City of Guelph   …

City of Guelph

 

Submission to the EBR Registry Posting 012-8840

 

December 16, 2016

 

The City of Guelph approved a Community Energy Plan in April 2007. Since renamed the Community Energy Initiative (CEI), the original Plan is in its 10th year of implementation and now counted among over 200 community energy plans in development or implementation across Canada.

 

The current goals of the CEI are a 50% per capita reduction in energy use and a 60% per capita reduction in GHG emissions by 2031.

 

The activities defined in the CEI focus on four main areas:

 

1.Energy Efficiency and Conservation

 

2.Local Generation

 

3.Local Electrical and Thermal Distribution

 

4.Urban Planning (that enables items #1 through #3)

 

The City has positioned its energy planning as an economic development objective. The Community Energy file is overseen in coordination with Economic Development and Downtown Renewal under the banner of Business Development and Enterprise.

 

In mid-2016, Council approved an update to the Community Energy Initiative to reflect a 10-year change in:

 

1.Market conditions;

 

2.Technological innovation; and

 

3.Policy context with the other orders of government.

 

This is why we are pleased to have the opportunity to submit our comments to the Province’s Long Term Energy Plan consultations. We thank the Ministry of Energy and its affiliated agencies, the Ontario Energy Board (OEB) and the Independent Electricity System Operator (IESO) for their support for policies and programs that support the goals of Guelph’s CEI and the growing number of similar initiatives underway in cities and towns across the Province.

 

The City encourages the Province’s support for networking organizations such as Quality Urban Energy Systems of Tomorrow (QUEST) – Ontario Caucus and the Clean Air Council. Like them, we believe that municipalities can play a significant role in helping the Province to achieve its climate change and energy-related objectives.

 

With this in mind, we offer the following comments:

 

Local Energy Plans and Relations to Provincial Plans

 

•Increase Energy Literacy: Community Energy Planning was referenced within the Province’s Climate Action Plan; however, in order to better integrate it with the Long Term Energy Plan, there is the need to increase energy literacy for municipalities and the public. As such, there is the need to enhance the understanding of the provincial electrical system and the factors affecting it. There is also the need to consider both electricity and natural gas in a more integrated fashion. Adopting and advancing policies such as Energy Reporting and Benchmarking and Home Energy Ratings and Disclosure will be critical to increasing energy literacy and informing and engaging energy consumers; but it is also critical that these policies are supported and accompanied by training and education.

 

•Improve the ability of Municipalities and their Stakeholders to Implement CEPs: While CEPs are challenging to develop; their implementation is an even greater challenge. There are significant regulatory, bureaucratic, institutional and financial barriers associated with advancing community energy projects. Specifically, the City of Guelph has developed a program based on the Local Improvement Charge (LIC) mechanism. The program is called the Guelph Energy Efficiency Retrofit Strategy (GEERS). The City encourages the Province’s financial participation and support in LIC-based building retrofit programs through the “Green Bank” under the auspices of the Climate Change Action Plan.

 

•District Energy systems can play a substantially larger role in enabling communities to meet their electricity and thermal needs in a more efficient and cost effective manner. However in order for District Energy to generate greenhouse gas reduction and resilience opportunities, the Province is encouraged to consider ways to support the difficult start-up period in developing integrated thermal distribution networks.

 

•Green Development Standards/Climate Change by-laws may be able to support community energy implementation, but only if municipal authority in this area extends to the building level. The City of Guelph looks forward to working with the Ministry of Municipal Affairs on updates to the Ontario Building Code to bring the Code into alignment with the Province’s Climate Change Action Plan.

 

Community Energy Plans and Utilities

 

•There are regulatory limitations for utilities to engage in Community Energy Planning based in applying rate-based financing. Community energy projects cannot access rate-based financing and municipalities are unable to mandate energy connections to ensure a long-term customer base for community energy projects. To address the regulatory framework in which community energy projects exist, the Province and Municipalities must work together.

 

•In order to increase alignment between land use planning and energy planning, municipal planners and utility planners could be more proactive in identifying energy demand from new developments. It is important to recognize energy limitations and where community energy may be best able to address local energy demand. Increased communication earlier in the process by the necessary stakeholders may also address the challenges distributed energy projects face when connecting to the existing grid and how targeted conservation and distributed renewables can best reduce the need for new transmission and distribution infrastructure. This consideration should also be applied to the IESO’s Regional Energy Planning exercise through incorporation of a lens for decentralized electricity systems as an alternative to, or complement to, future investments in electrical transmission and distribution infrastructure.

 

•Regarding energy data, the Ministry of Energy, Local Distribution Companies, and municipalities need to work more collaboratively  to improve access to energy use data to help understand how energy is used in Ontario communities. From past experience, municipalities have had to allocate a significant amount of time and staff resources to gathering energy use data for their CEPs. This increased time and staff resources for data collection has reduced the resources available for implementation and is highly inefficient. Improving access to community energy use as well as analysis was identified as part of the province’s Climate Change Action Plan and references to furthering that goal should also be addressed in the upcoming Long Term Energy Plan.

 

Natural Gas

 

•It will be important to be able to look at Renewable Natural Gas (RNG) and the role that municipal sewage, landfill sites, and solid organic waste can play in increasing RNG supply. Offsets may also create RNG opportunities. There is a need for the province, utilities and municipalities to work together to further develop the business case for RNG. In addition, the province should set RNG targets.

 

Micro-Grids

 

•Micro grids are important in the technological advancement of our communities’ energy systems. A greater understanding of micro grid projects being undertaken is needed to identify the opportunities and challenges of moving away from our traditional grids.  The City of Guelph looks forward to learning more from the IESO and utilities on micro grid projects being tested in Ontario.

 

•The City also encourages the province to consider supporting LDCs to make the necessary changes to increase grid capacity to integrate higher levels of distributed, renewable generation.

 

[Original Comment ID: 207150]