SPEA has commented on previous LTEPs and energy issues in Ontario and internationally.  We have authored a number of opinion pieces in major newspapers and published scores of letters in major newspapers on energy related matters.  Our members are engineers and scientists and technicians and technologists of almost every possible discipline and consequently have a broad range of expertise in energy and other technology fields.




SPEA commends the Ministry for developing a comprehensive Energy plan as opposed to just an electricity plan.  This was one of our criticisms of the 2013 LTEP.

Ontario has made great strides in creating one of the cleanest electricity generating systems on the planet.  For example, greenhouse gas emissions per unit of electricity generated are ten times lower in Ontario than in Germany, which has invested heavily in renewables and is widely seen as the industry leader on clean electricity.  Because of Ontario’s Climate Change Mitigation and Low-Carbon Economy Act, of 2016, base load demand will increase because fuel switching (to cleaner electricity) will become necessary to help meet the ambitious emission reduction targets.  Nuclear power is best suited to supply these increasing base load demands. 

Ontario’s CANDU reactors were designed and built in Ontario.  We have a healthy supply chain and manufacturing industry that provides engineering support, products, and services for reactors in Canada and around the world because the technology has been exported to other countries.  This adds approximately six billion dollars annually to Ontario’s economy and has great potential to contribute substantially more.

Nuclear generation can be used for base load (no hourly fluctuation) and intermediate load (gradual fluctuation but not sudden changes) 

With rapid expansion of electric and hybrid electric vehicles, the off –peak demand for base load electricity from Nuclear power is expected to greatly increase

Timely provisions are needed to compensate the shutdown of the Pickering plant, scheduled for 2024, due to the long lead time needed for planning and construction of new electricity generation.

The CANDU reactor used in Canada and six other nations in the world is a 100% Canadian achievement.  It can generate electricity from natural uranium or even spent fuel from other reactor types without the need for uranium enrichment.

Delaying a decision on new nuclear generation means, by default, that natural gas generation will be the choice because it can be deployed more rapidly.  However, this comes with a significant environmental cost.

The use of different units, depending on whether the subject is electricity generation or fuel consumption, makes it very difficult to compare the sources of energy.  Consistent use of the unit TWh would be more convenient for readers. 

There are a number of discrepancies between data provided in the LTEP Discussion Guide and what is available from the IESO regarding electricity generating capacity and electricity generation.  The discrepancies are substantial in the case of energy generated using wind, solar and biofuel – the LTEP Discussion Guide values are 50% higher than the IESO’s. 


The Planning Process

SPEA commends the OPA for producing an “energy plan”, as opposed to just an “electricity plan”, as in previous versions of the LTEP.  One of our criticisms of the 2013 LTEP was that a long term energy plan should be a holistic one if the objective of the government is to have clean, sustainable and cost-effective energy and to reduce pollution and greenhouse gas emissions. We argued further that not only should the Ministry of Energy be involved but also the ministries of Transportation, Research, Innovation and Science and the Ministry of Health, since the choices made will all have an impact on health. Ontario’s electricity generating system is now one of the cleanest in North America from a greenhouse gas (GHG) emissions point of view.  The single biggest contributors to Ontario’s GHG emissions are the transportation and home heating sectors. 

Whether energy is in the form of electricity, gasoline, or biofuel, it is all energy.  Hence, SPEA would suggest the use of consistent units in the LTEP.  Electricity generation is presented in units of terawatt hours (TWh) whereas fuel consumption is presented as petajoules (PJ).  These are both units of energy; hence we would suggest that for ease of comparison, and to give readers a better idea of the scope of the issue, that either PJ or TWh be used but not both.  The electricity industry is familiar with TWh and suggest that the section in the LTEP Discussion Guide on use of fuels be revised, such that total fuel energy consumption be presented as TWh (2700 PJ = 750 TWh). 

It is not clear if the value of 2700 PJ includes electricity generation or not.  Figure 5 in the LTEP discussion document, which shows the demand forecast for fuels, shows the 2015 demand as approximately 2320 PJ (644 TWh).  However, the figure states that this does not include electricity generation or non-energy use of fossil fuels.  It appears reasonable to assume that the value of 2700 PJ (750 TWh) does not include electricity generated by nuclear, hydro or other renewables.  Electricity generation, therefore, is approximately 17 % of total energy consumption in Ontario.  It would be useful to explain this fact somewhere in the discussion paper to give a clear indication of the relative size of the electricity generation industry.  This is particularly relevant because fuel switching is mentioned in the document as a way to reduce greenhouse gas (GHG) emissions in the future.

