Andrea Pastori Cabinet…

Andrea Pastori

Cabinet Liaison and Strategic Policy Coordinator

Ministry of Energy

Strategic, Network and Agency Policy Division

Strategic Policy and Analytics Branch

77 Grenville Street

Floor 6th

Toronto Ontario

M7A 2C1

LTEP Stakeholder Comments - specific to the Conservation portion of the LTEP

Conservation Programs:

Program Continuity – Giving LDC’s the task to “choose” which programs they offer to customers and for how long adds to the confusion of the programs as a whole. Go back to provincially available programs without the arduous task of assigning and dividing up target and budget ahead of time. LDC’s have a difficult enough time keeping track of the monthly reporting to the IESO, let alone being expected to predict how many customers will take part in a specific program, and/or how many specific measures (i.e. how many A-type light bulbs) are going to be installed by participating customers.

Eliminate the requirement for continual updates of the CDM plan.  LDCs are well aware of their assigned target and budget.  The issuance of IESO reports on a monthly basis (Participation & Cost Report and Value-Added Services), along with LDCs own internal tracking mechanisms, are sufficient to ensure the monitoring of achievements program-to-date.  A single annual update from the LDC on programs that will be offered for the upcoming year, with start and stop dates, along with a basic projected annual budget would eliminate the administrative burden most LDCs experience in the current framework in terms of reporting and planning.

Consistency - The ongoing scenario where programs are offered, then taken away, then offered again leads to lack of interest and confusion; not only for customers but also for channel partners and service providers. LDC’s in rural and remote areas of the province are tasked continuously with higher costs associated with attaining trained, willing and enthusiastic channel partners to be able to offer all aspects of the programs. Retaining these partners is even more difficult when the longevity of a program is not in the forecast.

Winter Peaking Programs and Innovation Funding – The demand for residential programs in the North has gained interest and speed exponentially over the past decade. LDS’s are constantly asked by their whether there are any programs available for adding insulation, siding or replacing windows and doors. The results of pilot funding that Algoma Power Inc. took advantage of for the “My Energy Kit” program lend to a prime example of this need for residential programs in the North; the pilot participation target was fulfilled in one week! Implement more pilots and local programs for winter peaking areas of the province and implement them directly in those areas. Add to this, provincially offered programs (i.e. Whole Home Program) offered to residents of Ontario via natural gas companies is confusing and leads to exclusion for those residents who are not natural gas customers. The “non-natural gas” or “electric only” residents of the province need attention and programs which offer incentives to home-reno/building envelope type projects as these customers are the hardest hit when it comes to energy costs.

Provincial Program offers need to be “Provincial” – Introducing new programs for an entire province without the necessary resources in place across the board is discourteous and shows a true lack of concern for the struggling customers without access to all services. If any resident of Ontario should be offered a specific program to help them conserve electricity, it should be the residents who have to use electricity for every energy need in their home.

Cost Effectiveness on Residential Programs – Historical performance of residential programs across the board typically falls into the non-cost effective category. LDC’s have vested interest in creating residential programs which suit the needs of their service territories; especially those LDCs which are composed of a heavily weighted residential customer base. A re-evaluation of current residential pilots, local programs and past programs for residential customers is vital.

Customer Service

Information on Customer’s Bills – Clarification and more information for consumers, given the availability of information on everything else today, are far overdue when it comes to provincial energy bills. An entire review and revamp of the breakdown of charges on bills should be implemented. Consultation with specific LDC staff members, who deal directly with the customer when it comes to explaining the bill, is paramount.

Energy Retailers – Consult with LDC’s on their struggles and frustrations when dealing with customers who have absolutely no idea of what an energy retailer is, yet have signed a contract with one. Going back to information on the bill, there is far more that can be done for customers seeking a contract with an energy retailer (or not seeking one) to explain the implications on the billed costs associated with entering into a contract.

Prices – The OEB, in issuing its Regulated Price Plan (RPP) Roadmap, concluded that two of the four objectives originally set out in the RPP were not being met.  Specifically, the RPP Roadmap concludes that the current TOU price structure is not easily understood by customers, nor does it set prices that provide consumers with incentives and opportunities to reduce their electricity bills by shifting their time of electricity use.  More recently, Minister Thibeault questioned time of use pricing and suggested that the industry explore ways of providing consumers with more options.

A number of LDC’s have submitted proposals for RPP Pilot Programs that incorporate a wide range of technologies and rate structures and in some cases offer elements of customer choice.  The results of these pilot programs should not only be compared to one another, but should also be considered in the wider context of customer preference, cost effectiveness, and achievement of overall conservation targets.   Consideration should also be given to pricing options in the context of the OEB’s Regional Planning initiatives.  Areas of the province with little to no load growth and/or winter-peaking areas may not realize the avoided infrastructure benefits that are often touted as justifications for TOU pricing.  Pricing options that encourage overall conservation as opposed to load shifting or demand response for residential customers in these areas may provide similar or greater overall benefits with greater customer acceptance.

[Original Comment ID: 205386]