My recommendations are…

My recommendations are summarized below. Further background is provided in the more detailed document submitted with these comments.
1. The government should direct the IESO and the OEB to make climate change (and national emissions reduction goals for the electricity sector) a key element of the planning, regulation, and operation of the Ontario electricity system.
2. System planning studies to support discussion of potential investments in the electricity system should use the best estimate available of the full externality cost associated with GHG emissions from natural gas fired generation.
3. The electricity system should devote more resource to acquiring, on an ongoing basis, new utility scale wind, solar power, and battery storage capacity as a means of reducing GHG emissions and obtaining timely cost and performance data of these rapidly changing technologies. Better “generation driven” pricing systems should be instituted on a large enough scale, in appropriate areas of the province to test their cost and efficacy. Serious discussions with Quebec should be undertaken to explore the potential of electricity exchanges with Quebec to address possible generation/demand mismatches resulting from more aggressive use of wind power in Ontario.
4. The Ontario Government, in concert with the IESO, municipal utilities, the Ontario Energy Board, industry and consumers should devote more resource to demonstrating, on an ongoing basis, both the new technologies and the new pricing systems associated with Distributed Energy Resource systems (DERs).
5. The government should ensure more aggressive action is taken to support energy conservation.
- It should revise its current modes of subsidizing the costs to consumers of the electricity system. Current modes discourage conservation/efficiency and encourage electricity use by all users rather than limiting subsidies to those that assist consumers who need financial assistance to meet basic electricity needs.
- The government and the electricity system should ramp up conservation/efficiency programs to drive to greater energy efficiency, reduce the environmental impacts of the energy system and lower total consumer energy costs.
6. The government and the electricity system planners should be sceptical of the projected cost, performance, and public acceptability of new nuclear stations, including those based on unproven technologies such as Small Modular Reactors.
7. Planning the development of the electricity system should take place in an open, transparent, and traceable process. The need for new generation (or demand management) in the short term should be used to provide better Ontario based information on system development options for the long term based on wind, solar, batteries, conservation, and Demand Management and DERs.