We thank MENDM for the…

We thank MENDM for the opportunity to provide comments to the new proposed CDM Framework. Our comments are arranged to mirror the sections in the "proposal detail" on the Environmental Registry of Ontario.

Context:
We applaud the Ministry for recognizing in their proposal that conservation “is the most cost-effective resource to help meet the province’s energy needs”. This is important to recognize because the general public often sees conservation programs do nothing but add cost to their electricity rates. One only needs to look at the Global Adjustment costs to see the inherent value provided by conservation – conservation allows the province to defer or avoid investment in expensive new electricity infrastructure, as well as reduce large operating costs of existing generation.

We also applaud the Ministry for their understanding that customers and the vendor community are looking for stability and predictability in CDM programming for the post-2020 period. This stability allows ratepayers to confidently invest in conservation equipment and activities, having a positive impact on the Ontario economy.

Objectives and Customers Served:
We agree it is vital this new framework maintain the capacity to deliver programs from both a conservation and economic value perspective. The “nega-watt” economy that employs a network of equipment manufacturers, engineers, sales people, skilled trade installers, and those involved in the CDM program combine to deliver high value products and services to business and residential rate payers.

If the framework is going to focus on providing education and tools for residential customers to empower them to improve their energy efficiency (which is a great idea), we urge the Ministry to consider residential condominiums completely separate from single-family residential for three reasons. Firstly, condominiums offer much more opportunity to conserve than a single-family home. For example, similar to an office tower, many condominiums use a large central cooling plant to provide cooling to the suites, and when retrofitted, these cooling plant projects yield large energy reductions. Also contributing to the large conservation opportunity, consider both the large number of people living in condominiums now, the fact that condominiums have become the primary choice for fist-time homeowners in the GTA, and condominiums are a significant channel for real-estate investment. The above also point to conservation efforts also being more impactful to customers that live in condominiums. Secondly, condominium buildings must be considered separately from single-family homes because their blend of commercial and residential pricing is completely different than a single family home. Interestingly, the decision making process in condominiums requires condominiums receive more guidance relative to commercial and industrial buildings. The conservation opportunity in condominiums makes this worth the effort, as demonstrated by the success of the Embedded Energy Manager program in the condominium segment.

Program Types:
We support the development of programs that provide an incentive for whole building electricity savings via increased internal energy management capacity. Quite a bit of the “low hanging fruit” that has delivered conservation, such as LED lighting, has been picked. So, the next wave of electricity savings will require more expertise, and expertise is difficult to outsource to less developed economies. This is not a bad thing, as it again supports (perhaps requires) high-value made in Ontario innovations. The one key thing that will support high-value made in Ontario innovations is predictability in electricity pricing as it stabilizes the investment landscape for rate payers.

Rob Detta Colli
Manager of Energy & Sustainability
Crossbridge Condominium Services