Guiding Questions…

Numéro du REO

019-9285

Identifiant (ID) du commentaire

122391

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire approuvé More about comment statuses

Commentaire

Guiding Questions

Overarching Question:

What policy options and actions should the government consider in the integrated energy resource plan to achieve Ontario’s vision for meeting growing energy needs, keeping energy affordable and reliable, ensuring customer choice and positioning us to be an energy superpower?

- The government should recognize the high social cost of climate change and the economic advantages of a defined strategy for clean generation with a moratorium on natural gas. With prices of renewable energy and batteries dropping by large amounts the policy should be forward looking and not reliant on status quo technology like it is now. This can also bring economic advantages and new developments and industries to the province beyond just manufacturing other peoples IP.

Planning for Growth

Building on the recommendations of the EETP’s final report, what actions should be prioritized to enhance planning across natural gas, electricity, and other fuels?
- The government should recognize the need to shift away from fossil fuels. A clear policy direction will support long-term investment in the province and provide clear signals for companies looking to invest. The current atmosphere of widely shifting vague policies is bad for business.
- The OEB should be directed to regulate to promote the energy transition shifting away from gas friendly approaches. There is no consumer benefit from not installing higher priced systems which will inevitably become stranded assets.

The government’s priority is to ensure Ontario has the energy resources it needs to support growth. Are there opportunities to enhance the province’s approach to procuring electricity generation supply to better serve this priority?
- The procurement of electricity should also focus on new technologies and customer choice allowing options to distributed energy and storage without paying punishing global adjustment and other costs. - Procurements should look at long-term costs and benefits, not only focusing on short term costs and savings with high discount rates. Generational assets such as hydro are important to the mix but often high priced up front and excluded. However, the existing fleet of hydro and pumped storage brings incredible value to rate payers and the energy system.

What actions should government consider to promote greater access to electricity and accelerate grid-connections that will support economic growth, connecting new homes, and electrifying transportation and heating?
- The government should institute new policies around EV adoption and EV readiness such as having new homes made EV ready. There should also be focus on distributed energy and local storage allowing consumers choice and increasing electrification with local supply. This also moves the cost closer to homeowners where the investment will result in eventual savings compared to gas alternatives.
-Investments in district heating and energy/heat storage are also good policies to support growth and heat buildings in cost effective ways.

As the need for new transmission infrastructure continues to grow, what steps can government take to ensure that transmitters have the certainty they require to move forward with development work as soon as possible, while also ensuring that competitive pressures keep costs as low as possible?
- A solid and stable long-term strategy and plan supports business in decision making. The government can also support the costs of early planning without making further commitments. This can de-risk investment planning and give the government greater certainty when procuring new transmission because planning will be further advanced and unforeseen cost over-runs will be less likely.

What policy guidance should the government provide to the Ontario Energy Board (OEB) with respect to the long-term role of natural gas in Ontario’s economy and opportunities for low-carbon alternatives in the gas system?
- The OEB should be directed to consider the energy transition in it's decision making recognizing the shift away from natural gas as a fuel and not force consumers to lock into costs for a soon to be stranded technology.
- The OEB should be directed to incentivize low-carbon alternatives such as to stop adopting policies that amortize natural gas over long periods of time.

How can the government best support Indigenous leadership and participation in energy planning and projects?
- The government should provide training and incentives for the participation of Indigenous peoples and others in investing and planning in the energy sector. However, the government should also not be providing handouts to drive up costs and uncertainty through the same process.

How can provincial planning processes be enhanced to support high growth regions, ensure greater coordination between energy resources, and better integrate municipal, distributor and regional planning processes?
- Provincial planning processes are currently very segregated and lack innovation and creativity. The IESO should be made to integrate with other planning processes and more investment put into integrated planning. Providing the resources for better planning of energy resources and integration with municipal and regional planning processes is important. This will require new staff, computational resources and research investment. It would be good to direct IESO and planners to work with expert creativity centres such as universities in these processes. This upfront money and effort will be well spent and save ratepayers considerable money when it comes to actual development.

What cooperation opportunities exist across other jurisdictions to support energy trade, construction of transmission infrastructure (ex. pipelines and interties), and transportation electrification?
- The government needs to support greater cooperation between jurisdictions particularly other provinces. It should look to support inter-provincial trade of energy in particular taking advantages of the synergies between Ontario and our neighbours in Quebec and Manitoba.

What types of technical information and forecasts would best support sector participants and energy consumers as the system is built out for growth and the economy increasingly electrifies?
- These systems are currently significantly lacking on Ontario. We need better regional weather forecasts, greater sharing of data and support for long-term outlooks, creating datasets that integrate climate scenarios at infrastructure planning timescales. This should be seamless between Ontario and Quebec who is well ahead in this regard. Ontario has consistently underinvested in knowledge capital which has only held back its economic potential.

Affordable and Reliable Energy

What further steps should the government take to enable households and businesses to manage and make informed decisions about their energy use?
- Energy data should be more transparent and readily available. It is published in some obscure formats but this should be made accessible to Ontarios.
- Local household should have more autonomy in choosing their energy and visibility as to where it came from, such as new pie charts of generation mix on electricity bills.
- Households should be able to monitor energy production and their own use in real time. Things are connected with smart meters which should be able to feed apps that homeowners could use.

