The Canadian Renewable…

The Canadian Renewable Energy Association (CanREA) appreciates the opportunity to provide comment on the proposal to repeal certain sections of the Electricity Act, 1998 and the Ontario Energy Board Act, 1998 pertaining to the promotion and prioritization of the development of renewable energy. CanREA is the national industry association serving as the voice for Canada’s wind energy, solar energy and energy storage solutions that will power our energy future.

On behalf of our diverse member companies, we advocate for the advancement of modern energy systems through stakeholder advocacy and public engagement. Our membership includes world class generators, utilities and manufacturers, all well positioned to deliver clean, low-cost, reliable, flexible and scalable solutions for Canada’s energy needs. CanREA objects to the proposed changes as we believe that they will delay the decarbonization of Ontario’s electricity sector while increasing costs for consumers and undermining energy system innovation.

 Proposal to repeal section 25.37 and clause 114 (1.4) (0.a.1) of the Electricity Act, 1998:

Distributed Energy Resources (DERs) encompass small-scale renewable and non-renewable generation and energy storage technologies, connected to distribution rather than transmission networks. DERs can make a significant contribution to reducing system operations costs and delaying or avoiding the construction of new electricity transmission, distribution and utility-scale generation infrastructure, thereby providing significant financial savings to ratepayers while helping to decarbonize the electricity system and enhance energy system resilience.

Ontario is already the most complicated and challenging jurisdiction in North America in which to connect a Distributed Energy Resource of any kind, and thus we are far behind neighbouring US states (notably New York) in realizing the economic and environmental benefits of these technologies.
Reducing the requirement for LDCs, Hydro One and the IESO to provide accurate and up-to-date information regarding the distribution system’s or transmission system’s ability to accommodate generation from a renewable energy generation facility will create needless obstacles to connecting new DERs of all technology types.

This will stifle private sector investment in Ontario’s energy sector and will result in wasted time and resources, with DER developers filing futile connection applications for areas on the grid where no capacity is available, because the transmission and distribution networks will be under no obligation to share even this basic information. Given that the networks collect and maintain this information as part of their normal day to day operations, there will be no financial savings associated with removing the requirement for this information to be published.

CanREA therefore rejects the assertion that “removing these provisions would help make Ontario more competitive by cutting red tape and reducing regulatory burden”. Furthermore, the claim that this reform “aligns” with the Ontario Energy Board DER Connections Review initiative is incorrect, as no such recommendation has arisen from the Connections Review process, in which CanREA is an active participant. In fact, the Connections Review working group has put forward a number of recommendations related to increasing LDC reporting requirements with respect to facilitating DER connections. Greater reporting and transparency related to all DERs is still needed and supported by a broad cross-section of industry stakeholders, including but by no means limited to those representing renewable generation assets.

 Proposal to repeal paragraph 2 of section 96(2) of the Ontario Energy Board Act

Similar to the foregoing, this proposal to remove “use and promotion of renewable energy” from the criteria for determining whether the construction, expansion or reinforcement of an electricity transmission or distribution line or interconnection is in the public interest will also delay the decarbonization of Ontario’s electricity sector, while failing to reduce costs for consumers and undermining energy system innovation.

Removing this provision from the Ontario Energy Board Act would have a chilling effect with respect to future consideration of non-wires alternatives to costly transmission and distribution lines, thereby helping to entrench emissions-intensive infrastructure and undermining energy system innovation and flexibility. This is a regressive step that will damage investor confidence among those seeking to deploy innovative and low-carbon DER solutions in our province.

CanREA believes that repealing these sections of the Electricity Act and Ontario Energy Board Act risk eroding transparency and accountability for Ontario’s energy network owners and operators, stifling innovation and private sector investment, entrenching costly and emissions-intensive infrastructure and delaying energy system decarbonization, without providing any substantive savings to ratepayers. The Government of Ontario has not demonstrated the need for these reforms to move forward.

Thank you for your consideration of our comments.