This proposal outlines a…

This proposal outlines a strategic approach to enhancing Ontario’s electricity energy efficiency (EE) programs to address increasing energy demand and to support environmental sustainability. Below are several key comments:

Affordability and Access:
The proposal's focus on expanding access to energy efficiency programs for all customer segments, including income-qualified households and First Nations communities, is commendable. Ensuring equitable access is critical, especially for vulnerable populations, and expanding the program portfolio will help make energy efficiency more attainable for these groups.

Reliability and Cost Savings:
By emphasizing demand-side resources to reduce the need for costly new electricity infrastructure, the proposal demonstrates a long-term commitment to a more efficient and cost-effective energy system. The projected $800 million net benefit is impressive, highlighting the financial advantage of investing in EE measures.

Customer Experience Optimization:
The idea of streamlining access to EE programs through a single window for residential customers is a practical improvement. Reducing customer confusion and expanding program choice through enhanced collaboration with LDCs and other stakeholders will likely increase participation and satisfaction.

Role of Local Distribution Companies (LDCs):
Increasing the involvement of LDCs in both local and province-wide programs is a positive step toward maximizing customer engagement and addressing specific regional needs. However, a more detailed outline of how responsibilities and budgets would be distributed between IESO and LDCs could help clarify their respective roles and ensure seamless program delivery.

Long-term Sustainability:
A longer-term framework with flexibility for mid-point reviews is a prudent approach, allowing for adjustments based on evolving energy needs and priorities. Incorporating best practices from U.S. jurisdictions such as Vermont and Massachusetts is a smart strategy to ensure the framework remains competitive and effective.

Environmental Impact:
The proposal’s alignment with environmental sustainability goals is well-articulated. The anticipated reductions in electricity consumption and greenhouse gas emissions will contribute to Ontario’s low-carbon economy and help achieve its broader climate change targets. This will also support sustainable economic growth through the promotion of green technologies and energy-efficient practices.

Stakeholder Engagement:
The commitment to ongoing stakeholder involvement, including on-reserve First Nations communities, ensures that the framework remains inclusive and adaptable. Continuous feedback will be key to refining the programs and maintaining stakeholder trust.

Execution and Transition:
Transitioning smoothly from the current framework to the proposed long-term structure by 2025 is critical. Clear communication about program changes and continuity of support will be essential to minimize disruption for customers and stakeholders during this transition phase.

Collaboration between IESO and Enbridge:
It's crucial for the IESO and Enbridge to align their energy efficiency programs to maximize both funding opportunities and energy savings. Many projects already consider both electricity and natural gas efficiencies at the same facility, and a coordinated effort between the two entities would enable customers to unlock deeper, more sustainable savings. This collaboration would help streamline the process for customers, reduce redundancies, and ensure that energy efficiency measures deliver longer-lasting benefits across both electricity and natural gas consumption. A joint approach could also amplify the overall impact of the programs and enhance Ontario’s transition to a low-carbon economy.
The intent of this comment is to underscore the importance of a holistic approach to energy efficiency for comprehensive, long-term solutions.

Overall, this proposal demonstrates strong potential to benefit Ontario’s electricity system through cost-effective and environmentally sustainable measures. It successfully balances the needs for affordability, reliability, and environmental stewardship while supporting long-term energy planning and stakeholder collaboration.