Hamilton Community…

Hamilton Community Enterprise's appreciates the Ontario Governments dedication to developing an integrated approach to developing energy infrastructure.

While it is important to consider a holistic, province wide, approach to how a diverse, integrated energy strategy can increase power generation, ensure energy resilience, and maintain energy affordability - it is equally important to empower local utilities to develop their own integrated energy strategies, that leverage local opportunities for energy efficiency and decarbonization.

Integrated Community Energy Systems, when properly incentivized through regional energy planning, can provide the rate base with affordable, resilient, sustainable heating, cooling and electricity while also reducing the total energy impact of that community on the electrical grid.
Integrated community energy systems, go beyond Distributed Energy Resources (DERs), and represent a systematic change to the energy planning process.

Rather than decoupling site planning (demands) and integrated energy procurement (supply), a properly dimensioned Integrated Community Energy System policy framework incentivizes developers to work with local utilities to develop a comprehensive energy plan for new developments.

These plans leverage the energy opportunities specifical to that location, such as - renewable generation capabilities, waste heat recovery (sewer, datacenter, industry) or transmission capacity, to develop an integrated strategy around these opportunities.

As an illustrative example, a new AI data center can be expected to have an electrical load of approximately 500MW and, at the same time, may reject waste heat of roughly 300 MW to the environment. If this waste heat is harvested and utilized for building heating, it will offset at least 100 MW of electricity that might otherwise be generated to meet the same building heating demand.

In other words, harvesting waste heat energy becomes an effective electrical conservation measure enabled by Integrated Community Energy Systems and results in a 20% increase in energy utilization.

This practice is not theoretical and has been adopted in jurisdictions that have regulations that support Integrated Community Energy System planning. A few examples include:

- Stockholm Exergi, Stockholm, Sweden - a regulated district heating company that provides heating to 31,000 residents using excess waste energy from a multiple datacenters

- Taylor Lumber Co, Middle Musquodoboit, Nova Scotia - a sawmill plant, using biomass waste from its operations to provide most of the fuel for the facility’s power and heat requirements. Surplus energy is sold to a local utility company.

In both these cases, private sector investment is being made based on an operational benefit gained by the business (net new revenue stream / waste recovery & cost reduction) and this in turn has a net benefit on the local grid (decreased energy demands).

To foster these types of developments within Ontario, policy changes must be enacted to incentivize these types of private sector investments by de-risking the long-term operations of these local energy assets and enabling local utilities to property account for these assets as part of their distributed system operations.

HCE is a strong believer in community-driven solutions that are sited with energy demands, provide multiple values, and are in line with our diverse needs, supported by network-wide expertise including partnerships with developers and First Nations.

We strongly recommend expanding the official regional planning working group to include community representatives and developers to help ensure sufficient lead time for market exploration of Integrated Community Energy Systems and other non-wires solutions in response to the load and/or supply constraints of that region.

In addition, we would benefit from having access to:

- Resources (such as risk assessment tools and technical guidance) including dedicated funding from the province that can support decision making for project selection in response to a forecasted load; and

- know-hows for HCE to be able to procure our own local Integrated Community Energy Systems co-sited with a load growth or constraint issue, including best practices for securing equity ownership in projects.