ERO 019-8562 Climate Action…

ERO 019-8562
Climate Action Newmarket-Aurora input and letter Submitted to ERO May 4/2024
Proposed Regulations Under the Ontario Energy Board Act, 1998 to Support Building Homes and Transit Faster by Prescribing Conditions for Fast-Tracking Approval of Certain Small Energy Infrastructure Projects

Climate Action Newmarket-Aurora approves of enhancement lines for electricity, if Indigenous Peoples’ Duty to Consult is in place. It is opposed to the proposed regulation changes suggested by this ERO and subsequent legislation, similarly with Bill 165 Keeping Costs Down, whereby the oversight of the Ontario Energy Board is eroded, more fossil gas pipelines are developed thus increasing GHG emissions, and DTC of First Nations is diminished.

The government’s ‘mandate to rebuild Ontario’s economy’ with the help of ERO 019-8562, the 413, and BIll 165, is false. The only economy it builds is that of fossil fuels. Jobs and businesses exist in clean energies and could be increased exponentially if not for the misguided steps of this government, like not revisiting offshore wind which would on its own, meet Ontario’s energy needs. Utilizing taxpayer money to create the infrastructure to align clean alternative energy sources to the grid like Toronto’s Enwave Energy Corp’s Deep Lake Water Cooling, and innovative storage facilities is the right way to go. Improving the electrification infrastructure of Ontario is the right way to go yet the federal and provincial carbon reduction investment in EVs and EV batteries will be nullified if our electricity is increasingly created by fossil gas. Emissions in Ontario are already set to rise 400% by 2030 because of this government’s plan to use more fossil gas to produce electricity when already viable clean alternatives exist, 750 of which were cancelled by this government.

ERO 019-8562 continues to reaffirm BIll 165 that costs ‘are not expected to have a significant impact on other electricity ratepayers’ yet one km of gas pipeline costs approximately $1.5 million so there would be some undisclosed increase and new homeowners would have to pay the hook up and amortization costs. Instead, developers and Enbridge should cover the cost since they will be making the profit? Perhaps the Auditor General needs to review this in consideration of the profit margins of developers as well as the 2023 $43.6 billion profit for Enbridge shareholders when we are focusing on ‘affordable and sustainable housing’?

The government is stating that the OEB’s decision to say no to amortizing the cost of further gas pipeline infrastructure for new builds is ‘rash’ and ‘could cost’ new homeowners thousands more dollars to purchase a home. The OEB decision highlights the additional gas pipeline and hook up costs of urban sprawl plans (such as Bill 162 and ERO 019-8364), for which most of the homes will not be ‘affordable’. The OEB doesn’t wish to have amortization of the costs for fossil gas to be tacked on for the consumers for the next 40 years and states after more than a year long process of consultation with energy experts, financial research, and publishing thousands of pages of reports to this effect, that Enbridge and developers should have to pay to provide a service from which it will reap immense profit. The OEB is looking out for Ontarians.

It is proven that air heat pumps drastically reduce energy bills, given less or no need for fossil gas, and therefore notably reducing its hold in the marketplace. This government refuses to legislate or offer wider incentives for air heat pumps to be included in new builds and yet also denies rebates to retrofit current homes unless those homes are already fully electric. This inaction increases costs and emissions for everyone.

Bill 165 implies that the OEB is not holding ‘fair and informed hearings’. The OEB Pipeline Coordinating Committee reviews specific and detailed project environmental assessments based on the 1998 Ontario Energy Board Act , reports by energy companies and raises concerns prior to a project going to the OEB for approval. The OEB heard many submissions over the span of a year and also considered the future costs to Ontarians of expanding gas pipelines when cities and countries are banning fossil gas. Ontarians will continue to pay for an underutilized system, and have to pay for retrofits when fossil gas is no longer in use, as soon as 5 years from now.

This legislation comes on the heels of the government pushing for gas plant expansions which municipalities have categorically said they will not have, increasing output from existing plants when many say its not needed, and not advertising that the cost of energy will double because of their current plan to use fossil gas for electricity generation for the foreseeable future. Conversely, the federal government’s Canada Carbon Rebate puts more money into the individual’s hand than many pay out and has been shown to shift industry into cleaner practices with less emissions. Ontario is part of this federal rebate plan by its own choice, because the current government got rid of the cap and trade system that was in place previously.

