Dear Sirs and Madams, We…

Dear Sirs and Madams,

We need more renewable energy in Ontario's electricity mix.

The current plan of nuclear refurbishments doesn't adequately address several key issues, cost being the main driver. The full costs of the nuclear plants have never been transparent. One easy example is the matter of insurance. The cost of the Fukoshima disaster was over 50 B CAD (http://www.japantimes.co.jp/news/2016/08/28/national/public-cost-fukushima-nuclear-accident-cleanu p-topped-%C2%A54-2-trillion-end-march/#.WDSaELIrLIU) and the liability carried by the plants would nowhere near cover these types of costs.

Further, transmission projects such as the $700M Bruce to Milton transmission reinforcement project (http://www.hydroone.com/REGULATORYAFFAIRS/Pages/BrucetoMilton.aspx) which is dedicated to the nuclear industry is a cost borne by ratepayers, rather than the nuclear industry.

These two areas seem to contravene section 25.33 of the Ontario Electricity Act (which I will refer to as "the Act" which prescribes that electricity prices should reflect costs.

Further, the projected cost of nuclear power is between $72/MWh and $81/MWh (https://news.ontario.ca/mei/en/2016/01/ontario-moving-forward-with-nuclear-refurbishment-at-darlin gton-and-pursuing-continued-operations-at.html) which is significantly higher than the current price of wind power, which came in at $63/MWh in Quebec and $65/MWh in Ontario. Nuclear plants have a poor track record of coming in on time or on budget. With an IPP model (such as that in the LRP) this risk is shifted to the developer. Were you to tweak contracts slightly (for example, extend them to 25 years, allow the developers to own the environmental attributes, or change the escalation rules) you would easily be able to set a ceiling price of $70/MWh and get wind power which is easily deployed and quick to build.

Our aging nuclear fleet is located on the biggest source of fresh water in the world. These reactors have run their course. We should not extend their operating licences at a huge cost and a massive liability.

I understand the need for new or upgraded transmission capacity in certain areas, however it seems that S.26 (1.1) isn't being honoured due to large interconnection costs being applied.

There are instances where Hydro One has refused access to feeder lines for even small 10kW solar projects as it claims there is no capacity. This is based on poor science- the arbitrary 15% rule for renewable penetration has been shown to be incorrect in jurisdictions around the world. Denmark, Scotland and Hawaii are three of such examples.

This means that transmission reinforcement isn't even required in many instances- rather we simply need to grant equal and fact-based access to the electrical system.

Transmission poses a big opportunity for the IESO to monetize their grid in an efficient way. Were we to build transmission into the New England states we could offer "firm wind" at a premium to those IESOs. The cost of the transmission would be outweighed by the ability to ship clean power at a profit. Further, the offshore wind projects proposed in Lake Ontario would have inherent transmission benefits- it would ease congestion in Toronto and would provide most of the transmission link required at low or no cost.

A similar case could be made for working closer with Québec. Québec has a winter-peaking system. whereas Ontario has a summer-peaking system. From an energy storage standpoint, an easy fix is to work with Québec to allow the water to build behind their dams during windy or sunny periods and then to run that water through the dams at low wind or low sun times.

Storage and renewables can provide a way to reinforce the transmission system and ease congestion. Having clearer transmission maps would allow developers to help by putting generation and storage close to load centers rather than having centralized generation.

Net metering poses a unique opportunity as well as challenges for grid operators. I would challenge the fact that net metered facilities, for example by a solar array revert away from time of use pricing to flat rate pricing. This seems contradictory to the Objectives of the Smart Metering Entity as outlined in S.53.8 (4) of the Act.

Electric vehicles provide an excellent opportunity for the current grid. With the smart metering system, strong market signals that lined up with time of use pricing (for example, dropping the price from 11pm-5am) would create an incentive for EV users to charge at those times. I drive an EV, and my charger and car both have the functionality to set when my car charges. I use this already, but would be happy to push this out further to line up with the grid requirements. Incentives such as pricing pressure would help shift the load to off-peak times.

Moving away from natural gas in our homes provides a big opportunity as well. Rather than approving expensive gas line extensions, we should work to provide smarter homes using clean electricity. A water heater can heat up at night, for example. Similar to the car scenario outlined above, you can shift load efficiently in these cases.

We need more renewable energy, upgraded transmission, and to work with neighbouring jurisdictions. We can lower the price of power by investing in renewable energy and by embracing the load shifting opportunities available to Ontario. Now is the time to remain a leader in the energy sector in North America. Together we can have the cleanest, safest and most cost effective system possible.

Thank you for your time, and I would welcome the opportunity to engage further. Though I attended the LTEP engagement meeting in Guelph last night, I think there is a lot to be gained through actual consultations that engage citizens.

Thank you very much.

-David Estill

[Original Comment ID: 196755]