Question 1: What are your…

On behalf of Canadians for Nuclear Energy, we thank the province for the opportunity to comment on these important topics, which fall within the scope of our research and advocacy. It is our hope to see smart energy policy guide Ontario to a bright future.

We offer responses to key questions posed during this public consultation:
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Question 1: What are your thoughts on the appropriate regulatory requirements to achieve accelerated infrastructure buildout? Do you have specific ideas on how to streamline these processes?

Response 1: The government of Ontario should work with the federal government to expedite site licensing. Namely, the Impact Assessment Act should have carve-outs for sites adjacent to existing facilities, such as the Bruce Nuclear Generating Station, to accelerate the deployment of new clean, firm sources of electricity on land that is already closely monitored and proven safe for the operation of facilities such as nuclear power stations. As it stands, the potential 10-year delay to the deployment of new nuclear power owing to the Impact Assessment Act amounts to clean energy obstructionism at a time when capacity shortfalls threaten Ontario’s ability to provide energy for businesses and residents.
At the same time, the government of Ontario should ensure it maintains current sites, recognizing that the development of new sites has been difficult for all types of generations. This entails the full refurbishment of existing sites.
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Question 2: What are your expectations for early engagement and public or Indigenous consultations regarding the planning and siting of new generation and storage facilities?

Response 2: The imperative of securing clean, stable energy from proven sources such as nuclear power, which has demonstrated its benefit to Ontario’s communities without posing environmental or health hazards, means that public and Indigenous consultation should be a priority, focusing on education, collaboration, and, crucially, opportunity-sharing.
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Question 3: Do you believe additional investment in clean energy resources should be made in the short term to reduce the energy production of natural gas plants, even if this will increase costs to the electricity system and ratepayers? What are your expectations for the total cost of energy to customers (i.e., electricity and other fuels) as a result of electrification and fuel switching?

Response 3: Investment in quick-to-build but intermittent energy, such as wind and solar after the Green Energy Act, drove prices skyward without proving their ability to significantly reduce the use of natural gas-fired generation in the province. This relationship has not been unique to Ontario. Prices soared in Germany and California when renewables were widely deployed. More recently, Alberta’s rates have leapt to the most expensive in Canada as the province adds renewables faster than the rest of the country combined. In fact, by necessitating fast-acting backup power, intermittent generators cement our reliance on relatively nimble gas plants. Only slower-to-build but steady power sources, like nuclear and hydropower, have proven their ability to permanently displace fossil fuels, such as coal. A short-term increase in the use of existing gas facilities provides the opportunity to temporarily bridge capacity shortfalls until the expedited licensing and construction of new nuclear facilities brings firm capacity online in the 2030s, without incurring long-lived extra costs.
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Question 4: Are you concerned with potential cost impacts associated with the [electricity infrastructure] investments needed? Do you have any specific ideas on how to reduce costs of new clean electricity infrastructure?

Response 4: To keep rates affordable, we should study what has worked. Nuclear facilities are highly scalable and provide some of the cheapest electricity in the province. They minimize rates by spreading costs over decades of operation, using cheap and energy-dense fuel, avoiding the need for transmission overbuilds as required for solar and wind, and avoiding the need to maintain a parallel generation system for backup power or battery storage. Because of the highly local supply chain, money that is spent on nuclear remains in the province, generating opportunity for communities in the form of high-quality jobs, local spending, and taxes.
In comparison, contractual allowances to wind and solar projects, such as first-to-grid rights, curtailment payments, and above-market rates cause prices to soar for little (and sometimes negative) value in return. Within less than a decade after the passage of the Green Energy Act, electricity rates for Ontario consumers had increased more than they did during the 30 years of the CANDU and hydropower buildout by Ontario Hydro, the products of which still provide over 80% of the province’s power.
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Question 5: Do you have any comments or concerns regarding the development and adoption of hydrogen or other low-carbon fuels for use in electricity generation? What are your thoughts on balancing the need for investments in these emerging technologies and potential cost increases for electricity consumers?

Response 5: Hydrogen shows promise for decarbonizing hard-to-electrify sectors. However, using it for electrical generation is inefficient, as it is an energy store akin to a battery, not a source. Building electricity generation for the express purpose of hydrogen production is likewise inefficient, and if the generation of choice is variable like wind, it can cause knock-on problems for grid operation as Ontario is already experiencing. Perhaps a more efficient solution would be to build hydrogen production as needed to manage surplus generation from the build-out of stable, low-carbon energy sources like nuclear.
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Question 6: Following the end of the current 2021-2024 energy efficiency framework how could energy efficiency programs be enhanced to help meet electricity system needs and how should this programming be targeted to better address changing system needs as Ontario’s demand forecast and electrification levels grow?

Response 6: Efficiency gains could save money by reducing the total investment needed in electricity generation. However, our choices of generation technologies affect the usefulness of efficiency gains. With heavy wind penetration, for instance, Ontario has needed to curtail or rapidly offload much electricity to neighboring grids to cope with sudden generation spikes. Such a system discourages efficiency, since during spikes it would be financially beneficial and environmentally neutral to use more electricity rather than less. An energy system based upon the steady output of nuclear plants, in contrast, encourages energy efficiency through deliberate generation, the ability to plan long-term offtake agreements with neighboring grids, and other measures to limit excess generation that signals to use more.
Efficiency programs should therefore expand their purview to incorporate energy generation technology choices as well, as part of systems-level planning.
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Question 7: What are your thoughts on the potential for development of new hydroelectric generation in Ontario by private-, Indigenous- and government-owned developers? While the capital costs for hydroelectric generation may be higher than nuclear, wind, solar, and natural gas, do you support investing in large scale hydroelectric assets that may operate for over a hundred years?

Response 7: Hydropower has desirable characteristics from an electricity generation standpoint, yet is highly disruptive to a vast land area while alternatives such as nuclear provide similar services on a much smaller land footprint. The James Bay Hydroelectric project, for instance, spans over 17,000 square kilometres yet produces less electricity each year than our CANDU nuclear plants, whose entire sector takes up fewer than 20 square kilometres.
Any new hydroelectric capacity should be owned and operated by the province (OPG) if possible, and those developments should take priority. This has the best economics and will have the lowest impact on rates. It also makes all taxpayers shareholders rather than just private parties, in contrast to the Green Energy Act and the problematic contracts that resulted. The province should partner with Indigenous groups if these developments are to take place on their land.
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Question 8: What steps should be taken to ensure that transmission corridors can be preserved and lines can be built as quickly and cost effectively as possible?
Response 8: The steps taken to ensure the building of adequate transmission capacity should first include an assessment of whether wind and solar are truly needed, given their track record of curtailment, offpeak supply surges, seasonal absence, and exorbitant costs in Ontario.
Leveraging existing transmission-connected sites such as Wesleyville, Nanticoke, Bruce, Pickering, and Darlington would minimize the need for transmission expansion and resulting rate hikes.
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Question 9: Do you have any additional feedback on the IESO’s “no-regret” recommendations?

Response 9: As an addendum, we submit our Canadians for Nuclear Energy report, “The Case for CANDU,” which argues for the construction of new CANDU reactors as a low-risk, high-benefit way to meet Ontario’s energy needs.