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March 19, 2015

Hon. Glen Murray, Ontario Minister of Environment and Climate Change

Dear Sir:
I have received and reviewed a document titled Ontario's Climate Change Discussion Paper 2015.

I regret to advise you that the authors of this document have no concept of the extent of the climate change problem facing Ontario and the world and the measures that are necessary to overcome this problem. To get a better understanding of the extent of this problem I refer you to:

The Ontario Climate Change Discussion Paper 2015 totally fails to address the fundamental problem, which is not conservation of energy. The fundamental problem is the industrial and societal changes that are necessary so that fossil carbon remains in the ground.

In this respect there are two areas where your government could and should act immediately.

1) The first area involves no expenditure of tax payer money but offers Ontario as much as $2 billion per year in increased electricity revenue and offers Ontario residents/industries as much as another $ 2 billion per year in annual fossil fuel cost saving.

Under the current electricity pricing regime for a substantial fraction of most days and each year Ontario constrains non-fossil electricity generation for voltage regulation and reserve purposes. The amount of that non-fossil energy constraint is of the order of 40 TWH per year. Ontario gets zero revenue from this constrained non-fossil power and sometimes has to pay other jurisdictions to accept it.

The solution to this problem is simple. To reduce generation constraint the IESO (Independent Electricity System Operator) should control a portion of the electricity load via the internet. Ontario should offer an optional interruptible electricity rate to those that can usefully use interruptible power. This rate, including all charges, would have to be less than $.05 per kWh. The purchasers of interruptible power would include owners of buildings that presently heat with oil or propane, refiners that hydrogenate heavy liquid hydrocarbons and producers of bio-methanol. The bio-carbon efficient production of bio-methanol is discussed at:

These parties can use low cost electricity to produce electrolytic hydrogen that is then immediately consumed in a chemical process so that there is no hydrogen storage or transportation problem. The issue is that interruptible electricity must be priced at a level which makes the resulting electrolytic hydrogen cost competitive with hydrogen obtained from natural gas. The metering methodology for interruptible electricity is discussed at:

In simple terms, for industrial purposes off-peak interruptible electricity must be offered without a global adjustment price component. Interruptible residential rates must look like >50 kW commercial rates. It may require acts of the legislature to achieve these two objectives. Currently all such industries have been driven out of Ontario by high off-peak electricity rates. Currently home heating with liquid fossil fuels costs about $.12 / kWh.

2) The second area involves a substantial financial commitment, which ideally should in part be borne by the federal government, but absent a change in federal policy Ontario may have to go it alone. Ontario is currently negotiating a ~$100 billion refurbishment of the Bruce nuclear generating station. Absent a change in policy that refurbishment will involve 1970 level CANDU technology.

After that ~ $100 billion is spent a further ~ $50 billion will be required for disposal of the resulting high, medium and low level nuclear waste. In order to fully displace fossil carbon over the next 60 years the installed reactor capacity in Ontario must be increased about 7 fold. That expansion is simply not economically, environmentally or fuel supply sustainable with CANDU technology.

The near term first step to solving these problems is the PARC (Pickering Advanced Recycle Complex) proposal which is set out at:

However, the PARC proposal must be immediately followed by a commitment to a prototype modular liquid sodium cooled fast neutron power reactor. It would be financial folly for Ontario to delay that commitment because absent a prototype power reactor to resolve engineering details there would be a repeat of the Darlington folly in which Ontario Hydro went ahead with simultaneous construction of four power reactors of an unproven design. That folly cost Ontario taxpayers/ratepayers over $3 billion 1990 dollars in loan interest while engineering details related to the new reactor design were sorted out.

Liquid sodium cooled fast neutron reactors have the following distinct advantages:
1) They are about 100 fold more efficient than CANDU reactors in usage of natural uranium;
2) They are about 1000 fold better than a CANDU reactor in terms of decay time required for nuclear waste disposal;
3) They are more thermally efficient than a CANDU reactor in electricity generation;
4) They lend themselves to natural draft cooling tower heat removal which reduces their impact on marine life as compared to a CANDU reactor;
5) They can track rapid changes in the grid electricity load which removes the present requirement for natural gas generation or steam turbine bypass for electricity load following;
6) They can be engineered to have much longer working lives and much less decommissioning waste than CANDU reactors;
7) They would place Ontario in a leadership position in the North American nuclear power industry;
Various aspects of liquid sodium cooled fast neutron reactors are discussed in detail in the nuclear section of:
An issue to which planners must pay attention is the net plutonium breeding rate.

In summary your government's present response to the Environment and Climate Change problems that Ontario faces is entirely inadequate.

I encourage you to seek advice from the engineering community via OSPE (Ontario Society of Professional Engineers). OSPE/PEO members are responsible for most of the energy infrastructure design in Ontario. The ongoing $60 billion dollar wind turbine fiasco in Ontario and the present $2 billion dollar smart metering fiasco are direct results of the McGuinty government ignoring informed advice from OSPE members. Please do not repeat these mistakes.

Please confirm receipt of this email by return email.


Charles Rhodes, P. Eng., Ph. D.
Xylene Power Ltd.
Telephone: 905 473 1704

This web page last updated March 19, 2015

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