If the government was really committed to lowering costs and climate action, in addition to air heat pumps, it would have legislated increased housing density percentages beyond transit areas (BIll 185) to prevent urban sprawl and the cost of more expanded infrastructure, and increased the percentage of required affordable housing for new developments. It has not. This will cause more emissions and more costs.

Any Bill providing a fossil gas choice is providing more costs to the homeowner down the line when fossil gas is no longer available, viable or permitted. Millions of consumers around the world and in Canada, including Ontario, are moving away from methane-heavy fossil gas because of the climate damage it does but also because of the health issues it silently bestows on its consumers, especially children. Enbridge advertising is like that of the tobacco industry who said it was trying to help people quit cigarettes and that vaping reduced the chance of certain cancers; yet it didn’t advertise what it could cause; we now know the damage. We already know the damage methane of fossil gas is doing. The government should be safeguarding the public and planet while being a leader of clean energy, clean homes, clean communities and clean economies.

Global clean energy investment is overtaking that of fossil fuel yet this government would have us fall behind in that marketplace, keep our own energy costs up for the profit of a few, and continue to allow emissions to rise, costing us more across the board and losing investors.

Additionally, this legislation supports BIll 165 to override the decision made by the independent energy oversight body, the OEB, while also now eliminating its oversight for these future gas pipelines with this ERO. The OEB’s role is to ‘protect the public and drive energy sector performance’. It makes ‘decisions and rules to ensure that consumers are treated fairly and that the energy sector is reliable and sustainable’. Fossil gas is one of the most costly sources of energy, is not considered sustainable, and is one of the worst contributors to the climate crisis through methane emissions.

Moreover, while this ERO notes that Indigenous communities can raise any Duty To Consult concerns during a project, this ERO limits that DTC to jobs costing between $2 million to $10 million. On average, 1 km of gas pipeline costs over $1 million. This undermines UNDRIP and Indigenous communities have already voiced this concern. This ERO also refers to Schedule 35 of the Electricity Act whereby Indigenous concerns will be balanced with the ‘impact on existing electricity consumers’ and ‘the impacts on Ontario's electricity distribution and transmission utilities and other stakeholders’. This basically translates that DTC can be overruled at any time.

Bill 165, Keeping Costs Down Act, and this ERO have been tabled on the premise that it will help Ontarians by keeping their energy bills low, ‘to ensure fair and informed decision-making at the OEB to foster affordable communities’. This letter shows how the OEB is fulfilling its mandate and that means a significant loss of revenue for Enbridge and developers. This Bill and ERO 019-8562 will increase costs for homeowners and taxpayers. This Bill and ERO 019-8562 continues this government’s detrimental path to undermine our economy, our democracy, our health and the global climate.

Climate Action Newmarket Aurora opposes Bill 165, and ERO 019-8562.

Supporting Links:

summary article on the information hidden by this government
OEB environmental process guidelines
OEB application process
OEB project planning review process
Ontario's energy options: cost comparison (Clean Air Alliance source)
one example of financial investment info on clean energy being cheaper than fos…
a sample demonstrating the increasing cost of natural gas (from within the natu…
Enbridge Profits
a sample article on the health and climate dangers of methane emissions
https://betterdwelling.com/home-builder-profit-margins-increased-in-can…

Should new homes in Ontario be connected to natural gas? | The Narwhal.

Ontario's carbon emissions jump back to pre-pandemic levels | CBC News.

Why are Ontario’s Greenhouse Gas emissions going up instead of down? - Environmental Defence

Response to Canada’s Latest Greenhouse Gas Emissions Data - Environmental Defence

Ontario energy grid emissions set to skyrocket 400% as Ford government cranks up the gas

Natural Gas Phase-Out Study

The world’s largest deep lake water cooling project just got bigger - The Globe and Mail

https://docs2.cer-rec.gc.ca/ll-eng/llisapi.dll/fetch/2000/90464/90550/3…

Duty to consult with Aboriginal peoples in Ontario

Bill 185, Cutting Red Tape to Build More Homes Act, 2024 - Legislative Assembly of Ontario