Xeneca Power Submission to…

Numéro du REO

019-6647

Identifiant (ID) du commentaire

84000

Commentaire fait au nom

Xeneca Power Development, 37 Rustwood St. Bowmanville, Ontario L1C 5B5

Statut du commentaire

Commentaire

Xeneca Power
Submission to the IESO Pathway to Decarbonization
April 18, 2023

Xeneca Power (www.xeneca.com) was established in 2008, and, during the MNR's site release program in 2008-09, through its subsidiaries, acquired tenure for 44 potential waterpower sites in the Province of Ontario. The sites, located in Northeastern and Northwestern Ontario have potential to produce in excess of 70 MW of dispatchable power.

Under the then-known Feed in Tariff (FIT) program Xeneca won contracts for 19 of its projects in 2009-10. Due to constraints imposed by Ministry of Natural Resources and Ministry of Environment, six Xeneca projects were allowed to proceed through Environmental Assessment. Two projects have been given conditional EA approval and four remain in draft approval stage. In all cases, Xeneca applied for EA approval of operating facilities to address the province's ongoing need for storage/dispatchable power.

For the following reasons waterpower is, and should remain, part of Ontario's Pathway to Decarbonization Plan. Moreover, IESO and the Ontario Ministry of Energy should invest in localized waterpower generation by incentivizing the development of new waterpower assets in the Province of Ontario:

-- Waterpower is longest lived form of generation with reliable operational lifespans that can exceed 100 years. As such, investment in waterpower can be much more flexible with amortization that provides a healthy, short term Return on Investment (ROI) leading to a much longer subsequent term of lower cost of energy. Alternatively, projects can be amortized for much longer periods than other forms of generation such as nuclear, wind, solar, biomass or natural gas, spreading costs out over decades with a predictable, stabilizing effect on electricity rates.

-- Once constructed, waterpower is virtually emission free. Additionally, properly constructed, waterpower requires less maintenance and equipment replacement than all other forms of generation further reducing the carbon footprint.

-- Waterpower has further environmental benefits including service as water control facilities, reducing effects of flooding and related erosion, property damage, infrastructure protection, etc.

-- Localized generation such as waterpower reduces the need for long distance transmission. Given that much of Northern Ontario remains constrained by lack of transmission capacity with the south and Ontario's Critical Minerals Strategy will drive increasing demand for energy in the North, Xeneca's waterpower projects continue to make good environmental and economic sense.

-- Societally, Xeneca's First Nations engagement resulted in the first multi community agreement through which First Nations saw long term economic benefits leading to ownership of heritage assets. This type of agreement can be replicated in a manner that supports reconciliation and brings lasting benefit to both Indigenous and non indigenous communities, businesses and industry.

As part of its Pathway to Decarbonization Plan, Ontario can, and should, incentivize waterpower as part of its Long Term Procurement (2027 and beyond). With environmental assessments completed or in late draft stages, Xeneca can move quickly to construct assets in a manner that supports key provincial environmental and economic objectives.

With look forward to working with the IESO and the Province of Ontario on its long-term procurement of energy and are pleased to submit comments and provide consultative input.