Integrated Energy Resource…

Integrated Energy Resource Plan Consultation Responses from Eden Energy Equipment

Relevant documents referenced in this response.

• Ontario’s Affordable Energy Future: The Pressing Case for More Power, MOEE October 2024
• Ontario’s Clean Energy Opportunity: report of the electrification and energy transition
panel, EETP Dember 2023
• Grid Cost and Total Emissions Reductions Through Mass Deployment of Geothermal Heat
Pumps for Building Heating and Cooling Electrification in the United States, US DOE
November 2023
• More Peguis, Fisher River First Nations homes to get geothermal heating, Winnipeg Free
Press March 2015
• Heating Electrification: Policies to Drive Ground-Source Heat Pump Adoption, Dunsky June
2021
• The Economic Value of Ground Source Heat Pumps for Building Sector Decarbonization,
Dunsky October 2020
• A Field Study of Ground-Source Heat Pumps Performance in Canadian Single-Family
Houses - Part I: Cooling Performance, Enbridge November 2019
• A Field Study of Ground-Source Heat Pumps Performance in Canadian Single-Family Houses - Part II: Heating Performance, Enbridge November 2019
• Annual Planning Outlook Ontario’s electricity system needs: 2025-2050, IESO March 2024

Overarching Question:

• What policy options and actions should the government consider in the integrated energy
resource plan to achieve Ontario’s vision for meeting growing energy needs, keeping energy
affordable and reliable, ensuring customer choice and positioning us to be an energy
superpower?

The key to becoming an Energy Superpower relies on three elements: 1) Scale 2) Technology
Leadership and 3) Resiliency. It’s critical these strategies are applied both to the supply and
demand side.

Ground source heat pumps (GSHPs) deliver the highest return on investment for high impact and
long-lasting energy dominance. Ontarians save up to 50% on energy costs while electrical grid
operators see increased load factors and reduced peaks.

In the Dunsky report “Heating Electrification: Policies to drive Ground-Source Heat Pump Adoption”
it identified that “In cold climates in particular, GSHPs can greatly minimize winter peak demandone of the greatest challenges associated with electrification in Canada. In the first phase of this
study, we found such savings could reduce the need for large scale expansion of Canada’s
electricity grid, which would more than offset their higher upfront costs” (page i)

In the earlier Dunsky report “The Economic Value of Ground Source Heat Pumps for Building Sector
Decarbonization” (responding to a report prepared by ICF for the Canadian Gas Association called
“Implications of Policy-Driven Electrification in Canada”) they concluded the following. “Our
analysis of the original Implications of Policy-Driven Electrification in Canada study finds that
including GSHPs as a space heating electrification solution can help reduce the overall costs of
electrification for Canadians by $49B to $148B assuming a 10-30% market share, and by nearly
$500B assuming a 100% market share over the next 30 years” (page 15)

Incentivizing private investment in GSHPs through reduced taxation, rate structures, or even ratebased rebates will drive further mass deployment of this beneficial technology. Resulting in
consumer energy savings, electrical generation and distribution system saving, as well as achieving
Ontario decarbonization targets.

The fleet of residential GSHPs in Ontario is conservatively estimated to exceed 20,000 systems with
an average capacity of 4.1 Tons. Based on 10-second electrical metering data taken from over 330
systems province-wide. GSHPs require 0.75kW less electrical energy per ton for cooling during
peak hours than a high performance ASHP. Therefore, it is reasonable to estimate this modest
deployment of GSHPs are currently reducing Ontario summer peak load requirements by over 60
megawatts.

In the current IESO report “Annual Planning Outlook Ontario’s electricity system needs: 2025-2050”
states that “under current policy conditions the system will transition from a summer seasonal
demand peaking characterization to dual seasonal demand peaking by the early 2030s. The
intrinsic value of GSHP’s is that they will significantly lower the summer peak demand over
alternate home heating sources such as air conditioners and air source heat pumps. Electrification
of home heating after the early 2030’s will produce a winter peaking condition that GSHP will again
moderate this peaking condition.

Planning for Growth

• Building on the recommendations of the EETP’s final report, what actions should be
prioritized to enhance planning across natural gas, electricity, and other fuels?

