I greatly appreciate the…

I greatly appreciate the opportunity of being able to provide these comments regarding the LTEP 2017. I have been actively engaged in Energy Conservation efforts and the last 10 years (perhaps more) have been filled with smoke and mirrors from the existing energy supply chain whom seem to have only their own vested interest(s) at heart. The Minister has a challenging role ahead but I believe he, and his government, can and will end the charade and hopefully present the big reveal. I implore the Minister to put Ontario back on the global map for all the right reasons… show us the math… show us a renewable energy future.

 

My recommendations (in no particular order) are:

 

Auditor General Report 2015

 

I encourage the Minister to listen to the Auditor General. AR2015 highlights lack of transparency and a lack of alternatives provided by the IESO. Decisions made over the past decade have produced dire consequences for everyone. Generation is primarily responsible for both increased energy costs and excess energy supply, both of which are mostly due to Nuclear power. As such, I implore the minister to revisit the $13 billion Nuclear refurbishment contract signed by the previous Minister and explain - in clear and concise terms – why we need more expensive and toxic Nuclear power when better alternatives are available.

 

FIT Contracts

 

I encourage the Minister to bring back the FIT program and to continue the MicroFIT program regardless of MW contracted. FIT contracts serve well in maintaining fixed, fair and stable energy costs and there needs to be further encouragement for building owners to utilize roof top area for solar PV.

 

Data Acquisition

 

I encourage the Minister to adopt GB (Green Button). Do not let resistance from utilities slow this process as GB will serve to benefit everyone and therefore needs to come into effect as soon as possible.

 

Data Reporting

 

I encourage the Minister to issue a directive to the IESO to show real-time POWER and ENERGY data - by ‘Type’ – in a clear and concise manner. Currently the IESO skews information in-favour of Power which causes many to believe Renewable Energy efforts are responsible for the high cost of Energy. But the IESO is slow, lethargic, and hides the truth. The IESO is no more “independent” than the former OPA so let’s stop pretending. The Minister must direct the IESO to report both potential and actual contributions to the supply mix, not just the potential to supply the mix, in a clear and concise manner. Showing energy by ‘type’ will help citizens understand where the energy comes from. I encourage the Minister to reject the IESO OPO Outlook scenarios A thru D as inadequate. All four are “top-down” models based on centralized power generation, with little to no respect for grid migration.

 

Participation Fairness

 

I encourage the Minister to amend Ontario Energy Board Act, 1998 Net Metering Regulation 541/05:

 

a) credits for energy generated must remain until consumed (similar to Bill 47, the Protecting Rewards Points Act);

 

b) not biased in-favour of LDC but rather in-favour of eligible generator; c) written in plain English; d) consistent throughout the province.

 

I encourage the Minister to amend Ontario Energy Board Act, 1998 such that up to 2000 W (2 kW) of solar PV may be installed by any citizen without permission from LDC and/or IESO. Citizens are now free to install multiple electric water heaters without permission, the same should be true for similar sized energy producing units.

 

I encourage the Minister to demand all Smart Meters be bidirectional types and suggest that all LDCs be mandated to change - at no charge - any currently installed Smart meter that is not a bidirectional type if requested to do so (currently there are discretionary charges applied by LDC’s which can be excessive and accompanied by too much paper work and too many T&C’s). I encourage the Minister to remove all barriers for small power input systems and design the regulatory process to support and simplify the economic participation of the communities hosting the projects. Doing so will encourage many people to participate a small ways which is a gentle transition on the grid.

 

I implore the Minister to direct the IESO and LDC’s to accept all products that conform to CSA/UL safety regulations and meet ESA standards. The IESO and LDC’s are not recognized safety agencies and therefore must not be permitted to override existing measures.

 

Less is More

 

I encourage the Minister to accept all BTM (Behind The Meter) activities as every citizens right under the GEA (Green Energy Act) and possibly also under the Canadian Charter of Rights and Freedoms. The IESO and LDCs should not have the right to stop or hinder anyone in the province from doing their part to reduce consumption and/or self generation of energy.

 

I encourage the Minister to initiate changes to the OBC (Ontario Building Code) so that – starting as soon as possible – all new detached and semi-detached housing starts MUST incorporate between 1000 W and 2000 W (1 kW to 2 kW) of Solar PV in a Net Metered arrangement. Further, all building permits should adhere to some expected level of electrical energy efficiency.

 

I encourage the Minister to immediately stop any and all salary increases within the “electricity and energy” sectors and to start demanding early retirement. The existing attrition rate seems low as if being employed in this sector is a guaranteed for life job.

