• the policy should…

• the policy should establish a clear pathway to reduce reliance on conventional natural gas and ultimately phase it out by or before 2050.
• Ontario should prioritize electrification and energy efficiency as more cost-effective, proven, and sustainable solutions, supported by investments in renewable energy generation and storage technologies to support the effective phase-out of natural gas.
• There needs to be a clear definition of required conditions for endorsing natural gas as a means for heating or for electrification as such should only be endorsed as a “last resort” when there is no other option for reliability and affordability.
• Principles used by OEB for natural gas connections must include full life cycle total cost with comparison of life cycle total cost of the alternatives.
• As a natural gas policy is a “secondary” policy to the masterplan for electrification in Ontario and as there are other “secondary” policies addressing role of wind & solar and batteries the electrical grid needs to be assessed and updated to support the transition from Natural Gas to a distributed energy system using alternative energy sources. If not done it is a charade to suggest there is serious intent to substantially reduce, if not eliminate, natural gas as a contributor to the mix of electricity sources.

Although in theory incorporating alternative fuels such as hydrogen, renewable natural gas (RNG), and carbon capture technologies would lessen the carbon intensity of natural gas these options face significant technology and economic barriers to viability at scale. Any analysis for justifying maintaining gas assuming these technologies must include probability of the technology being at necessary scale and the timeline for being at scale.
There is urgency to identifying the policy due to the significant risk of stranded assets. These stranded assets could result in long-term costs for ratepayers and taxpayers.
A policy reducing reliance on natural gas and phasing it out by or before 2050 will support a new standard for building homes: all new housing should be designed with heat pumps or hybrid-heating, capable of participating in demand response programs. By incorporating high-efficiency standards, electrification readiness, and renewable energy technologies into new housing, Ontario can achieve its housing targets while building a low-carbon, affordable, and resilient energy system. To achieve this the Ontario Building Code should be updated immediately to support the transition from Natural Gas to alternative energy home heating solutions.