We would like to offer…

   We would like to offer our most sincere thanks for the opportunity to contribute to this consultation process.

  The City of Guelph has established itself as a leader in community energy management. The Guelph Community Energy Plan was the first municipal energy plan in the country when it was approved by Council in 2007, and it continued to lead on this file when it became the Community Energy Initiative (CEI). Guelph continues to break new ground on this file through the update to the CEI, which is scheduled for completion in the 2nd quarter of 2018.

  COMMENTS

  In general, we are supportive of the proposed Green Button implementation approach. We are particularly supportive of including both “Download My Data” (DMD) and “Connect My Data” (CMD) in the regulatory proposal, as well as extending these capabilities to natural gas utilities operating in the province. We believe that direct access to this data, as well as delegated access through third parties offering value-added services, will help ratepayers in the province to understand their energy consumption patterns, and make decisions to reduce both expenditure and consumption through conservation and energy efficiency retrofits.  This will also help reduce the contribution that individuals and organizations are making to climate change.

  The proposal allows for two implementation types, namely single integrated and multi-integrated. We believe that the best implementation type is a single, integrated platform, for these two reasons: 1.User convenience. Like many ratepayers in the province and in our community, the City of Guelph has accounts in more than one LDC service area. A single, common platform used by all utilities would place minimal administrative burden on these multi-LDC ratepayers, as their energy management staff will only need to learn how to use one system. By contrast, if ratepayers face an inconsistent collection of disparate platforms, it will add administrative complexity and cost to the process of managing utility data and decrease the likelihood that these ratepayers will actually use the service. By allowing heterogeneity of platforms, the proposal appears to favour ease of implementation for LDCs (a one-time event) over usability for ratepayers (an ongoing factor in the success of the system).

 2.Asset resilience. With the Province promoting electricity LDC consolidation, the

 multi-integrated implementation type increases the likelihood that future LDC mergers will involve consolidating disparate Green Button platforms. In each merger, one platform will be selected for use by the merged entity; the other (or others, if there are more than two parties to a given merger) would be abandoned. These abandoned platforms will be stranded assets. The investment in those platforms – made at ratepayer expense, since the cost will be recovered from the rate base – will be lost. Given the high cost of electricity in the province, it is preferable to avoid setting up LDCs for future write-offs of ratepayer-funded investments. Instead, a single platform should be mandated to which all LDCs must adhere. This would eliminate an unnecessary additional cost implication of LDC consolidation.

  CONCLUSION

  The City asks that these comments and recommendations be taken into consideration when implementing the proposed approach for climate adaptation in Ontario.

  Sincerely,

  Mario Petricevic

 General Manager

 Facilities Management

 City of Guelph

 T 519-822-1260  x 2668

 E mario.petricevic@guelph.ca

  Alex Chapman

 Manager, Climate Change Office

 Facilities Management

 City of Guelph

 T 519-822-1260  x 3324

 E alex.chapman@guelph.ca

[Original Comment ID: 212220]