About Canadian Renewable…

About Canadian Renewable Energy Association (CanREA)

CanREA is the leading national industry association advocating for wind energy, solar energy, energy storage and behind-the-meter solar & storage solutions in support of a reliable, affordable, and non-emitting electricity system.

CanREA's network of about 350 companies represent all parts of the value chain to develop and operate wind, solar and energy storage technologies across Canada.

Limiting Foreign Jurisdictions’ Participation in Ontario’s Economy

CanREA recognizes and supports the government's objective to secure Ontario’s economy and critical energy infrastructure from threats by foreign antagonists, including protecting the energy sector against risks of malware, manipulation, tampering, extortion, surveillance, rate payer harms, and other prospective threats directly or by extension from a foreign state-owned enterprise.

CanREA recognizes and supports the government's objective to ban any Chinese state-owned enterprise from buying or taking equity in any Ontario government funded energy, critical mineral or major infrastructure asset.

Limiting Foreign Jurisdictions’ Participation in Ontario’s Energy Sector

CanREA acknowledges the government’s objectives to:

• Enable MEM to limit the participation of foreign jurisdictions in Ontario’s electricity sector (i.e., specifically as it relates to foreign equipment, systems, services, facilities or technologies) via regulation-making authority and Minister’s directive making authority.
• Keep the province’s energy supply safe and secure by limiting the involvement of foreign antagonists in Ontario’s electricity sector as deemed appropriate by the government.
• Enable a mechanism to respond to future trade restrictions imposed by other countries which target the Canadian/Ontario economy.
• Formalize the government’s ability to outline specific parameters pertaining to the country, region or territory of origin and their abilities to participate in Ontario’s electricity sector.
• Keep the province’s energy supply safe and secure by limiting participation or components from companies or entities from specific countries (or foreign state-owned enterprises) in Ontario’s energy sector (i.e., to protect against risks of malware, manipulation, tampering, extortion, surveillance, rate payer harms and other prospective threats directly or by extension from a foreign state-owned enterprise).
• Solidify MEM’s authority to provide direction to the energy sector at a future date related to foreign participation in energy procurements.

CanREA notes that the proposal details include the following critical clarification language:

“With respect to resource procurements, MEM’s proposal to limit foreign participation in the energy sector would focus on future resource procurement activities not processes already launched, awarded and being implemented.”

CanREA recognizes that global supply chains are evolving quickly and that the government is focused on fostering and developing domestic and continental supply chains. CanREA also recognizes that decoupling from Chinese supply chains is a priority for the government. CanREA is generally supportive of these goals, with the important caveat that any go-forward related regulations or policies be carefully implemented over time to manage the transition effectively.

We support the government's objective to develop domestic and continental supply chains and we want to help develop a pathway to ensure that all technologies can participate in electricity resource procurements. This is good for reliability, the economy, communities, and ratepayers.

CanREA Recommendations

1. We recommend that any potential limitations on components from China not be applied retroactively to already completed procurements or procurements in progress. This could significantly impact grid reliability, affordability, Indigenous equity partnerships, municipal and community benefits, local jobs and economic development, and private sector investment confidence in the province.

2. On a go-forward basis, we recommend that any potential limitations be implemented over time, in a careful and staged manner. Presently, solar energy and battery energy storage are heavily reliant on components from China. For these technologies, there are many key components which are currently not available outside of China. Limitations could significantly reduce the availability and / or significantly increase the cost of these technologies, potentially impacting grid reliability and affordability. We note that it will take time and large investments in manufacturing capability to shift supply chains and source these components from outside of China. Ontario should enable exceptions for components that are currently not available outside of China and provide time for supply chains to evolve.

3. We recommend that incentives also be considered to encourage the sourcing of components from outside of China, and to encourage the fostering and development of domestic and continental supply chains.

4. We recommend that the government provide the sector with the opportunity to review and comment on any potential draft regulations or policies before implementation to ensure there are no unintended consequences that inadvertently restrict technology participation in electricity resource procurements.