The Greater Toronto Airports…

The Greater Toronto Airports Authority appreciates the opportunity to respond on this important topic. Integrated energy planning is critical to meeting the energy requirements for economic growth, energy resilience and supporting GHG reductions. The GTAA's experience and view on energy planning is both as a large energy consumer and an energy producer (via our 117MW cogen facility). The GTAA is also an organization with a mature GHG reduction program that overperformed on our goals to reduce GHG 20% by 2020 (actual reduction was over 60%) and is further committed to Net-Zero GHG by 2050.

Responses to each question are provided below in Question/Response format:

1 Overarching Question
Question: What policy options and actions should the government consider in the integrated energy resource plan to achieve Ontario’s vision for meeting growing energy needs, keeping energy affordable and reliable, ensuring customer choice and positioning us to be an energy superpower?

Response: The government's approach to an “all-of-the-above” strategy that does not exclude technologies is the correct path to follow however some technologies should be given extra consideration when they can concurrently provide solutions to keeping energy affordable and reliable while helping to meet growing energy needs. Hydrogen via electrolysis is one such technology. The ability of electrolyzers to provide grid services and act as a dispatchable load (not on peak) has been demonstrated and this helps to balance the grid, reduce global adjustment (utilize off peak only) and thereby keep energy affordable and reliable for Ontarians. Additionally, the hydrogen produced can act as a storage medium for areas saturated with clean electricity and as an energy carrier to move that clean electricity to areas where existing transmission may be grid-constrained, such as Toronto Pearson (where the GTAA is exploring hydrogen-fired gas turbines for power generation) or to industries that are difficult to electrify or decarbonize (such as aviation). Supporting an Ontario Hydrogen Backbone Pipeline Network would enable this and would be in line with actions that help keep energy affordable. Multiple studies have shown that moving hydrogen via pipeline is more cost-effective for getting large volumes of hydrogen to areas of demand than high-voltage electrical transmission lines. Having hydrogen as part of the energy transition has become an agreed-upon necessity globally. For Ontario, a hydrogen pipeline network provides energy storage for dispatchable loads and energy security by enabling hydrogen-powered peaking plants in addition to hydrogen-powered mobility.
Energy resilience, energy transition to support net-zero GHG and energy availability to support low-carbon airport growth under the LIFT (Long-term Investment in Facilities and Terminals) program are critical to the long-term success of Canada’s largest airport and the transportation ecosystem as a whole. A Hydrogen Backbone Pipeline Network will be “one more arrow in the quiver” to help address low carbon energy needs at and around Toronto Pearson. The GTAA must also pursue micro-grid technologies, expanded backup power options (cogen, battery technologies, etc.) for airport operational resilience and other clean fuel options such as sustainable aviation fuels (SAF) and renewable natural gas and renewable diesel. In effect, Toronto Pearson is trending toward becoming a microcosm for Ontario’s “all-of-the-above” strategy. The airport’s inherent needs for excess energy availability means that there are likely to be further opportunities for energy resources at the airport to support the local energy ecosystem similar to how our existing 117MW cogen facility currently supports peak demand in the local grid as well as back-up power to the airport. There may even be opportunities to intentionally overbuild airport energy assets in order to provide broader support to the grid, local community and transportation network.
The concept of airports as energy hubs is an emerging, global trend as identified by the World Economic Forum, Airports Council International and Airbus. Provincial support for the development of an Airport Energy Hub strategy would integrate well with the existing “all-of-the-above” approach, position Toronto Pearson among leading airports globally and support low-carbon energy availability and resilience in a grid-constrained region that is Canada’s second largest employment market and sees over 1 million cars and trucks passing through daily.

2 Planning for Growth
Question: Building on the recommendations of the EETP’s final report, what actions should be prioritized to enhance planning across natural gas, electricity, and other fuels?

