“Pathways to Decarbonization…

“Pathways to Decarbonization” (P2D) Study

A General Caution

Thank you for the opportunity to provide responses and adding further comment on the future expansion of Ontario's electricity grid. The grid is critical to life today as it will be in the future. Any expansion must be critically considered and engineered. Responsible authorities should not bank on products and procedures yet to be developed, or added to a grid without massive testing to ensure the fit correctly provides the required response, and the consequences of any technology are well-understood.

The thrust of ongoing grid studies to reduce carbon from a grid that is better than 90% carbon-free is commendable in light of the aims of the provincial and federal governments. Climate change discussions for Canada and Ontario are quite over-wrought with carbon dioxide emissions and their ultimate and true effect on weather and climate which frankly is not as well-established as many politicians and climate activists would like Canadians to believe.

However, current leadership has decided to squeeze carbon dioxide from Canada by closing carbon emitting electricity generating plants, electrifying transportation and home heating and cooling while expanding generating and transmission capacity to serve the markets created by legislating the demise of ICE vehicles, coal burning, and if possible, the use of oil and natural gas.

Of course, in the dash to "rewire" our grid over the next 25 years, to reduce the emission of only a few mega-tonnes of carbon dioxide from the atmosphere, to which the whole country only contributes 1.5% of carbon dioxide emission, context is usually important. To this end, let us understand that India and China are and continue to build-out their coal burning electricity generation capacity at an enormous rate and these plants will have 40-50 year lifespans. Moreover, OECD forecasts carbon emissions declining in G7 countries like our own, and rising overall due to the economic expansion of the developing world. So, while Ontarians will reduce carbon dioxide from their grid, the effect and benefit of the expense to do so will be basically zero from a climate/weather perspective.

The hundreds of billions to be spent by Ontarians over the next 25 years are only to bring this new and improved grid to the Local Distribution Company (LDC). These local distributors will have their own capital expenses to bring electricity to homes and businesses. How to pay for the capital and operating expenditures becomes a major issue.

Obviously, reducing to zero is where we seem to be going, notwithstanding the net-zero moniker attached to most carbon issues these days. And it is going to be very expensive to squeeze out that last nasty carbon dioxide molecule. So how much must rates rise, not just the generation costs, but the delivery costs as well? But there is no question who will pay because there is only one taxpayer and one ratepayer!

Where Good Ideas Go To Die - Ottawa's Light Rail Transit (LRT)

For years urban and suburban Ottawa were well served by buses on city streets. An innovative bus transit-way backbone evolved and eventually the bus-way morphed into a rail project expanded east, south and west.

A business case supported the federal and provincial funding. Major portions of the population travelled to the centre core where much government workers spend 5 days a week working. The LRT was seen a way to reduce traffic and reduce carbon dioxide emissions from the reductions of buses and personal vehicles. Not an inappropriate use of government money.

Construction has been underway for years with a few more to go for later stages while a major chunk through the downtown was opened for use. We have since discovered thanks to a public inquiry that bureaucratic and political pressure pushed the project forward at a rapid pace with unproven train technology, the power wires that break at the sniff snow and ice, the wheels come off to derail, the doors don't open or close and the track likely needs to be replaced at certain points. Oh, and the tunnel under the city has a major water leak that confounds engineers.

Now for the unknowns, not the fault of anyone really. The pandemic and everyone was required to stay home, certainly all the public servants of the federal, provincial and city levels who worked in the core. No traffic for the LRT. Next the famous 2022 Freedom Convoy derailed LRT plans, a derecho wind storm which took down the LRT power supply and the 2023 ice storm which did the same, all supported by a clamour to work from home for public servants for a trifecta of a mess.

Meanwhile the diesel buses remaining from a depleted fleet, based on the assumption of a successful LRT, had much to do with too few resources leaving passengers stranded and angry. So what do many these angry folks do now, they drive their personal vehicle. And the Ottawa Transpo company is suffering millions of dollars in lost revenue - and we know who pays, right?

Although the LRT project was undertaken for many good reasons which I supported, leaders, untried innovations and many unknowns took the legs out of a righteous project.

My purpose is to caution IESO and government not to be trapped by the fantasy of innovations yet to be developed and yet to be proven, governments/politicians too eager too please environmentalists who have no idea that an electricity grid is not just about adding turbines and panels, insulation and turning down the heat.

A grid is not a place to experiment.

