I wish to make the following…

I wish to make the following comments on the IESO Pathways to Decarbonization (P2D) Plan of December 15, 2023.

1. The P2D Plan does not pay sufficient attention to the Dunsky Energy + Climate Advisors, Ontario’s Distributed Energy Resources (DER) Potential Study, Volume 1: Results & Recommendations, Prepared for IESO, (September 28, 2022).

- According to this report (see pages ES-1 to ES-4)., Ontario can avoid the need for new methane gas generation facilities by investing in load controls, solar, stationary batteries and bi-directional chargers.

2. The P2D Plan proposes to double Ontario’s nuclear generation capacity by 2050 despite the fact that energy efficiency, wind and solar, and Quebec water power, can all meet Ontario's electricity needs at less than half the cost, without producing more nuclear wastes.

- Nuclear power is costly to use and slow to construct -- nuclear facilities have consistently far exceeded budgets and construction time frames.

- It is also irresponsible to propose new nuclear generation facilities without consideration of the externalities, including the costs of storing and disposing nuclear waste, and of decommissioning of nuclear facilities.

- As well, it is purely speculative to factor small modular reactors into the P2D Plan. They do not yet exist and therefore have no track record upon which to evaluate their costs or the time necessary to build and commission them.

3. The P2D Plan contemplates a doubling of solar from 2,700 to 6,100 MW. Given the fact that the cost of solar continues to plummet, and the rapid adoption of solar power in many jurisdictions, the solar target in the P2D Plan is inexplicably unambitious

4. The P2D Plan caps onshore wind at 15,800 MW, saying that expansion beyond that is limited by sites, regulatory requirements, and transmission infrastructure. However, these constraints are not seriously evaluated or described in the P2D Plan. As well, the P2D Plan does not give sufficient consideraton to the role that offshore wind can play - a study for the Ontario Clean Air Alliance found that offshore wind alone could supply 80% of Ontario's electricity at a very affordable price.

5. The P2D Plan contemplates too great a role to hydrogen, without giving consideration to the factors that determine whether the hydrogen will result in decarbonization, such as what will be the costs of producing and transporting hydrogen, and will it be created using fossil fuels?

6. The P2D Plan does not give serious consideration to low carbon strategies that have been successfully used in other countries, such as district heating and co-generation.

7. The P2D Plan does not provide a rationale for factoring out of the plan the import of hydro power from Quebec and Manitoba. While new transmission capacity would be required, such imports are worth considering given their low cost and reliability.

8. The P2D Plan does not take into account the forthcoming federal Clean Electricity Regulations, and their effect on the ability of methane gas electricity generation facilities to continue to operate. As well, the Plan does not factor into its cost analyses for new methane gas faciilties the provision in recent IESO procurements that Ontario ratepayers will continue to have to play for power that is not supplied by these facilities if they cannot meet the standards of the imminent Clean Electricity Regulations.

9. The P2D Plan takes no account of the current climate emergency which requires significant lowering of GHG emissions by 2030. Long term strategies (such as nuclear facilities and hydro power) cannot possibly begin to supply power within this time frame. More ambitious action on proven decarbonization strategies must be undertaken and included in the P2D Plan. If sufficient reductions in GHG emissions are not made by the end of this decade, we will see the beginning of feedback loops that will have massive and irreversible consequences.