Submissions

The PWU is an engaged stakeholder in Ontario’s Electricity Sector and participates fully in all of the industries formal processes.

Submission on the IESO’s Northwest IRRP April 2022 Update

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 […]

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Submission on the IESO’s Clean Energy Credit Registry

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 […]

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Submission to the IESO on the LT RFP

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 […]

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Submission on the IESO’s 2022 Annual Acquisition Report

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 […]

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PWU Submission on Canada’s Clean Electricity Standard Discussion Paper

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 […]

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Extending Atikokan Operations Report

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 […]

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PWU Submission to the Ministry of Energy on its TOU rate consultation

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 […]

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Submission to the IESO on the Clean Energy Credits Registry

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. […]

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Submission to the IESO on the Pathways to Decarbonization Study

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 […]

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Submission on the IESO’s Long Term (LT) Request for Proposals (RFP)

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 […]

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Feedback to Ontario Government 2022 Budget Consultation

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 […]

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ECCC 2030 Emission Reduction Plan

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 […]

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IESO Resource Adequacy November Engagement

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 […]

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IESO Resource Adequacy October Engagement

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 […]

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Electrification Pathways Report

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

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Biomass and Forestry Action Plan

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 […]

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Federal Clean Fuel Standard

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 […]

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May Resource Adequacy Engagement

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 […]

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Gas Phase Out

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 […]

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Northwestern Integrated Regional Resource Plan (NW IRRP) Submission

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 […]

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Submission on IESO’s Resource Adequacy Engagement – April 2021

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 […]

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Submission to the IESO on Enabling Resources

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 […]

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Submission to the MENDM on Eliminating Renewable Energy Requirements

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 […]

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PWU to the Update to the Ministry of Transportation’s Statement of Environmental Values

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

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CNSC Submission to Renew the Darlington Site Preparation License – May 2021

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

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Submission on Ontario’s Long Term Energy Planning Framework

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 […]

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Submission on IESO’s Resource Adequacy Engagement – March 2021

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

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PWU Long Term Energy Plan 2017 Submission

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 […]

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Pre-Budget Submission, 2015

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

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