Energy Ministry Questions

The near-total electrification of our homes, businesses and transportation appears to be the trajectory governments wish Canadians to make their own. Major investments in electric vehicle manufacturing, battery production, mining and small modular nuclear reactors are on the near horizon, having many unintended and potentially bad consequences for which governments pray will not occur on their watch, such as overly expensive EVs, rapidly rising electricity prices to support the electrification of everything: new generation, transmission, demand management, heat pumps, hydrogen production, all requiring massive and costly provincial grid and local distribution grids build-outs.

Now to the consultation questions.

1. Streamlining Regulatory Processes

I have no advice on the regulatory processes other than to note this is one where our politicians, indigenous, local and provincial must come together resolving to expedite processes, otherwise no timeline set will ever be met.

2. Planning and Siting of New Generation and Storage Facilities

This planning needs to start immediately. Storage and generation from and to pumped sites is limited due to southern Ontario geography, although I understand the Meaford and Marmora sites hold some promise.

Transmission is a major impediment to the electrification effort. Hydro sites in northern Ontario require major routes to draw power down to the consumers in the GTA and south-western Ontario, and many square kms of native lands.

Transmission routing applies equally to all future generation siting considerations. New gas generation is likely to be near the major consumption points, or it should be, to reduce transmission routing demand. And I would hope the same principle would apply to SMRs, when they proliferate.

Given the new power demands being brought on by the new battery and vehicle factories between Oakville and Windsor, wind and solar generation should only be located in this corridor, again to remove the need for more lines.

2500MW of power storage is to be developed over the next few years. 250MW was just contracted for 20 years near Brantford. It would appear to be a good location if the major users are nearby, as is the generation from Niagara and Bruce nuclear. Wherever new gas generation is sited, planners should consider their replacement with SMRs so sufficient property should allocated for the future as communities grow around the generation facilities, and to permit reuse of the grid connection points at these sites.

3. Short and Medium Term Generation

I do not believe short term non-emitting sources should be contracted. Doing so would seem to be throwing something against a wall to see what sticks. Likely an uneconomic action not permitting sufficient thought to its rightful placement on the grid. As one who clearly remembers a similar scenario by a provincial government where billions were spilled for no effect than higher overall power costs and government subsidies (which form the largest line item on the province's budget), I rebel at knee jerk considerations where wind and solar companies were given 20 year contracts at 12 times the going power rates. Unacceptable! Please, let Ontario not get ahead of reality, technology and affordability. Give this whole matter some time to be clearly conceived and implemented by engineers rather than being green at any cost.

Electrification and fuel switching will drive consumer costs through the proverbial roof. One needs only look at the gross figures IESO published in the Pathways document. And that is only to bring power to the LDC door. Add the LDC costs to the provincial grid costs and you have a formula of high cost with marginal return for the massive and expensive build-out.

4. Cost of New Electricity Infrastructure

At a median cost estimate of $400 billion to expand the grid by 3 times for 2050, IESO is likely well below the actual cost, 25 years from now.

Transformers of all ratings, major components of the provincial and LDC grids, are in such demand that the queue is 3 to 5 years and current price rises of between 35 and 55%. With USA's push to electrify I am sure prices and delivery times will rise as surely as the sun. Moreover, the major power transformers required for the provincial grid are not even made in Canada or the US, and I do not believe there is a manufacturer in Canada for the smaller local distribution versions. Adding to these woes is the global lack of very specialized G.O.E.S. (grain oriented electrical steel), the major component of every transformer, even the one on a pole outside your house.

As more power is pumped through grids to satisfy consumers, will transformers and other critical grid components need to be swapped out more frequently as those currently engineered may not last their rated life-cycle?

All the concrete used in sub-station foundations, poles, dams and SMRs is rising in price as the need to reduce carbon emitting cement production. How much is a new wooden pole? Wire? Fasteners? Asynchronous switches? And so forth.

What will it cost LDC consumers once the power flows into their cities and towns where major upgrades will be needed not only by the LDC, but for the actual consumers who may have to upgrade the power to their homes before adding a car charger and heat pump?

How to reduce costs? Plan well, engineer, prioritize the most cost-effective project to fund and take the time it takes to do this massive project. Do not jam up the planners with dates and cost limitations that no responsible engineer should countenance. Curb the enthusiasm.

