Instead, its simply a plan to replace aging reactors that will likely go out of service by the end of the decade.
But the Canadian Environmental Law Association argues that building new reactors is unethical because Canada still has no firm plan on how to deal with toxic nuclear waste.
The comments have been filed in closing submissions to a federal panel probing the environmental impact of the proposed new reactors.
The panel will file a report in August with the environment minister. Depending on the governments response, it can authorize Ontario Power Generation OPG to prepare the site for new units.
OPG still hasnt decided what kind of units it will build, nor is there a cost estimate for the multi-billion-dollar project.
The new units would supply 2,000 megawatts of generating capacity. Thats about one-tenth of the power needed to supply the province on a moderate spring or fall day.
The energy ministrys submission says the new units are in line with the provinces long-term energy plan and will simply hold the line on nuclear capacity, which now supplies about half the provinces electricity.
Far from being an expansion of nuclear as claimed by several intervenors, 2,000 megawatts of new-build would in effect result in the replacement of about half of the total capacity at the Pickering A and B stations, which are expected to be out of service post-2020, the ministry says.
Existing reactors at Darlington and at the Bruce nuclear site will undergo mid-life refits over the next decade.
The ministry argues that demand for power will grow over the next 20 years.
Power use peaked in Ontario in 2005 and has retreated modestly since then, but the ministry argues thats not a long-term trend.
Some intervenors have cited reports that claim electricity usage in Ontario could be reduced dramatically over the next 10 to 20 years without offering any credible evidence, it says.
Such reductions would be unprecedented internationally in the absence of a falling population and a declining economy.
The Canadian Environmental Law Association argues, however, that neither OPG nor the ministry has proven the need for the new reactors.
The ministrys projections show no growth in power demand for the next decade, but it then inexplicably predicts a huge increase in total electricity demand in the 2020s, the associations submission says.
The ministry further assumes no increase in renewable generation will occur during the decade, it says.
The association also notes that a long-term disposal solution for nuclear waste still hasnt been found.
It is not ethical to entertain a plan to construct a facility that will produce new nuclear waste from new reactors when there is currently no permanent solution to the high level fuel waste and other radioactive waste already being produced from existing reactors, it argues.