Executive Summary Comment for Submission Document on Wesleyville New Nuclear Project

Regulatory Gaps, Deficient Need Assessment, and Failure to Assess Reasonable Alternatives

Submitted by: Climate Action Newmarket–Aurora
Process: Impact Assessment Act – Initial Project Description (Wesleyville New Nuclear Project)
Proponent: Ontario Power Generation (OPG)

Executive Summary 

Climate Action Newmarket–Aurora (CANA) submits that the Initial Project Description (IPD) for the Wesleyville New Nuclear Project is yet to meet the evidentiary threshold required under the Impact Assessment Act (IAA) to justify proceeding toward a full impact assessment without substantial additional information.

International best practice, including guidance from the International Atomic Energy Agency (IAEA) and the UNECE Espoo Convention, requires that major nuclear proposals be evaluated in the context of reasonable alternatives, lifecycle impacts, and systemic risk. These requirements are not meaningfully satisfied in the current IPD.

The IPD frames new nuclear generation as a necessary and timely response to projected electricity demand growth in Ontario, arguably 11,200 - 46,000 mWh by 2050. However, it is yet to show a rigorous demonstration of need, is without a comparative assessment of reasonable alternatives, and is without transparent disclosure of long-term environmental, health, cost, mid-term energy security and governance implications. Moreover, the proposal doesn’t address the reduction in emissions in a detailed manner, which is the main goal of cleaner energy.   As a result, the project description reflects more of a policy preference rather than an unavoidable technical necessity.

Specifically, this submission finds that: 

- The need for new nuclear capacity at the proposed timeline is not demonstrated, given Ontario’s existing reserve margins, planned storage uptake and demand-response resources, and the rapid deployability of renewable alternatives. 

- Reasonable non-nuclear alternatives, including offshore wind, onshore wind, utility-scale solar, storage, and hybrid portfolios, are not rigorously assessed, despite their ability to deliver earlier emissions reductions at comparable or lower cost and risk. 

- Long-term radioactive waste obligations associated with new reactors are not resolved, particularly given the finite capacity and extended timelines of Canada’s proposed Deep Geological Repository. 

- System-wide concentration risk, ratepayer exposure, and intergenerational governance burdens are understated.

- While reducing emissions is implied as a rationale for expanding nuclear capacity in Ontario and Wesleyville is referenced within a “clean energy” context, the public proposal so far including the initial project description doesn’t yet contain specific quantified emissions reduction commitments for the Wesleyville plant itself. This should be apparent now rather than closer to construction. 

See attached document for greater detail and alternative considerations.