While Planning Ontario's…

While Planning Ontario's Energy Future has comments that suggest conservation is a high priority the technologies and programs don't appear to reflect that sort of goal. The technologies discussed seem to have a focus on the supply side; distribution and grid modernization, natural gas expansion, microgrids, electricity transmission and pipelines, storage, innovation in supply areas but not in conservation or renewables. The only mention of conservation and energy efficiency says there are frameworks put into place. Two statements are troubling. First, "The Conservation First Framework is designed to reduce electricity consumption by 7 terawatt-hours (TWh) or seven billion kilowatt-hours (kWh) by December 31, 2020". The ambiguous wording leaves it open to missing this target by as little or much as can be spun by the LDCs, OPA/IESO, government.

The second says the frameworks "give distributors the flexibility to meet local needs and require programs to be cost-effective to ensure value for money'. This appears to be saying that conservation is now a program that can be undertaken "wherever economically viable" or these are not hard targets rather there is a lot of flexibility in doing something or as little as the LDC can argue is all that is economically viable.

Recommend that strict reduction targets be set that LDCs are required to meet and commensurate budgets be provided.

[Original Comment ID: 207198]