"Start with Sustainability" Waterkeeper advises Ontario's energy planners

The Ontario Power Authority's fall consultations wrapped up last week. In response to a series of reports on the future of Ontario's energy system, Lake Ontario Waterkeeper submitted a formal paper critiquing the government's efforts to integrate sustainability, flexibility, and social acceptance into its energy Plan.

In our report, Waterkeeper argues that Ontario's Preliminary Plan utterly fails to successfully integrate sustainability-based principles. The OPA uses rhetoric to create the impression of a sustainable Plan, but the actual assumptions, methodologies, and information it relies upon on are fundamentally flawed.

To address these flaws, Waterkeeper recommends that the next Plan should do the following:

1. Start with sustainability 2. Do not ignore risks, consequences 3. Embrace flexibility, innovation

A truly effective Plan would start with sustainability. It would gather, present, and analyze facts about the feasibility, reliability, flexibility, etc. of each and every possible technology. Unfortunately, the Plan does not do this.

As Jeffrey Simpson noted in the Globe and Mail last week, "Countries such as Canada are very good at creating growth. We are not very good at creating 'green growth'. We still think of growth first, then tack on green as an afterthought."

Similarly, an effective plan would frankly address both environmental risks and opportunity costs. It would also contain an honest assessment of Ontario's regulatory environment. Waterkeeper argues that the failure to integrate a frank consideration of the nature of energy regulation in Ontario is perhaps one of the greatest, most potentially devastating, flaws in the Preliminary Plan.

Finally, Waterkeeper expresses concern that the OPA's entire plan is based on estimates of future energy needs. We note that forecasting electricity demand accurately is problematic and that past attempts have proved to be wildly inaccurate. The best solution is a flexible system - and that is what the OPA is currently proposing.

Lake Ontario Waterkeeper sees the creation of an energy plan as an opportunity to show world-class leadership. The province is no longer walking in the shadows of other jurisdictions, mimicking foreign practices or echoing others' rhetoric. It has an opportunity to take a new direction in energy conservation and sustainability by adopting a fresh approach to the challenge of electricity demand and supply.

Click here to read our entire paper in .pdf format.