Andrea Pastori   Cabinet…

Andrea Pastori

 

Cabinet Liaison and Strategic Policy Coordinator

 

Ministry of Energy

 

Strategic, Network and Agency Policy Division

 

Strategic Policy and Analytics Branch

 

77 Grenville Street, Floor 6th

 

Toronto, Ontario, M7A 2C1

 

It is with great pleasure I write in response to the Ministry of Energy’s discussion guide: Planning Ontario’s Energy Future about Ontario’s Long Term Energy Plan (LTEP).  In reviewing the broad spectrum of guiding questions in the guide, ClimateActionWR has identified four priority areas for the LTEP that would address needs and concerns we see in the community of Waterloo Region. These priority areas are: i) conservation and demand management, ii) local, renewable energy supply, iii) innovation and, iv) communication.

 

First some background on our own project: ClimateActionWR focuses on supporting actions and developing new opportunities that will lead to a reduction in greenhouse gas emissions at a local scale in the community of Waterloo Region. Led by REEP Green Solutions and Sustainable Waterloo Region, ClimateActionWR supports the implementation of the Climate Action Plan for Waterloo Region. The community Climate Action Plan set a community-wide greenhouse gas reduction target of 6% by 2020, a target that would be best supported by a LTEP for Ontario that makes greenhouse gas reductions a priority in energy supply, distribution and use and prioritizes local investment in achieving such reductions.

 

Conservation and Demand Management

 

As our provincial electricity supply shifts away from fossil fuel based sources, it will become an imperative to focus on conservation targets for our other fuel types including natural gas, oil, and propane.  As such, a critical first step will be to set conservation targets for these fuel types, and provide either the financial mechanisms (carrot) or legislative requirements (stick) to ensure that service providers achieve these targets.  In addition, it will become increasingly necessary to balance the scope of any conservation and demand management (CDM) efforts so that they support all sectors: industrial, commercial, institutional and residential.

 

In electrical CDM plans, we are seeing an increasing emphasis on servicing the largest industrial, commercial and institutional customers with incentive programs because it is currently the most cost effective way to deliver demand reductions.  This approach has left residential customers with fewer incentives available to them, and as electricity costs rise, it becomes increasingly difficult to offset those rising costs with a corresponding investment in energy efficiency in homes. To overcome this, we recommend that the Ministry of Energy alongside the IESO, consider resuming sector specific targets for conservation, so that our local distribution companies (LDCs) are able to invest in innovative programs for all sectors.

 

We recognize the importance of emphasizing “Conservation First” under the new framework of the IESO – we undoubtedly need substantial reduction in overall demand to support our growing population with our existing generation capacity.  However, this emphasis appears to have come at the cost of considering the power of shifting demand as a mechanism to reduce cost as well as the greenhouse gases generated by natural gas during peak hours.  We recommend resuming targets and financial support for LDCs to support demand shift amongst their customers.  Moreover, we are encouraged by recent announcements about the expansion of the Industrial Conservation Initiative to include 1MW customers and expand the number of sectors eligible for this program.  We encourage this effort, and suggest opening the program to all customers who have a demand of 1MW or more regardless of sector.

 

Finally, in the areas of conservation and demand management, we want to emphasize two systematic barriers to the uptake and success of CDM programs.  First, the environmental attributes section of legal agreements between the IESO or LDCs and their customers has proven to be a deterrent for some consumers.  In its current form, this language suggests that the IESO or LDC would gain the associated benefits (be it cap and trade or tax benefits) for any greenhouse gas reductions that result from the project, regardless of what proportion of the project was funded through these entities.  We recommend reviewing and clarifying this language, and consider allocating any benefits based on the proportion of the project funded.   Second, we ask that the Ministry of Energy carefully consider ways to mitigate the inherent conflict of interest that occurs when a utility provider is asked to focus on conservation and demand management. For any business, it would be difficult to grapple with a mandate to reduce the amount of your own product that is used by a customer, and it is no different for our local utilities.

 

Local, Renewable Energy Supply

 

When considering the future of our provincial grid, we want to emphasize the importance of resiliency.  In particular, resiliency of a grid can be support by an increased concentration on local, renewable generation.  To support this, we recommend the Ministry of Energy improves the ease of access to the grid for residents, businesses and institutions through simplified net-metering or ‘virtual’ net-metering processes.  Moreover, we support the Ministry’s continued investment and support for Community Energy Planning (CEP) through project funding.  We encourage the Ministry to look for ways to provide deeper support to communities once their CEP is developed so that they are able to implement these plans. Such an investment may include seed funding, or loan guarantees to cover the risks of community owned small to mid-sized energy projects. Finally, placing emphasis on renewable generation for any growth in our base-level demand must be a continued priority for the Ministry of Energy and, as such, we advocate for the renewal of the Large Renewable Procurement Program.

 

Innovation

 

To succeed in our local, provincial, national and international long-term greenhouse gas reduction goals we will require innovation.  As such, we support investment in innovation.  However, such an investment should not be limited to technical innovation; in many areas we need an equal, or perhaps larger, focus on social innovation.   Three particular areas have been discussed in our community with regards to innovation: thermal energy, energy storage, and energy benchmarking. First, we see the need to investigate the development of a thermal grid and utility provider, to support the sharing of heat waste in communities.  Such a development requires a large paradigm shift in how we think about supplying heat to our communities.  Secondly, in order to achieve reliability and resilience in our grid we see the need to invest in research and community projects for renewable energy storage.  Finally, we encourage the Ministry of Energy to continue its pursuit of energy benchmarking for all buildings.  Overall, what we have observed in our community is that the technical solutions are available, but the success of our initiatives depends on uptake by citizens and business, and we need creative ways to engage them. Therefore, social innovation must be a priority for investment in innovation.

 

Communication

 

As a broad final comment, we want to stress the importance of providing clarity and guidance around the issue of fuel switching.  We feel that the Ministry of Energy is in a strong position to influence communication around this issue.  In particular, we still see low level of energy literacy amongst the broader community, which makes it difficult to have conversations about fuel switching.  For example, residents and businesses in our community have been encouraged to move their heating systems off of electricity and toward natural gas for over a decade.  It will take some substantial and well-guided work to re-educate the public about the benefits of switching in the opposite direction. We encourage the Ministry to take a stance on this issue, and clearly communicate the benefits and costs to businesses and residents.

 

We thank you for your time and consideration in reviewing these comments and look forward to seeing a new LTEP from the Ministry of Energy that that makes greenhouse gas reductions a priority in energy supply, distribution and use while also prioritizing local investment in achieving such reductions.

 

Sincerely,

 

ClimateActionWR Plan Manager

 

[Original Comment ID: 207187]