Reduce the number of transmission corridors by placing generation (gas, nuclear, solar and wind) very close to the consumer. Place an SMR where the Oakville gas plant was planned, for example, or wherever current grid connections exist. The Sarnia/Courtwright site could a very good site for an SMR to pump power to Windsor, Leamington and London/St Thomas. An SMR in Kingston/Bath could help power Eastern Ontario. What of the Nanticoke site?

Where transmission is necessary, upgrade the current cables to higher rating to follow existing routes to reduce/avoid regulatory issues. What of using rail and road rights of way for power transmission?

Building any major hydro site should not be undertaken until 2045 to give technology deployment and innovation to be maximized to determine if even such a major build is even necessary

I am sure these are not new ideas but they should be aired.

5. Hydrogen and Other Low-Carbon Fuels

Hydrogen currently is produced at scale through extraction from natural gas. As far as I know, the other method is by electrolysis using electricity. So, I am not sure how hydrogen would produce electricity. Perhaps the idea is to produce hydrogen to store power from baseload excess to be burned for generation at a time of greater need. The efficacy of this concept is an unknown for me.

Perhaps hydrogen will be a fuel for transportation. CP Rail has a prototype locomotive it is testing, and Toyota has recently revealed an ICE engine fuelled by hydrogen.

6. Investment in Non-Emitting Supply and Energy Efficiency

The Pathways document relies heavily on demand management to meet the future's needs. Demand management could be new building codes, but as I understand it, renovating older houses is superior with a better return on the dollar than tweaks to new builds. But with an average Toronto house price of $1M how much is the owner and government willing to spend to reduce the megawatts?

New digital circuit breaker technology in its infancy is now being deployed by companies such as Atom Power in North Carolina, using its system to charge outlets in carparks and condos in New York City, eliminating heavy construction installations. Perhaps if these systems are viable they could eventually be developed for the grid. An innovation worth exploring.

Whether there are other innovations in the circuit breaker field, I am unaware, but these "yet-to-be" built possibilities need time to come to fruition, having been successfully tested and proven. This can take many years before any technology is accepted as a proven grid component.

Pathways also appears to rely heavily on hydro power from Quebec. A recent Bloomberg article would seem to pour cold water on any such plan as Quebec has maxed out its own production to sell into the USA. More recently 400,000 customers were blacked-out when an generator tripped. Where will Quebec gain more reliable power without damming more rivers? How long will such a process take, if even indigenous folks agree? More wind turbines?

Mainspring in California developed a linear generator that uses any fuel. It is not a grid generator yet, but it is an innovation that may have potential over the next 20 years.

With the rise in demand from electrification, the source and generation of electricity will be critical for government demands and mandates. Where will the power come from? Efficiencies are important to the overall picture, but they do not generate power at the place and time of need. Ontario's nuclear generating stations will be critical to the grand electrification plans for the province.

The construction of an SMR at Darlington is a smart move. And on the horizon, there appears to be a good competitor in Terrestrial's molten salt reactor. From a generation view these reactors appear as the solution to a truly carbon dioxide-free grid. The fly in the ointment today is that they are neither a proven nor an operational product. Theoretically, a sound innovation, but until they are up and working their addition to the grid is not a fait accompli and should not be considered as potentially available MWs. If the technology proves reliable and cost-wise, perhaps locating such facilities close to, if not in the city limits of major consumers like Toronto and Ottawa would make sense to reduce transmission line build-outs and other associated needs.

Clear-Eyed Understanding of Consumer Costs

Ontarians busy with life likely do not have a firm grip on the costs of the Ontario-wide massive electrification project being proposed by the private and public sectors although they are barraged by all and sundry to reduce carbon. Do they really appreciate what this will cost them? I do not believe so. That is, and will be a major failure of local and provincial governments. Why do I think so? Let's take a look at a recent electrification study for Toronto.

Toronto Hydro's city electrification plan increases costs to the ratepayer. How much? To just meet the 2040 city goals, the price of power within the city is to rise by 8% per year for the next 15 years. Wow!! Now add on the provincial grid charges. Double Wow!! That's called a double-whammy! Has anyone of the groups pushing for electrification of everything clearly expressed these costs in The Star or Globe. Not a chance, because what sane ratepayer would agree to 8% increases compounded over 15 years? Folks are already struggling to meet mortgages, housing and food with costs rising.

To my knowledge, Hydro Ottawa has not published such a study although having one would likely be an eye opener. Any inquiries I have made have been answered by non-reassuring platitudes that all is in hand. Shades of LRT.

