We are pleased to have…

We are pleased to have received and reviewed the Ontario Planning Outlook from the IESO and the Technical Fuels Report prepared by Navigant Consulting. We are also pleased to have received and reviewed the Consultation Discussion Guide.  Collectively, these documents represent a positive step toward a viable long term energy planning process.

 

We are in agreement with the 2016 amendments to the Electricity Act, 1998, as amended in 2016, that require the following changes:

 

•The Ministry of Energy must consider the IESO report.

 

•There must be a public consultation, conducted through the Environmental Registry.

 

•The Plan must consider all energy sources, not just electricity.

 

We are troubled by the following:

 

•In spite of the IESO and the OEB having significant experience in managing the supply and conservation of electricity, and the responsibility to promote a viable, sustainable and efficient energy sector that serves the public interest and assists consumers to obtain reliable energy services that are cost effective, respectively, both of these organizations have been overtaken in managing their roles in the recent past by the Ministry of Energy.

 

•There is a lack of transparency regarding the rationale for final decisions to be made in the LTEP.

 

•LTEP has previously adhered to a thirty-six month period between the 2010 version and the 2013 version, but for the 2017 version the interval will be forty-two months, this when the need would seem to be for a shorter, not a longer, interval.

 

•The consideration of Conservation First in the Discussion Guide is not positioned as a primary resource or activity, in spite of its descriptor. The focus on reducing energy use is critical for existing buildings, and the current effort in CDM and DSM by the electricity and natural gas distributors must be accelerated, rather than play a lessor role in the LTEP.

 

The Climate Change Action Plan targets for GHG reductions of 15% by 2020, 37% by 2030, and 80% by 2050 are aggressive and can only be met by aggressive actions. To do this, they need to be considered in all aspects of the LTEP. This is especially important when it is realized that LTEP will now address over 70% of current Ontario GHG emissions, and the many changes to the current sources and uses of fuels and electricity that are proposed, including:

 

•Electrification of space heating, transportation, and industrial energy use. •Alternative fuels in place of petroleum and natural gas.

 

•Conservation of natural gas.

 

In Ontario, space and water heating represent approximately 60% of the total energy use in the buildings sectors. These uses are primarily served by relatively inexpensive natural gas. Electrification of these end uses will bring significant additional demands on the electricity system and will also burden building and home owners with higher utility bills unless major investments in energy efficiency are made to off-set this increase.  Energy efficient design of new buildings and the energy conservation retrofit of existing buildings will help to reduce these operating cost increases, but only when significant investments in capital projects are made by their owners. For these reasons, ensuring that financing is available for energy retrofit of existing homes and buildings will be a key factor.

 

We suggest that Local Improvement Charges offered through municipalities would be an ideal option that would extend the payback periods so that energy costs savings equal, or exceed the annual repayments. Property loans would be off balance sheet to the owners and the municipality would have all the powers to enforce repayment granted by the Municipal Act for the collection of property taxes.

 

Building owners are very sensitive to the cost of energy to heat, cool, and otherwise power their buildings. Any actions that can be taken to slow the annual cost increase of electricity, or even reverse it, would be of great value to the buildings sector.

 

As the Building Code moves towards net zero homes and buildings, the most likely source of renewable electricity will be building-mounted and/or building integrated solar PV, with some electricity from off-site renewable sources offered by a vendor.  Combining solar PV with site electricity storage will require net metering for the sale and/or purchase of electricity to the local distribution company (LDC). While this has significant potential for reducing the overall load on the local or regional electricity system, the recompense for the sale must be sufficient to justify building owners and operators making the investment in larger and more extensive solar PV systems, and the associated storage.   Like the energy efficiency issue, the appropriate price signals, including potential incentives must be in place to induce the desired investment from the buildings sectors.

 

Finally, we note that the move to electrification is driven by the notion that our electricity generation is “green”.  It is the case that the current mix of generation assets represent low carbon sources, however a significant dependence on nuclear assets is also troubling.  Nuclear based generation has cost and reliability implications and potentially significant long term environmental and economic repercussions related to the disposal of nuclear waste.  Our preference would see a significant reduction in dependence on nuclear assets and a corresponding increase in renewable assets.

 

We look forward to receiving the completed LTEP report, and would be pleased to provide any further information and/or guidance if requested.

 

[Original Comment ID: 207095]