December 12, 2024…

December 12, 2024

Environmental Registry of Ontario
Toronto, ON

Dear Sir/Madame:

Re: Integrated Energy Resource Plan Consultation, Proposal No. 019-9285

I am writing to you today as Senior Director of Intergovernmental Affairs for Mississauga of the Credit First Nation (MCFN) and would like to thank you for the opportunity to provide comment on Ontario’s Integrated Energy Resource Plan, proposal number 019-9285. We have reviewed this policy in conjunction with Ontario’s Affordable Energy Future: The Pressing Case for More Power, Bill 214 Affordable Energy Act, as well as the final report and recommendations of the Electrification and Energy Transition Panel (December 2023). We have set out below our comments as they relate to the engagement questions in Ontario’s Integrated Energy Resource Plan (proposal number 019-9285) as well as our introductory and concluding comments on emerging electrification and energy issues in Ontario.

Introduction:
We would like to begin by underscoring the importance of the Ministry of Energy and Electrification (the provincial crown) consulting with MCFN on its draft policies, such as the supporting vision paper, Ontario’s Affordable Energy Future: The Pressing Case for More Power and Bill 214, Affordable Energy Act, 2024. We appreciate your engagement efforts to date as well as the need to engage First Nations consistently going forward to arrive at an energy plan that recognizes, and respects Aboriginal Treaty rights and integrates same into a comprehensive energy plan for Ontario. As Ontario’s population grows, it is more important than ever to address energy needs in a responsible, sustainable, renewable, economic and otherwise environmentally sound way. We further understand the importance of attracting investors to Ontario so that all Ontarians benefit from the prosperity that such investments generate. With that in mind, we would like to request that any energy agreements respect economic reconciliation with our First Nation and further that all proponents and government corporations partner with MCFN as they undertake energy projects within our Treaty territory. As recognized in the draft policy, number 019-9285 and supporting vision paper, engagement and partnerships with First Nations are essential to address the unique relationship we have with the land, water and air as well as the unique relationship our First Nation has with the Crown.

While we understand the approaches to providing integrated energy options, we would like to see renewable and/or other green energy initiatives and projects be upheld as the ideal for Ontario. This could be affected by way of compensation and other incentives for creating these types of projects within the province. As carbon emissions grow and the environment compromised, there needs to be incentives for switching energy sources and for creating new green energy projects/sources.

Going forward, it is crucial that Ontario partner with MCFN on renewable and other green energy projects that are good for the environment, our Treaty territory (see supporting MCFN Treaty map) as well as our community members. Any partnership/resource sharing agreement on energy and electrification should, at a minimum, provide for resource sharing between MCFN, proponents and Ontario. We would also like to see a largely discounted energy cost for MCFN members residing on our Treaty lands.

As reflected in the Integrated Energy Resource Plan and Ontario’s vision paper, it is stated that the vision commits to working in partnership with Indigenous communities in the build out of Ontario’s energy system, to advance economic reconciliation and enable Indigenous leadership and participation in the energy sector. Ontario needs Indigenous representation on energy projects that respects and acknowledges these commitments. The Ministry’s vision to include Indigenous communities (specifically MCFN) in all energy-related policies, papers, legislation, initiatives and projects is a long overdue approach but we look forward to continuing the collaboration with your Ministry.

Engagement Questions:

In relation to the questions posed in Ontario’s Integrated Energy Resouce Plan, we respond as follows:

Overarching Question:
• What policy options and actions should the government consider in the integrated energy resource plan to achieve Ontario’s vision for meeting growing energy needs, keeping energy affordable and reliable, ensuring customer choice and positioning us to be an energy superpower?
Implementing policies which encourage and support an integrated energy plan that is environmentally and economically responsible for Ontarians

The Ministry should engage with MCFN members, Elders and Knowledge Keepers to gain insight into their vision to ensure the environment is sustainable for its members for the next seven generations

Partnering with MCFN to advance Indigenous economic reconciliation and ensuring that voices of Indigenous elders, leaders and community members are reflected in a sustainable green energy and electrification network across the province, specifically within its treaty lands

Ensuring grid modernization and resiliency

Implementing policies relating to energy economic programs and initiatives to attract investors to Ontario while mandating and providing incentives to proponents who partner with and employ MCFN members

Increasing First Nation (MCFN) capacity and modernization of the energy and electrification infrastructure within Ontario

Working on exporting to other jurisdictions which could result in a decrease in the cost of electricity to Ontarians and increased jobs for MCFN members

Becoming a global leader in green and renewable energy sources and providing financial incentives for those who transition energy sources to a resilient and affordable clean energy economy which encourages energy options such as biomass, small modular reactors, renewable natural gas, hydroelectricity, and low-carbon hydrogen, wind, solar, battery plants, etc.

