Andrea Pastori Cabinet…

Andrea Pastori

Cabinet Liaison and Strategic Policy Coordinator

Ministry of Energy

Strategic, Network and Agency Policy Division

Strategic Policy and Analytics Branch

77 Grenville Street

Floor 6th

Toronto Ontario

M7A 2C1

Dear Ms. Pastori,

Following are comments from the David Suzuki Foundation with respect to EBR Registry number 012-8840.

Introduction

Our overall recommendation is that Ontario should use the LTEP to facilitate a transition to a society whose power, heating and transportation are supplied from 100 per cent renewable sources. We believe this is a necessity based on economic and environmental considerations.

The Economic Case for Renewable Energy

The cost of renewable energy is on a downward trajectory. In 2012, then-U.S. Energy Secretary Steven Chu told Scientific American, "Renewable energy is getting cheaper and cheaper. Perhaps within this decade, wind and solar will be as inexpensive as any form of new energy."

The International Energy Agency says that, in 2015, renewable power "expanded at its fastest-ever rate...thanks to supportive government policies and sharp cost reductions."

More recently, in August 2016, an article in Bloomberg New Energy Finance argued, "The rapid uptake of renewable generation in the power system [is] unstoppable now because of cost reductions in wind and solar..." Turning specifically to Ontario, we have seen solar costs — reflecting FIT prices and LRP bids — drop 66 per cent since 2009.

At the same time that the renewables' cost-curve has been trending downward, the curve for nuclear power has been trending upward. Ontario Power Generation recently sought permission from the Ontario Energy Board to raise nuclear base payment amounts by 11 per cent a year from 2017 to 2021. Nuclear costs will also be under pressure from expensive rebuilds and the unknown, but likely considerable, expense of decommissioning the reactors and keeping them isolated from humanity for the rest of time. Needless to say, the significant cost of managing radioactive waste is not something renewable projects face.

In sum, shifting to renewables is a necessity if we are to contain the costs that Ontarians pay for their power.

Expanding renewables can also lead to significant job growth. As Environmental Defence makes clear in a recent report, "continuing to develop increasingly low cost wind and solar energy post 2021 would not only keep the valuable supply chain the province has developed intact, it would also sustain the thousands of jobs in Ontario's renewable energy industry." It is crucial to remember that from 2008 to 2014, Ontario's solar and wind sectors saw the creation of some 180,000 direct and indirect jobs. A further roll-out of renewable power would enhance job creation even more.

The Environmental Case for Renewable Energy

The importance of tackling climate change cannot be overstated. Ontario is to be commended for its coal-power phase-out, one of the world's most important climate change mitigation actions. However, if we are to ensure a temperature rise of no more than 1.5 degrees C — as the science says we must — it is essential that Ontario fully decarbonize its electricity system. This means, to start, that we must phase out our natural-gas-fired power plants. Fortunately, we are now in a strong position to do this. Seventy-five per cent of our natural gas stations' contracts are set to expire by 2018. The province should simply refuse to renew them. Instead, it should ramp-up solar projects — which are ideal for replacing gas during the summer — and purchase additional hydro-power from Quebec. We were gratified to see that, in the October 21, 2016, statement on Ontario-Quebec electricity trade, the provinces wrote that Ontario will import "up to 2 terawatt hours annually of clean hydro power from Quebec at targeted times when natural gas would otherwise be used." This is a significant start and we would like to see much more of it.

We also believe that, to protect our climate, renewables must replace nuclear power. The process of uranium production — an essential component of the nuclear system — is carbon-intensive. Writing in Scientific American, Mark Jacobson and Mark Delucchi argue, "Nuclear power results in up to 25 times more carbon emissions than wind energy, when reactor construction and uranium refining and transport are considered." Renewables are a climate solution; nuclear is not.

Community Power

To build a 100 per cent renewable grid, the province needs to offer more support to community-based renewable initiatives. These projects — many owned by co-ops, First Nations, religious groups and farmers — have numerous benefits. First, they are popular with Ontarians. A recent poll from Ekos Research found that 78 per cent of respondents think it's important for the province to "increase community ownership of renewable energy projects." This is not a small consideration because if we are to build out renewables we need widespread citizen support; community-based projects build that support. Second, these projects are advantageous to the local economy. A June, 2016, report produced by TREC Renewable Energy Co-op compared the economic benefits of local solar projects with those from non-local commercial projects. Conclusion: If the project was locally owned and the solar panels and inverters locally manufactured, the economic impact was 77 per cent greater than if ownership and production were non-local. Overall, TREC estimates that "every dollar of the FIT rate spent on community energy results in more than $2 in additional economic activity."

Finally, community power is a good source of employment. The Institute for Local Self-Reliance says renewable projects that are community-owned usually generate twice as many jobs as projects that have a corporate owner.

Recommendations

In sum, the David Suzuki Foundation believes the Long-Term Energy Plan should:

1) Set out a clear trajectory to take the province to 100 per cent renewable power, transportation and heating by 2050 at the latest.

2) Replace costly nuclear reactors with affordable wind, solar and water power.

3) Keep in place the FIT program for community-owned renewable projects.

4) Create a new FIT for community-held wind projects.

5) Commit the province to providing loan guarantees for renewable energy co-ops and other community power organizations.

Thank you.

[Original Comment ID: 196190]