Introduction - Comments…

Introduction - Comments submitted by Toronto East Residents for Renewable Energy

The fundamental basis for this proposed policy – that the continued use of natural gas well into the future in Ontario’s energy system is both a cost-effective and sustainable option – is faulty and short-sighted. Current projections are that the world will run out of natural gas well before the end of this century. Putting money into expanding or retaining natural gas infrastructure without ramping up investments in the known, proven and lower-cost renewable alternatives (wind, solar, battery storage, conservation) is a waste of taxpayer money. Natural gas was seen as a stop-gap when coal was removed from Ontario’s energy mix. It is now almost three decades later and it is time to put the stop-gap solution behind us.

Continuing to burn natural gas has inter-generational implications. While we are looking at using natural gas to solve present day needs there must also be some thought given to the impact the climate and health impacts on future generations,.The natural gas we burn today is contributing to the long-term heating of the Earth and children alive today will have to contend with the economic and health implications. Projections show that the economic cost of a hotter Earth will grow year after year with no mitigation or contingencies able to counter or control the threat.

It is disconcerting to read this proposal when it is clear that an increasing number of countries have reduced their reliance on fossil fuels, like natural gas, and have been successful in providing the electricity their people need and a healthier air shed. Nordic countries, well north of most Ontario communities, now have the highest rate of heat pump installation in Europe. That there is now a monopoly in Ontario for supplying natural gas should cause concern because heat pumps provide a more constant, comfortable, temperature, at a lower cost, than natural gas furnaces. The Ontario government continues to push natural gas at its own peril and the peril of its citizens and natural environment.

Various jurisdictions have shown that a transition to renewables and away from gas can clean the air, drive down energy costs, and provide reliable energy to their community. See examples included below. That Ontario is not placing an equal or greater emphasis on renewables than they are with gas puts them as an outlier in comparison to the rest of the world.
Examples of transitions to reliable, cost-effective renewable energy sources:
- This study shows the percentage of wind-water-solar by country (24-Countries100Pct-Q423-Q324).
California, and other U.S. states, are having days when more than 100% of their energy requirements are provided by renewables and the rest is stored to supply some of the demand for overnight electricity (https://electrek.co/2024/07/29/california-achieves-100-days-of-100-elec… https://theprogressplaybook.com/2024/04/08/these-12-us-states-now-get-m…).
- Portugal is able to run entire days on renewables (https://thepremierdaily.com/renewable-energy-portugal/).
- The UK has days when the amount of electricity from wind turbines exceeds 50% of their energy requirements (https://www.nationalgrid.com/stories/energy-explained/how-much-uks-ener…).
- China installed more solar capacity in 2023 than the rest of the world combined.

Question 1 - What principles should the government provide to the OEB to help inform the Board’s ongoing development of natural gas connection policies?

Natural Gas as a fuel is coming to the end of its broad useful life. In order to prevent stranded assets the proposed path of expanding natural gas infrastructure needs to be halted, the burning natural gas needs to be phased out, and the government needs to support the rapid development of clean, renewable energy sources such as wind, solar, and battery storage.

Consumers should be given the option of choosing less expensive alternatives, such as heat pumps for heating and cooling. Enbridge should be prohibited from passing on higher infrastructure and energy costs to consumers as their customer base shrinks.

Question 2 - What role should natural gas play in supporting energy affordability and customer choice in residential and small commercial applications (e.g., space and water heating)?

The use of natural gas in space and water heating in residential and small commercial applications should be phased out rapidly and replaced with options such as heat pumps, thermal district networks, and conservation which will ultimately save money for the consumer and slow the impacts of climate change (e.g., flooding, extreme heat, forest fires). Use of natural gas should only continue when absolutely needed until it is ultimately replaced.

A recent Toronto Star Article (Ontario launching rebates for energy efficient home renovations and upgrades, January 7, 2025) quotes Energy Minister Lecce saying “With greater pressure being placed on the province’s grid, energy efficiency programs are an opportunity to mitigate demand without compromising
Affordability.”

Question 3 - What role should natural gas play in supporting economic development in Ontario’s industrial and agricultural sectors, including those processes that may be difficult to electrify?