Response: An integrated approach that takes into account new energy systems is going to increasingly connect natural gas, electricity and clean fuel systems such that they become highly interwoven. For example, electrolyzers could be used for grid benefits to balance demand and reduce global adjustment, the hydrogen produced be combined with captured CO2, for example from natural gas power generation facilities, to create Sustainable Aviation Fuel (SAF).
To support the hydrogen industry in helping to decarbonize power, heating, transportation and other industrial processes, a network of hydrogen pipelines should be prioritized to connect production hubs to end-users as it would enable large-scale decarbonization with hydrogen across sectors.
As part of the commitment and policy principles for achieving a clean energy economy for Ontario by 2050, hydrogen needs to be part of this commitment. By prioritizing hydrogen and a hydrogen pipeline network it will ensure Ontario can access federal funding opportunities such as through the Smart Renewables and Electrification Pathways Program (SREPs’) Critical Regional Priorities (CRP) stream and align the province with other regions within and outside of Ontario.
The creation of an Energy Transition Advisory Council (ETAC) that could convene a task force to help streamline the permitting and approval process for a hydrogen pipeline network should be prioritized with clear direction to accelerate the role of clean hydrogen for a successful energy transition.
Finally, existing electricity rate structures should be redesigned to provide either a hydrogen-specific rate or a mechanism to provide price predictability so that financial models can lead to investment decisions.

Question: The government’s priority is to ensure Ontario has the energy resources it needs to support growth. Are there opportunities to enhance the province’s approach to procuring electricity generation supply to better serve this priority?

Response: The GTAA’s priority is to ensure Toronto Pearson has the energy resources it needs to support growth and decarbonize its operations to meet Toronto Pearson's stated net zero goals. There are opportunities to help existing power generators like GTAA meet Clean Electricity regulations by extending, repowering and upsizing existing clean energy contracts. Clean energy power generators should be linked with hydrogen production (and other forms of energy storage such as battery storage) and the government can provide support to connect them by hydrogen pipeline. The GTAA is expected to at least double its power demand and a hydrogen pipeline enables hydrogen gas-fired turbines to be a clean power-generating option. For existing natural gas-fired power plants, such as the existing 117 MW Cogen facility at Toronto Pearson, electrolytic hydrogen brought in via pipeline with carbon capture can produce low-carbon fuels such as sustainable aviation fuel (e-SAF) and reduce the carbon intensity of the electricity grid.

Question: What actions should the government consider to promote greater access to electricity and accelerate grid connections that will support economic growth, connecting new homes, and electrifying transportation and heating?

Response: Where industrial processes, new homes and transportation can use electricity directly they should be, but there will be a large number of cases where direct electrification is not possible. For example, Toronto Pearson is in a grid-constrained area and airlines are continuing to scale up battery electric equipment. The risk in this scenario is burning diesel in a genset to power battery electric equipment chargers as bringing in new transmission is likely to be too expensive or not feasible. Hydrogen allows for access to low carbon electricity in difficult-to-electrify areas and applications. It allows for an alternative to battery-electric equipment while still electrifying the equipment thus easing the demand on the local grid or it can be used to generate electricity and provide a clean alternative to having to use diesel gensets.
To promote greater access to electricity, the government should consider streamlining the approval processes for hydrogen pipelines. This will allow grid connections on both the generation and end-use of hydrogen. On generation, it will be hydrogen hub production on end use it will be hydrogen gas turbine power generation (and possibly fuel cell generation in the long term). Toronto Pearson is undertaking a feasibility study with industry partners to assess this opportunity in addition to hydrogen for mobility.
Further, Toronto Pearson has a feasibility study underway in partnership with Airbus and other stakeholders to determine infrastructure requirements to support hydrogen-powered flight. An electrolytic hydrogen-fed pipeline would electrify not only ground support equipment (GSE) and public transit in the Pearson area but also electrify aviation with hydrogen-powered flight when it arrives in the future. Furthermore, Toronto Pearson’s existing gas-fired plant could potentially run more with less emissions if it was upgraded with carbon capture. The captured carbon could be combined with hydrogen via a pipeline to produce SAF (e-SAF). Making productive use of captured carbon to produce e-SAF provides an opportunity for existing natural gas-fired turbines to run more if a hydrogen pipeline exists.

Question: As the need for new transmission infrastructure continues to grow, what steps can the government take to ensure that transmitters have the certainty they require to move forward with development work as soon as possible, while also ensuring that competitive pressures keep costs as low as possible?

Response: To ease the burden on the transmission infrastructure, the development of a hydrogen pipeline system to transport gaseous hydrogen has been shown in other jurisdictions to be more cost-effective than building new high-voltage transmission lines to take the electricity to areas of hydrogen demand and produce the hydrogen. The government of Ontario can play a crucial role by initiating a streamlined approval process and stakeholder engagement process to accelerate the implementation of hydrogen pipeline networks in Ontario.

