Power Workers’ Union…

The Power Workers’ Union (PWU) is pleased to submit comments and make recommendations to the Ontario Ministry of Energy and Mines (the Ministry) regarding the Proposal for Advancing Critical Transmission Expansion in the Toronto Area (ERO) 026-0019. The ERO relates specifically to the Ministry’s proposal to:

… to direct the Independent Electricity System Operator (IESO) to undertake a competitive procurement process and enter into a procurement contract with a transmitter to develop and construct the Toronto Third Line project to meet electricity demand in Toronto and help address capacity constraints in the greater Toronto area.

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[T]he Ministry anticipates bringing this proposal forward for a possible decision in 2026. The IESO would endeavour to have a transmitter selected within 18 months of receiving the proposed Directive, if government decides to proceed with this proposal.

The PWU is a strong supporter and advocate for the prudent and rational reform of Ontario’s electricity sector and recognizes the importance of planning for low-cost, low-carbon energy solutions to enhance the competitiveness of Ontario’s economy. The PWU represents the majority of the skilled workers that operate and maintain Ontario’s electricity generation, transmission, and distribution systems. As a union deeply invested in Ontario's safe, reliable, and sustainable energy infrastructure, we recognize the critical importance of new and enhanced transmission capacity and infrastructure.

The PWU applauds the Ministry’s proposals for building more electricity transmission (as outlined in Chapter 3 of Energy for Generations: Ontario’s Integrated Plan to Power the Strongest Economy in the G7 (the Integrated Energy Plan or IEP)). The IEP has identified several priority projects, which represent critical transmission projects to alleviate bottlenecks and system constraints. In 2025, the PWU provided feedback to the Ministry on the following priority projects:

1. The Barrie to Sudbury Transmission Lines, to enhance the transmission capacity between northern and southern Ontario; (ERO) 025-0656.

2. The Orangeville to Barrie Reconductoring Project, to enhance the transmission capacity between northern and southern Ontario; (ERO) 025-0657.

3. The Bowmanville to GTA Transmission Line, to enhance the transmission capacity east of Toronto; (ERO) 025-0658.

4. The Windsor to Lakeshore Transmission Line, to support critical transmission infrastructure in southwestern Ontario; (ERO) 025-0659.

5. The Greenstone Transmission Line, to enhance the transmission capacity in northern Ontario; (ERO) 025-0660.

6. The Red Lake Transmission Project, to enhance transmission capacity North of Dryden; (ERO) 025-1212.

The Ministry is currently seeking feedback by February 21, 2026 on Advancing Critical Transmission Expansion in the Toronto Area (ERO) 026-0019.

According to the IEP (pp 70-71) (our emphasis):

The Greater Toronto Area (GTA) is a key driver of Ontario’s economy. Ensuring reliable, affordable electricity in this region is essential for the province’s long-term prosperity. While past growth has been supported by existing transmission lines, energy efficiency programs and strategically located generation assets, including the Portlands Energy Centre (a natural gas generation station), new transmission will be needed to meet rising demand.
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To support growth and electrification in the City of Toronto, the IESO is also developing a new Integrated Regional Resource Plan (IRRP) that will include recommendations for additional transmission capacity into the downtown core. This work builds on government direction issued through Powering Ontario’s Growth, which recognized that Toronto will require a third major transmission line to downtown Toronto to meet future demand, and Ontario’s Affordable Energy Future, which highlighted the need to enhance system resiliency.

Also as discussed in the IEP (p.78) (our emphasis):

Transmitter Selection Framework

With more transmission needed across Ontario, the government is committed to supporting new infrastructure that is delivered as efficiently, affordably, and transparently as possible. While the government will need to maintain the ability to designate some projects directly to existing transmitters – such as Hydro One – due to their urgency or complexity, there is also a clear opportunity to introduce healthy competition where timelines allow. Competitive procurement can help deliver transmission more cost-effectively, encourage innovation, and drive opportunities for Indigenous participation.

For each of the above six 2025 transmission proposals, the Ministry has designated Hydro One as the transmitter for the justifiable reasons of urgency and/or complexity. The PWU supported each of the six priority projects proposed by the Ministry in 2025, as well as the designation of Hydro One as the developer. For the reasons discussed in the next section, the PWU strongly supports designation of Hydro One as the transmitter for Toronto’s Third Line (TTL) due to (a) the consequentiality, urgency and scale of the project; (b) the complexity of the TTL; (c) the importance of supporting Ontario workers and nurturing our domestic supply chain at this pivotal moment in Ontario and Canadian history. As the PWU has emphasized in our comments on the 2025 priority projects, Hydro One has a proven history of delivering quality transmission projects.