Effects of US System Operators Connections with Ontario

The IESO geography as part of the North American grid connects with a number of US system operators. I have concerns that what may be shaping up in the US could have profound effects on IESO roles and functions, and the reliability of Ontario's grid. My reading of the reliability issues in the US gives me pause. My reasons follow.

With the Inflation Reduction Act to electrify the USA and replace coal, gas and oil with wind and solar, is from what I have read, going to greatly de-stabilizing to their grid, reducing reliability from the 99.99% standard to something less. As I understand it, the changes in their regulatory bodies, FERC and NERC, over the past 25 years or so, although well meaning have actually put their grids in jeopardy, as the utility companies were forced to segregate generation and transmission planning with no sharing of data; effectively shutting down reliability open discussion.

Before NERC was given the powers to fine utilities for not meeting its reliability criteria, utilities would meet to share reliability issues to learn from each other's mistakes. Publicly expressing reliability concerns today, could see NERC, with its powers to fine at millions of dollars per day, lean in to impose massive fines which is occurring at this moment for utilities in the TVA as a result of recent storms. Now there are generation companies declaring bankruptcy due to reliability fines.

As one former utility VP points out, "... regulation by FERC through NERC, took the reliability function away from the utilities. Utilities are no longer responsible for ensuring reliability."

It appears federal regulatory actions served to quiet dissenting voices as there were no near-term incentives for utilities and utility experts to speak up regarding planned threats to reliability. In fact, there were and remain today near-term disincentives if the grid experts spoke up questioning the unreliability aspect of wind and solar as coal and gas plants were shuttered.

Though many platforms are provided for those opposing fossil fuels and promoting renewables, none exist for those with true reliability concerns, as speaking truth to power in the age of renewables and carbon dioxide reduction means excoriation in the extreme. Who could withstand such pressure? And so experts go quiet, follow compliance standards and hope for the best.

Utilities are not developing reliability experts, but experts in standards compliance. When outages occur it is hard to figure out where the blame lies, the former VP concludes.

Do we in Ontario face the same reliability and regulatory framework that seems to be threatening US grid reliability? Will their ills affect Ontario? How many us remember the Great Blackout of August 2003?

Concluding Remarks

Ontario's electricity grid must be rock-solid and 99.99% reliable. Brown-outs and blackouts are totally unacceptable. Reducing carbon dioxide cannot be the sole criterion for the future grid as many would wish it to be. Reliability, first and cost, second. Carbon-free farther down the spectrum.

If shutting down gas fired generation would negatively affect the prime criteria, reliability and cost, then gas should remain in play until nuclear plants, hydro, or whatever best suits Ontarians, at the time come on line as reliable and cost-effective.

Many wish to jump to wind and solar, but few realize these sources are unreliable and costly to connect to the grid; being asynchronous requires special treatment and possibly best served to charge batteries that may be advanced as the surplus baseload disappears in time.

Innovations, as critical and important as they may be, should not be factored into the hard power requirement calculations required in adherence to reliability and cost criteria until proven.

Heat pumps and EVs are the latest craze. Perhaps their uptake will be as strong as predicted, but again they are innovations for most folks, especially EVs. It is yet to be proven if the EV numbers forecasted will actually come to pass, but only when price comes down to reasonable for the average person.

Reducing regulatory processes and time seems to be a major obstacle to speeding the carbon-free drive of activists and politicians looking for near-term wins. On the other hand, giving pause to some of the radical thinking could possibly be a good thing, allowing innovation to catch-up with reality.

The grid is absolutely essential. It is neither an experimental toy nor a play-thing to endear a government to activist groups whose sole goal is carbon dioxide reduction.

Let's take the time it takes for sound engineering, testing and gradual implementation. The world will not end in 2035, 2045 or 2050 if Ontario is still using some level of natural gas to keep the lights on.

Finally, please no Ottawa LRT-style debacles. One was too many!

P.S. For context, a little personal information. I constructed my home 30 years ago, complete with ground-source heat pump and fully electric. When the power goes out, there is no water (hot or cold), no sump pump, no light, no internet, and no TV. As goes the price of power so goes my budget, therefore I am very sensitive to price and the hundreds of billions being proposed to reduce a little, inconsequential carbon dioxide. Given all the talk of the carbon-free grid, and my experience with the former government's "green" power fiasco a few years back that raised my rates and did nothing for the atmosphere, grid reliability is foremost in my mind. As such, and as many Ontarians are doing, I am investing in a whole house personal generator to ensure I can survive notwithstanding the machinations of the utilities and government.