Errors and/or Discrepancies

SPEA would like to note that there are many discrepancies between data provided in the LTEP Discussion Guide and data provided by the IESO regarding both electrical generating capacity and electrical generation in Ontario. The following are examples:

Near the bottom of page 8 of the Discussion Guide, it states that Ontario generated 160 TWh of electricity in 2015.  This is an exaggeration.  According to the IESO1, the figure is only 153.7 TWh.

Near the bottom of page 9 of the Discussion Guide, it states “Since the 2013 LTEP, the share of wind, solar and bioenergy capacity in our supply mix has grown from 9% to over 18%.”  This is incorrect.  According to the IESO2, the combined installed capacity of wind, solar and biofuel is 13%.  

At the bottom of page 9 of the Discussion Guide it states that the installed capacity of wind power in Ontario as of June, 2016, is 4500 MW.  This is an exaggeration.  The IESO Supply Mix document states that wind power capacity as of September, 2016, is only 3923 MW. 

The data in Figure 1 of the LTEP Discussion Guide is largely inconsistent with the IESO’s Supply Overview data.  Specifically, hydro output in the LTEP is given as 37.3 TWh versus 36.3 TWh (IESO), gas output is listed as 15.9 TWh (LTEP) versus 15.4 (IESO) and combined wind, solar and bioenergy is listed as 14.2 TWh (LTEP) versus 9.7 TWh (IESO).  The latter comparison is the most egregious discrepancy.


1 This is according to the IESO Supply Overview Document, and arrived at by summing the data in the table titled “Energy Output By Fuel Type – Yearly” (See http://www.ieso.ca/Pages/Power-Data/Supply.aspx ) 

2 IESO Supply Mix Document (http://www.ieso.ca/Pages/Ontario%27s-Power-System/Supply-Mix/default.aspx)


The Nuclear Industry, Nuclear Power in Ontario and Greenhouse Gas Emissions

The LTEP discussion paper makes the point, when discussing renewable technologies, that “Ontario firms are now poised to challenge foreign competition and export their products and expertise just as other jurisdictions accelerate their efforts to procure clean energy technologies following the 2015 United Nations Climate Change Conference in Paris (COP21)”.

SPEA urges the Government and the Ministry not to forget that the nuclear industry in Canada, most of which is based in Ontario, has been doing exactly this for decades and continues to do so.  Indeed, a major spin off effect of having developed a nuclear industry in Canada, and in Ontario in particular, is that the supply chain is also well established in Ontario.  CANDU nuclear reactors, therefore, are one of very few high tech industrial products that are designed in Ontario.  By contrast, wind turbines are designed elsewhere and largely manufactured elsewhere.  Where they are manufactured in Ontario, it is often by foreign owned companies.  As a result, spare parts and design support will likely come from outside Ontario.

By contrast, almost all of the parts for our nuclear industry are made in Ontario.  There are approximately 40 CANDU nuclear reactors around the world, half of them in Ontario.  Their domestic

construction, maintenance and refurbishment has spawned an industry that generates more than six billion dollars annually for the province of Ontario and directly employs approximately 30,000 people.  Even when sales are made to foreign countries, most of the parts for the reactor are made in Ontario.  For example, when two CANDU reactors were built in China a decade ago, more than 80% of the parts were made in Ontario.  Indeed, a recent joint venture between SNC Lavalin/Candu Energy and Chinese partners have demonstrated the ability of CANDU reactors to re-use nuclear fuel for the purpose of generating electricity.  This appears almost certain to lead to many more sales in China and perhaps elsewhere in the world, which would be a tremendous boon to the Ontario economy. 

Nuclear power has played an evolving role in electricity generation in Ontario and presently, as the LTEP points out, the majority of power in Ontario is generated using nuclear power (about 58%).  As an aside, this figure also conflicts with the IESO Supply Overview Document which states that nuclear power’s share of generation is 60%.  This is a slight increase from 3 years ago, when 56.4% of the electricity was generated by nuclear power.  It is worth noting that, while nuclear power generates 58% of Ontario’s generation, it represents only 36% of installed capacity.  This illustrates the reliability and high capacity factors of nuclear power.  Nuclear power is currently generated at a unit price of under 7 cents/kWh; about half the price of wind or natural gas and 1/7th the price of solar.

