Given the complexity of what…

Given the complexity of what is being considered in the province’s Long Term Energy Plan, I have broken down my submission into several categories based on topic.

 

1) Continued reliance on nuclear energy generation as a significant portion of Ontario's electricity mix:

 

While nuclear energy offers many advantages over fossil fuel generation, continued safe operation of Ontario’s aging nuclear reactors is a primary concern for all Ontarians. OPG has had a particularly poor record when it comes to safety at the Pickering Nuclear Generating Station. Most recently OPG was heavily fined for violating its licensing requirements. Extending the life of PNGS to 2024 as currently recommended in the long term energy plan represents an unnecessary risk, especially given that the province could easily replace the retired capacity with an equivalent amount of renewable energy coupled with energy storage and inexpensive imports of hydro electricity from Quebec.

 

Furthermore, the recent rate application by OPG to the Ontario Energy Board to increase the cost of nuclear power by more than double is an indication of the increasing liability of continued operation of Ontario’s aging nuclear fleet. The requested price for nuclear energy will be more than twice the cost of new wind power projects based on the winning bids from the LRP. The province’s reliance on nuclear energy is now a threat to the affordability of electricity, which has been repeatedly identified as a primary concern to ratepayers.

 

2) Suspending the second round of the Large Renewable Procurement and the Energy from Waste Standard Offer Program:

 

The decision to cancel the second round of renewable energy procurement amounting to over 1,000 MW of renewable energy at such a late stage was an enormous mistake, as this has directly resulted in undue hardship to local renewable energy equipment manufacturers and developers. It also sends a message of instability to the market and makes for an uncertain investment climate for companies that provide much needed well paying manufacturing and technology based jobs to the province’s economy. The decision to cancel the LRP runs directly counter to the goal of pursuing a continued reduction in the carbon intensity of the electricity grid.

 

3) Residential price mitigation:

 

Subsidies for electricity consumption in the form of rebates such as the “Ontario Clean Energy Benefit”, “Ontario Electricity Support Program” and the “Rural and Remote Electricity Protection” run directly counter to the Ministry of Energy’s own energy conservation goals. Such rebates granted directly on electricity bills are a disincentive to conserve electricity. While support should be provided to low-income households to assist with the living costs, mechanisms such as robust funding programs for increasing household energy efficiency through retrofits would result in both conservation of energy and reduced energy bills. According to NRCan, in 2011 approximately 38% of single-family dwellings in Ontario relied on electricity for space heating and 42% of single-family dwellings relied on electricity for hot water production. Given that hot water use and space-heating make up 85% of the total energy use in a single-family dwelling, focusing on increasing the energy efficiency of these homes would provide a significant benefit for a large proportion of Ontario’s households. Such energy efficiency programs would also reduce the financial burden on all Ontarians, given that according to the Financial Accountability Office of Ontario, the aforementioned rebate programs are funded via charges to all ratepayers. Should additional financial assistance be required, it would be better accomplished through an income tax rebate, as at least then it would not financially reward wasteful energy consumption.

 

4) Home energy audits and retrofit programs offered through Enbridge and Union Gas:

 

While these programs offer a sizeable benefit for home owners using natural gas for heating and hot water production, rural and low income households that use electricity for space heating and hot water and could benefit the most form energy efficiency upgrades are excluded. Given that over 1/3 of all households in Ontario rely on electricity for space heating and nearly 50% rely on electricity for hot water heating, a significant proportion of the population receives no benefit from these programs. While carbon emissions savings associated with efficiency upgrades in homes using natural gas may appear to be greater than those for electricity, the age of the building and the existing level of efficiency play very large roles in determining the effectiveness of efficiency upgrades. Adding insulation to a 100 year old house with no insulation would result in a much greater reduction in energy use and green house gas emissions than the same amount of insulation added to a 10 year old house that is already insulated to code minimum levels.

 

5) Grid integration of electric vehicles and energy storage systems:

 

Looking to the next decade, electric vehicle uptake is certain to increase along side peak shifting energy storage systems, offering synergies between dispatchable demand and renewable energy generation. Another example would be hydronic heating or cooling systems that rely on water storage tanks that can be dispatched to generate and store thermal energy for heating or cooling during periods of high wind or solar production for use during peak periods, thereby alleviating strain on the electricity grid and helping to increase penetration of renewable energy on the grid.  The University of Guelph has a great example of a thermal energy storage system that can store up to 5 MW worth of energy for cooling buildings on campus. Another current example is a net zero energy home on the Bruce Peninsula that uses hydronic heating, relying on hot water heated from off-peak electricity that is then stored in insulated tanks for use during on-peak times. Other examples could include energy storage using electrolysis to produce hydrogen, which can then be stored for conversion back to electricity or as a transportation fuel. A framework needs to be developed to investigate the opportunities that exist from using both currently available and nascent technologies that can be integrated into a smart grid network that is able to facilitate both the addition of more renewable energy to the grid and a flattening of peak demand curves to help reduce the strain. While the 50 MW pilot program for energy storage was a good start, a large concerted push needs to be made to support and rapidly roll out grid energy storage systems to assist in rapid de-carbonization of the electricity grid and transportation network. Not only will this mitigate climate change, it will also help develop a new green technology sector and if planned properly, would facilitate further grid stabilization and resilience.

