ABOUT ENERLIFE CONSULTING…

ABOUT ENERLIFE CONSULTING INC. www.enerlife.com

Based in Toronto, Enerlife Consulting Inc. is a North American leader in energy efficiency for commercial, institutional and multi-residential buildings. We monitor energy use data for thousands of buildings in Ontario, across Canada and the United States and in Europe. We work with hundreds of building owners, including commercial offices, school boards, hospitals and municipalities, applying data analytics to identify energy efficiency measures, implement improvements and verify savings. We are responsible for a growing number of buildings which are among the most energy efficient in North America.

Enerlife is also leading the low carbon energy transition for commercial buildings. We have documented the necessity to first achieve high levels of energy efficiency in order to make decarbonization and electrification affordable. We have shown that most commercial buildings can displace a substantial portion of fossil fuel combustion without adding demand to the electrical grid.

Enerlife represents the Building Owners and Managers Association (BOMA) in regulatory hearings at the Ontario Energy Board (OEB). We have a multi-year contract with NRCan to document actual energy efficiency of recently opened buildings across Canada, and to recommend code and process improvements to deliver consistently high energy performance for new construction. We advise Enbridge Gas and the Independent Electricity System Operator (IESO) on energy efficiency program design. We freely share our latest knowledge and data through workshops and webinars attended by hundreds of people each year.

As such, Enerlife has unique influence, knowledge and insight into actual energy trends in the commercial building sector, the characteristics of high energy performing buildings, electricity and natural gas load forecasting, and the nature and magnitude of the real energy savings potential.

ENERLIFE’S COMMENTS ON THE MINISTRY OF ENERGY AND MINES’ (THE “MINISTRY”) PROPOSED LEGISLATIVE AMENDMENTS

1. Data Centres (DC)– the Ministry’s proposed amendments to the Electricity Act, 1998, if passed, will impose connection requirements/restrictions on new DCs:

Opportunity - The Independent Electricity System Operator (IESO) expects that by 2035, 13% of new electricity demand will comes from new DCs. The massive amount of heat from these new DCs represents a great opportunity to substantially displace fossil fuel combustion and/or electricity heating through heat recovery.

Recommendation - Enerlife recommends the Ministry’s legislative amendments should include incentives or requirement to have new large DCs located beside commercial/industrial facilities and/or district energy systems to take advantage of heat recovery (from large DCs) to reduce electricity and fossil fuel usage.

2. Adding Economic Growth to the Objective and Objects of the Independent Electricity System Operator (IESO) and the OEB:

Opportunity – The Ministry’s proposed amendments are targeted towards enhancing electricity transmission and distribution planning process to drive innovation and economic growth, and to strengthen self-reliance and energy security. Energy transition projects (such as using Data centre’s waste heat to displace fossil fuel consumption, as described above) and energy efficiency improvement projects will also drive innovation and economic growth in Ontario.

Recommendation – To make Ontario a North American energy efficiency/energy transition powerhouse for products and services, driving investment and job creation within the province and exports to other jurisdictions, the Ministry’s amendments to update the objectives of the Ontario Energy Board and the IESO should also consider the innovation and economic growth driven by energy transition and energy efficiency projects. In addition, the Ministry should consider establishing comprehensive skills and workforce development courses to support energy transition/efficiency projects for all sectors (residential, commercial, institutional and industrial).

3. Future Clean Electricity Fund (FCEF)

Opportunity – The Future Clean Electricity Fund (FCEF) would use proceeds from the Emissions Performance Standards program and net proceeds derived from the transfer of Ontario Power Generation and IESO clean energy credits (CECs) to offset costs associated with clean energy projects. The proposed legislative amendments, if passed, will enable the implementation of the FCEF by allowing certain amounts payable for non-emitting and rate-regulated hydro-electric and nuclear electricity resources, as well as transmission projects, to be funded by proceeds from the FCEF.

Recommendation – Enerlife supports the proposed legislative amendments, subject to appropriate governance in selection and oversight of clean energy projects.