Comment
Re. Ontario Long-Term Energy Plan (LTEP) review
Toronto's urban energy needs are rapidly changing mainly due to three drivers: intensification growth, resilience, and climate change.
GROWTH
Toronto continues to experience significant intensification growth, driven by targets in the 2006 Provincial Smart Growth Act, echoed in our Official Plan. Increases in electrical peak demand are expected to continue in Toronto, particularly in the downtown core from new buildings, along the avenues for electric transit, and from displacement of fossil fuels to achieve climate change goals.
As indicated in our input to the 2013 Long Term Energy Plan - LTEP (see letter attached), we continue to be concerned that the traditional approach of exclusively large electricity infrastructure planning has a lead time that is well beyond the critical growth period for Toronto.
The next LTEP is well positioned to advance a whole 'energy' strategy (not just electricity), provide a policy framework, and play a coordinating role, including Ministry of Energy and Climate Change, Minister of Municipal Affairs, on urban energy issues and ensure energy does not become a limiting factor for smart growth, prosperity, and addressing climate change.
RESILIENCE
The 2013 summer flood and winter ice storm exposed significant electricity vulnerabilities in the City of Toronto. In addition, the trend towards urban vertical growth (multi-residential buildings), significantly increases the vulnerability of residents during these multi-day, area-wide power outage occurrences.
The City of Toronto has published a voluntary guideline for minimum back-up power in multi-residential buildings (www.toronto.ca/communityenergy)
There is significant work to do on a provincial energy resilience strategy as part of the LTEP, to signal changes to the Building Code, including back-up power standards in the event of multi-day, area-wide power outages.
CLIMATE CHANGE
Approximately 80 per cent of Toronto's greenhouse gas (GHG) emissions are from natural gas use in buildings and fossil fuel use in vehicles. Ontario's climate change action plan and Toronto's climate action plan focus on reducing use of fossil fuels, which in turn puts significant pressure on electricity for heating buildings and electric transit/vehicles.
Moreover, as Toronto continues to develop net-zero Community Energy Plans, including the Port Lands and other growth areas, demand for natural gas distribution networks will be greatly diminished in these areas potentially affecting the business model/franchise of OEB regulated utilities.
The new LTEP needs to be in alignment with Ontario's Climate Action Plan and cap & trade. Energy demand projections and targets are needed to match GHG emission targets at the provincial and regional level.
ENERGY PLANNING: Regional and Municipal
Toronto staff are engaged in the Independent Electricity System Operator's (IESO) Central Toronto Regional Plan Local Advisory Committee. As requested by the IESO, City staff made a presentation on City of Toronto priorities.
Please click on the slide to see the presentation or use the link below. https://prezi.com/7gakl0tfvy7z/2016-06-01-energy-crunch-in-the-city-city-of-toronto-ieso-local-advi sory-committee-meeting-2/
In January 2017, the City if Toronto will launch Toronto's Energy Future, an energy plan sponsored by the Ministry of Energy's Municipal Energy Plan program. Toronto's Energy Future plan will be aligned with Toronto's Climate Change Action Plan (www.toronto.ca/transformTO)
REGULATORY ENVIRONMENT
The next LTEP is well positioned to advance a whole 'energy' strategy, not just electricity, for the expected shift from fossil fuels to electricity in cities, including repositioning the Ontario Energy Board as an enabler of change.
There is an opportunity to expand the scope of the next LTEP to specifically address urban energy issues to ensure comprehensive energy planning enables smart growth, prosperity, and climate change action plans.
Please contact Jim Baxter, Director Environment and Energy Division, if necessary, to further discuss the scope of the new LTEP at 416.338.1295 or jbaxter2@toronto.ca.
Sincerely,
Josie Scioli
Chief Corporate Officer
City of Toronto
cc. Roberto Rossini, Deputy City Manager & Chief Financial Officer, City of Toronto
Peter Notaro, Executive Director, Strategic and Corporate Policy, City of Toronto
Jim Baxter, Director, Environment and Energy Division, City of Toronto
[Original Comment ID: 207144]
Submitted June 8, 2018 4:22 PM
Comment on
Planning Ontario's energy future: A discussion guide to start the conversation
ERO number
012-8840
Comment ID
4841
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