Question: What policy guidance should the government provide to the Ontario Energy Board (OEB) with respect to the long-term role of natural gas in Ontario’s economy and opportunities for low-carbon alternatives in the gas system?

Response: For power generation, increased clean electricity is needed to keep Ontario’s electricity carbon intensity as low as possible to draw investment. Carbon capture at power plants should be given special consideration and there should be policies in place that support the utilization and sequestration of the captured carbon. For example, policies that support using the captured carbon to be combined with clean hydrogen to produce low-carbon fuels such as SAF. Ultimately the long-term role of natural gas without carbon capture in Ontario’s economy should be minimized and a transition to low-carbon alternatives made. This is supported by Enbridge’s report done by Guidehouse, where a diversified scenario of pipes and wires was recommended as a pathway to net-zero for the province where natural gas use with no carbon capture was eliminated and the use of hydrogen to meet the energy demand in 2050 nearly matched that of electricity (Guidehouse, 2022)

Question: How can the government best support Indigenous leadership and participation in energy planning and projects?

Response: Ensure that as part of energy planning and/or energy projects, local Indigenous communities are brought to the table in the early stages as recommended in Recommendation 8 of the EETP. Indigenous communities engaged from the beginning can provide the leadership and participation needed to guide projects to a successful outcome. Ensuring Indigenous communities are part of the approval process for projects, specifically for hydrogen pipelines will help community engagement. Where feasible provide reasonable incentive mechanisms to clean hydrogen producers, hydrogen distributors (including hydrogen pipeline transmitters), and hydrogen end-use applications that motivate Indigenous / Private partnerships.

Question: How can provincial planning processes be enhanced to support high-growth regions, ensure greater coordination between energy resources, and better integrate municipal, distributor and regional planning processes?

Response: High-growth regions have been identified as Central Ontario, Eastern Ontario, and Southwestern Ontario (Government of Ontario, 2024). Knowing that 15,000 MW of hydrogen has been identified by the IESO as being needed as part of a pathway to a decarbonized grid (IESO, 2022) and that in Enbridge’s report done by Guidehouse, a diversified scenario of pipes and wires was recommended as a pathway to net-zero for the province where natural gas use with no carbon capture was eliminated and the use of hydrogen to meet the energy demand in 2050 nearly matched that of electricity (Guidehouse, 2022), the provincial planning process needs to look at the most economical way to get hydrogen to high-growth areas. Given that the energy resources are spread out across the province, it has been shown that producing hydrogen near the resources and transporting it via a pipeline to areas of demand is more cost-effective than transmitting the transmission lines and producing the hydrogen at the demand site; and substantially more than transporting via truck (Slowinski et al., 2023). While Recommendation 8 of the EETP talks about forming an external Energy Transition Advisory Council (and sub-committees as necessary), one of the first groups that needs to be convened is a task force to specifically evaluate options to streamline the approval process for hydrogen pipelines.

Question: What cooperation opportunities exist across other jurisdictions to support energy trade, construction of transmission infrastructure (ex. pipelines and interties), and transportation electrification?

Response: As recommended in Recommendation 3 of the EETP, there should be strategic policy alignment and engagement with the Federal Government, other provinces, neighbouring states and other countries. Ontario is bordered by three different hydrogen hubs planned in the United States which are among 7 hubs the U.S. Federal government has granted $7 billion. In 2022, Quebec developed a framework and environment to accelerate the production, distribution, and use of green hydrogen (Canada Energy Regulator, 2024). The IESO’s Pathways to Decarbonization (2022) contemplates bringing in hydrogen via pipelines, the development of a hydrogen pipeline system connecting hydrogen hubs in Ontario to the Pearson economic zone that can eventually be connected to the hubs in the U.S., as well as other provinces will support clean energy trade.

Question: What types of technical information and forecasts would best support sector participants and energy consumers as the system is built out for growth and the economy increasingly electrifies?

