Canadian Solar Industries…

Canadian Solar Industries Association (CanSIA)
Submission Regarding Ontario's Climate Change Plan (EBR Registry Number: 013-3738)

1. Introduction

CanSIA is a national trade association that represents the solar energy industry throughout Canada. CanSIA’s vision for Canada’s solar energy industry is for solar electricity to be a mainstream energy source and an integral part of Canada’s diversified electricity mix by 2020. CanSIA is also targeting the solar energy industry to be sustainable, with no direct subsidies, and operating in a supportive and stable policy and regulatory environment within a similar time frame.

On July 25th, the Government of Ontario introduced Bill 4, the Cap and Trade Cancellation Act, 2018, which, if passed, would repeal the Climate Change Mitigation and Low-carbon Economy Act, 2016 (CCMLEA). Furthermore, the proposed Act, establishes a requirement for the Minister to prepare a climate change plan and to prepare progress reports in respect of the plan. This submission is CanSIA’s initial recommendations concerning a new Made in Ontario climate change plan which serves to meet both climate goals while strengthening the economy.

2. Benefits of Solar Energy

2.1 Solar Energy is a GHG Emissions Free Energy Source

Solar energy technologies provide clean and carbon-free energy in the form of electricity, heat or cooling. By making solar energy a part of the Ontario climate change plan, the province can further reduce greenhouse gas emissions in not only the electricity sector but also through the transportation and buildings sector, as electrification of these sectors continues to evolve.

2.2 Solar Helps to Reduce Consumers Electricity Bills

Ontario electricity consumers, including hardworking families and small business owners, can lower their electricity bills by reducing the amount of electricity they purchase from their local distribution company (LDC) by means consuming their own self-generated solar electricity through net metering.

Net metering is a billing mechanism that allows electricity consumers who install a solar system on their home or building to generate their own solar electricity during the day, use what it needs to meet the requirements of the home (or another type of building), injects the rest into the electricity grid, and consumes from the grid when the solar is unavailable. Electricity bills can be greatly reduced as the customer is then only billed for their net electricity use. If they generate more than they use in a month, they receive a credit to apply against next month’s bill. If the solar system generates less than the customer uses, they will see a charge on their bill.

2.3 Solar Creates Local Jobs

The solar industry employs between approximately 5,000 Ontarians. As the solar energy continues to come down in cost and as consumers continue to demand new ways to enhance their energy independence and lower their electricity bills, the number of tradespeople employed, such as solar installers, HVAC technicians, and electricians, will only continue to grow.

For example, in the US, a leading country in terms of solar energy deployment, since 2010 the solar workforce has increased by 168% to over 250,000 jobs. The U.S. Bureau of Labor Statistics has forecasted that solar-photovoltaic installer will be the fastest growing occupation of the decade to 2026.

2.4 Consumer Empowerment and Choice

Ontario families and business owners want to be empowered consumers when it comes to electricity. For example, a 2016 poll released by the Pew Research Center showed that pubic opinion, across political party lines, is widely supportive of expanding solar energy. The key reason cited by Americans for considering solar panels is financial, as 92% of respondents said their reasoning to adopt solar energy was to save money on their electricity bill.

Consumers want to have choices between purchasing electricity from the LDC and potentially self-generating their own electricity on site, to enable them to further lower their energy bills and hedge against possible future rate hikes. Solar energy technology is the most practical way for Ontarians to self-generate their own electricity.

3. Other Considerations

3.1 Solar Reading Buildings

A central focus of Ontario’s Climate Change Plan should be on revisions to regulations and codes that can facilitate the transition to less emissions intensive forms of energy use for buildings. Generally, the changes recommended in this section would require that a conduit be included in new buildings that would enable the future installation of solar photovoltaic panels or solar hot water systems at a lower cost by allowing the wires and or pipes to travel through a pre-existing conduit to allow easy connection between the solar collectors, located on the roof of the building, to the utility room, generally located in the basement of the building. More detail on the specific approaches recommended for residential buildings vs. industrial/commercial/institutional buildings is available below.

In 2011 the Ministry of Municipal Affairs and Housing (MMAH) launched process E-B-12-03-04 to consider stakeholder feedback on a proposed revision to the Ontario Building Code (OBC) that would require at least one conduit to facilitate the future installation of a photovoltaic system or a solar domestic hot water system in dwelling units governed by Part 9 (of the OBC), to be effective as of January 1, 2017. The conduit would be required on residential units that and would link the roof of the unit to the utility room (often located in the basement).