It is largely because of nuclear power that the greenhouse gas footprint of the electricity generating system has decreased from over 300 g(CO2)/kWh to less than 50 g(CO2)/kWh since 2003.  The complete elimination of coal-fired generation in Ontario was made possible by increase production from nuclear generation.  This reduced emissions from the electricity generating sector by 30 million tonnes (a 4% reduction in Canada’s total greenhouse gas emissions from all sources).   To put this in perspective, the greenhouse gas emissions from all of Ontario’s automobiles are approximately 35 million tonnes.  Removing 30 million tonnes from the electricity generating system is almost equivalent to taking all of Ontario’s cars off the road. 

SPEA believes that Ontario does not get enough recognition for this achievement.  The country of Germany, by reputation at least, leads the world in advanced power generation and deployment of renewable energy.  Indeed, many anti-nuclear groups have argued that Ontario should follow the lead of countries like Germany and shut down our nuclear plants, replacing them with intermittent renewable energy.  However, the reality is that Germany still generates more than half of its electricity by burning fossil fuels and its electricity generating system has a GHG intensity 10 times as high as Ontario’s; closer to 500 g(CO2) per kWh.  But reality and perception are often different and this is one area where the divergence is huge.  Indeed, Germany’s fossil fired electricity backbone gives it the flexibility to deploy large quantities of renewable energy.

Is Nuclear Power Just a Baseload Generator?

Currently, nuclear power is used for baseload generation in Ontario.  Baseload power is defined as the minimum amount of power that you need at the lowest demand time of day, which is always in the middle of the night.

The output of Ontario’s nuclear plants is stable, irrespective of the time of day or weather conditions.  This is for a couple of reasons.  One is that nuclear plants operate best when run near full power.  The second is that most of the cost of electricity from nuclear power is tied to the capital cost of building the plant (the cost of fuel represents only about 5% of the cost of electricity).  Hence, once the plants are built the most cost effective way to operate nuclear plants is to run them as close to their maximum capacity as possible.  Since nuclear plants are also capable of running at close to 100% capacity factor, this is a good match.  

While nuclear plants are not used to follow the electricity load, they are capable of doing so to a limited extent.  Newer CANDU designs, for example, can be comfortably throttled back to 60% of full power if needed, without having to shut down.  In this respect, they are similar to single cycle gas turbines, which also perform best when operated close to full power.  However, it is more economical to operate gas fired plants at lower capacity, and use them for load following.  This is because their operating costs are high compared to nuclear plants because of the cost of fuel can represent as much as 75% of the cost of the electricity.  When the cost of the electricity that is generated is more a function of the fuel cost than the capital cost of the plant, as is the case for gas versus nuclear, then it is more economical to use the gas plant on an “as needed” basis.

In SPEA’s last LTEP submission in 2013 we made the point that while there appeared to be plenty of baseload power in Ontario at present, fuel switching, for things such as transportation, could change that picture. If 5% of Ontario’s automobiles were converted to electricity, 3 TWh more baseload electricity would be needed; approximately the annual output of a Pickering sized nuclear unit. The reason that this is “baseload” is because electric vehicles would mostly be charged in the middle of the night when electricity is cheapest.

The current LTEP Discussion Guide, makes the point that Ontario’s Climate Change Mitigation and Low-Carbon Economy Act of 2016, commits the province to some very challenging GHG reduction targets.  As a result, a substantial amount of fuel switching will be required; replacing fossil fuels with much cleaner electricity generation.

In 1990, Ontario’s GHG emissions were 182 MT of CO23.  Based on the data in figures 2, 3 and 4, SPEA estimates that Ontario’s GHG emissions in 2015 were 168 MT.  This represents an approximately 8% reduction compared to 1990.  The goal for 2020 from the Climate Change Mitigation and Low-Carbon Economy Act of 2016 is a 15% reduction from 1990 levels, a 37% reduction below 1990 levels by 2030 and an 80% reduction below 1990 levels by 2050. 

3 Source is “Environment and Climate Change Canada - Canadian Environmental Sustainability Indicators

Greenhouse Gas Emissions – see (https://www.ec.gc.ca/indicateurs-indicators/18F3BB9C-43A1-491E-9835-76C8DB9DDFA3/GHGEmissions_EN.pdf )

4 This is according to figure 3 in the LTEP Discussion Guide.

To meet the shortest term goal, for 2020, would require a further reduction of about 13 MT of CO2. Given the closure of Ontario’s coal fired generating stations has already occurred, this reduction cannot be found in the electricity generating sector, where the total emissions are now only about 7 MT4.  To

put this in perspective, if one were to attempt to reduce emissions from the transportation sector by 13 MT, it would require electrification of about one third of Ontario’s automobiles and the addition of about 3 Bruce sized nuclear units (or equivalent5).  Given the slow pace at which electrification is taking place, this is unlikely to happen by 2020.  Some combination of fuel efficiency, conservation, fuel switching and financial tools that are allowed by the cap and trade system will be needed to meet the 2020 goal.

