We commend the government on…

We commend the government on proposing to include beneficial electrification as part of the broader energy efficiency program (or electricity Demand Side Management, or eDSM) funding. Enabling cost-effective fuel switching through beneficial electrification can help to lower greenhouse gas emissions from Ontario’s energy sector.

We recommend a framework for beneficial electrification that is guided by the objectives of today’s electricity system, including and not limited to affordability, whole-system efficiency through load shifting, and decarbonization.

A careful and thorough review of the Electricity Act and the Ontario Energy Board Act will be necessary to ensure the objects and mandates of the program administrators like the Independent System Operator are expanded to include reduction in greenhouse gas emissions whole-system efficiency.
The Ontario government should also commission studies and provide regular updates on integrated demand side management to help evaluate the potential for beneficial electrification as well as load management/demand flexibility in addition to traditional DSM measures. The results should be disaggregated by geographic region, sector, customer segment, end use, and fuel source (including fuel oil, propane, natural gas, etc.) and technology type.

To help mitigate the impacts of increased electrification (e.g., as a result of fuel switching or beneficial electrification) on the peak electricity demand, NRStor strongly recommends continuing to explore mechanisms and tools like the Ultra-low Overnight rate, as well as technologies that help with load shifting. For the residential sector, this could be contemplated as part of the one-window eDSM bundled offering.

One high potential solution is thermal storage through district heating, grid interactive water tanks, and (hot bricks) electric thermal storage. Thermal storage solutions can not only serve as a critical reserve of thermal energy but also help balance energy demand and supply while reducing peak demand and emissions.

To help ensure equitable access to eDSM program offerings including beneficial electrification and load shifting, NRStor recommends conducting an energy affordability baseline analysis and benchmarking data on issues such as energy burden and access to marginalized and vulnerable communities.

These studies should serve as an input into the funding and design of programming and tools that help to achieve the stated objectives for beneficial electrification and overall eDSM programming (e.g., reducing the energy burden, improving Ontario’s overall energy system efficiency, and supporting cost-effective decarbonization).

Coordination in programming and rate structures for all fuel types as well as between IESO, Transmission Operators, and Local Distribution Companies will be necessary to unlock the benefits of beneficial electrification including optimal use of infrastructure and assets.