The Context for Action

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In December 2009, the ECO released its second annual review of the progress made by the Ontario government in achieving its GHG emission reduction targets. Click here for more information on this report, including videos and communications materials.

Climate and Environment

Since the Intergovernmental Panel on Climate Change (IPCC) released its Fourth Assessment Report in 2007, a significant body of new peer-reviewed scientific research has been published that suggests that the IPCC may have underestimated the potential severity of future climate change impacts. In particular, recent data indicates that global ice cover is melting more quickly than predicted, which will contribute to acceleration in rising sea levels. Northern permafrost, which contains vast quantities of carbon dioxide and methane (a potent GHG), is thawing more quickly than previously projected and releasing these gases into the atmosphere. Finally, carbon dioxide is absorbed by oceans. As the gas dissolves, it forms carbonic acid which increases the acidity of ocean waters. Ocean acidification poses a significant threat to the world’s coral reefs, shellfish and marine ecosystems. With increasing amounts of carbon being released, each of these processes will occur at a more rapid rate.

As acknowledged within the CCAP Annual Report, recent findings are now leading towards a global scientific consensus that more than 2°C of average global warming above pre-industrial levels would constitute a dangerous level of climate change. In order to have a chance of remaining below this threshold, the IPCC has indicated that industrialized countries need to reduce their combined emissions of GHGs to 25-40 per cent below 1990 levels by 2020 and by 80-95 per cent by 2050. While the Action Plan target for 2050 is in line with that of the IPCC, the ECO believes that a target more than 40 years into the future cannot really serve as a catalyst for transformational change.

The transformational change must begin now and, within a decade or so, we must be much further along the path towards dramatic reductions. As indicated by the IPCC, this means that by 2020 the minimum reductions required would need to be 25 per cent, with more aggressive targets in the range of 40 per cent. Accordingly, the ECO questions the government’s use of the term ‘aggressive’ to describe Ontario’s current short- and medium-term targets (6 per cent below 1990 by 2014 and 15 per cent below 1990 by 2020) and is concerned that the targets set by the government might become viewed as maximums that need to be achieved, rather than what they should actually be considered – bare minimums. The ECO urges the government to carefully re-assess its targets in light of current scientific evidence.

Along with substantially reducing GHG emissions, there is an urgent need to focus on adaptation measures. Even if we were able to stop all emissions tomorrow, some climate change impacts will still occur. It is important, therefore, to adapt now to limit both future damage, as well as the long-term costs of responding to climate-related impacts that are predicted to grow in number and intensity in the years to come.

Electricity Planning

There is considerable uncertainty surrounding electricity policy planning in Ontario. In June 2006, the then Minister of Energy directed the Ontario Power Authority (OPA) to prepare an Integrated Power System Plan (IPSP). This Directive contained various goals that would have a direct bearing on GHG emissions in the province, depending upon future projections regarding the fuel mix. In particular, the goal for peak demand reduction from conservation measures was 6,300 megawatts (MW) by 2025. Interim measures were to reduce projected peak demand by 1,350 MW by 2010, with an additional 3,600 MW by 2025.

The Directive also called for the expanded use of renewable energies and for an increase in the total capacity of renewable energy sources to 15,700 MW by 2025. In the interim, the IPSP was to result in an increase in the installed capacity of new renewable energy sources by 2,700 MW by 2010, compared with a 2003 baseline. Unlike the Directive regarding conservation targets, the IPSP did not strive to exceed the targets for renewable resources on the grounds that incremental renewable resources would “be large wind projects…[that] would not be cost effective when compared to the supply resources included in the Plan that would be displaced…”.

A continuation of nuclear generation was also anticipated, as the Directive called upon the OPA to plan for nuclear capacity to meet base-load requirements but to limit the installed in-service capacity of nuclear to 14,000 MW. The plan was to “maintain the ability to use natural gas capacity at peak times and pursue applications that allow high efficiency and high value use of the fuel.”

