Thank you for the opportunity to provide written comments on Bill 276, Supporting Recovery and Competitiveness Act, 2021.
These comments are specifically focused on Schedule 5 of the Bill, which states:
Electricity Act, 1998
The Schedule repeals provisions of the Electricity Act, 1998 that require priority connection access to renewable energy generation facilities and the provision of information about a distribution system’s or transmission system’s ability to accommodate generation from a renewable energy generation facility. A related regulation making power is also repealed.
This section of the Bill leads Ontario in the wrong direction, and should be removed from the proposed Bill. Current provisions of the Electricity Act, 1998 should remain in effect.
Prioritizing full and rapid transition from fossil fuels to renewable energy is globally accepted by governments, scientists, economists, and citizens as the only way to limit catastrophic climate change due to global warming within the lifetimes of our children.
In 2018 this provincial government established a target of reducing GHG emissions by 30% below 2005 levels by 2030. It also acknowledges the positive impact of phasing out coal-fired power in Ontario between 2003 and 2014:
The elimination of coal stands as the single largest greenhouse gas (GHG) emissions reduction action on the continent and was primarily responsible for Ontario achieving its 2014 emissions reduction target of 6% below 1990 levels.
However, the provincial Auditor General reported in 2020:
Overall, our audit found that the province risks missing its 2030 emission-reduction target, in part because climate change and the reduction of greenhouse gas emissions is not yet a cross-government priority, even though there is a specific commitment in Preserving and Protecting our Environment for Future Generations: A Made-in-Ontario Environment Plan (Environment Plan) to make climate change a cross-government priority to meet the target.
Schedule 5 of Bill 276, together with ERO 019-3471, Eliminating Renewable Energy Requirements does not meet the government’s commitment to reduce emissions. Instead, it paves the way for a return to fossil fuel-powered electricity in Ontario. This is by design on the part of the provincial government. As the nuclear plants that currently power two-thirds of Ontario’s hydro requirements are refurbished, the government is looking elsewhere to cover that gap, and to prepare for the projected increase in demand over the next few decades.
But it does not make environmental or economic sense to erode the progress Ontario has made in greening its energy sources. Here are just a few examples:
In 2018-2019, $230 million was spent by the provincial government to cancel renewable energy contracts and more recently, almost $3 billion was spent to purchase gas power plants. This is at the cost of Ontario startups and industries who invested in innovation and technology that is recognized around the world but still needs support here at home. The direction set in Schedule 5 would continue this negative impact on local businesses. Investing in and giving priority to renewable energy-focused solutions made in Ontario and Canada would result in jobs, local tax revenue, and improved health and well-being for Ontarians.
The health impacts of air pollution are serious, both on the individuals and families affected and on our health system, which COVID-19 revealed clearly to be overtaxed. De-prioritizing green energy and moving instead to gas-powered plants will increase loss of life and quality of life, while costing more in terms of healthcare and absentee rates in schools and workplaces.
Lazard, in its annual report on the levelized cost of energy for 2020, shows that energy generated by renewable sources, particularly wind and solar, both of which are well-suited for Ontario, is more economical than conventional power sources. This report is considered a benchmark for governments, utilities and infrastructure investors around the world. If Ontario is serious about lowering and stabilizing energy rates, it is clear that we need to increase the use of renewables.
Serious commitment to reducing GHG emissions cannot be set aside for purposes of expediency. Recovery from the effects of COVID-19 is undoubtedly a priority for the government and people of Ontario, but that recovery cannot be separated from or achieved at the cost of a liveable future. Increased global temperatures are already impacting the health and safety of children and vulnerable populations through severe weather and intense heat events. Prioritizing renewable energy sources is a necessary step in making the transition to net-zero emissions happen as quickly as possible.
We want and demand a liveable future for our kids and future generations. Their health, and the health of the planet, can’t be set aside while leaders continue to make decisions that benefit corporations who hold power and influence. We expect our elected representatives to uphold the best interests of their electorate, particularly those who are most vulnerable and those who will face the consequences in the future of poor decisions made today.