Response: Considering a current GTAA peak demand of 42MW that is expected to more than double under its Long-term Investment in Facilities and Terminals (LIFT) program over the next decade, understanding the technical limitations of the grid to meet these demands as well as forecasts on planned infrastructure upgrades and additional capacity will help to support the GTAA in managing its energy planning. As the GTAA is limited in its ability to deploy renewable energy assets in and around the airport, the balance of the GTAA’s clean energy will need to come from offsite via power purchase agreements, clean energy RECs, or through the production and transmission of clean hydrogen via pipeline to the airport. Technical information on the feasibility of a pure hydrogen pipeline to Toronto Pearson is already set to be undertaken in 2025 and any forecasts on clean energy deployment from the government would help support this undertaking.

3 Affordable and Reliable Energy
Question: What further steps should the government take to enable households and businesses to manage and make informed decisions about their energy use?

Response: Energy is not just electricity and natural gas but rather power, heat and transportation. Streamlining processes that help businesses integrate with federal regulations such the clean electricity regulation and clean fuel regulation.
Implementation of Corporate Power Purchase Agreements (Corporate PPAs), real-time emission credit generation and an interruptible hydrogen production electricity rate would help businesses such as the GTAA, to implement more dynamic energy use plans that optimize renewable energy use, minimize emissions and maximize hydrogen production for decarbonization efforts across sectors.
 
Question: What actions could the government consider to ensure the electricity system supports customers who choose to switch to an electric vehicle?

Response: The government should consider that there are two types of electric vehicles currently on the market. The first is the battery-electric vehicle (BEVs) which has seen wider initial adoption, but the second is hydrogen fuel-cell electric vehicles (FCEVs). Technically, the lifecycle energy efficiency is better using BEVs however BEVs are not necessarily the right choice for every scenario such as for when battery weight, charging times, or cold weather performance are an issue. In these scenarios FCEVs allow customers to still switch to an electric vehicle, but only if the government takes necessary actions to support the development of the hydrogen economy and hydrogen production hubs in Ontario using clean electricity (off-peak). The government should consider ways to make more productive use of off-peak clean electricity resources such as a dedicated hydrogen rate or providing hydrogen producers with electricity pricing predictability.
Toronto Pearson already has a significant BEV charging network that is anticipated to grow rapidly under the LIFT expansion program. The government should support utilities to be able to move faster and on a larger scale than ever to expand the electrical infrastructure required to support BEV charging. Expanded BEV charging will add to variability in electrical demand as vehicles connect and disconnect form chargers. The variation in demand can be smoothed by integrating BEV charging networks with hydrogen generation and/or battery storage. The government should consider actions to promote the implementation of energy storage (battery and/or hydrogen) and demand management technologies in combination with large BEV charging installations in order to maximize efficiency and value obtained form the grid expansion required to support further vehicle electrification.

Question: What actions should the government consider that would empower customers to install innovative technologies to generate or store energy on-site to reduce costs and improve resiliency?

Response: The GTAA owns a 117 MW Cogen facility to generate power for resiliency and when needed can feed electricity back into the grid. Streamlining a hydrogen pipeline process would enable hydrogen powered peaking plants. With the Long-term Investments in Facilities and Terminals (LIFT) program underway at the airport, energy needs are forecast to double or more. This requires the consideration of increasing generation capacity to maintain resiliency. One option to be investigated via a feasibility study is bringing in hydrogen via a pipeline which would enable power generation via zero-emission hydrogen-fired gas turbines that could also be used as a peaking plant. Enacting policies and programs that support the implementation of this hydrogen pipeline network would empower not just Toronto Pearson in using hydrogen to lower emissions and improve resiliency but also others in the Pearson Economic Zone, the second-largest employment zone in Canada.

Question: What specific actions could position the integrated energy resource plan to best leverage distributed energy resources (DER) that enhance local and province-wide grids to support energy system needs reliably and at the lowest cost?
Clean hydrogen production via electrolysis can act as a valuable grid balancing tool for the province by using off-peak low-carbon energy in other regions of the province to supply clean hydrogen energy to the GTAA and surrounding area. The lowest-cost form of transmitting hydrogen at scale is via a pipeline. Streamlining an approval process for a dedicated hydrogen pipeline will help to connect these distributed DERs and support energy system needs.

