1. Pathways severely…

1. Pathways severely underestimates the peak demand that would result from electrification of building heating, hence underestimates the extent and cost of new electrical infrastructure that would be required.

2. Combustion turbines fuelled by hydrogen are not a credible solution, especially to generate electricity for heating, which has much higher and longer duration peaks than apparently recognized by Pathways, hence would need even more combustion turbines and consume more hydrogen, which would be unnecessarily costly in view of an obvious alternative.

3. District heating could serve most of the heating load, thereby avoiding much of the proposed new electricity infrastructure and specifically the hydrogen fuelled combustion turbines.

4. More nuclear may be needed. It would be better to have more surplus power and a reliable supply than to continue producing greenhouse gases and/or compromise reliability, hoping in vain that hydrogen fuelled combustion turbines will prove viable.

5. District heating is another potential market for nuclear and bioenergy and would make them dispatchable through Combined Heat and Power (CHP). This would phase out gas plants, without hydrogen.

6. Two of the new uses of surplus power could be temporary deration of nuclear CHP while cogenerating heat and dispatchable or interruptible industrial heat pumps serving district heating through large scale thermal energy storage.

7. Ontario needs a thermal strategy (for heating and cooling) incorporating community energy plans into provincial plans. Without it, energy will become even more ruinously expensive than it needs to be, resulting in loss of competitiveness and great hardship, possibly a consumer revolt.