Click here to read Lake Ontario Waterkeeper's official submission.
Lake Ontario Waterkeeper has submitted comments on the Draft Supply Mix Directive issued by the Ontario Ministry of Energy. The Directive instructs the Ontario Power Authority to plan for Ontario's power system for the next twenty years. Waterkeeper objects to the proposed Supply Mix Directive on the grounds that it is fundamentally and seriously flawed.
The draft Supply Mix Directive includes a major policy announcement: The OPA shall continue to plan for nuclear generation to account for approximately 50 per cent of total Ontario electricity generation. In other words, Ontario will invest in more nuclear power programs.
The decision to maintain the proportion of nuclear energy in Ontario’s supply mix was made without public notice, transparency, or evidence. Such an important policy decision must be open to debate, scrutiny, and refinement. It is the most important issue in energy planning. No other energy technology requires as much capital investment, has such a lengthy planning window, has as much potential for environmental impact, or affects the energy system as dramatically as a nuclear power plant.
The directive restricts the OPA’s planning ability. The draft Directive does not provide the OPA with the authority to create a flexible energy plan, one that is capable of serving the province even if a nuclear new build cannot go forward. This is a very serious - insurmountable - planning problem.
The Supply Mix Directive states that the IPSP shall include the refurbishment of both the Bruce Nuclear Generating Station and the Darlington Nuclear Generating Station as well as the construction of two new reactors at the Darlington site. These proposed projects, two refurbishments and one new build, have not been licensed. No environmental assessments have been completed to determine whether the projects should take place. They have not been subject to any public scrutiny. They have not been evaluated by an independent decision-maker on the basis of evidence.
The draft Directive interferes with the decision-making expertise and authority of other provincial and federal officials. If the Supply Mix Directive sets nuclear power at 50% of Ontario’s energy plan, what validity or purpose will the subsequent hearing before the Ontario Energy Board hold? Or any environmental assessment or licensing processes? The Minister’s Directive pre-judges the outcome of a wide variety of decision-making processes that are outside of the Ministry’s, and in many cases, the province’s jurisdiction.
The decision to commit Ontario to 50% nuclear power for the next 60 years is too important to be made without considering or testing its foundation. Ontario has not conducted an assessment to determine whether nuclear development is a choice or a necessity. Neither has any evidence-based, transparent consideration been given to the problems associated with nuclear, including: Long-term Waste, Cost, International Safety and Security, Inflexibility, Undermining Energy Efficiency, Pollution, and Habitat Destruction.
Lake Ontario Waterkeeper has additional concerns related to the Supply Mix Directive. We believe that detailed submissions, however, are meaningless in light of the Directive’s primary flaw: the commitment to an energy system based on 50% nuclear power.
A meaningful consideration of the energy future that is possible in Ontario has been scoped out before it could begin.
For 50 years, Ontario has experienced the negative consequences of nuclear power, as costs mount and waste piles up in our communities. The Supply Mix Directive will lock us in to a nuclear future for the next 60 years. The issues associated with committing to long-term nuclear energy in Ontario are complex and the consequences will be wide-ranging, with impacts on everything from air and water quality to energy bills and terrorism. These decisions are far too important to be made without a factual or evidentiary basis and without involving the public that will ultimately face the costs incurred.
For more detail regarding why the Directive must be amended, read our complete submission here.
The Ontario Ministry of Energy and Infrastructure [MEI] released its “Long-Term Energy Plan” [LTEP] on Tuesday, November 23, 2010. A draft “Supply Mix Directive” was loaded to the Environmental Registry on the same day.
The LTEP and new Directive replaces the Supply Mix Directive that was first issued by the MEI on June 13, 2006, then updated by then-Minister Smitherman on September 17, 2008. Like the previous Supply Mix Directives, this latest plan serves as a directive to the Ontario Power Authority [OPA] to create an Integrated Power System Plan [IPSP].
If the Supply Mix Directive is finalized, the OPA will develop a new IPSP, potentially by mid-2011. There will then be a hearing before the OEB (expected 2011-2012) to consider the details of the plan.