Thank you for the additional…

Thank you for the additional opportunity to provide feedback to the Environmental Registry of
Ontario’s (ERO) proposed amendments related to the treatment of corporate power purchase
agreements (PPA).

As Ontario’s largest clean energy generator with one of the world’s most diverse and clean
electricity portfolios, Ontario Power Generation (OPG) is an innovative leader in the
development of emerging technologies of advanced nuclear, hydrogen, and energy storage.
Our vision is to always improve, add new voices, and find newer, better ways of generating
clean power that move us closer to realizing our vision for an electrified Ontario. OPG creates
clean, reliable, safe, and low-cost power as the core of our business and the future of our
economy.

While OPG understands the need to accelerate the growth of new clean electricity generation in
the province by allowing for corporate PPAs, we had provided recommendations in the last PPA
ERO posting that included impacts to customers, resource eligibility and community
engagement & municipal support. These previous recommendations to the proposed
regulatory changes would support the build out of new clean electricity, minimize the risks to
electricity consumers and ensure municipal support for new projects.

I would like to focus on resource eligibility, as it’s important to determine which types of clean
technologies will be eligible under the amendment. The proposal may include “wind, solar,
hydroelectric and biofuel”. However, it is not clear whether this includes only new incremental
generation or if existing generation with expiring contracts will be eligible. Allowing existing
generation to participate could result in higher GA costs for Class A and B customers by shifting
lower cost expiring contracts to PPAs. Additionally, allowing existing generation to participate
does not support the growth of new clean generation in the province.

Small modular reactors (SMRs) provide new, non-emitting, reliable electricity at scale that could
offer significant benefit for proponents in offsetting their facility’s demand in the top five peak
hours under the Industrial Conservation Initiative due to it’s high-capacity factor. Several large
customers have shown interest to OPG in exploring a corporate PPA for SMRs.

Recommendation: Extend eligible technology to all non-emitting generation, this would
include small modular reactors (SMRs) and micro modular reactors (MMRs).

OPG looks forward to positive progress to advance this opportunity, as a key lever in the energy
transition.