Region of Peel ERO Response…

Region of Peel ERO Response
The Region of Peel appreciates the opportunity to comment on the proposed Repeal of the Green Energy Act, 2018, ERO number 013-3832.

With a population of over 1.4 million people, the Region of Peel is the second largest municipality in the Province of Ontario. Through past growth and commercial development, Peel has transformed into a dynamic urban community with a vibrant economic base. Peel Region is experiencing rapid growth, and by 2041, will welcome more than 500,000 new residents and 250,000 new jobs.

The Region of Peel is committed to taking leadership and action on climate change and responsible energy management. This is reflected in the Region’s Energy and Environment Sustainability Strategy which has set the following goals;
i) Reduce corporate greenhouse gas emissions to 80% below 1990 levels
ii) Ensure sustainable energy procurement
iii) Ensure regulatory compliance

The Region has built on these goals through commitments such as the Climate Change Statement of Commitment, endorsed by Regional Council in 2017. The statement contains guiding principles and desired outcomes related to climate change to support the transition to a low carbon and resilient future.

In recognition of the Region’s strategic direction and the repeal of the Green Energy Act, the Region of Peel provides feedback in the following area;
i) Renewable Energy Siting
ii) Electricity Conservation
iii) Sustainable Energy Procurement
iv) Reporting

Renewable Energy Siting

Energy conservation and renewable energy are critical components in the transition to a low-carbon and resilient future. The Region of Peel Official Plan contains a series of energy policies relating to energy conservation, energy efficiency programs and renewable energy. It is the objective of the Official Plan to:
• Conserve energy by promoting energy efficient land use and development patterns, efficient transportation, and alternative and renewable energy systems.
• Plan and develop greener, healthier communities by reducing harmful greenhouse gas emissions and improving the air quality in the Region.
• Develop a culture of conservation that supports energy conservation, reduces emissions from vehicles as well as municipal, residential, commercial and industrial sources and protects air quality.

While the Region appreciates the return of municipal planning authority related to the planning of renewable energy projects, we recommend that the Provincial Government maintain an approvals framework in provincial legislation that removes barriers and streamlines approvals for renewable energy projects and continues to provide strong policy support for the renewable energy sector.

Electricity Conservation

The Region supports the re-introduction of provisions related to certain conservation and energy efficiency initiatives through the Electricity Act, 1998. The Region asks that the Province consider the following recommendations as it shapes the electricity conservation and efficiency provision.

• Allow for greater energy conservation by continuing to support and strengthen municipal influence over aspects of the building code as they relate to exceeding current building code standards for building envelope and mechanical equipment
• Encourage market transformation through the promotion of energy efficiency standards and certification. This can range from home appliances to energy efficiency ratings on homes
• Restrict the sale and/or installation of equipment that does not meet the minimum energy efficiency standards

Sustainable Energy Procurement

Through the Energy and Environment Sustainability Strategy, the Region recognizes the importance of reducing exposure to volatile energy prices and achieve manageable energy costs, while increasing the opportunity to purchase energy from renewable resources. The Region asks that the Province is mindful of the following opportunities as it makes future energy procurement decisions.

• Promote net metering to allow customers to generate electricity at one site and transfer energy to another. This would allow excess electricity generation to be sold to grid based on hourly price (net metering required)
• Promote the local generation of Renewal Natural Gas (RNG) to offset natural gas use and transportation costs through larger natural gas networks
• Promote the banning of any substance to a landfill that would generate methane in order to support the local generation of RNG

Reporting

The Region of Peel has renewed its Regional Values to define how we work together and drive our daily interactions and decisions; among these values is the need to be ‘genuine and transparent’. In the spirit of this value, the Region would like to provide the following feedback as it relates to energy reporting:
• Continue to require the five year energy conservation and demand management plan and annual energy and greenhouse gas emission reporting for the broader public sector, as per Ontario Regulation 397/11
o Improve the utility of the of these inputs by referring to them to inform Provincial energy programs and decisions and reporting findings back to build broader public knowledge and capacity.
• Expand the reporting requirements of the Energy and Water Reporting and Benchmarking to include the public sector
• Explore the inclusion of water conservation in the development of energy conservation and demand management plans
• Require billing from utilities be provided in an electronic string for loading into software

The Region of Peel looks forward to building a strong partnership and working collaboratively with the Province to address climate change and energy management needs of Ontarians.

Thank you for the opportunity to provide our comments.