QUEST applauds the government for putting forward a renewed conservation and demand management framework.
QUEST is a national non-government organization that works to accelerate the adoption of efficient and integrated community-scale energy systems in Canada by informing, inspiring, and connecting decision-makers. Our vision is Canada as a nation of Smart Energy Communities.
A smart energy community is one that:
- Understands the compelling challenge of climate change
- Recognizes the reality of community energy needs and priorities
- Integrates local, renewable, and conventional energy sources
- Efficiently, cleanly, safely and affordably meets its energy needs
Grounded in our technical and policy principles (https://questcanada.org/pathways/#principles) and emphasis on efficiency, QUEST believes that Smart Energy Communities are an essential foundation for effective energy and climate policy.
We wholeheartedly endorse the statement from the registry posting: “Electricity conservation can help defer or avoid investment in new, more expensive electricity infrastructure, as well as reduce operating costs of existing generation.”
QUEST is encouraged by the registry posting and the government’s stated intent to move forward with a new conservation framework. We also see opportunities for improvement based on our national experience and expertise in energy efficiency and energy systems.
We applaud the government’s efforts to focus on peak demand reduction compared to the previous framework which had an “energy only” focus. The importance of peak reductions as a way to defer or avoid investments and reduce emissions was highlighted extensively in QUEST’s planning alignment work (https://questcanada.org/project/toward-planning-alignment).
We also endorse the government’s stated intent to allow proponents to put forward custom programs and the openness to a variety of market delivery agents. We encourage the government and IESO to build in as much flexibility as possible when considering the types of programs and projects that would be eligible for CDM programs.
We would further encourage the government to consider how communities could participate and leverage CDM programming to advance conservation, economic development and climate change objectives in their municipal/community energy plans.
Further to this last point, municipal energy plans consider the use of all fuels, including electricity and natural gas, and we would encourage the government and IESO to consider how they might better integrate electricity and natural gas conservation programming, as called for by the OEB.
Another area of strong potential for CDM are distributed energy resources that are designed primarily for load displacement purposes, including Distributed Energy Resources and Combined Heat and Power systems, as an eligible measure to reduce electricity and reduce peak demand.
We would encourage the government to launch a process for consultation on the detailed framework to solicit ideas from customers and stakeholders.
Thank you for your consideration.
Tonja Leach, Executive Director
Submitted August 17, 2020 4:28 PM