Malone Given Parsons Ltd. (…

Malone Given Parsons Ltd. (“MGP) is the Group Manager for the Brooklin North Landowners Group (“BNLG”), which represents the participating owners in the northern part of the Brooklin Community Secondary Plan area in the Town of Whitby.

BNLG is comprised of 13 umbrella development companies and owns the majority of landholdings within North Brooklin, a new community area that is expected to accommodate 14,000 dwelling units, schools, commercial and retail areas, and other uses expected for full build-out by 2041, in accordance with the Brooklin Community Secondary Plan and the Brooklin Comprehensive Block Plan.

MGP has reviewed ERO File No. 019-9284, Proposed Amendments to the Electricity Act, 1998, Ontario Energy Board Act, 1998, and the Energy Consumer Protection Act, 2010, to enable an affordable energy future on behalf of the BNLG and is pleased to provide the following comments for the Minister’s consideration.

BNLG commends the Province in its efforts to modernize the Electricity Act of 1998, and the Ontario Energy Board Act of 1998. These changes are crucial to addressing the challenges of energizing and building homes in today’s housing crisis. While the proposed changes generally aim to promote efficient planning for the delivery of electricity and to mitigate unfair burdens on First Movers, the BNLG believes it can offer additional insights and propose further direction that can assist in achieving the Province’s goal of building 1.5 million homes by 2031. We are pleased to provide additional comments on the proposed amendments in the following sections of this letter.

Integrated Energy Resource Planning Amendments:
Prioritize Master Planning to Meet Municipal Housing Pledges

We strongly recommend that the Province consider regulatory and legislative amendments to require the OEB and LDCs to prepare 5-year integrated energy plans that:
1. Must be updated every 5 years to plan to implement Provincial and municipal planning forecasts.
2. Establish transmission and supply requirements to ensure that overall system planning anticipates and provides inputs into regional planning for generation and transmission requirements.
3. Require LDCs to complete local distribution design planning to accommodate growth in Large and Fast Growing Municipalities and any other municipalities that have signed a housing pledge with the Province.

Expedite and Fund Critical Transmission Infrastructure to achieve the Province’s 2031 Housing Targets.

We ask that the Province expedite integrated energy resource planning in Housing Pledge municipalities by:
1. Expediting the approval and funding of critical transmission infrastructure that is required to achieve the 2031 housing targets.
2. In Whitby, immediately approving and funding the GTA East MTS in order to enable the Town to meet Whitby’s 2031 Housing Pledge.

Electricity Connections to Support Growth
Current Practice Places an Unfair Burden on First Movers

We ask that the province consider changes to the legislative and regulatory system and take actions to expedite energy delivery in a fair way to new community areas by:
1. Requiring and enabling LDCs to deliver infrastructure to the doorsteps of new community areas in time to support the initial growth with Provincial financial guarantees to eliminate the risk to return and existing rate-payers should growth take longer than expected.
2. Providing financial incentives and fairness for first-movers that are required to fund capital works to bring energy to the doorstep of their developments, such as:
a. Allowing such funding to be a financial partnership with LDCs, including the potential for ownership in the LDCs commensurate with the investment in building a portion of their system;
b. Allowing developers/groups to reserve the capacity created from such investments and require new users to pay a fair share of indexed costs so that the cost of such infrastructure is shared proportionately and recovered by first-movers;
c. Ensuring that first-movers can recover the full capital costs with indexing from LDCs through modifications to the distribution system code and economic analysis calculations.