructure gaps while supporting municipalities in overcoming budgetary challenges to meet their ambitious electrification targets. Maintaining affordable energy rates throughout this transition will require leveraging Ontario’s nuclear and hydro baseload capacity, alongside natural gas for peaking, and ensuring an aggressive and on-time expansion of new generation procurement. This will be particularly crucial as energy consumption by data centres is projected to triple over the next decade, necessitating a corresponding expansion of clean energy supply.

Becoming an Energy Superpower

Ontario’s expertise in nuclear technology firmly positions the province as a global leader in clean energy innovation. The expansion of isotope production represents a distinctive advantage that Ontario should prioritize, with continued support and strategic investment to maximize its potential. Moreover, the deployment of BWRX-300 reactors offers a unique opportunity to expand exports to emerging nuclear markets such as Poland, which is adopting the same technology. The development of the CANDU Monark reactor also offers potential for deployment at home and abroad. This alignment enables Ontario to deepen its supply chain through the export of components, expertise, and services, creating significant economic benefits for the province’s manufacturing and energy sectors.

Expanding and diversifying Ontario’s energy portfolio will further strengthen its leadership in the sector. Advancing renewable and alternative energy sources, such as geothermal and deep-water energy systems, alongside other innovative technologies, will not only enhance resilience and sustainability but also unlock promising new export opportunities. Introducing a government-led focus positioning Ontario as a hub for clean technology manufacturing would further cement the province’s standing as a global leader in the energy transition.

International collaboration and cross-border energy trade agreements can further bolster Ontario’s influence in both regional and global energy markets. Expanding partnerships, such as EV corridors and shared transmission projects, will enable Ontario to export clean energy technologies and expertise more effectively. Comprehensive financial incentives and streamlined regulatory frameworks would support first movers and position Ontario as a preferred partner in the global clean energy transition.

The Board appreciates the opportunity to provide its perspective on these critical energy priorities. We welcome further engagement with the Ministry to discuss these recommendations and convene our members to advance Ontario’s leadership in clean energy and electrification.