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Posted in: Ontario | Climate Change / Renewables

Apr 23, 2018

Environmental Commission of Ontario reports that LTEP Ignores Climate Law

By Zoë Thoms

The Ontario government’s 2017 Long-Term Energy Plan (LTEP) is not consistent with its obligations under climate change mitigation law, according to a progress report issued by the Environmental Commission of Ontario (ECO) on April 9, 2018. 

In Making Connections – Straight Talk About Electricity in Ontario (Vol 1), the ECO examines the impacts of Ontario’s low-carbon energy transition on the electricity system, electricity prices and the environment.1 The report also looks ahead to Ontario’s electricity future and the government’s 2017 LTEP, Delivering Fairness and Choice (described further here). The ECO concludes that the LTEP focuses on lowering near-term electricity prices while ignoring the transformation needed in the province’s energy sector to ensure that Ontario meets is GHG emissions reduction target enshrined in the Climate Change Mitigation and Low-carbon Economy Act, 2016 (the Climate Act).

The Climate Act requires Ontario to reduce GHG emissions from fossil fuels by 30% in 2030. The ECO argues that the government has failed to plan for the fact that electricity use may need to increase by up to 35% in order to replace fossil fuels at the pace needed to meet the GHG reduction target. The ECO developed a possible scenario to meet the 2030 GHG limit and compared it to the LTEP.

What this modelling exercise makes clear is that the 2017 LTEP does not plan for adequate levels of electrification:

  • the LTEP assumes 2.4 million electric vehicles using 8 TWh a year of electricity by 2035; the ECO’s potentially-compliant scenario assumes more than three times this level in 2030, and
  • while the LTEP mentions electric heat pumps, and their potential to reduce fossil fuel use for space and water heating, it does not plan for any related increase in electricity demand.2

Despite these concerns, the ECO’s report notes that overall, compared to the state of Ontario’s electricity system in 2005, “Ontario can be proud of its cleaner, more reliable electricity system” that was 96% carbon-emission free in 2017.3


1 The Environmental Bill of Rights Act (s. 58.1) requires the Environmental Commissioner to report annually on the progress of energy conservation activities in the province.

2 Making Connections – Straight Talk About Electricity in Ontario, 2018 Energy Conservation Progress Report, Volume One, Environmental Commission of Ontario, April 9, 2018 at  p. 238 (“Making Connections”).

3 Making Connections at pages 3 and 7.

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