The Clean Air Council (CAC)…

The Clean Air Council (CAC) is a network of over 30 municipalities and health units from across the Greater Toronto, Hamilton and Southern Ontario region who collaboratively work on the development and implementation of clean air and climate change mitigation and adaptation actions.
CAC members do not support the repeal of the legislative provisions in the Electricity Act, 1998 (EA) and the Ontario Energy Board Act, 1998 (OEBA) that promote and prioritize renewable energy generation projects. Ontario has made significant progress on eliminating coal from electricity generation, however there is the recognition that for the Province of Ontario and each of the CAC municipalities to achieve their GHG reduction targets, there is the need to ensure that Ontario is undertaking actions that will enable it to phase out fossil fuel use from the electricity system. For this to happen, however, there is the need for the Province of Ontario to advance the decarbonization of the electricity system and renewables and other distributed energy resources. It is also concerning that the ERO posting stated that the Province of Ontario believes: “Prioritizing renewable generation is no longer appropriate. Going forward, Ontario will ensure value for ratepayers by allowing all resources to compete to meet system needs.”
Prioritizing distributed energy opportunities such as renewables is key to ensuring value for ratepayers. The global energy system will be experiencing a significant transformation in the coming decade as distributed energy solutions become more cost effective and enable communities to meet local energy needs with local energy solutions. There is recognition that the costs for renewables and storage continues to drop and has achieved price parity in many jurisdictions. There is also recognition that while nuclear can provide base load, nuclear generation prices continue to increase. Moving towards lower cost and more responsive/resilient distributed energy opportunities is key for ensuring value for ratepayers. There is no doubt that Ontarians want to ensure that we get as much value in our existing electricity system as possible. It does need to be recognized, however, that at present there is not an equal playing field across the different options available to Ontarians to meet our energy needs. The Clean Air Council has been asking the Province to develop a level playing field across energy options via the development of an Energy Decision Making Matrix to help understand and compare potential options for meeting our energy needs. Some of the areas we would like to better understand include:
• Advancing deeper and all cost-effective energy efficiency opportunities;
• Traditional, decentralized and individual generation scenarios, and how they impact or support each other;
• Identification of the various pros and cons, and costs and benefits associated with each of these scenarios, and the development of a transparent decision matrix to compare among them; and
• The application of different lenses to these decisions, including resilience, climate, traditional economic, social, market transformation, etc.
Without such a decision matrix it is likely that the distributed energy solutions will be at a disadvantage since much more focus has been placed on investing in big generation such as nuclear and natural gas expansion. For example, at present the OEB and IESO do not have a mandate to consider climate in their decision making. Considering that Ontario has committed in its Environment Plan to a 30% GHG reduction based on a 2005 baseline, it is neglectful that the entities responsible for delivering Ontario’s electricity system do not consider the climate impacts of their decisions. It is also disappointing that another opportunity to advance this was missed during the most recent Ministerial mandate letter that was sent to the IESO and the OEB re the CDM and DSM Framework not requiring any GHG analysis considerations or alignment with Ontario’s Environment Plan 2030 targets. Municipalities have been declaring climate emergencies and are working to apply a climate lens to their decision making. It would be logical for those entrenched in Ontario's energy system to also factor climate commitments and impacts into their decision making