5 Approximately 20 TWh of electricity would be required to electrify about 1/3rd of Ontario’s approximately 7 Million vehicles. This is approximately the output of 3 Bruce sized nuclear units or 5,000 X 1.5 MW wind turbines operating at 30% capacity factor.

A 37% reduction from 1990 levels, which is province’s goal for 2030, would require a reduction of approximately 53 MT of CO2 from 2015 levels.  This is a monumental reduction and is virtually impossible to achieve without substantial fuel switching as shown in Figure 4 of the discussion guide. This would require substantial new electricity generation.  The challenge for the government of Ontario is to decide what form this new generation will take.  To meet GHG emission targets, the electricity generation needs to be GHG emission free. Given that new hydro generation in Ontario is unlikely because of our geography, the only reliable form of GHG emission free generation is nuclear power. Wind and solar can help but, because their capacity factors are only approximately 25%, they require back-up generation by natural gas at present.  This makes fuel switching to wind and solar much less effective as a means to reduce GHG emissions. 

A newly-built base load nuclear plant also has the advantage that once built, the electricity that it produces is virtually inflation proof, because the cost of fuel has little impact on the price of electricity and it can be built such that electricity costs are competitive with other forms of generation regardless of technology.

Some have argued that the answer to our future emissions problems lies in electricity imports from Quebec. In reality, while imports may be helpful, it is unlikely to have a major impact without major new investment by the province of Quebec in new generation as well as major new investment by Ontario in transmission infrastructure.  

Meeting the GHG emission targets in Ontario’s Climate Change Mitigation and Low-Carbon Economy Act will also require fuel switching for home heating from fossil fuels to electricity.  Quebec actually has to import some electricity during cold spells in the winter because its supply is very seasonally dependent and home heating in Quebec is often supplied by electricity.  So, if Ontario needs electricity for heating, it will not be coming from Quebec unless they make major investments in hydro-electric generation.

The current seven year agreement with Quebec calls for exports to Ontario of 2 TWh per year.  If this displaces 2 TWh of gas fired generation, it could lead to a reduction of 1 MT of carbon emissions. However, there are many instances in the fall and spring in Ontario, where gas-fired generation is used because of contractual obligations while water is spilled from hydro-electric stations and steam is exhausted from nuclear stations rather than having those non-emitting generators make electricity. If

the imports from Quebec do not result in a reduction in gas-fired generation, it is unlikely that it will actually result in lower GHG emissions.

The Retirement of the Pickering Nuclear Units

Ontario Power Generation originally planned to retire the Pickering nuclear units in 2020 but there are now plans to extend the life of the station until 2024 to cover some of the generation shortfalls during Bruce and Darlington refurbishment.  This extension is a good thing because it will provide significant non-emitting power generation over this refurbishment period thus lowering greenhouse gas (GHG) emissions, generating up to $600 million in savings for electricity ratepayers, securing up to $1.3 billion annually in community benefits for Durham Region, and providing additional net income to OPG while Darlington units are offline.  

However, inevitably, the closure of Pickering will create a gap of 3,000 MW in Ontario’s baseload capacity.  If this power is not replaced by another non-emitting source then Ontario’s electricity sector emissions will rise again.  Unfortunately, there are no good alternatives.  For example, 3,000 MW of non-emitting power cannot be replaced by wind power because it is so intermittent and has large seasonal variability; being about 3 times as effective in the winter as it is in the summer in Ontario. Replacement of Pickering by wind-power means replacement by a mixture of wind and natural gas back-up power. If wind power has a capacity factor of approximately 25%, an additional 75% of that installed capacity will have to be generated by natural gas. This translates to approximately 10 MT of extra CO2 emissions annually that would come at a time when Ontario is looking to reduce its GHG emissions by 53 MT below today’s levels. 

It is difficult to imagine how GHG emissions can be kept in check unless Pickering is replaced with like technology.  If a decision is not made soon to replace the lost baseload from the closure of the Pickering units with new nuclear power, then the only available choice will be natural gas.  This will increase Ontario’s GHG emissions, decrease its air quality, and fail to meet any of the GHG emission targets in Ontario’s Climate Change Mitigation and Low-Carbon Economy Act.