June 17, 2011
Ontario Power Authority
IPSP Consultation
120 Adelaide St. W., Ste 1600
Toronto, Ontario M5H 1T1
Re: Submission on Planning and Consultation Document.
To whom it may concern,
I am writing to you to provide my comments on the IPSP Planning and Consultation Document
I general I note that the OPA is largely proposing to follow the same approach to the development of the 2011 IPSP as it followed with the original 2007 Plan. Such approach seems likely to reproduce many of the problems that emerged with the original IPSP, particularly with respect to the consideration of environmental sustainability in the development of the plan, as documented in the attached paper authored by myself and colleagues at York University and the University of Waterloo, and published in the international journal Energy Policy August 2010. The OPA's approach is particularly surprising in light of the developments from 2006 onwards with respect to electricity demand in Ontario, the outcome of the province's new build nuclear procurement process, continuing serious questions about the capacity of either of the proponents in the 2009 procurement process to file viable new bids in the forseeable future, the Fukishima nuclear disaster, continuing delays and cost-overruns involving current nuclear refurbishment projects in Ontario, the response to the Green Energy and Green Economy Act and changes in the North American natural gas supply and market. Indeed, these developments indicate that fundamental assumptions that underlay the 2007 IPSP were flawed, and that a different approach to electricity system planning in Ontario was required.
I am particularly concerned regarding the reliablity of the demand forecasts to be incorporated into the second IPSP. My understanding is that the medium demand forecast on which the plan is to be based reflects peak demand and annual consumption net of successful conservation efforts as per the province's conservation targets as expressed in the February 2011 Supply Mix Directive. However, in reviewing recent and historical patterns of electricity demand in Ontario, the projections would seem more reasonable estimates of potential demand before the impact of conservation is taken into account. Many of the points on this matter raised by the Pembina Institute in its 2006 submission on the IPSP demand forecast seem to me to remain relevant today. I therefore attach that document, for which I was the primary author, to this submission (http://pubs.pembina.org/reports/Com_OPA_IPSP_DP2_Load.pdf)
A plan based on these forecasts, if net of conservation, would suggest that either:
1) The plan will result in a massive overbuild of supply if the province's conservation efforts are successful; or
2) The plan is assuming that the conservation will in fact, largely be unsuccessful and that a realistic demand scenario will have to be meet through supply-side options.
The demand forecast on which the 2011 IPSP is to be based should be reviewed in light of these considerations and a more realistic forecast employed as the basis for the plan.
Yours sincerely,
Mark S. Winfield, Ph.D.
Assistant Professor
Coordinator Joint MES/JD Program
Chair, Sustainable Energy Initiative
Faculty of Environmental Studies
York University
4700 Keele St.
Toronto, Ontario
M3J 1P3
Tel: 416-736-2100 ext. 21078
Fax: 416-736-5679