 

I encourage the Minister to consider conclusions made by Mr. Elston’s in his report December 2012, two points stand out: (1) “It [Ontario’s electricity system] is not suitable, however, for the challenges and the opportunities of the future. This province needs a stronger, more innovative distribution system that can meet the changing needs of the consumer and the province.” and (2) “The Panel believes most municipalities and LDCs understand the status quo will not serve the citizens of the province well in the decades to come.”

 

Conservation First

 

There is a conflict of interest with the existing Energy Conservation programs administered by the IESO and LDC’s. The IESO and LDC’s concoct their own rules to serve their own purposes which leads one to believe real change towards true energy efficiency is stymied in-favour of higher energy options. Clearly the IESO has a vested interest in status quo and therefore the Minister must send a clear directive to the IESO and LDC’s to stand-down and facilitate energy conservation.

 

The Minister must direct the IESO and LDC’s to co-operate enthusiastically on all Energy Conservation efforts and Renewable Energy projects especially those that serve to reduce daytime usage of energy.

 

To really drive home the Conservation First message, I encourage the Minister to consider imposing penalties equivalent to double the incentives provided by LDC CDM Target and Budget Allocations. In other words, energy reduction efforts reward LDCs at a staggering rate of $0.25/kWh yet most LDCs struggle to meet their minuscule targets. To encourage meeting/exceeding targets, there needs to be a deterrent… a $0.50/kWh penalty on shortfall. Currently most LDC’s are not focused on real energy conservation efforts and the IESO has an inherent Centralized Power mindset based on ever increasing energy demand.

 

I encourage the Minister to support development of advance energy processing systems for commercial/industrial buildings with flat roofs that can easily accommodate roof top solar PV.

 

Creation of Energy Ombudsman

 

There needs to be an impartial body, perhaps the Social Justice Tribunals Ontario (SJTO) could have a ninth adjudicative tribunal assigned for matters relating to Energy. We need somewhere that we can take arguments for/against a particular process, and address such concerns in a timely fashion. Many existing rules favour the establishment and challenging those rules is difficult if not impossible.

 

Avoid Top Down Centralized Planning

 

I encourage the Minister to stop using only top down models based on centralized energy and delivery plans with ever increasing base load. The OPO data shows the past decade increased slightly but when exports are considered demand decreased. Unfortunately the OPO does not include clear data therefore a true picture of provincial energy ebb and flow is not known.

 

Community Power

 

Encourage Sustainable Development by mandating the IESO and LDCs to allow Community Power. Communities must be permitted to act independently and develop their own low-carbon energy systems that support their own local economy. The goal should be to move towards regional and community energy self-sufficiency. This can be achieved – if allowed and encouraged – and it will serve to benefit the existing infrastructure by reducing line losses; a win-win for all.

 

An integrated approach must be permitted such that privately-owned DG, energy conservation, storage, and community energy self-sufficiency can flourish. These will all be integral to the future distribution and transmission systems therefore steps must be taken now in LTEP 2017 to prepare the grid for multiple energy inputs.

 

Bio Energy is largely ignored in the planning documents yet there is great potential in all parts of Ontario and those communities that already have systems connected need billing adjustments made so they are not treated as consumers. Encourage Combined Heat and Power (CHP) plants thereby maximizing efficiency and flexibility.

 

Other Efforts

 

Set aggressive targets for heavy trucking to reduce Fuel consumption and GHG emissions, example: City of Toronto garbage trucks on the 401 (between Toronto and Michigan) have no aerodynamic enhancements and therefore consume more fuel and emit more GHG than needed.

 

Mitigate future stranded assets by cancelling the rebuilding of 50% of the nuclear reactors. Decentralized electricity supply is the future and it works and it is far more cost effective in the long run and best of all, it does NOT produce radioactive waste for future generations.

 

Support proponents of alternative energy on an equal basis as the Centralized Power consortium has been supported in the past. Groups such as OSEA (Ontario Sustainable Energy Association) are leading the way in demonstrating alternatives are viable and available and have no harmful side effects. If the rest of the world can do it, Ontario can too and become a leader.

 

Put more funding into P2G (Power to Gas) energy storage; Ontario has vast caverns for storing NG and we have an abundant supply of night time electrical energy to produce the Hydrogen… P2G is an excellent win-win solution.

 

Prohibit Power Workers Union and OMERs from holding shares in Bruce Power. This is clearly a conflict of interest as PWU will roadblock any DG/MG projects to protect their stock options. Allowing ownership in foreign power generation is one thing but local generation is another.

 

Ban advertising claiming Nuclear power is clean. Nuclear power is not clean, it’s deadly and dangerous for generations to come. We are burdening our children’s children with radioactive waste and we need to look no further than the mess at both Chernobyl and Fukushima nuclear power sites to see how devastating the consequences can be.

 

[Original Comment ID: 207111]