Dear Minister Sala,

We are writing to express serious concerns about the development of Manitoba Hydro’s 2025 Integrated Resource Plan based on the information presented to the Public Utilities Board on February 24, 2025 and sent to engagement participants on March 20 & 25, 2025 (see: Engagement Summary, Key Inputs and Scenarios, and Evaluation Metrics). We write with urgency because the IRP as presented will lock in decades of emissions and steer Manitoba away from cost-effective investments in clean energy infrastructure. The energy transition pathways in the IRP do not align with Canada’s near-term emissions reduction commitments, or with cumulative emissions trajectories that could keep us within 1.5°C or even 2°C of warming. The vision of a “net zero economy” in the IRP relies heavily on direct air capture (DAC) of CO₂, which is expensive and unproven at scale.

Hydro’s Round 1 Engagement Summary confirms that emissions reduction goals and concerns about DAC were brought up by engagement participants, but Hydro’s response to these concerns is far from sufficient. Additionally, there is no mention in the Engagement Summary of anything that has been done in response to feedback about Reconciliation.

We urge you to reset the IRP process to ensure that it centres sound climate science, Indigenous rights, and public input. We also ask that a full Public Utilities Board hearing be required for the approval of this IRP.

While the draft IRP materials reflect an intention to reach net zero emissions by 2050, the pathways currently on the table neglect important considerations and lose the climate change mitigation purpose of reaching net zero. We recommend the following revisions for the forthcoming IRP:

• Explicit evaluation of how scenarios align with federal near-term climate targets and 1.5°C and 2°C warming pathways, accounting for cumulative emissions.
• An emphasis on near-term electrification and efficiency measures for heating, transportation, and industry to start achieving meaningful emissions reductions by 2030.
• No reliance on DAC without a publicly available full cost-benefit analysis of DAC compared to electrification and conservation strategies for combustion emissions and feasibility study of DAC and carbon storage for the Manitoba context.
• A commitment to environmental impact assessment for all new energy infrastructure.
• Connections to (or recommendations for) provincial climate policies that reduce emissions across sectors before offsets.
• An emphasis on clean, renewable energy sources such as wind, solar, and biomass, and supportive technologies such as energy storage, efficiency, and grid modernization, and an analysis of the investment in these strategies necessary to meet peak demand.
• Better reflection of the values expressed by engagement participants and explicit explanation of how the IRP has evolved based on input from engagement.
• Transparency about modelling data and assumptions, and consultant involvement.
• Clearer decision-making roles for Indigenous Peoples in the IRP process and for resulting energy projects that reflect government-to-government, Crown-Indigenous relationships.

The information presented in the appendix to this letter backs up our concerns and recommendations. We would like a public response detailing how you will address these concerns by April 30.