What actions could the government consider to ensure the electricity system supports customers who choose to switch to an electric vehicle?
- The government should adopt policies that enable and support the installation of EV chargers, but at home and fast chargers at key locations. These chargers are still hard to find and not always function.
- The government should work with other governments to enforce standardization of outlets and charging ports for EVs
- The government should require that local distribution and transmission planning consider the potential of EV installation. The growing infrastructure should be funded aiming for no regrets actions or developing the T&D system in such a way that it can be easily expanded in the future.

What actions should government consider that would empower customers to install innovative technologies to generate or store energy on-site to reduce costs and improve resiliency?
- This should be done through incentives and removal of counter incentives. For example, households should be able to develop and store electricity in their own house and not be required to sell to the IESO unless they have a surplus. Requiring customers to choose selling only to the IESO or being grid-disconnected is a disincentive that must be removed.
- Uplift and global adjustment should be lifted from energy storage so there is not an unfair economic disincentive
- Rebate, loan programs or other incentives should be used to lower the initial cost of the investment. Many people could afford EVs and batteries and there would be a payback but the initial investment or bank-rate loans is a barrier to many households.

What specific actions could position the integrated energy resource plan to best leverage distributed energy resources (DER) that enhance local and province wide grids to support energy system needs reliably and at the lowest cost?
- New energy system planning tools are needed that actually consider the value of DER rather than relying and planning on grid scale sources
- The government should allow for the procurement of DER or aggregated DER within IESO procurements, such as a central company bidding in amalgamated DER resources that could then be realized with customers.
- Microgrids and local grids are important new techniques for energy planning. The province should study the value of interconnected microgrids as a planning tool. This could also include local energy storage such as the installation of grid scale batteries around the province or within microgrids that could be support by non-traditional energy players such as municipalities.

What policy or regulatory changes should government consider to address financial risks and support adoption of DER in the long-term?
- Selling to the IESO only is a policy change needed to drive better DER adoption. This is especially true as negative energy prices could be a major risk exposure to households.
- The government should embrace DER. This government has had a long standing policy of not promoting or accepting DER.
- Low interest loan programs or the ability to refinance local wind or solar panels into a mortgage would enable households or small business to better participate and absorb the high upfront capital costs which would pay themselves back over time.
- The government should incentivize leading technologies to be manufactured locally in Ontario like it has done for EVs. A local supply chain should lower costs and grow jobs in Ontario rather than China.
- I would challenge the requirement of this question to be "long-term". Most DER already have pretty large manufacturing capability globally and could be scaled and installed much more quickly than traditional energy infrastructure. This solution could be implemented as a relatively short-term solution.

With the energy sector evolving and distributors considering new roles in serving customers, what barriers exist that limit local distribution companies from taking on new duties that could enable more efficient grid operations, leverage new technologies and further the integration of DERs?
- The OEB can be a cumbersome process for smaller players in the space. There should be ways to streamline the OEB process, especially for those that can least afford it.
- The OEB should allow certain activities to be more market exposed rather than providing variance accounts that promote mediocrity and stifle innovation.

What actions can the government take to enhance collaboration between the OEB, the IESO, local distribution companies, industry stakeholders, and local communities to support the investment and integration of DER?
- The government can remove barriers and increase clarity particularly with the OEB. It is important to recognize the OEB and to some extent IESO are regulators. This means energy companies must always be careful about what is said to avoid troubles. It means players keep their cards close to their chest. Creating ring-fences around the regulatory processes of these entities but allowing them to share certain types of knowledge through those ring fences would promote greater sharing of information while de-risking the conversation for utilities.
- The OEB, IESO and others need to be forced to collaborate. The IESO is well known for it's insular perspective and unwillingness to accept good advice. A cultural change is needed in some of these institutions.

What further actions could the government take to maintain an affordable energy system for Ontarians throughout the energy transition?
- Allow participation of a greater number of players such as households, small businesses and municipalities to spread the cost of capital investments. DER's in particular offset grid costs by having other players in the energy space.
- The government should move beyond archaic thinking that surplus energy is a bad idea. Development for surplus would allow for selling energy to other jurisdictions, production of hydrogen or storing energy in other means. Historically there was a mindset that developing surplus was a bad thing, but it should now be seen and realized as an opportunity if it comes from renewables, nuclear or hydro.
- The government should prioritize local procurement. Purchasing Ontario made steel (particularly from arc furnaces) supports the demand, local economy and the spin on benefits. These local products may be more expensive than China made products for the purchaser, but the broader local economics are greater making the local purchase a better whole of economy solution.
- The government should develop a regulatory market for carbon offsets. This would allow the industrial sector to lower it's EPS costs while keeping money local.

Becoming an Energy Superpower

What opportunities exist to further capitalize on Ontario’s leadership and expertise in nuclear technology and nuclear innovation?
- The government should explore opportunities provided by Article 6 of the Paris Agreement to export this technology.

What opportunities should Ontario consider to leverage its position as a clean energy leader?
- Building a larger supply of clean energy will allow for the creation of export energy or the manufacture of low-carbon goods or materials. This will enhance the opportunities for export to markets with carbon border adjustments being applied. This will not happen if there is a growth in natural gas and the opposite will apply limiting trade opportunities.
- Ontario should enhance it's leadership and innovation in the clean energy space. Greater funding should be directed to leading Ontario research universities to develop better battery, renewable or manufacturing processes. We import many products for the energy sector but should work harder at being an intellectual leader in these processes to we can have the patents, processes and manufacturing all originating from Ontario. We should not look to be only a manufacturer.