Response: What policy or regulatory changes should the government consider to address financial risks and support the adoption of DER in the long term?
Changes that recognize that the Ontario electricity grid system is just one component of the Ontario energy system. The energy system consists of power, heating, and transportation. As the energy system becomes more interconnected, policy and regulatory changes need to adapt so that the system as a whole is looked at, not just the Ontario grid or the natural gas system on its own.
If the interconnectedness is addressed and the integration of DERs that support the energy system is supported this will help to address financial risks. For example, an electrolyzer can be used as a DER to help manage demand or frequency in the electricity grid. At the same time, it is producing low-carbon fuel for the transportation system. Recognizing this multi-faceted ability to support different areas of the energy system simultaneously will make the adoption of DERs such as this less risky in the long term. Additionally, a dedicated hydrogen rate or electricity pricing predictability is necessary for financial investment decisions on electrolytic hydrogen DERs.

Question: With the energy sector evolving and distributors considering new roles in serving customers, what barriers exist that limit local distribution companies from taking on new duties that could enable more efficient grid operations, leverage new technologies and further the integration of DERs?

Response: As previously stated, the use of electrolysis to produce hydrogen can be used as a DER. Having a hydrogen pipeline network to collect the hydrogen and transmit it to areas of hydrogen demand allows local distribution companies to leverage this technology as a DER to make grid operation more efficient. To enable this a streamlined approval process for dedicated hydrogen pipelines needs to be examined.

Question: What actions can the government take to enhance collaboration between the OEB, the IESO, local distribution companies, industry stakeholders, and local communities to support the investment and integration of DER?

Response: In line with Recommendation 8 of the EETP, the formation of a task force such as the Energy Transition Advisory Council should bring together all stakeholders to accelerate hydrogen pipeline development. It is crucial to make the approval process streamlined as this is a major infrastructure project that will take years if not decades and the need to start is critical to the energy transition.

Question: What further actions could the government take to maintain an affordable energy system for Ontarians throughout the energy transition?

Response: All clean energy options need to be put on a level playing field (hydrogen, energy storage such as batteries, pumped storage, compressed air, etc.). Where increasing the off-peak consumer base directly reduces global adjustment however a complete and holistic view of hydrogen generation benefits needs to be taken into consideration when assessing it against other energy storage mediums. This means that when assessing hydrogen production against other technologies for grid services the assessment should take into consideration other benefits provided such as clean fuel production, GHG reduction, and health benefits of reduced pollutants.

4 Becoming an Energy Superpower
Question: What opportunities exist to further capitalize on Ontario’s leadership and expertise in nuclear technology and nuclear innovation?

Response: Toronto Pearson’s facilities electrical demand is growing rapidly through the LIFT program and our energy transition to net-zero GHG by 2050. Hydrogen and/or electric flight will drive even greater load growth that will need low carbon electricity as very large scale. Nuclear power, along with wind, solar and hydroelectricity will be critical to meeting the province’s growing energy demand while maintaining a path to net-zero GHG.
The hydrogen industry is growing rapidly around the world. One industry that has historically had expertise with the use and handling of hydrogen is the nuclear industry. Besides leveraging Ontario’s expertise in nuclear technology and innovation just for the nuclear industry, there is the opportunity to leverage it across the energy sector to help make Ontario a hydrogen energy leader as well.

Question: What opportunities should Ontario consider to leverage its position as a clean energy leader?

Response: Ontario recently announced the largest energy procurement in its history to address increases in the forecasted electrical load. While it is expected that natural gas power generation facilities will be an integral part of this procurement, ensuring that these plants are hydrogen-ready, supporting the availability and cost-effectiveness of renewable natural gas and/or enabling carbon capture and sequestration will help to leverage future opportunities in order to maintain Ontario’s low carbon intensity grid.
Ontario has one of the most abundant clean electricity resources in the world during off-peak timeframes. Ontario should make use of that off-peak clean electricity resource. Make productive use of investments in clean electricity that is in transmission-constrained areas. Put mechanisms in place that motivate owner-operators of existing clean electricity generation to repower their facilities and add additional capacity. Utilize existing grid interconnection facilities to collocate hydrogen production at electricity production with contract renewals (for wind for example) coming up and put measures in place that justify not only extending but repowering and upscaling.
The GTAA is looking for clean energy that can help meet our net-zero commitments. GTAA has limited onsite renewable potential and is therefore exploring clean energy forms that can be imported from other areas in the province, including energy that can be imported via hydrogen pipeline in the future.