I would like to first affirm…

I would like to first affirm my support of the overall direction and intention of the proposed amendments to the Electricity Act, 1998, Ontario Energy Board Act, 1998 and Municipal Franchises Act, to modernize Ontario's energy regulation framework in such a way as to enable a more sustainable, resilient, and 'big picture' approach to Ontario's energy generation and transmission systems.

In addition, I would like to specifically express my support for a few key amendments that have been proposed. For one, I strongly appreciate and encourage the proposal to build on Ontario's existing Emission Performance Standards program by implementing a Future Clean Electricity Fund to offset costs associated with clean energy projects and thereby promote further clean energy innovation and adoption. Similarly, I am happy to see amendments that enable the Independent Electricity System Operator to pursue clean(er) energy hydrogen-related pilot projects for non-specifically-electricity applications as a means to look at the 'bigger picture' of the whole energy system -- i.e., beyond solely energy production and transmission to also think about how our energy system can be shaped by how (and how much of) that energy is used. As well, I am greatly relieved by the proposed amendments to provide authority to evaluate and, if necessary, prohibit the electricity connection requests of large data centres unless the security of the overall electricity system can be maintained -- an amendment that will be increasingly critical for the safety and security of our communities as digital technologies become more and more 'energy hungry'.

At the same time, there are a few proposed amendments about which I would like to express concerns. Most importantly, I am disappointed to see proposed amendments to remove municipal electors’ assent requirements for granting natural gas franchises. While I understand that these requirements can be burdensome and that they are often waived, removal of this assent requirement undermines our democratic participation and resilience; as well, as energy demands increase over the coming years at the same time as our environment is increasingly overburdened/deteriorating, ensuring avenues for the impacted local communities to retain governance and control over projects will become increasingly important. Therefore, rather than full removal of municipal assent requirements, I would like to see proposals for how a requirement for local assent can be maintained while being streamlined, made less burdensome, and perhaps promote greater engagement in the assent process by everyday people (e.g. do text-based announcements with comment opportunities get more engagement or do hearings that gather the community together? instead of a full vote, can municipal elected officials be required to reach out to their constituents for feedback and then just a vote of the elected officials representing their communities will suffice?). Additionally, I have concerns with the proposal to add the terminology of “economic growth” as a core consideration in electricity system planning and decision-making. While the economy is certainly a crucial element of strong, safe, and prosperous communities, the specific term of "economic growth" may be too vague and enable for decisions to be made that prioritize the profits industry even when they are in conflict with the wellbeing needs of local communities. Instead, I would like to propose to adjust the language to terminology more like "economic resilience", "economic sustainability", or "economic benefits for the Ontario community" (or something else, but along those lines), to better nuance the scope of these considerations.

Thank you kindly for taking the time to consider these comments and for your work to keep our province secure and prosperous.