In response, in August 2007 the OPA filed an application for approval for its proposed 20-year electricity plan, for the period 2008 to 2027, with the Ontario Energy Board (OEB). Within the IPSP, two options were presented, each of which assumed nuclear power, and an increased reliance on natural gas, would be part of the future electricity mix.

In September 2008, the Minister of Energy and Infrastructure directed the OPA to “revisit” its plan in light of changed circumstances. In particular, this September Directive requested that OPA enhance the contributions to be made by renewable energy, conservation and distributed energy. The OPA was directed to provide an amended and revised IPSP which, it was expected, would be submitted to the OEB by March 2009. On March 12, 2009, the OPA indicated to the OEB that, in part because of the introduction of the Green Energy and Green Economy Act (GEGEA), it would require more time to respond to the September Directive.

In a further development, in June 2009 the government suspended a nuclear procurement process for two replacement reactors at the Darlington Nuclear Generating Station. While indicating a continuing commitment to modernize Ontario’s nuclear fleet and, therefore, retain nuclear as a key component of its generation mix, the government determined that only one of the three bids, from Atomic Energy of Canada Limited (AECL), met the terms and objectives outlined by the government. Concerns regarding the quoted price, combined with uncertainty surrounding the future of AECL, led to the suspension.

A recent market assessment report has forecasted the OPA’s IPSP near-term capacity expansion requirements at just over 10,000 MW between 2008 and 2016. The government originally assumed that just over one-quarter of this new capacity would come from natural gas; the emissions of which the ECO is assuming have been factored into its GHG forecasting. However, based on the nuclear cost issues noted above, there is a distinct possibility that only a portion of new nuclear capacity planned will ever be built. The report cautioned that two-thirds of this capacity expansion will likely need to be met by natural gas. The Ontario government should confirm that this much higher natural gas contribution scenario has been factored into Ontario’s future GHG emissions forecasting.

Along with these developments, the government is proceeding with its planned phase-out of coal-fired electricity generation by 2014. Pursuant to Ontario Regulation 496/07 – Cessation of Coal Use, made under the Environmental Protection Act, none of the four remaining coal-fired generating stations (Atikokan, Lambton, Nanticoke and Thunder Bay) are permitted to burn coal after December 31, 2014. In September 2009, the government announced that two of eight units at Nanticoke and two of four units at Lambton would be closed by October 2010. In phasing out the use of coal, Ontario Power Generation (OPG) is now testing the use of biomass (such as wood pellets and agricultural by-products) as a new renewable energy source and is targeting 2012 as the year it will begin using biomass as a replacement fuel in its former coal facilities.

Given each of these major changes in the Ontario electricity system, including the introduction of the game-changing GEGEA, it appears that the IPSP that was submitted in August 2007 is no longer current as a key document guiding electricity policy planning in Ontario. With the uncertain future that now surrounds new nuclear procurement, and the phase-out of coal, a stronger emphasis on conservation and demand management, along with renewables, will likely be necessary than was contained in the original IPSP. The GEGEA creates the necessary conditions to increase conservation measures and expand renewable energy in the province, and it is likely that the current targets contained within the IPSP are significant underestimates. A recent survey by the OPA, for example, indicated a near-term potential of 15,128 MW of renewable energy potential, including 13,382 MW of wind and 1,213 MW of solar photovoltaic.

To date, no further clarity has been provided by the government or the OPA as to what the actual path forward will be with regard to electricity planning in the province. Given that much of the government’s climate change plans are premised upon activities in the electricity sector and, in particular, coal phase-out, the ECO is concerned about the uncertainty and risk factors that currently exist in this area.



Citing This Article:
Environmental Commissioner of Ontario. 2009. Annual Greenhouse Gas Progress Report 2008/2009: Finding a Vision for Change. Toronto, ON : Environmental Commissioner of Ontario. pp. 9-12

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