Dear Minister Smith, Thank…

Thank you for the 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, 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, the following 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.

Impact to Other Customers
The proposal does not contemplate the potential impact to other electricity consumers in
Ontario. There is a real risk that enabling corporate PPAs without the appropriate framework will
lead to increases in Global Adjustment (GA) charges that the remaining Class A and Class B
customers would need to bear should the proposal receive approval. For example, if existing
lower cost generation which has been paid for by Ontario ratepayers is transferred to corporate
PPAs, costs will increase for the remaining customers as they take a greater share of the GA
costs.

Recommendation: Include a separate mechanism to offset cost increases to ineligible
customers.

Resource Eligibility
To determine the potential impact to the system and ratepayers, it is important to determine
which types of clean technologies will be eligible under the amendment. The proposal may
include “wind, solar, small hydroelectric (i.e., less than 10 megawatts), biofuel and battery
storage”. 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.

Recommendation: Only new incremental generation should be eligible or existing
generation that was not awarded a contract through an IESO procurement.

The proposal would benefit from flexibility and optionality through a “hybrid” corporate PPA
structure to keep up with the pace and volume of the required supply build out for Ontario. This
would allow for new generation to be reimbursed partly through corporate PPAs and partly
through other mechanisms, such as the IESO capacity market or IESO contracts.

Recommendation: Eligible renewable generation be permitted to enter into a corporate
PPA and a separate revenue mechanism for the remaining capacity (IESO contract or
rate regulation).

Small nuclear provides 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 (ICI) due to it’s high capacity factor.

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

Community Engagement & Municipal Support
Community engagement and municipal support play pivotal roles in the energy transition,
fostering a collaborative approach that is essential for building a sustainable future. Engaging
local communities ensures that the diverse needs and perspectives of residents and indigenous
communities are considered, allowing for input and empowerment. The current Independent
Electricity System Operator (IESO) resource procurements require proponents to obtain a
Municipal Council Support Resolution if the proposed project is to be located on land under
municipal jurisdiction, and Indigenous Community Support Resolution if the proposed project is
to be located “on-reserve”.

Recommendation: Require Municipal Council Support Resolutions and Indigenous
Community Support Resolution for PPAs with new renewable generation facilities.

OPG looks forward to positive progress to advance this opportunity, as a key lever in the energy
transition. We will be reaching out to set-up a meeting to discuss the above recommendations at
a time that best suits your office.