OFA provided comments on IESO’s (Independent Electricity System Operator) Pathways to Decarbonization Study presented to the Ministry of Energy. Decarbonization and electrification, according to the Pathways Study, will require a footprint of 2.2 million acres, about 14 times the size of the city of Toronto. OFA recommends the Ministry of Energy policymakers consider the impact of Pathway forecasts on the finite supply of farm land. As we replace our remaining fossil-fuelled generation with net zero generation, it is important to prioritize the reuse of existing sites, before considering the absorption of specialty crop and Canada Land Inventory Class 1 through 4 farm lands.
OFA recommends that decarbonization and electrification project approvals continue to require local government support resolutions, as is the case in IESO procurement of battery energy storage systems (BESS). We recommend the Ministry and IESO be explicit that local council support is needed for approval of proposed projects, separate from permitting and regulatory requirements.
Decarbonization and electrification project proponents should need to obtain energy, environmental and municipal approvals. OFA recommends that, as with transmission lines over 2 km in length and transformer stations over 115kv triggering EA requirements, stand-alone BESS, or BESS integrated with renewable generation, should also trigger EA requirements. This is in addition to Renewable Energy Approvals (REA) or Environmental Compliance Approval (ECA).
To address streamlining regulatory, approval and permitting processes, OFA recommends investigating how reuse of decommissioned assets and sites could be streamlined.
Related to the continued short-term investment in clean energy resources to offset natural gas plants, and the associated cost of energy to customers, OFA notes that Ontario’s Clean Energy Credit registry does not include fuel sources such as biogas and RNG as molecules. We recommend Ontario include these renewable fuels in any credit system as both combustible fuel and for electricity generation, and review the viability of supporting an RNG production credit to help commercialize RNG production from forest, agriculture and municipal biomass waste.
OFA supports IESO’s position that removing all natural gas generation by 2030, even without including other low-emission fueled capacity to provide system flexibility, is unacceptable to customers and tax payers. We recommend a careful timeline to meet provincial and federal emission targets that does not overburden customers.
Related to the transmission capacity needed to balance intermittent resources (solar, wind) and meet decentralized generation throughout the province, OFA recommends IESO take an aggressive approach to ensuring existing corridors, and commercial and industrial lands are used and repurposed, and are ranked as priority siting locations. Where possible, OFA recommends IESO and government encourage designs that locate generation in urban centres to reduce the need for extensive transmission corridor construction.
OFA recommends decision-makers take a practical approach to improving local and grid system level deficiencies when designing procurement requirements, including developing three-phase power, looping terminal lines to help mitigate stray voltage, brownouts, and voltage drops, and reducing downtime during outages.
Previous related OFA submissions: