oxide emissions by 90 percent or an additional 10 percent. Converting OPG’s existing coal-fired
stations to gas would cost approximately $5 billion. And although coal prices are expected to
remain stable well into the future since proven coal reserves are ample for several hundred
years, replacing coal by gas at current prices would cost an additional hundreds of millions of
dollars per year. The capital costs associated with replacing Ontario’s coal generation capability
with renewable technologies is equally formidable. Using the least expensive renewable genera-
tion, it would require about 6,000 one megawatt wind turbines operating at full capacity to
produce 25 percent of Ontario’s summer peak requirements. These 6,000 megawatts would
require capital investment of $1.5 million per megawatt, for a total cost of $9 billion. (29)
While several respondents suggest that the Ozone Annex holds great promise for addressing
the public health crisis of transboundary smog, it was generally suggested that the commit-
ments are largely unfulfilled as evidenced by the 27 smog emergency days that Toronto experi-
enced in summer of 2002. (17)
The Ontario Clean Air Alliance (OCAA) disagrees with statements in the Progress Report on
Ontario’s efforts to control nitrogen oxide emission’s from fossil fuel plants. They point out that
while the statement is made on page 10 of the Progress Report that “Canada will comply with
emissions cap in the Ontario portion of the
its commitment to achieve a 39 kt (kilotonnes) NO
Pollutant Emission Management Area (PEMA) by 2007 from fossil fuel-fired electricity genera-
tors with capacities larger than 25 megawatts” in fact, there are no Ontario or Canadian
emission caps which require southern Ontario’s power plants to achieve compliance with the
39 kt NO  Ozone Annex cap. The government of Ontario’s regulations measure NO  as NO.
The Ozone Annex cap of 39 kt NO  is equivalent to a NO cap of 25.49 kt. (8, 9)
The OCAA further commented that the Government of Ontario’s regulations which took effect
on January 1, 2002 cap the nitrogen oxides emission allowances of southern Ontario’s power
plants at 25.6 kt of NO or 39.168 kt of NO . Furthermore, Ontario’s emissions trading rules
permit the fossil plants’ NO  emissions to exceed this level if they buy emission reduction credits.
Thus, the regulations cap the total (allowances and emission reduction credits) nitrogen oxides
emissions of southern Ontario’s power plants at 34.048 kt of NO or 52.093 kt of NO , not
25.49 kt of NO or 39 kt of NO  as is required by the Ozone Annex. That is, the Ontario regula-
tions permit southern Ontario’s power plants to exceed the Ozone Annex’s cap by 33.6 percent.
A further concern is that the fossil plants can buy their emission reduction credits from compa-
nies that have not reduced their total emissions. It was noted that Canada’s Federal Minister of
the Environment has repeatedly requested the Government of Ontario to bring its nitrogen
oxides emission regulations for southern Ontario’s fossil power plants into compliance with the
Ozone Annex (letter of July 18, 2002, Anderson to Stockwell). The OCAA points out that,
unfortunately, the Government of Ontario has not responded positively to these requests. (8)
The Ontario Clean Air Alliance urged the IJC to recommend that the Government of Canada use
its authority under the Canadian Environmental Protection Act to establish regulations which will
cap the nitrogen oxides emissions of the southern Ontario power plants at 39 kt of NO  com-
mencing in 2007. Several respondents supported the position that the Government of Canada
exercise its authority to cap these nitrogen oxide emissions. (9, 10, 11, 12, 13, 14, 21, 24)