Planning for Growth
• The government’s priority is to ensure Ontario has the energy resources it needs to support growth. Are there opportunities to enhance the province’s approach to procuring electricity generation supply to better serve this priority?

Developing creative and innovative programs to encourage procurement with MCFN and/or other First Nations for the various green and renewable energy sources

Introducing legislative or regulatory changes to encourage and incentivize green energy transitions in all new projects

• What actions should government consider by promoting greater access to electricity and accelerate grid-connections that will support economic growth, connecting new homes, and electrifying transportation and heating?

Economic programs and incentives to encourage and accelerate grid connections with green heating options, EV vehicle and charger rebates for owners

Incentivizing increases for proponents that offer distribution energy systems that respond to local needs in an economically beneficial way

• As the need for new transmission infrastructure continues to grow, what steps can government take to ensure that transmitters have the certainty they require to move forward with development work as soon as possible, while also ensuring that competitive pressures keep costs as low as possible?

Adequate capacity and/or timely modernization of the transmission infrastructure employing MCFN guidance

Exporting energy sources with neighbouring and other jurisdictions which would keep costs low for MCFN, Ontarians and investors

Continue to expand and grow cost-effective approaches for energy and electrification while seeking guidance from MCFN

Installation and increase of other renewable / green energy sources that would decrease the demand for transmitters

Partnering with First Nations (specifically MCFN) to advance economic reconciliation which would translate into new sustainable developments and keep costs competitive for First Nations

• What policy guidance should the government provide to the Ontario Energy Board (OEB) with respect to the long-term role of natural gas in Ontario’s economy and opportunities for low-carbon alternatives in the gas system?

Provision of financial and other incentives to transition from natural gas to more environmentally friendly energy options

• How can the government best support Indigenous leadership and participation in energy planning and projects?

To engage early and often throughout the energy planning and project processes to ensure MCFN voices and perspectives in the energy projects. As stewards of the land, water and air, Indigenous perspectives are essential to ensure environmentally sound and sustainable practices are undertaken in all energy and electrification projects

In keeping with the Electrification and Energy Transition Panel’s final report (December 2023), it is suggested that the Ministry of Energy and Electrification follow the following recommendations:

Recommendation 4 recommends that the Ministry of Energy should develop and communicate an energy transition vision that is inclusive of Indigenous perspectives and informed by clean energy economy policy principles. It is essential that Indigenous voices (leadership, elders, community members) are captured in any energy economy policies, legislation and/or regulatory framework.

In keeping with recommendation 8, the provincial government should establish an external Energy Transition Advisory Council to provide advice, independent of government and on an ongoing basis, on the overall trajectory of Ontario’s energy transition, emerging governance or energy system-level questions and the integration of energy planning and coordination with sectoral strategies. Ontario must ensure Indigenous members (MCFN) are part of any external Energy Transition Advisory Council.

Recommendation 19: The government should support meaningful Indigenous participation in the clean energy economy through consistent and enhanced capacity-building support. Providing capacity funding so that MCFN (and other Indigenous communities) can participate in projects and share knowledge.

Recommendation 20: The government should advance economic reconciliation through flexible financing models and mechanisms that incentivize Indigenous project ownership across small, medium and large-scale energy projects.

Recommendation 21: The government should amend the enabling statutes of the IESO and OEB to ensure Indigenous (MCFN) representation on the Boards of Directors.

Recommendation 22: The Ministry of Energy should review its current resources to enhance the Ministry’s capacity to support Indigenous (MCFN) partners’ effective participation in energy planning and decision-making.

