The City of Ottawa declared…

The City of Ottawa declared a climate emergency on April 26, 2019.  On October 28, 2020, Energy Evolution, the City’s community energy transition plan, was passed unanimously by Ottawa City Council. Energy Evolution has identified short-, mid- and long-term targets to achieve community emission reductions of 100% by 2050 and corporate emission reductions of 100% by 2040 in an effort to keep global heating below the crucial threshold of 1.5°C.

Electrification will play a critical role in achieving these emission reductions. Since the Energy Evolution plan will see the City remaining heavily reliant on the Province’s bulk electricity system for its energy, Ottawa is advocating for zero emission generation at the provincial level to help reach its targets.

As mentioned in the feedback form to the IESO’s Clean Energy Credit (CEC) engagement, the City would like to reiterate that ratepayers have been paying to decarbonize the grid. Environmental attributes (EAs) from existing generation should be retired on behalf of ratepayers, following the IESO’s ‘Free Unbundled CEC Distribution’ option. If CECs are able to be purchased for electricity generated historically, this would affect scope 2 emissions accounting for the Province and organizations, including all electricity consumers in the city of Ottawa.

An additional benefit to the Free Unbundled CEC Distribution is that it guarantees that EAs from electricity generated in Ontario will stay in Ontario. Since the market is intended to be voluntary, some generators may be enticed to sell credits in other jurisdictions with higher credit prices. This option could be combined in a hybrid model with another product offering to provide a monetary benefit for new renewable energy generation in Ontario.

The City also encourages the Province to evaluate the effectiveness of CEC registries in other jurisdictions for their ability to encourage new renewable energy generation. NYISO’s 2021 Power Trends Report notes that the State and NYISO stakeholders see Buyer-Side Mitigation (BSM) measures as imposing unnecessary and unjust costs on to consumers and doing more harm than good. They acknowledge that the current BSM rules are not a lasting, durable solution. Another approach may be to increase the scope of the Community Net Metering program to encourage renewable generation in areas with growing electrical demand.

On the topic of CECs, the City has recently learned that OPG has been selling EAs of their generation to buyers outside of Ontario for some time. We have encouraged the IESO and OEB to investigate whether this practice has led to double counting and if generators have the authority to undertake trading of EAs from existing assets. The City is concerned that this has potential to affect the legitimacy of Ontario’s claims about the GHG intensity of the bulk electricity system supplied power, and in turn scope 2 emissions accounting for Ontario-based organizations and consumers in the city of Ottawa.