2023-08-22 RE: Proposal to…

2023-08-22

RE: Proposal to amend O. Reg. 509/18 under the Electricity Act, 1998 (“Efficiency Regulation”)

Wolf Steel Limited manufactures Central Heating Gas Furnaces & Air Conditioners, Through the Wall Furnaces/Air Conditioners, Gas Grills, as well as Gas and Wood Burning Fireplaces. Existing for over 50 years, it is a privately owned Canadian corporation with over 1,500 employees located in multiple manufacturing facilities within Ontario Canada. Its appliances are sold throughout Ontario to a vast number of retail outlets and HVAC contractors employing hundreds of Ontario residents.

While we can appreciate the benefits the proposed implementation of a rolling harmonization system with NRCAN’s Energy Regulations represents to Ontario Energy Board; this proposal threatens the stability of our manufacturing future. Recent history has demonstrated the Ontario Energy Board possesses the flexibility to provide exemptions to Regulations under extreme circumstances while NRCAN has not.

In 2021 during the pandemic, our industry along with the rest of the world was faced with a shortage of microchips. These components were essential to equip gas fireplaces with the controls necessary to comply with the requirement for electronic ignition systems. Unable to source the necessary controls, we appealed to both NRCAN and the Ontario Energy Board to grant an exemption to the Regulation so that we could continue to manufacture and sell non-electronically controlled gas fireplaces until the electronic components became available.

NRCAN’s stated their Regulation was steadfast and could only be changed by an amendment. Unfortunately, that could only occur when the next amendment was scheduled. This provided no solution to our urgent situation. Thankfully, the Ontario Energy Board was understanding of our dilemma and was able to provide an exemption, enabling our company to continue manufacturing our gas fireplaces without interrupting support to our market and keeping our employees, employed. Without the flexibility demonstrated by the Ontario Energy Board, we would have been forced to shut down production of these appliances.

We confirmed with the BC Energy, Mines and Petroleum Resources Ministry that they have no intention to automatically harmonize with NRCAN’s Energy Regulations. We are thankful of their position as it was this Provincial Ministry that initially consulted with our industry to better understand gas fireplaces and how they fit into energy regulations. It was their energy regulations that were eventually adopted by NRCAN and the Ontario Energy Board. Our ability to effectively communicate with members of the Ontario Energy Board and the BC Energy, Mines and Petroleum Resources has been and continues to be invaluable to us a Canadian Manufacturer.

It is our ability to approach the Ontario Energy Board and discuss possible solutions to unforeseen circumstances, that makes us appreciate the relationship the Ontario Energy Board affords us and other resident manufacturers. It is our deepest fear that this proposal signals the end of that relationship should the Ontario Energy Regulations automatically default to NRCAN Regulations. As such, we request the Ontario Energy Board reconsider adopting the proposed rolling automatic harmonization of the NRCAN regulations in favour of maintaining an open dialogue with Ontario Manufacturers in support of a healthy manufacturing environment in Ontario.