• How can provincial planning processes be enhanced to support high growth regions, ensure greater coordination between energy resources, and better integrate municipal, distributor and regional planning processes?
The creation of a comprehensive, province-wide integrated energy plan that has distinctions and benefits for local regions, incentives and initiatives for energy suppliers to work collaboratively with Indigenous communities and local municipalities to expand a grid system and infrastructure plan. There needs to be regional distinctions based on need and capacity that can sustain growth for the next seven generations

• What cooperation opportunities exist across other jurisdictions to support energy trade, construction of transmission infrastructure (ex. pipelines and interties), and transportation electrification?
Relationship building agreements, setting out how opportunities can be mutually beneficial for each party

Cost effectiveness of clean energy projects and the provision of energy to other jurisdictions

Employment and/or contracting opportunities for parties within each jurisdiction

• What types of technical information and forecasts would best support sector participants and energy consumers as the system is built out for growth and the economy increasingly electrifies?
Independent, comprehensive studies of renewable energy sources including classifications, challenges, best practices and suggestions

Information on how it saves consumers money over time, how it benefits the environment and reduces greenhouse gas emissions, improves product quality or consumer quality of life and how it fosters a more robust or resilient grid
 

Affordable and Reliable Energy
• What further steps should the government take to enable households and businesses to manage and make informed decisions about their energy use?
Educate, legislate and regulate green/clean energy sources, incentivize certain energy options over others

• What actions could the government consider to ensure the electricity system supports customers who choose to switch to an electric vehicle?

Continued improvement of the electricity grid system and energy infrastructure

Refinement and subsequent enactment of Bill 214, Affordable Energy Act, amending the Electricity Act, 1998 to promote electrification and facilitate energy efficiency measures aimed at using electricity to reduce overall emissions in Ontario

• What actions should government consider that would empower customers to install innovative technologies to generate or store energy on-site to reduce costs and improve resiliency?
Financial and other incentives to encourage on-demand energy systems

• What specific actions could position the integrated energy resource plan to best leverage distributed energy resources (DER) that enhance local and province wide grids to support energy system needs reliably and at the lowest cost?
Financial and other incentives to support consumers in the transition to DERs

• What policy or regulatory changes should government consider to address financial risks and support adoption of DER in the long-term?
Policies relating to financial incentives for smaller companies that offer DERs

Government guarantees for those that enter into DER projects.

Expansion of Schedule 2 to Bill 214, Affordable Energy Act giving the government more authority to regulate and incentivize DERs

• With the energy sector evolving and distributors considering new roles in serving customers, what barriers exist that limit local distribution companies from taking on new duties that could enable more efficient grid operations, leverage new technologies and further the integration of DERs?
Conflicts with larger utility companies are making it more difficult for smaller utility companies to compete

Lack of government incentives or grants for local distribution companies to take on new duties and roles in the need for local, clean energy distribution systems

Lack of investigation and enforcement of government competition laws relating to the position of larger utility companies over smaller companies. It is necessary to ensure that small and medium-sized enterprises have an equitable opportunity to participate in the Canadian economy and in order to provide consumers with competitive prices and product choices.

High cost to enter the industry or transition for those companies wishing to transition from older energy systems to renewable sources

• What further actions could the government take to maintain an affordable energy system for Ontarians throughout the energy transition?
Drawing investors to Ontario and MCFN Treaty lands by increasing return on investment

Increasing energy exports which would bring investment dollars into the province that should decrease the cost of energy for Ontarians, specifically the MCFN Community

Provide legislative and regulatory incentives for consumers (specifically MCFN Community members) wishing to transition to a more renewable or clean energy source

Becoming an Energy Superpower
• What opportunities exist to further capitalize on Ontario’s leadership and expertise in nuclear technology and nuclear innovation?
Encouraging the innovation, manufacturing and installation of SMRs which have a lower carbon footprint in areas not suitable for larger nuclear power plants. Prefabrication units of SMRs can be manufactured and then shipped and installed on site making them an affordable nuclear option

• What opportunities should Ontario consider to leverage its position as a clean energy leader?
Partnering with First Nations across the province to gather expertise relating to the environment and green/clean sustainable energy options in Ontario. Partnering with MCFN in all projects on Treaty lands

Keep costs low

The use of Small Modular Reactors and Distribution Energy Systems to meet local needs and the cost effectiveness of their installation and use of such energy sources

Distinct regional approaches to meet the local energy demands

The increase in electrification in meeting energy needs

Provide financial and other incentives to transition to more green/clean energy sources

Relationship building with other jurisdictions to whom Ontario seeks to export energy
 

Conclusion:
We trust that our comments adequately address the various energy-related issues raised by your Ministry in the above-mentioned policies, papers and legislation, and that we can continue to work collaboratively on energy and electrification projects, initiatives, and legislative changes.

Regards,

Mark LaForme
Senior Director of Intergovernmental Affairs