Northland Power Inc…

Northland Power Inc. comments with a focus on expanding the eligibility of Renewable Natural Gas (RNG) in the context of electricity generation.

Northland believes RNG injected into a natural gas system should be considered as if it is being used directly, as an EPS facility responsible for the injection of RNG need not be the one to combust those exact RNG molecules, nor combust those molecules at the same time they are injected, to have the same environmental impact. The important point is to displace natural gas sourced from underground with RNG, a carbon-neutral fuel. Expanding eligibility would also reduce the cost and emissions associated with RNG transport (via existing pipeline infrastructure instead of heavy transport vehicles), and potentially eliminate the need for RNG storage at an EPS facility site.

With respect to eligibility criteria and other considerations, Northland has the following comments:

1. Injections outside of Ontario should be allowed if 1) there is a substantial decrease in price, reducing the cost to electricity ratepayers; or 2) the injection jurisdiction matches the destination of electrical capacity or energy in the case of firm export agreements.

2. Contracts with RNG marketers should be permitted so long as the underlying RNG comes from Ontario or aligns with the exceptions noted above. Contracting with a marketer that works with multiple RNG suppliers adds resiliency should an issue arise with a single RNG supplier. A clear record of RNG deliveries can still be facilitated while using a marketer.

3. To the extent the use of RNG results in an EPS facility carbon intensity below the performance standard for generating electricity (currently 310 tCO2e/GWh) in any compliance period, credits created should be valued at the applicable federal carbon price and returned to electricity ratepayers to offset the incremental costs of RNG and decarbonization.

4. Ontario becoming another province that supports this RNG eligibility (in addition to British Columbia and Quebec already) could further drive its consideration under the federal Clean Electricity Regulations, permitting the operation of EPS facilities beyond the 450 hrs/year and 150 ktCO2e/year limits if utilizing conventional natural gas alone.

At this point in time Northland does not believe there are circumstances to this approach that would affect the integrity of the EPS program but does believe that making this change is an important step towards a net-zero electricity system and economy. If implemented, this could be the means to remove those most difficult and costly emissions from the electricity system, the ones created from natural gas that provides flexibility and reliability, with the benefit of maintaining the utility of existing resources.