Response to the Ontario Power Authority
Last week, Lake Ontario Waterkeeper highlighted a few of the "big picture" problems with the Ontario Power Authority's ("OPA") proposed electricity plan. We have since completed our official submission to the OPA. Here is a summary of our recommendations:
Recommendation #1: Update the energy plan's priorities to reflect the province's overall environmental objectives. Currently, the OPA plan seeks to replace coal-fired power plants for "environmental and health reasons." Yet it does not really seek to protect the environment or public health. If environmental justice requires the government to close Ontario's coal plants, then it also requires the government to eliminate all harmful emissions. Anything else would be two-tiered environmental protection, sacrificing the some Ontario communities for the benefit of others.
Recommendation #2: Finish researching the potentials of conservation and demand management before committing to new energy sources. Unfortunately, the OPA published its recommendation to the Minister of Energy before it had all the data it needed to predict exactly how much energy can be save by more efficient generation, transmission, and consumption. This means that we don't actually know yet how much more power Ontario needs, or where we are going to need it.
Recommendation #3: Prepare a legitimate and independent analysis of the environmental impacts of nuclear power. Waterkeeper highlights a number of very serious flaws in the environmental analysis contained in the OPA's report. The conclusions are largely unsubstantiated by the data. Since the report's conclusions are based in large part on the OPA's understanding of the environmental impacts of different energy technologies, it is extremely important that the OPA have access to real facts. Right now, the OPA report explicitly ignores the impacts of wastewater emissions, air emissions, and waste on land use, fisheries, and drinking water supplies.
Recommendation #4: Refine the official Integrated Power System Plan through a joint Ontario Energy Board - Environmental Review Tribunal hearing. In Waterkeeper's view, this is the most logical way to create an economically and environmentally sound energy program for Ontario. A joint hearing would provide expertise, experience, professionalism, and a level playing field.
Recommendation #5: Enshrine the goals of the energy policy in a compliance program that encourages all members of Ontario's energy sector to meet environmental standards and effectively penalizes those that do not. It's not enough to write a great energy plan, the Ontario government needs to make it work. A clear compliance program and continued public participation will help ensure that all electricity generation remain clean in the years to come.
Throughout this process, it is extremely important that the OPA recognize the spiraling impacts that electricity generation has on Ontario's economy and environment. The lifecycle of our energy program affects air and water quality, land use, and the economies of dozens of communities – not just those hosting power plants. Transportation – road, rail, and water – along with mining, refining, bundling, burning, and burying touches most Ontario residents in some way.
This is a turning point. Will we adopt a clean energy policy today? Or will we ask these residents to bear the costs – dirty air, polluted water, lost land – for generations to come? It is also an opportunity. Will we create a visionary energy policy and emerge as leader on the world stage?
To read our entire 7-page submission, please visit our web site: www.waterkeeper.ca