CAC Feedback on Ontario Energy Decisions
Dear Premier Ford, Minister Rickford (Energy, Northern Development and Mines) and Minister Yurek (Environment, Conservation and Parks)
RE: Clean Air Council Feedback on Province of Ontario's Plan to Increase Natural Gas Use for Electricity Generation
About the Clean Air Council
The Clean Air Council (CAC) is a network of over 30 municipalities and health units from across the Greater Toronto, Hamilton and Southwestern Ontario Area who work collaboratively on the implementation of clean air and climate change mitigation and adaptation actions[i]. More information on the Clean Air Council is available here. CAC representatives are the municipal staff change agents within leading climate action municipalities and have been working for over 20 years to advance progress on clean air and climate change actions. This submission presents the consensus of feedback from the Clean Air Council to energy decisions occurring within the Province.
The Need for Ontario Climate Action and Leadership
The Province of Ontario's 2030 greenhouse gas targets as committed to in Ontario's Environment Plan are at risk with several of the energy decisions that are taking place at the provincial level.
Natural Gas Infrastructure Investments
These decisions include the expansion of the natural gas system into Ontario communities without transparency on how these decisions are being made and the cost benefit analysis that is informing these decisions. For example, the Clean Air Council has been unable to find any information on the criteria and analysis that is informing an evidenced-based approach to natural gas infrastructure expansion, such as:
- how much it costs per customer connection and the payback period for that infrastructure expansion; and
- what other options were considered in order to meet the customer's energy needs, including energy efficiency and renewable energy.
This lack of transparency is of concern as they directly affect Ontario's climate commitments and targets.
Natural Gas Electricity Generation and Phase Out of Natural Gas in Electricity Generation by 2030
In addition to the above issue, the Clean Air Council is also concerned about the implications of Ontario's decision to increase natural gas' contribution to Ontario's electricity production. Ontario phased out coal-powered electricity generation in order to address air pollution public health care costs[ii] and meet our 2020 GHG reduction target. Using natural gas for electricity generation will greatly undermine Ontario's ability to meet our 2030 GHG reduction targets and will greatly diminish the ability of Ontario municipalities to achieve their climate commitments and targets.
The Clean Air Council recommends the Province make a commitment to phase out natural gas electricity generation by 2030. This timeframe coincides with Ontario's 2030 GHG target date and approximately 90% of Ontario's contracted gas generation capacity will expire on or before 2030.
We understand that infrastructure investments in natural gas electricity generation have already been made. Natural gas, however, is not our only option in meeting Ontario's electricity needs in a cost-effective manner[iii]. There is the ability to work with Quebec to bring carbon free, low cost electricity to Ontarians. There may be concerns related to a reliance on another jurisdiction for our energy needs but it is also important to remember that our natural gas also comes from out of province and out of country (trade and tariff risks). It is also important to consider that Increased investment in natural gas generation may require pipeline construction to import fracked gas from the United States to meet electricity generation needs[iv].
The Need to Invest in Local Energy Solutions
Investing in nuclear and natural gas generation will increase electricity prices for Ontarians and undermine our competitiveness in the emerging distributed energy transformation[v]. The Clean Air Council network wants to work with the Province to ensure that Ontario is not only responding to our energy choices right now, but also advancing emerging energy systems that will enable our communities to be more resilient and competitive.
Planning our future energy systems while also optimizing our existing investments is certainly challenging. However, Ontario's investments in nuclear and natural gas energy solutions will undermine our ability to meet local energy needs with local solutions. We need to work together to better enable Ontario to meet our energy needs.
As such, the CAC would like to work with the province to develop an Energy Decision Making Matrix to help understand and compare potential options for meeting our energy needs. Some of the areas we would like to better understand include:
- Advancing deeper energy efficiency opportunities
- Traditional, decentralized and individual generation scenarios, and how they impact or support each other
- Identification of the various pros and cons, and costs and benefits associated with each of these scenarios, and the development of a transparent decision matrix to compare among them
- The application of different lenses to these decisions, including resilience, climate, traditional economic, social, market transformation, etc.
Climate Lens Application into Energy Decisions
The CAC recognizes that there are many policy goals and outcomes to be considered in provincial decision making. However, the Ontario Energy Board, Enbridge Gas, and the IESO do not have a mandate to consider climate in their decision making. Considering that Ontario has committed in its Environment Plan to a 30% GHG reduction based on a 2005 baseline, it is neglectful that the entities responsible for delivering Ontario's energy do not consider the climate impacts of their decisions.
Municipalities have been declaring climate emergencies and are working to apply a climate lens to their decision making. It would be logical for those entrenched in Ontario's energy system to also factor climate commitments and impacts into their decision making.
We look forward to hearing back on the above input and recommendations. The Clean Air Council is keen to develop a long-term collaborative process with the Province to better enable Ontario municipalities to act on climate change.
Through enhanced communication and alignment between provincial ministries and agencies and municipalities, we can create the livable, resilient and economically competitive communities Ontarians desire. Helping businesses, municipalities, and individuals transition to clean, lower-cost, energy-efficient solutions can make our province more competitive and healthier, create new jobs, increase our energy independence, and reduce carbon pollution all while reducing energy costs for Ontarians.
cc. all Provincial MPPs
[i] 1 CAC Municipal and Public Health Unit members include: Ajax, Aurora, Brampton, Burlington, Caledon, Clarington, Durham Region, Guelph, Halton Region, Halton Hills, Hamilton, King, Kingston, London, Markham, Mississauga, Newmarket, Northumberland County, Oakville, Oshawa, Peel Region, Pickering, Richmond Hill, Simcoe-Muskoka District Health Unit, Toronto, Vaughan, Region of Waterloo, Whitby, Windsor, York Region.
Municipal staff representatives on the Clean Air Council (CAC) were consulted in the preparation of this submission to reflect the feedback of member municipalities but direct endorsement of this submission by municipal councils was not sought due to time constraints. However, municipal council discussions and resolutions are being advanced.
[ii] A study by DSS Management Consultants Inc. and RWDI Air Inc. (2005), examined the total cost of electricity generation over four scenarios in Ontario. It found that the financial costs of Scenario 1 (status quo on coal fired electricity) represented a levelized cost1 of 3.7 ¢/kWh. However, this cost did not include external costs associated with health and environmental damages. When these costs were added in, the total cost of coal-fired generation rose to 16 ¢/kWh. In total, health and environmental costs accounted for 77% of the total cost of generation. The report found that pollution from coal-powered electricity generators caused damages of $3 billon/year, with 668 premature deaths, 928 hospital admissions, 1,100 emergency room visits and 333,600 minor illnesses.
[iii]
https://www.cleanairalliance.org/gas-phasehout/
[iv] Enbridge's application for this pipeline has been adjourned for a period of approx 6 months due to COVID and more information on the need for it.