Natural gas should have no role supporting economic development (e.g. new business) in Ontario’s industrial sector. For current industrial users, natural gas should continue to be used only until transition to a renewable energy source can be put in place. The one agricultural use that stands out is drying of crops. Natural gas for drying of crops should continue until such time as a viable alternate process can be put in place.

Question 4 - What role should the government play in supporting and expediting the rational expansion of the natural gas system to make home heating more affordable and support economic growth in communities that are seeking natural gas service?

The government should defer to the decisions of the OEB on questions of expansion, including the Board’s original decision in late 2023 to require home developers to pay up front the costs of natural gas connection, and not interfere with or limit their decision making process. The fundamental premise of the above question is false: natural gas does not make home heating more affordable. There are at least 10 municipalities in Ontario that do not support expansion of the natural gas system in their communities.

For natural gas expansion projects receiving government support, should the approvals processes be streamlined to support affordable home heating for Ontarians? In what ways?
The fundamental premise of the question is false – natural gas does not make home heating more affordable. Heat pumps are a more affordable means of home heating. A recent Toronto Star Article (Ontario launching rebates for energy efficient home renovations and upgrades, January 7, 2025) quotes Energy Minister Lecce as saying that homeowners that install heat pumps will save money, with savings of up to 50 percent in their heating costs.

Question 5 - What role should natural gas play in supporting power system security and resiliency?

Natural gas should play a minimal role in the power system and should be phased out as quickly as possible through greater use of renewable energy sources, conservation, energy efficiency and storage solutions which will increase security and resilience.

An independent party should assess the IESO forecasts given the IESO’s previous history of inaccuracy. Forecasts might be faulty as situations change.

Question 6 - What role should natural gas play in offsetting higher GHG-emitting fuel sources?
Natural gas was championed as a stepping stone fuel to replace coal with the final step to end with renewables. Higher GHG-emitting fuel sources should not be replaced with natural gas which is itself a high emitting fuel source. There are currently less expensive energy sources.

Question 7 - What are the challenges and opportunities for enhanced energy efficiency, adoption of clean fuels (e.g., RNG, Hydrogen) and emission reduction methods (e.g., carbon capture and storage) to lower emissions in the natural gas system?

The most effective emissions reduction mechanism is to NOT burn natural gas in the first place. Improved energy efficiency makes sense with heat pumps being 300% more energy efficient than natural gas furnaces. It makes good sense to significantly scale up renewable energy and to use a combination of renewable energy with battery storage and only burn natural gas for electricity when renewable energy is not available.

Conservation and demand management have a very significant role to play in Ontario. It is the most cost-effective source of energy. The Ontario Electricity Distributors Association in their Power of Local Conservation report (October, 2022) indicates that energy conservation and demand management (CDM) is the most cost-effective mitigation solution. Further, it states "In our estimation, by 2026, the proposed solution will eliminate 94% of the energy supply shortfall identified in the IESO’s 2021 Annual Planning Outlook. By 2032, the energy supply gap will be eliminated, and the peak energy shortfall will be reduced by 55%."

The Pembina Institute and Rocky Mountain Institute have concluded that solar and wind combined with energy storage and demand side management can largely provide the same service as gas and more cost-effectively. (Reliable, affordable: The economic case for scaling up clean energy portfolios, Pembina Institute, 2019).

The Royal Bank of Canada Power Shift report (https://thoughtleadership.rbc.com/wp-content/uploads/Power-Shift-Report…) indicated “By 2040, Ontario could meet nearly 20% of its expected demand growth—or 28 terawatt-hour (TWh)—via economically viable conservation.”

Particularly for emission reduction methods like carbon capture and storage, first, it has to work and the results have not been impressive to date. Despite being promoted as a way to continue burning natural gas, with governments pouring huge amounts of money into it, CCS remains an unproven technology. “Researchers point to the frequent failure of projects to meet carbon capture targets, cost-overruns, the need for multi-billion dollar subsidies, and the tendency of the oil and gas industry to use the technology to justify investments in new fossil fuel projects — rather than focus on cleaning up existing dirty industries. Nevertheless, oil and gas companies have continued to press the case to ministers that gas-fired power plants fitted with carbon capture can be a climate solution.” https://www.theguardian.com/business/2024/oct/07/uks-22bn-carbon-captur…