Lake Ontario Waterkeeper is a registered charity, pursuing environmental justice in the Great Lakes Basin and protecting people's rights to safely swim, drink, and fish in public waterways. Since our launch in 2001, Lake Ontario Waterkeeper has investigated, documented, and monitored the impacts of power generation sources on our watershed. We have been active in the Integrated Power Supply Plan process from the outset, submitting comments in February of this year on the Supply Mix proposals made by the Ontario Power Authority ("OPA") to the Minister of Energy. Since then, we have participated as a funded agency in the stakeholder consultation process.
This submission summarizes our comments on the IPSP stakeholder consultation process and in particular on the OPA's Discussion Paper #7, â€œIntegrating the Elements â€“ A Preliminary Planâ€.
In our paper, Waterkeeper suggests that the creation of an IPSP as an opportunity to show world-class leadership. The province is no longer walking in the shadows of other jurisdictions, mimicking foreign practices or echoing others' rhetoric. It has an opportunity to take a new direction in energy conservation and sustainability by adopting a fresh approach to the challenge of electricity demand and supply.
At the same time, we argue that the Preliminary Plan utterly fails to successfully integrate sustainability-based principles. The OPA uses rhetoric to create the impression of a sustainable Plan, but the actual assumptions, methodologies, and information it relies upon on are fundamentally flawed.
Waterkeeper identifies three actions that will address Ontario's energy Plan flaws:
1. Start with sustainability 2. Do not ignore risks, consequences 3. Embrace flexibility, innovation
Ontario Hydro's legacy has been an approach to electricity system planning that matches supply to demand as its first priority. This model accepts long-term financial and environmental costs without questioning if alternatives are available. The consequences of this approach are apparent in the more than $20 billion of stranded debt that Ontario Hydro ran up, our dependence on a inflexible technology like nuclear power, and contaminated air, land and water.
The fundamental reason for breaking Ontario Hydro up was to get away from the "bigger is better" approach to planning and to introduce some market discipline to the electricity supply system. Ontario now has the opportunity now to develop a sustainable approach to electric power planning that can avoid many of the mistakes of the past forty years. But it will require more than just repackaging the power planning studies of that era. Real analysis of load trends with an emphasis on how those trends can be shaped to fit with a sustainable energy culture is the priority in electricity system planning. Matching supply and demand is a simple enough task for the marketplace to manage. Ensuring the Plan is sustainable and reflects long-term foresight is the value the OPA must add.
Click here to read our entire paper in .pdf.
Mark Mattson is an environmental lawyer with extensive relevant expertise, including numerous OEB hearings and CNSC interventions, participation in government advisory groups, and working on the Demand-Supply Plan hearing and constitutional challenge to the Nuclear Liability Act. Mark is also co-author of The Citizens Guide To Environmental Investigations and Private Prosecutions (2000) and a forthcoming citizen's guide to the Canadian Nuclear Safety Commission.
Peter Faye is a retired executive from the electricity distribution business. During his career as an engineer with Ontario Hydro he worked on generating stations, high voltage transmission lines and distribution systems. He subsequently worked for Markham Hydro and rose to the position of President from which he retired in 2001. Mr. Faye attended law school at the University of Toronto and was called to the Ontario Bar in 2005. He consults to the electricity industry on regulatory matters and assists Lake Ontario Waterkeeper with energy related projects.
Krystyn Tully is Vice President of Lake Ontario Waterkeeper, editor of Waterkeeper.ca Weekly, and administrator of LOW's Clean Water Workshop, a mentoring program that serves 25 law students each year. She has worked alongside Mark Mattson on interventions and environmental assessments since 2001. Krystyn is also the Lake Ontario Advisor to Great Lakes Aquatic Habitat Network & Fund.