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CAE Alliance

We have listed a summary of our submission and also available a copy of the full submission (45 pages) for you viewing click below.
Listed is a copy of Thomas Hughes Consulting (Corunna) Ltd. submission to the EBR click below to view.  

THE CAE SUBMISSION TO THE EBR re: Coal Closure Regulation

Tom Hughes Submission to the EBR







The CAE (Clean, Affordable Energy) Alliance is a volunteer organization representing the interests of Ontario’s energy ratepayers.  Our members have followed the evolving energy policy and the significant changes that have taken place in the electricity sector over the past few years.  We have spent considerable time researching credible energy and environmental information.  The CAE has reviewed and responded to OPA reports and discussion papers; made submissions and presentations to the media, MPPs, the Minstry of Energy, Ministry of the Environment, and Legislative Committees.  We continue to participate in energy conferences and public forums.


The CAE Alliance asserts that:


1.  The proposed “Coal Closure Regulation” conflicts with, and therefore contravens existing legislation and regulations. Therefore, this Regulation cannot be implemented.


2.  There are too many contingencies and uncertainties in respect of electricity supply resources in the next decade.  Mandating a coal cessation date has real potential to impact electricity system reliability.


3. The stated reasons for this proposed Regulation do not acurately reflect the health and environmental impacts of coal-fired generation in Ontario.  Provincial and federal environmental information demonstrates that the coal-fired facilities do not pose the serious threat suggested by the "Purpose" for this proposed Regulation.  It is incumbent on the Ministry of the Environment to show evidence to justify the claims of the "Purpose" and "Regulatory Impact Statement" included in the Regulation Proposal Notice before the proposed Regulation can be implemented.


4.  The "cost of action" for this purported climate change iniative, will be more than the Ontario economy can bear.  As this has been included as a "Purpose" of the proposed Regulation, a full cost assessment of the coal closure, and all ramifications, must be completed.


5.  This proposed Regulation, if passed, will likely result in greater environmental and health damages.  A full environmental assessment must be completed with regard to all alternatives and replacement generation, before any such Regulation can be considered.


6.  This proposed Regulation will result in significantly higher use of natural gas, contrary to Minister of Energy Directives, and OPA recommendations.


7.  The coal closure timeline will be impacted by significant concerns related to supply and cost of natural gas -  the slated replacement for coal-fired power -  in the next decade.


8.  It is more beneficial, environmentally and economically, to retrofit all remaining coal fired units with the best available emissions reduction technology. 


The CAE Alliance therefore requests that the Proposed Coal Closure Regulation be rejected. Rather, we propose a Regulation under the Environmental Protection Act, calling for the installation of the best available emissions reduction technology, without further delay, on all remaining coal fired units in Ontario.

The Ontario government is proposing a Coal Closure Regulation which would legislate December 31, 2014 as the date by which coal fired generation in Ontario must cease.  To view the information posted on the Environmental Bill of Rights registry read below.  The public has until August 12, 2007 to provide comments and input. This is your opportunity to address this!   Please submit your comments. 



Regulation Proposal Notice:


EBR Registry Number:   010-0945

Title:   Coal Closure Regulation


Ministry: Ministry of the Environment
Date Proposal loaded to the Registry:
July 12, 2007

All comments on this proposal must be directed to:

David Argue, Senior Policy Advisor
Ministry of the Environment
Air Policy and Climate Change Branch
135 St. Clair Avenue West
Floor 4
Toronto Ontario
M4V 1P5
Phone: (416) 314-4908
Fax: (416) 314-4128

Comments can also be posted on the website:



Comment Period: 30 days: submissions may be made between July 12, 2007 and August 11, 2007.


Description of Regulation:

This proposed regulation under the Environmental Protection Act (EPA) will ensure that coal is not used to generate electricity at the Atikokan, Lambton, Nanticoke and Thunder Bay coal generating facilities after December 31, 2014. The proposed regulation is attached to this notice.

Purpose of Regulation:

Coal-fired electricity generating facilities are major sources of air pollution. Emissions include: oxides of nitrogen (NOx); sulphur oxides (SOx); particulate matter (PM); and a variety of toxic pollutants (e.g., mercury). These emissions are associated with major health impacts (e.g., premature death, increased hospital emissions for patients with asthma and chronic lung disease) as well as environmental impacts (e.g., buildings, crops and ecosystems).

Coal-fired electricity generating facilities are also major emitters of greenhouse gases (GHG) and therefore are contributors to global climate change.

In 2006, the "Stern Review on of the Economics of Climate Change" identified the global cost of climate change to be as high as 20% of global GDP. In the same report, the cost of action was found to be as low as 1% of global GDP.

Public Consultation:

This proposal has been posted for a 30 day public review and comment period starting July 12, 2007. If you have any questions, or would like to submit your comments, please do so by August 11, 2007 to the individual listed under "Contact". Additionally, you may submit your comments on-line.

All comments received prior to August 11, 2007 will be considered as part of the decision-making process by the Ministry of the Environment if they are submitted in writing or electronically using the form provided in this notice and reference EBR Registry number 010-0945.

Please Note: All comments and submissions received will become part of the public record. You will not receive a formal response to your comment, however, relevant comments received as part of the public participation process for this proposal will be considered by the decision under for this proposal.

Other Public Consultation Opportunities:

The public review period provided by this notice constitutes the major opportunity for formal consultation on the proposed regulation for the ending of coal use at generation facilities.

Regulatory Impact Statement:

Coal is the most significant source of criteria air contaminants, greenhouse gases and toxic emissions in the electricity sector. Removing coal as an electricity generation fuel will provide significant human health and wider environmental benefits.




Draft Regulation


made under the



Cessation of coal use at certain generating stations

1. (1) The owner and the operator of each of the following generating stations shall ensure that coal is not used to generate electricity at the generating station after December 31, 2014:

1. Atikokan Generating Station, located on Highway 622 in the Township of Atikokan.

2. Lambton Generating Station, located on St. Clair Parkway in the Township of St. Clair.

3. Nanticoke Generating Station, located on Regional Road 55 South in Haldimand County.

4. Thunder Bay Generating Station, located on 108th Avenue in the City of Thunder Bay.

(2) Subsection (1) applies in respect of each generating station named in that subsection even if the generating station’s name or ownership changes.


2. This Regulation comes into force on the day it is filed.