Submissions

PWU Submission to the Ministry of Energy and Electrification Integrated Energy Resource Plan Consultation (ERO 019-9285), December 2024. The Ministry of Energy and Electrification is seeking feedback on the development of an Integrated Energy Resource Plan to achieve the objectives in its recently released vision paper, “Ontario’s Affordable Energy Future: The Pressing Case for More […]

In January 2024, the IESO released its 2024 Annual Planning Outlook (APO) and provided an overview for stakeholders on April 23, 2024. The PWU remains concerned that IESO’s approach does not adequately inform stakeholders about our province’s energy needs and fails to mitigate affordability and reliability risks. The PWU has initiated a series of discussion […]

The Ontario Energy Board (OEB) prepared a proposed amendment to the DSC to enable electricity flexible hosting capacity arrangements when distributed energy resources (DERs) in aggregate could exceed feeder and/or substation capacity. The PWU agrees in principle with the intent to optimize the capacity available on the distribution system. However, the PWU recommends conducting a […]

The IESO has initiated is LT2 RFP engagement. The PWU finds IESO’s procurement approach is overly complex and replete with planning and analysis deficiencies that underpin unmitigated reliability and affordability risks. The PWU recommends that the IESO expeditiously focus on: comprehensive specification of system needs; understanding the possible solutions; better accommodating long-lead time generation development; […]

Natural Resources Canada (NRCan) is seeking input on barriers to and solutions for achieving Canada’s net zero goals for the electricity sector in order to inform the Canada Electricity Advisory Council (CEAC). The PWU has assembled its previous Federal submissions and recommends the government should: build a national energy vision to align provincial, territorial and […]

On December 13, 2023, the IESO provided an overview of its Preliminary 2023 Annual Planning Outlook (APO) forecasts in support of its Dec 11 procurement options report to government. The PWU remains concerned that IESO’s approach does not adequately inform stakeholders about our province’s energy needs and fails to mitigate affordability and reliability risks. The […]

The Ministry of Energy is seeking feedback regarding the Treatment of Corporate Power Purchase Agreements within the structure of the Industrial Conservation Initiative (ICI) rate program for large energy consumers. The Ministry is seeking to use the mechanism to provide system benefits, enhance Ontario’s industrial competitiveness, and promote new clean generation such as solar and […]

The IESO introduced its approach to the Evolution of Annual Planning Outlook (APO) and Annual Acquisition Report (AAR) and acknowledged that policy urgency is accelerating with the Ministry’s release of the Powering Ontario’s Growth (POG) report (which relied heavily on the IESO’s Pathways to Decarbonization study (P2D)). The IESO has recognized the need to better […]

Environment and Climate Change Canada (ECCC) proposed the draft Clean Electricity Regulation (CER) that significantly reduces the ability to use gas-fired generation after 2035. The proposed CER reflects many of the inputs the PWU has provided. However, the proposed CER many risk areas that make it impossible for the CER to achieve its objectives anywhere […]

The IESO presented its findings of the recent scoping assessment for the GTA North (York Region) and recommended that they undertake a new Integrated Regional Resource Planning (IRRP) activity. The PWU applauds the IESO’s consideration of the new demand identified in the provinces recent Powering Ontario’s Growth Report and the government’s directive to ensure a […]

The federal government is seeking feedback on the design of a number of clean energy related refundable Investment Tax Credit (ITC) that were proposed and or refined in the 2023 Budget. The PWU is pleased that the federal government is responding to the U.S. direction in its Inflation Reduction Act and has acted on many […]

The Ministry of Energy (MoE) is seeking feedback regarding the priority of three Critical Transmission Infrastructure projects in Northeast and Eastern Ontario. The PWU recognizes the urgency of these projects and supports the Ministry’s prioritization of these three transmission projects by Hydro One in order to accelerate the development. However, the PWU also recommends that […]

The IESO provided an update on the bulk system planning and study for the Central-West area to ensure continued, reliable supply to the London area in light of the recently announced Volkswagen EV plant. The Central West Area encompasses the Bruce and Niagara Peninsula and all areas to Windsor. The IESO sought feedback on bulk […]

