The Clean Air Partnership…

ERO number

019-2149

Comment ID

48416

Commenting on behalf of

Clean Air Partnership and Clean Air Council

Comment status

Comment approved More about comment statuses

Comment

The Clean Air Partnership and the Clean Air Council (CAC) would like to recommend to the Province that there should be a timeframe/deadline allocated to the development of a LTEP for the Province. We recognize that the February 2021 deadline may need to be extended, but there should be a timeframe/deadline allocated to the LTEP. It ensures government accountability and transparency. If Ontario does not commit to a timeframe for the updates to its LTEP it will set up Ontario to fall behind on the energy transformation taking place in communities across Canada and the world and result in Ontario becoming less competitive and less prepared to move towards increasing efficiency and distributed energy opportunities. It would make ideal sense that the LTEP should be for a 4 year term and then coincide with the government direction and platform. It would also be ideal if the LTEP that is developed would move Ontarians in the direction of being able to compare their energy need options. For example:

There is the need for the Province to Develop an Energy Transition Road Map and Decision Making Matrix. The province, municipalities and utilities need to work together to develop and navigate a road map for the transition to a more decentralized energy system. Suggestions that CAC members would like to work with provincial and utility partners to develop and test include analysis of the following:

Identify potential futures: Accessing ever deeper energy efficiency opportunities (Conservation First principle); business as usual generation (centralized system); decentralized generation (community with or without micro grid); individual generation (not connected up to any other grid simply at the building level) and how these scenarios impact or support each other.

Identification of the various pros and cons; costs and benefits associated with each of the scenarios, and development of a decision matrix to compare among them.

Review of the various scenarios from a variety of different lenses: provincial system, local/community system; resilience; climate; economics and economic development; social, short term, longer-term, market transformation, etc.

New developments present an ideal opportunity to test out the above energy decision matrix and this would also present an opportunity to increase alignment between land use/growth planning and Ontario's energy decisions. In order to increase alignment between land use planning and energy planning, municipal planners and utility planners should 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 need for new transmission and distribution infrastructure. This consideration should also be applied to the IESO’s Regional Energy Planning exercise through the incorporation of the above mentioned energy decision matrix to be better equipped for decentralized electricity systems to be able to serve as an alternative to, or complement to, future investments in electrical transmission and distribution infrastructure.

The LTEP should also be aligned with Ontario's GHG reduction targets and its Environment Plan.