While the IESO's P2D study…

While the IESO's P2D study does a good job of laying out a plan for one possible path to decarbonization, Workbench Energy believes there are other options which will allow the Province to decarbonize more quickly while also achieving lower electricity costs. While the report does a good job of recognizing that large scale decarbonization will require the utilization of a wide variety of technologies and programs, there are two aspects which are under-represented in the report.

The first area which is under represented in the report is Distributed Energy Resources (DERs). The P2D study says that DERs are included in the system buildout but lacks details of how those have been included and to what degree. The IESO's own DER potential study has indicated there is opportunity for thousands of megawatts of DERs in Ontario but that existing barriers prevent their adoption. An additional "no regrets" action would be to immediately focus on removing those barriers to enable DERs as a cost effective and low carbon piece of the Ontario grid.

The second area which should be expanded upon in the P2D report is the utilization of responsive loads. Ontario has an existing demand response (DR) program which has successfully been operating for many years. The P2D report includes a continued and growing utilization of that DR resources. To meet those goals, another "no regrets" action would be to lay out a clear, long-term roadmap for expansion of the DR resource over a 10 - 15 years period with procurement target commitments to allow the resource to scale over time.