In the EETP’s “Ontario’s Clean Energy Opportunity” report they noted that “Participants across all
streams of engagement shared their view that electrification of homes must be coupled with a
reduction in energy demand to prevent overloading the grid. This requires pathways to make
energy-efficient technologies affordable and accessible to the entire market. Participants saw a
need to improve the effectiveness of such programs and allocate marketing budgets to engage with
communities that can benefit the most.” (page 52)

This is further supported in EETP’s “Recommendation 27: The provincial government should explore
mechanisms to support broad adoption of fuel switching, decarbonization and supportive
technologies such as electric vehicles, storage and heat pumps to support its clean energy
economy objectives, foster change at the needed pace and scale, and ensure that all customers
can benefit effectively from the energy transition.” ( Page 118)

• The government’s priority is to ensure Ontario has the energy resources it needs to support
growth. Are there opportunities to enhance the province’s approach to procuring electricity
generation supply to better serve this priority?

No additional comments

• What actions should government consider to promote greater access to electricity
and accelerate grid-connections that will support economic growth, connecting new
homes, and electrifying transportation and heating?

No additional comments

• As the need for new transmission infrastructure continues to grow, what steps can
government take to ensure that transmitters have the certainty they require to move forward
with development work as soon as possible, while also ensuring that competitive pressures
keep costs as low as possible?

As identified previously in the Dunsky reports for Canada, there are significant possible reductions
in transmission infrastructure costs with the expansion of GSHPs installations.

This is further supported in the US DOE Oak Ridge National Laboratory “Grid Cost and Total
Emissions Reductions Through Mass Deployment of Geothermal Heat Pumps for Building Heating
and Cooling Electrification in the United States” report. The report concludes that “GHPs have
traditionally been viewed as a building energy technology. The most notable result of this study,
however, is the demonstration that GHPs coupled with weatherization in SFHs (single family
homes) are primarily a grid-cost reduction tool and technology that, when deployed at a national
scale, also substantially reduces CO2 emissions, even in the absence of any other decarbonization
policy” (page xii)

• What policy guidance should the government provide to the Ontario Energy Board (OEB)
with respect to the long-term role of natural gas in Ontario’s economy and opportunities for
low-carbon alternatives in the gas system?

While retaining the existing requirement to serve, the OEB should allow natural gas providers to
explore the alternative of circulating ambient water to networked GSHPs. This technology being
pioneered by gas companies throughout North America offers significant energy savings for homes
and businesses while providing low intensity electrification.

The OEB should also promote to the Utilities adoption of hybrid heating/cooling with GSHPs. As
GSHP overall performance exceeds that of air source heat pumps (ASHPs) especially in cold and
hot ambient temperatures, this will result in lower energy costs and more benefits to the
electrification process.

This statement is supported by the Enbridge “A Field Study of Ground Source Heat Pumps
Performance in Canadian Single Family Houses- Part I Cooling Performance” it concluded that “The
higher capital cost of GSHP systems is considered one of the main reasons that limit the adoption
od GSHPs. However, the COP of GSHP systems are higher than the COP of ASHPs, thus the
operating cost of GSHP systems is less than ASHPs.” (page 31)

In Enbridge’s follow up study “A Field Study of Ground Source Heat Pumps Performance in
Canadian Single Family Houses- Part II Heating Performance” it stated “Compared to traditional
ASHP (HSPF=6.8), GSHP A, GSHP B and GSHP C reduced electricity required for space heating by
up to 46%, 40% and 24% respectively.” (page 41)

• How can the government best support Indigenous leadership and participation in energy
planning and projects?

