The Province’s development…

ERO number

019-2132

Comment ID

47588

Commenting on behalf of

Toronto Association of business Improvement Areas

Comment status

Comment approved More about comment statuses

Comment

The Province’s development of a renewed Conservation and Demand Management Framework for 2021- 2024 is essential to address forecasted generation shortfalls as well as to support municipal, provincial and federal goals related to climate change. While Ontario’s grid is relatively clean at 30-150 grams of CO2 per kWh generated, there is a significant opportunity to provide broad programming that will support lower GHG emissions and work to reduce electricity demand.
It is essential for the new framework to continue existing programs with a review on incentive rates for various technologies. The programs in place currently have created jobs for energy efficiency professionals such as Applicant Representatives and Energy Managers as well as providing a clear pathway to project approval that supports energy efficient technology adoption. Previous programs under the Conservation First framework should also be investigated and potentially reinstated. Programs such as Business refrigeration and Roof Top Unit replacement address the needs of businesses and in some cases, also capture natural gas as well as electricity savings.
Additionally, the Small Business Lighting Program and other direct install programs should be provisioned. These types of programs provide ease of access and adoption. As an Energy Manager representing over 74,000 businesses in Toronto, these programs help our small and medium enterprises adopt energy efficient technologies without substantial (if any) upfront costs. Once a business has had a positive experience with these programs, they are more inclined to explore other offerings within the CDM framework.
New programs under this framework should consider Ontario’s electrical future. A renewed CDM framework should support the development of district energy projects that create micro-grids and alleviate some of the burden of electricity distribution from the IESO. Major jurisdictions across the province have implemented these types of projects with great success and many more have been planned. Financial and technical support for these projects will create a network of distributed energy assets that can address both base load and peak load electricity requirements as well as address heating and cooling needs.
Dual incentive programs similar to the current IESO/Enbridge Demand Control Kitchen Ventilation program should be explored as they allow for both natural gas savings and electricity savings and larger incentives, making these projects more feasible for business owners.
Finally, new programs that look at technological advancements and the electrification of the province should be explored. Once such program would be a prescriptive incentive program for Heat Pump technology. Heat pumps are highly efficient, relatively easy to install and can provide multiple control points which enable greater comfort control and zoning at a potentially lower cost to operate. While the provincial AffordAbility Fund does provide incentives for heat pumps, it only applies to residential buildings and there is currently no provision for businesses.

Ultimately, a new CDM framework needs to consider the future needs of the province, support businesses as they try to stabilize themselves after a devastating hiatus due to COVID, all while empowering electricity consumers to make the right decision as it pertains to energy efficiency.