 

To help inform decisions related to development of energy storage, renewable energy and electric vehicles, the Ministry should look to some of the research done by other jurisdictions such as the United States Department of Energy’s National Renewable Energy Lab (NREL). Over the last decade, NREL has undertaken extensive work in this field, including the modelling of entire grids using super computers to determine what effect the level of wind energy penetration and electric vehicle uptake has on grid operation. Publications from these studies are currently available from NREL (http://www.nrel.gov/transportation/project_ev_grid_integration.html), though given the US president elect’s stance on climate change, they may only be accessible for a limited period of time...

 

6) Expansion of natural gas to rural communities:

 

The current goal of the province is to rapidly reduce carbon emissions, however the proposal to increase access to natural gas for use as a heating fuel via expansion of the natural gas pipeline network to rural communities is directly counter to this goal and should not be allowed to occur. A significant proportion of natural gas produced in North America is through the use of hydraulic fracturing which has been shown to have many detrimental effects on communities and ecosystems, including multiple earthquakes that damage buildings, groundwater contamination, ecosystem fragmentation, and proliferation of wastewater ponds to store spent fracking fluid. Therefore, the province should not only cease the expansion of the natural gas network, but also follow the lead of New Brunswick and Quebec in putting moratorium on all hydraulic fracturing well development. For rural communities, redirecting the $230 million currently earmarked for expanding natural gas service and instead investing it in energy efficiency retrofits for homes, farms and businesses, and promoting the use of advanced technologies such as heat pumps for use in drying facilities would both help to increase local jobs in the technology and building sectors and help to reduce carbon emissions. This would be a far better option than spending $230 million in subsidizing fossil fuel use and aiding development of a destructive industry! In fact, even doing nothing at all or just handing rural homeowners and businesses the cash would be a better option than subsidizing natural gas use.

 

7) Net Zero Energy Communities:

 

The province via the Ministry of Municipal Affairs and through the Climate Change Action Plan has announced that all new homes will be net zero energy by 2030. Efforts to develop net zero communities should be harmonized between the Ministry of Municipal Affairs and the Ministry of Energy to avoid unintentional difficulties for the development of such communities. The Ministry of Energy must mandate that grid operators and local distribution companies plan for and accept such developments. Hydro One seems to currently have an arbitrary cap on the amount of distributed generation that they accept on their network. A first step toward reducing barriers for net zero community development would be for the Ministry of Energy to require a third party evaluation of the actual capacity for distributed generation on the grids of companies such as Hydro One. Grid utilities need to be carefully and closely regulated to ensure the goals of carbon emission reductions are not compromised, otherwise Ontario runs the risk of utilities engaging in anti-competitive behaviour such as recently seen in Nevada.

 

8) Expansion of electricity grid to northern communities:

 

Rather than spending billions of dollars building inefficient long distance electrical transmission lines through the boreal forest and destroying habitat in the process, the money would be better spent on developing localized grids powered by local energy sources that would support local jobs and independence for northern communities. These communities could also double as test beds and living labs for new technologies for management of micro grids and integration of renewable energy and storage.

 

9) Oil Pipelines – Energy East:

 

The Energy East pipeline should not be allowed to proceed, since repurposing an old natural gas pipeline for transport of diluted bitumen is a risky venture.  Improved access to markets would result in further expansion of oil sands, which would quickly negate Ontario’s emission reduction efforts. Given the poor safety records of TransCanada and other pipeline companies in the past, allowing Energy East to proceed would greatly increase the risk of a significant oil spill event in the province. Furthermore, according to a 2015 article in the Ottawa Citizen, the Ontario Energy Board has identified that allowing this conversion would increase winter natural gas prices in the province by 12%. The meager short-term employment opportunities that this pipeline project would provide are just not worth the high risk to drinking water of communities and to sensitive ecosystems.

 

10) References:

 

PNGS Regulatory Action 2016: http://www.nuclearsafety.gc.ca/eng/pdfs/Regulatory_Action/2016/20160112-AMP-Ontario-Power-Generatio n-eng.pdf

 

NRCan 2011. “Comprehensive Energy Use Database”, Tables 28, 29 & 35. http://oee.nrcan.gc.ca/corporate/statistics/neud/dpa/showTable.cfm?type=CP&sector=res&juris=ca&rn=2 8&page=0

 

Financial Accountability Office of Ontario, 2016. “Home Energy Spending in Ontario: Regional and Income Distribution Perspectives”

 

http://www.fao-on.org/en/Blog/Publications/hespending

 

Ottawa Citizen, D. Butler, August 13, 2015 “Energy East would raise winter natural gas prices by 12% in E. Ontario, OEB says” http://ottawacitizen.com/news/local-news/energy-east-pipeline-would-raise-winter-natural-gas-prices -12-in-e-ontario-oeb-says

 

[Original Comment ID: 207085]