Comments regarding the…

Comments regarding the Repeal of the Green Energy Act - ERO number 013-3832
(Italics copied from GEA Summary)
1. Re: “reintroduce select energy efficiency and conservation provisions.....”
Firstly I note that this is far from a simple ‘Repeal’; but a complex ‘pick & choose’ of retention and additions and maybe we should consider a clean repeal and start from scratch with a new approach to Green Energy especially whether we need to have a ‘Green Energy’ designation in the first place (e.g. Hydro Power is green Energy also).
My general comment on this topic is that all proposed programs should consider economic trade-off evaluations that include the value of any subsidies as all is eventually paid by Ontarians out of our budget. Any subsidies in the energy field that are retained or introduced should include a termination date to renew. The objective should be to eliminate all subsidies once they are no longer ‘needed’.
2. Conservation and Energy Efficiency
Any retained conservation and energy efficiency initiatives should meet ridged ‘cost-benefit’ economic scrutiny and allow free enterprise to operate and give the consumer the choice of how much money they wish to save or spend on energy. It should be no different from any other consumer goods or services. All reasonable energy saving mandates for houses should be incorporated in the Ontario Building Code which Municipalities have the choice to adopt.
Re: “Permits the use ....... despite restrictions that may prevent their use, .... and clothestrees
Municipal or Commercial restrictions on what are really visible ‘lifestyles’ or preferences (e.g. outdoor clotheslines) should mostly be left up to Municipalities; but the province could consider to prevent Municipalities from un-reasonably restricting their residents from the freedoms to exercise their lifestyles that do not effect others.
Energy Efficiency Standards
3. Re; “ . ... efficiency standards .. with the highest available minimum efficiency standards in North America.
“Highest Available” without economic cost-benefit considerations would in my opinion be an over-reach and would result in increased prices for consumers and wasted spending. Ontario should only develop its own “Efficiencies” as guidelines and leave it up to consumers to decide. For exports, manufacturers will continue to comply with any efficiency standards their export customers may require as they are used to doing. The design and cost for services should be based on costs with due allowances for real expectation of supply shortages if any (such as water supply in arid areas). Again, in a free enterprise economy, the customer should have the choice of deciding how much water or energy to ‘save’ or to ‘waste’; the province should however continue to provide relevant information to the consumer – as is ‘by and large’ done today.
Energy and Water Reporting and Benchmarking and Broader Public Sector Energy Reporting
I am completely opposed to the proposed requirements for commercial and service institutions to report their building’s energy and water consumption, greenhouse gas emission data on their websites annually and provide conservation plans. I would not expect a conservative government to be so intrusive in the operation of our businesses and services, certainly not by legislation. For government controlled institutions this can easily be done by management or governance on an ‘as needed’ basis. It unnecessarily adds significant bureaucratic procedures with added costs and little benefits. This is more befitting of Socialism which I for one did not vote for!
Override on Restrictions on certain Renewable Energy Projects:
Re: “roof or wall-mounted solar, thermal air, water , ground-source heat pumps.. exempt from many legal restrictions
I am opposed to exempting any ‘green’ energy installations from any legal restrictions. The use of this equipment should be no different than any other equipment and anything to do with ‘Green Energy’ should not get any preferential treatment in our government regulations or acts.
Certain Provisions would not be re-enacted:
I am in complete agreement in cancelling all of the 5 provisions stated. In fact I would suggest that all provisions should be scrutinized as to their necessity and this list should be expanded as much as is reasonable in a free enterprise economy.
Restore Municipal Authority
I am in complete agreement to eliminate this special exemption for ‘green energy’. But I remain concerned that Municipals may have too much power, legal or otherwise, in preventing certain industries, including energy plants from locating in a municipality even if all environmental and zoning laws are met, such as was the case in the NG Power Plants in Oakville and Mississauga.
Environmental Protection Act
Re: “....to prohibit the issuance or renewal of Renewable Energy Approvals. ... where the demand for the electricity .... has not been demonstrated”.
This is probably redundant as neither government or free enterprise would invest in any service or product if the demand is not there – this is the first fundamental requirement in an project (called Feasibility Studies’). I believe a more important requirement would be that the Technology and Design Life of the proposed facility is proven and Long Term costs of generation include all replacement and maintenance costs that can be envisioned. Most important is that the Permitting, Environmental Approvals including public hearings will be required to the same standards as any other industrial or commercial facility. Green Energy should meet the same standards as any other kind of energy. In other words, a full Feasibility Study should be required for all such projects.
I note the designation: “The Ministry of the Environment, Conservation and Parks”. I was not aware of the change in name and scope from the previous ‘M.O.E.’ that I was very familiar with in my engineering career in the resource industry. I believe that ‘Conservation and Parks’ should remain separate from ‘Environment’.
Footnote:
The issues of Green Energy, Cap & Trade and Carbon Tax, are all part and parcel of the much bigger issue of Man-Made Global Warming without which there would be no need for any of them. In other words, to consider any action on these three issues, one must first accept that Man-Made Global Warming is real and factual. I would respectfully point out that this is not the case and that 31,487 American scientists have signed a petition that says: “There is no convincing scientific evidence that human release of carbon dioxide......will cause heating of the Earth’s atmosphere ...and disruption of the climate” etc.). All this is readily available information, including their names, qualifications and affiliation. As an Ontario citizen I would respectfully request that my elected representatives and leaders acquaint themselves with the existence of this unparalleled long-standing scientific controversy that would not exist if the science of man-made global warming were a fact. There are also individual Canadian scientists, more qualified than myself, who are on record rejecting the IPCC proposed Man-made Global Warming Theory and they should be consulted, along with the Americans, before action on “Green Energy”, “Cap & Trade”, “Carbon Tax” is finalized. Eventually It would also need consulting with the Federal government as commitments to the 2015 Paris Accord is a federal jurisdiction. To continue to ignore such a preponderance of qualified opposing viewpoints on this hugely significant subject would in my considered opinion be a disservice to the public.

Thank you for considering my comments