(this fixes an error in my…

(this fixes an error in my earlier submission - please delete the earlier version if possible)

The proposed CEC registry misses a major consideration for much of the energy that is produced and consumed in Ontario.

Ground source (GSHP) and air source (ASHP) heat pumps produce zero-emission renewable energy from the ground or air, which qualifies them as non-emitting energy facilities. Recognition of this fact would help businesses meet their environmental and sustainability goals, support system owners by offsetting installation costs from CEC sales, and lead the province’s efforts to decarbonize by supporting investment in production and consumption of clean renewable energy.

Federal data (NRCan OEE 2019) quantify that Ontario’s residential sector consumed 138,416,667 MWh of thermal energy (space heating, water heating, space cooling) that year, while the CI sector consumed 83,500,000 MWh. These applications accounted for 20 Mt of the residential sector’s total GHG emissions of 20.2 Mt (excluding electricity impact), and 12.5 Mt of the CI sector’s total emissions of 13 Mt.

If these three applications had been supplied from GSHP and ASHP, the total of 222,000,000 MWh would have contributed significant positive environmental attributes, even after the technologies consume grid power to run their components (70,000,000 MWh assuming a minimum COP of 3.2). Electricity is a carrier – not an energy – and a minor portion of the province’s energy consumption.

Inclusion of these renewable energy producing systems in a registry for the voluntary purchase of CECs would allow consumers to demonstrate compliance with clean and renewable energy targets by enabling transparency around the creation, trading, and retirement of CECs produced in Ontario.

Ontario’s investment in nuclear, hydro, wind, solar and bio-energy would be optimized if the registry encourages the efficient use of electricity to thermal applications which produce renewable energy with the assistance of a low-emission grid. Relevant to the Minister’s guidance to the IESO, renewable energy produced by GSHP and ASHP is produced and consumed in the province; it would offer CECs from all non-emitting sources in different areas of the province; it would monetize investments made in Ontario; and it would offer flexibility and the potential for future expansion to other products or markets.

NetZeroPLUS Canada is working on a system to use web-based tools to monitor the production of renewable energy in real time, which would complement your goal to recognize and display output of our systems for certification and tracking. It would de-facto provide a unique identifying tag for the producing facility, date and time, and more.

Inclusion of the renewable energy produced by GSHP and ASHP systems would enhance the value of the proposed registry in areas which your discussion paper does not even address, all to the benefit of the province and its residents, and our suggested inclusion would position Ontario into a leadership position in the recognition of ALL renewable energy sources and their concomitant reduction of carbon emissions here and around the world.