March 5, 2025 Policy…

March 5, 2025

Policy Coordination and Outreach Branch
Ministry of Energy and Electrification
77 Grenville Street, 5th floor
Toronto, ON
M7A 2C1

RE: Environmental Registry of Ontario ERO #025-0130

The Association of Major Power Consumers in Ontario (“AMPCO”) would like to thank the Ministry of Energy and Electrification (“Ministry”) for providing an opportunity for comment on the regulatory amendments to support OPG in retaining readiness to operate the Pickering “B” Nuclear Generating Station post-refurbishment

AMPCO is the voice of industrial power users in Ontario. Our objective is to advocate on behalf of our members for reliable power at a competitive price.

Our submission covers three basic points.
1) Cost prudency and transparency must be practiced throughout the development of this and all energy refurbishment and infrastructure projects.

2) What is being suggested in this ERO appears to be a departure from past practices that assets must be in service to attract earnings, and those costs remain in a deferral account. Given the challenging and uncertain competitive landscape Ontario industries are faced with, it should be understandable that our members are reluctant to support departures from past practices that could result in increased energy costs.

3) AMPCO urges Ontario to remain vigilant about the risks involved in large energy infrastructure projects. Should costs become unaffordable and unsupportable as the project planning develops, AMPCO strongly recommends that Ontario concurrently maximize opportunities to advance conceivably less costly and more certain generation infrastructure alternatives.

Submitted by
Brad Duguid
President, AMPCO
March 5, 2025