To start, I would like to…

To start, I would like to recognize the work that the IESO, past governments, OPG and others have done to shift the energy mix in Ontario from high-carbon sources to lower-carbon sources. All Ontarians benefited from the phase-out of coal electricity generation in the mid 2000s, for example. The air quality has noticeably improved.

While I understand that the current government is seeking to remove regulations en masse, I'm disappointed that they would target regulations that have had incontrovertible positive effects for business, for individuals, and for the planet.

I am especially concerned that this proposal uses language like "allowing any resource that can meet system needs to compete." This statement is dangerous, along withthe broader context of focusing only on price, reliability, and quality of service: it opens the door for a return to late-1990s Ontario with dozens of smog days, terrible air quality, and countless downstream impacts on humans and other species. Any action taken to "level the playing field" gives high-carbon, environmentally destructive energy sources a natural advantage, given their significant state and industry subsidies at every level of government.

I will now address each of the three proposals in turn.

First, I think repealing section 25.37 and clause 114 (1.4) (0.a.1) of the EA is premature. Given that the OEB and IESO are currently in consultation for updating the related frameworks, I think a decision on the necessity of repealing these sections/clauses should be taken once the review is complete. This way, government will be able to ensure that the OEB/IESO policies provide similar protections to the existing legislation. By acting prematurely, the government risks divergence between legislation and OEB/IESO policy that must be reconciled in the future at potentially significant expense.

Second, I am opposed to repealing sections 26 (1.1), (1.2) and (1.3) of the EA, and paragraph 1 of subsection 70(2.1) of the OEBA, There are countless provisions in Ontario's legislation that provide the opportunity to enact regulations that have yet to be exercised. However, this is no reason to remove them. Fortunately, the Province has never needed to enact regulations under this authority, but it ought to reserve the right to make such regulations in the future. There is no harm in letting these provisions stay, but removing them would cause all future governments significantly more work (and cost taxpayers significantly more money) if they decide that such regulations are required. It simply isn't good policymaking to deny ourselves options we may need to use in the future.

Finally, I am strongly opposed to repealing paragraph 2 of section 96(2) of the OEBA. In a world where the choice between renewable and non-renewable energy sources only impacts price, this removal could be sensible. However, we do not live in such a world: the choice to derive energy from renewable or non-renewable sources has decades- or centuries-long effects on the well-being of Ontarians, the quality of our natural environment, and the survival of at-risk species. Just as environmental assessments are required by statute for major construction projects, environmental assessments must form part of the OEB's assessment of new energy projects.

In closing, I would urge the Ministry and Government to facilitate future policymaking processes and protect the natural environment we all share by leaving these protections in place until and unless similar protections are implemented by the OEB and/or IESO.