PWU Submission on IESO York Region NWA Demonstration Project EPRI Study, Aug 17, 2023 The IESO is seeking feedback on the draft Electricity Research Power Institute (EPRI) Distributed Energy Resources (DER) Scenarios and Modelling Study findings prepared for the IESO’s York Region Non-Wires Alternative (NWA) demonstration project. In response to questions posed by the IESO, […]

The Ministry of Energy (MoE) is seeking feedback on the IESO’s Pathways to Decarbonization Study (P2D) report and, in particular, the IESO’s “no-regret” recommendations. This submission draws upon previous PWU advice to the government, the OEB and the IESO. There is evident urgency to resolving Ontario’s energy planning framework and initiating the siting and procurement […]

The Ontario Energy Board (OEB) has been asked to provide the Minister of Energy with advice on the role of the OEB affordable, reliable, and sustainable energy system for Ontarians. The PWU supports the Government’s Direction to the OEB as they reflect the PWU’s previous recommendations to the Ministry for Energy. The urgency to make […]

Natural Resources Canada (NRCan) is seeking input on the regulatory and market barrier implications of accelerating the pace of electrification and electricity grid modernization to meet Canada’s net zero goals. The PWU believes that NRCan’s underlying premise is flawed. The real barrier is the timely creation of new low-carbon baseload generation. The existing regulatory framework […]

The IESO held a webinar on February 23, 2023, discussing the approach for the development of the 2023 Annual Acquisition Report (AAR) and asked for feedback on the risks presented and the potential approach to renewing existing assets to help address those risks. The PWU is concerned that the IESO will not be considering the […]

Submission to the Electrification and Energy Transition Panel re: IESO Pathways to Decarbonization, January 2023 The IESO has recently released its Annual Planning Outlook (APO) and Pathways to Decarbonization study. These new IESO documents underscore an urgent lingering risk to Ontario’s system reliability that must be addressed as the IESO continues to under-estimate Ontario’s electricity […]

Power Workers’ Union Supplementary Submission on OEB’s Framework for Energy Innovation (FEI) Working Group (WG) Benefit Cost Analysis (BCA) Framework, Dec 2022. The completion of Ontario Energy Board’s (OEB) efforts to advance the Framework for Energy Innovation (FEI) as it relates to Distributed Energy Resources (DERs) has resulted in the FEI Working Group (FEIWG) delivering […]

At the jointly sponsored November 23, 2022 webinar, the IESO and OEB proposed to cooperatively examine the roles of pricing, programs, and procurement (3 P’s) in optimizing DER adoption. The PWU supports their objectives to produce more economically efficient outcomes and ensure incentives do not work at cross purposes. The IESO has asked for feedback […]

Environment and Climate Change Canada (ECCC) sought comments on a draft Federal Sustainable Development Strategy (FSDS) regarding the Government of Canada’s sustainable development goals and targets and implementation strategies including for its net zero carbon emission vision for 2050. The PWU response identifies that the FSDS did not present a strategy to achieve national goals […]

The IESO provided an update on the bulk system planning for the Northeast region and sought feedback on bulk system planning scope, regional needs, and the potential solutions. The IESO described the insufficient capabilities of the transmission system and identified transmission options including a potential Tx line from Timmins to Wawa. The PWU supports investments […]

Environment and Climate Change Canada (ECCC) sought comments on proposed frame for the Clean Electricity Regulation (CER) that outlines a balanced phased approach to a net zero emissions electricity system by 2050 by targeting the emissions performance of electricity generating facilities. The proposed CER frame reflects many of the inputs the PWU provided on the […]

The IESO provided an update to Integrated Regional Resource Plan (IRRP) for the Northwest region and sought feedback on how it has considered local reliability concerns, growth scenarios and local supply options. The PWU remains concerned that the Atikokan Generating Station (AGS) continues to be excluded from the IESO’s assumptions for the development of the […]

