Ontario's new long-term energy plan may look like it is all about green power (it is called "Building Our Clean Energy Future", after all). It isn't. First and foremost, Ontario's energy plan commits Ontarians to building more nuclear power stations - no matter what the economic or environmental costs may be. The fierce commitment to nuclear power spelled out in the Minister of Energy's instructions to Ontario's power planning authority limits the ability of every other planner and regulator in the country to finish crafting what we really need: the best energy plan possible.
Read our submission here.
The Ontario government wants you to believe that its new energy plan - "Building Our Clean Energy Future" - is clean and forward-thinking. It isn't.
Despite its title, Ontario's energy plan is a nuclear power-focused, central-planning proposal that resembles the ideas of 1961 more closely than the ideas of 2011. There is very little clean or futuristic about Ontario's new energy plan.
On Friday, another stage in the energy planning process ended. The Minister of Energy's draft instructions to the Ontario Power Authority had been available for public comment. These instructions (the "Supply Mix Directive") will be polished by Cabinet and then sent to the Agency. The Agency will then create a more detailed power system plan and head to the Ontario Energy Board for approval.
The Ontario Power Authority is limited by the instructions it receives from the Minister of Energy. In this case, the Authority is supposed to create an energy plan that must (absolutely must, without a doubt must) assume nuclear power accounts for about half of Ontario's electricity generation. If there is a better (cheaper, cleaner, faster, less risky) way of meeting energy needs, the OPA cannnot pursue it. That's the plan.
Here at Lake Ontario Waterkeeper, we don't object to nuclear power on ideological grounds. Our problem is with fish kills, habitat destruction, thermal plumes, radioactive waste, hazardous waste, air pollution, wastewater pollution, threats to our drinking water supply, and enormous water takings. Every one of those environmental impacts comes with a nuclear power plant (the way we build them in Ontario, at any rate).
Direct environmental impacts are Waterkeeper's primary focus. Our experience working on energy issues has also taught us that nuclear power poses a major policy problem: it takes over the energy grid. Nuclear power plants cannot be scaled up or down on an hourly or daily basis to respond to actual electricity demand. They are on, or they are off ... for decades at a time. By investing $33-billion in nuclear power, Ontario's plan is akin to buying a whole bunch of hulking mainframe computers from the 1970s (think: big, clumsy, expensive, inflexible). A truly modern future could be flexible, decentralized, innovative, and iterative (think: micro-generation, co-generation, innovation, conservation).
Given the environmental impacts and the cost of nuclear power, it is wise to at least consider other ways to meet our energy needs.
Here are the concerns Waterkeeper filed with the Ontario government on Friday:
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.
The solution is so simple: give the Ontario Power Authority and other regulators the ability to look at alternatives to nuclear power. Set the 50% target as an ideal if you must, but do not make it a mandatory target. Let the best plan emerge.
For more detail regarding why the Directive must be amended, read our complete submission here.