I support the comments of…


I support the comments of the City of Ottawa below, which were developed as part of the Energy Evolution process, of which I was a participant. In addition I make the following suggestion:

In addition to retaining access to market rate electricity in Class A & B accounts, as suggested below, Ontario should create a new class for Market Rate accounts. This would give customers who have electrical or THERMAL storage the opportunity to access the 5 minute rate or the HOEP.

While this might sound outrageous, it would have many benefits:

1. Encourage storage of both electricity and thermal energy (the largest source of GHGs in buildings).
2. Reduce peak demand because of the price signal, also reducing transmission and distribution upgrades and, of course, reduce GHGs from gas peaker plants.
3. Flatten the demand curve (as well as COVID, we need to bend the GHG curve and energy demand).
4. Encourage, even further, home charging of EVs to night-time low cost charging.
5. Reduce curtailment of wind and solar by encouraging off-take with low grid prices (reducing the need for PPAs)
6. While it might lead at first to rampant arbitrage in the electricity storage market, note that it is self-regulating in the sense that, as demand goes up in the low or negative price parts of the curve, that will raise the price and eventually balance the market.
7. Since the Market Price already intrinsically includes a measure of the overhead of the system and is a direct measure of the cost, the Global Adjustment should not be assigned in an arbitrary way, as is done with Class A, but as a percentage of the Market Price, or a sliding scale (or even waived to jump-start storage in Ontario).

IESO is moving very slowly with non-wires solutions while the rest of the world is moving rapidly forward with innovation. Ontario should remove restrictions on LDCs to do test pilots to evaluate programs like Market Rate.

We need to be much more aggressive to remain competitive in the global energy and manufacturing sectors.

Points courtesy of the City of Ottawa:

• Align conservation demand management programs with Provincial GHG targets

• Remove small scale solar siting restrictions

• Allow net metered accounts to stay on time of use billing as an option

• Require local distribution companies to have a standardized process to renewable energy connections which standardizes costs, times for studies and times for connections

• Ensure ongoing access to low priced, market rate electricity in Class A accounts

• Obtain access to low priced electricity during periods of low demand for Class B accounts

• Research distribution scale wind systems suitable for urban settings

• Encourage movement to a zero emission electricity grid

• Guarantee market access to conservation or renewable generation through provincial power purchase agreements if it is lower cost than existing generation

• Ensure that initiatives which encourage better utilization of the electrical system can be funded from the electrical rate base at large or from distribution company earnings

• Work to ensure that electrical distribution system reinforcements driven by electrification do not trigger economically prohibitive costs to individual consumers

• Remove the stipulation which limits behind the meter generation to 1% of a distribution system's peak demand

• Develop frameworks which allow evaluation of non-wires solutions to be evaluated as capacity and energy resources

• Encourage the continued publication of a long-term energy plan

• Place a moratorium on combustion-based new electricity generation on either the transmission or distribution systems or behind the meter

• Discourage the renewal of contracts with combustion based electricity generators at the transmission and distribution systems or behind the meter

• Limit or eliminate demand charges for stand-alone EV charging

• Enable virtual net metering and third-party ownership of renewable electricity projects