In response to a Ministry of Energy request, the IESO has outlined an approach and options for a voluntary Clean Energy Credits (CECs) registry based on the Environmental Attributes (EAs) of electricity generation (i.e. emissions properties). Mostly due to internal IESO concerns, the IESO presented no viable options for fully achieving the government’s objectives to […]

The IESO continues to engage on the design of the LT RFP to secure new capacity. Based on the recent 2022 Annual Acquisition Report (AAR), the LT RFP is now seeking 5500 to 6500 MW of new generation, an increase from the 1000 MW targeted as recently as March 2022. However, the PWU is concerned […]

The IESO recently released its 2022 Annual Acquisition Report (AAR) that now addresses the urgent generation challenge that the PWU has been identifying for the last two years and includes multiple procurement options to address both the near term and medium-term procurement needs as the Pickering Nuclear Generation Station retires. However, the PWU is concerned […]

Environment and Climate Change Canada (ECCC) sought comments on a Clean Electricity Standard (CES) discussion paper regarding a net-zero emissions electricity system by 2035 and the prevention of using carbon-emitting electricity generating sources to meet demand growth. The PWU response identifies that a net zero goal by 2035 is impossible for Ontario, but such a […]

The analysis, “Extending Atikokan Biomass Generating Station (AGS) Operations: A Need and Benefits Impact Assessment”, prepared by Strategic Policy Economics, recommends that Ontario take immediate steps to extend and enhance the operations of the station. The assessment established a clear need for additional, low-carbon electricity to meet the growing demands in the Northwest over the […]

The Ministry of Energy sought input on new time-of use (TOU) electricity rate to encourage residential and small business consumers to shift electricity use, including electric vehicle (EV) charging, to low demand periods, prepare the electricity system for electrification of the economy and support decarbonization of the electricity system. The PWU provided several recommendations including […]

Submission on the IESO’s Clean Energy Credits Registry Design The IESO has been recently asked by the Ministry of Energy to develop a voluntary Clean Energy Credits (CECs) registry to help decarbonize Ontario’s electricity system; flow CECs proceeds to ratepayers, and to help businesses leverage the province’s clean energy advantage to attract jobs and investment. […]

Submission on the IESO’s Pathways to Decarbonization Study Assumptions The IESO has recently undertaken a study on the electrification implications of achieving net zero emissions for Ontario. This pathways to decarbonization study will for the first time in 7 years result in an IESO forecast that will portray how much new electricity this province requires […]

The IESO recently presented its preliminary design for the LT RFP. The PWU supports effort to competitively acquire the resources that Ontario needs and recognizes the IESO’s urgent need to acquire the resources to replace Pickering. However, the PWU does not believe that the approach being taken for the LT RFP will be successful in […]

The PWU built on its 2021 submission to the Ministry of Energy, Northern Development and Mines long term energy consultation last April and described how the identified risks to Ontario’s electricity system are increasingly jeopardizing Ontario’s climate objectives and the reliability of the electricity system in the province. The PWU made two budget recommendations government […]

Environment and Climate Change Canada (ECCC) requested inputs in support of its 2030 Emission Reduction Plan. In order to double to triple the low-carbon electricity required to achieve Canada’s Net-Zero 2050 goals, the PWU recommended development of a national energy vision, rapidly develop domestic nuclear, hydrogen, and renewable biomass capabilities, develop a fair transition process […]

The IESO updated it approach to the Long-Term (LT) RFP for securing adequate resources for Ontario’s electricity system, reflecting some of the PWU inputs. The PWU identified that critical areas in the current design remain unaddressed and the IESO has now been provided with new direction from the Ministry of Energy to explore phasing-out of […]

The IESO’s approach to securing adequate resources for Ontario’s electricity system includes a Long-term RFP/RFQ process. The PWU identified that the proposed design will not result is a competitive procurement that acquires the resources required. The PWU recommend that the IESO allow for more development time and longer contact life, increase the target capacity of […]