The suggested revision to the OBC specified:

12.3.2. Residential Solar Energy System Installation Preparedness after December 31, 2016

1. Except as provided in Sentence (3), every residential building within the scope of Part 9, shall have one or two conduits to facilitate future installation of a solar domestic hot water system.

2. The conduits required by Sentence (1) shall
a. have a minimum nominal inside diameter of (i) 50 mm if two conduit runs are provided, or (ii) 100 mm if only one conduit run is provided,
b. extend from the area adjacent to utility space to attic space or roof,
c. be continuous, straight, identified by marking and accessible at both ends,
d. be sealed at both ends,
e. be terminated 150 mm above the insulation and 500 mm of vertical distance from the underside ofthe roof sheathing, where an attic space is available, or 150 mm above the roof, sealed and flushed around the roof penetration using a rubber or corrosion-resistant metal flange with a gasket around the conduit,
f. be securely fastened at maximum 1.8 m intervals, and
g. be constructed of pipe conduit materials such as PVC pipes conforming to ASTM D1785 - 06, “Poly(Vinyl Chloride) (PVC) Plastic Pipe, Schedules 40, 80, and 120" that will withstand the maximum temperatures encountered in solar domestic hot water systems,

3. Buildings that will be shaded for at least 50% of daylight hours because of trees, buildings or other obstructions need not meet the requirements in Sentence (1).

This change to the OBC was supported by the majority of submitters into the stakeholder feedback process, however, the changes were not implemented by MMAH. In order to integrate design considerations that impact the feasibility of installing solar energy systems into the original design of new buildings, CanSIA recommends that the Ontario Government initiate an Ontario Building Code revision process that will incorporate a specific stream of revisions designed to make new constructed buildings solar ready. This process should include building code revisions that will be applicable to both residential and ICI buildings and focus on: ensuring sufficient space is available for the future installation of solar PV or solar thermal collectors, that the building can support the dead and live loads of solar installations, the installation of a dedicated conduit from the roof to the utility room, and sufficient space within the utility room for solar related equipment.

3.2 Net Zero Buildings

A net zero energy building is defined as a building that produces as much energy as it consumes over the course of a year. These buildings achieve net zero energy status first through high levels of energy efficiency, and then through the addition of clean, on-site renewable power generation, typically solar PV. In Ontario, approximately 17% of total GHG emissions come from buildings and 9% come from the electricity sector. Therefore, ensuring as much future building and community development as possible achieves net zero energy status can be an effective way to help the Ontario government achieve its greenhouse gas targets going forward. A building’s emissions profile is largely made up of fossil fuel use for heating (space and water), and electricity use that can come from fossil fuel sources (the percentage of which changes depending on the time of day and how much generation is sourced from the natural gas fleet). Additional deployment of solar technology can reduce emissions from both sources.

Ontario’s private sector is already taking steps to develop net zero energy communities. West 5 is a net zero energy community being developed in the London Area as a partnership between s2e Technologies, Sifton Properties Ltd., London Hydro, the City of London and a network of over 11 universities and colleges with access to over 100 graduate students. This 70-acre green field development will include 2,000 residential units (high rise, medium rise, and townhomes), 300,000 sq. ft. of retail/commercial space, and 100,000 sq. ft. of office space.9 The community will be net zero energy through the use of energy efficiency measures, distributed solar generation, and geothermal heating. These types of developments could be the future of community planning in Ontario if supportive codes and standards are implemented to support their construction.

CanSIA recommends that the MOECC have a strong focus on encouraging the development of net zero energy buildings and communities, which could be phased in over a period of years to help the business community adapt.

4. Conclusions

In conclusion, CanSIA recommends that the Ontario Government strengthen and enhance solar energy technology regulations to enable clean, solar energy to play a prominent role in Ontario Government’s Climate Change Plan. In addition to being a clean, safe and waste-free source of energy, solar energy can provide electricity consumers with another option to help them lower their electricity bills while simultaneously helping to create local jobs in communities across the province.

CanSIA looks forward to working with the Ministry of Environment, Conservation and Parks, along with other Ministries to further the dialogue on how solar energy technologies can fulfill various goals and mandates brought forward by the new Ontario Government.