GHG reduction strategies…

GHG reduction strategies particularly related to shifting natural gas heating loads to electricity, require a valid accounting of net reductions which are not currently in use. Natural gas upstream fugitive methane GWP over the next twenty years triples current accounting methods. Additionally, impacts of demand-side activities require  marginal operation and marginal construction calculation procedures based on locational and temporal system response. It is of utmost priority to generate the accounting protocols and undertake GHG analysis for scenarios.

Current IESO capacity projections for fuel switching are in error by several-fold. If 50% of fossil-fuel heating is converted to air-source heat pumps, Scenario D, the peak demand will be 3 times the current peak and will occur in winter. This would necessitate a massive expansion in generation capacity to serve on demand and idle for most of the time. Natural gas generation to serve this load, would result in increased gas usage hence GHG emissions.

If 'conservation' is the first option and includes demand management, then building design and retrofit are the priority activities. Although the fuel and electricity industry are stakeholders that have been consulted, the Ministry has failed to engage building energy engineers in pre-planning analysis. Without doing so, there is no chance that a workable plan will be derived. Without transparent and defensible GHG accounting methods in place, Climate Change policies will have little or perverse influence on outcomes.

[Original Comment ID: 204879]