A new report by Strategic Policy Economics (Strapolec) shows that Ontario faces an electricity supply shortage and reliability risks in the next four to eight years and will not meet net zero objectives without building new low-emission, nuclear generation starting as soon as possible.   Download the report here

Ontario is developing a Biomass and Forestry Action Plan to sustainably grow the sector and create jobs for local communities in the north. The PWU recommends that the Atikokan GS be included in the plan as a possible accelerator of the action plan’s goals. The importance to the area of the biomass fueled Atikokan GS […]

The federal Clean Fuel Standard (CFS) is an important element of Canada’s climate plan, particularly for the electrification and decarbonization of the transportation sector. The CFS provides incentives to switch away from liquid carbon-intensive fuels (e.g. oil). The PWU provided inputs for the CFS to properly emphasize the value of domestic clean electricity in EV […]

IESO is developing an information guide to clarify to stakeholders how IESO is approaching Ontario’s future electricity supply.  The PWU identified the need for clarity on how baseload and daily demand supply will be procured including timelines and the principles for decision making and setting of capacity targets. The PWU emphasized that the current approach […]

As many municipalities press to phase out gas-fired generation in Ontario, the IESO is evaluating the implications of options to do so. The PWU recommended that IESO focus on emission reduction not the gas plants themselves, consider electricity demand growth from decarbonizing the economy, incorporate the full carbon price on gas-fired generation, and enable low […]

The IESO has initiated development of the NW IRRP and is seeking inputs to help build a forecast for the region’s needs. The PWU recommended that IESO factor in electrification due to climate action as laid out by the Thunder Bay Net Zero Strategy and recognize the important role of the emission benefits and critical […]

With Pickering Nuclear ceasing operations in 2025 and new procurement mechanisms to rely on 3-year procurement contracts, Ontario risks being left without long-term, cost-effective, viable supply solutions. In this submission, the PWU recommends IESO advance long-term competitive mechanisms to better leverage existing resources while seeking new resources and meet both the urgent mid-term capacity shortfall […]

The IESO is exploring the expanded participation of various resources in the IESO markets as potential sources of additional capacity to help meet the looming capacity gap in 2026, left by the closure of the Pickering Nuclear Station. The PWU recommends that the IESO first clearly define these needs, fully explore the capabilities of Atikokan […]

Years after the Ontario government officially ended the Green Economy Act and the associated prioritization of renewable energy projects, legislation and regulations continue to enforce these outdated policy positions. In this submission, the PWU supports repealing several such biases of the Electricity Act, 1998 and the OEB Act, 1998 to bring clarity to Ontario’s electricity […]

The PWU supports a sustainable, environmentally-responsible transportation sector that includes addressing climate change as a priority. We are encouraged by the Ministry’s shared vision and support the Ministry’s initiative to update their Statement of Environmental Values (SEV). Download PDF

Supporting the CNSC recommendation to extend the Power Reactor Site Preparation License for the Darlington New Nuclear Project. A renewed license will permit OPG to continue the process of planning and development of new nuclear generation at the Darlington site. View PDF

Ontario’s commitment to replace Pickering with renewed natural gas-fired generation contracts is increasing emissions and putting the reliability of the electricity system at risk. In this submission to the government’s energy planning reform consultation, the PWU recommends placing environment, jobs, and energy security at the top of the procurement agenda, and seriously considering how new […]

With Pickering Nuclear ceasing operations in 2025 and new procurement mechanisms not being ready until that year, Ontario risks being left without cost-effective, viable supply solutions. In this submission, the PWU recommends IESO accelerate the procurement timeline for new low-emitting resources, and seek solutions to broader system needs beyond capacity alone. View PDF

The Power Workers’ Union (“PWU”) represents a large portion of the employees working in Ontario’s electricity industry. The PWU is committed to participating in public consultations to contribute to the development of energy policy that ensures a robust and sustainable electricity system and competitively priced electricity for Ontario consumers, and to ensure transparency and stakeholder […]

2015 Pre-Budget Submission to the Standing Committee on Finance and Economic Affairs, Legislative Assembly of Ontario   View as PDF