Investing in green, energy efficient technologies can have many benefits. In MOEE’s “Ontario
Affordable Energy Future” report regarding Indigenous Leadership and Participation it states “Those
communities see immediate and lasting economic benefits that come from their participation in
energy projects, including stable streams of revenue and knock-on benefits such as increased
opportunities for indigenous businesses, job creation and skills development.” (page 24)

One such example is what was reported in the Winnipeg Free Press article “More Peguis, Fisher
River First Nations homes to get geothermal heating” more than 200 homes were retrofitted with
GSHP’s and it was reported that “The deal will lead to over $13 million in geothermal retrofits and in
return will generate $17 million in energy savings.” David Crate, the Fisher River Cree Nation Chief
stated “this is an excellent first step to us becoming energy independent. Crate added the
agreements mean work crews will add to their experience, allowing them to branch out and
eventually work off-reserve in non-First Nations communities”

• How can provincial planning processes be enhanced to support high growth regions, ensure
greater coordination between energy resources, and better integrate municipal, distributor
and regional planning processes?

The OEB should allow and encourage thermal energy networks. Additionally, the provincial
government should streamline regulations relating to the use of surface water, ground water, and
wastewater for heat exchangers connected to GSHPs.

• What cooperation opportunities exist across other jurisdictions to support energy trade,
construction of transmission infrastructure (ex. pipelines and interties), and transportation
electrification?

No additional comments

• What types of technical information and forecasts would best support sector participants
and energy consumers as the system is built out for growth and the economy increasingly
electrifies?

The consumer needs to be informed of the actual space heating operating costs of all their energy
options; gas only, oil only, gas hybrid with GSHPs, gas hybrid with ASHP, GSHP only and ASHP only.
That information should also include, system life expectancy and carbon footprint for all the
options.

This is supported by statements in the MOEE “Ontario’s Affordable Energy Future” report (page 28)

“Priorities for Helping Ontarians Save through Energy Efficiency:
• There is an opportunity to expand energy efficiency to help consumers lower their energy costs
and to help offset investments in new, more expensive electricity infrastructure.
• Households, businesses and institutions would benefit from easier-to-access information about
their energy use to make informed decisions about their building’s energy performance, through
streamlined processes that protect consumer information.
• Encouraging and supporting consumers who want to reduce their overall energy use to save
money and lower emissions should be a continued priority over the long term.”

Affordable and Reliable Energy

• What further steps should the government take to enable households and businesses to
manage and make informed decisions about their energy use?

Energy providers should use every opportunity available to communicate smart and affordable
energy strategies to homeowners. An integrated public and private information campaign to teach
Ontarians about technologies like GSHPs would drive a more unified and informed approach to
energy success.

• What actions could the government consider to ensure the electricity system supports
customers who choose to switch to an electric vehicle?

No additional comments

• What actions should government consider that would empower customers to install
innovative technologies to generate or store energy on-site to reduce costs and improve
resiliency?

Remove unnecessary permitting, taxation, and regulations relating to proven and reliable solutions
like GSHPs. With underground heat exchangers that last over 100 years and heating and cooling
equipment lasting over 25 years, GSHPs will provide decades of reliable indoor climate control and
a windfall for electrical providers.

The incentive programs to empower customers to install innovative technologies to generate or
store energy on-site to reduce costs and improve resiliency are currently delivered in Ontario by the
IESO trough the Save on Energy brand. Many of these programs are restricted to income-eligible
residents, to certain geographic locations, existing fuel types and types of residences or business
classifications. The programs should be open to all and have a stated multi-year duration. They
also should be of a large enough significant to engage the customers.

• What specific actions could position the integrated energy resource plan to best leverage
distributed energy resources (DER) that enhance local and province wide grids to support
energy system needs reliably and at the lowest cost?

No additional comments

• What policy or regulatory changes should government consider to address financial risks
and support adoption of DER in the long-term?

No additional comments

• With the energy sector evolving and distributors considering new roles in serving
customers, what barriers exist that limit local distribution companies from taking on new
duties that could enable more efficient grid operations, leverage new technologies and
further the integration of DERs?

No additional comments

• What actions can the government take to enhance collaboration between the OEB, the
IESO, local distribution companies, industry stakeholders, and local communities to
support the investment and integration of DER?

No additional comments

• What further actions could the government take to maintain an affordable energy system for
Ontarians throughout the energy transition?

No additional comments

Becoming an Energy Superpower

• What opportunities exist to further capitalize on Ontario’s leadership and expertise in
nuclear technology and nuclear innovation?

No additional comments

• What opportunities should Ontario consider to leverage its position as a clean energy
leader?

No additional comment