Policy Coordination and…

Policy Coordination and Outreach Branch
Ministry of Energy and Electrification
77 Grenville Street, 10th Floor
Toronto, ON, M7A 2C1
Tel.: 416-327-6758

Integrated Energy Resource Plan Consultation

Ontario’s Affordable Energy Future: The Pressing Case for More Power

ERO number: 019-9285
Notice type: Policy
Notice stage: Proposal
Proposal posted: October 22, 2024
Comment period: October 22 - December 13, 2024 (52 days)

Respondent: The Corporation of the Town of West Gwillimbury Response
Submitted by:
Mahesh Ramdeo, Deputy CAO
mramdeo@townofbwg.com

Jenn Best, Director of Growth Services
jbest@townofbwg.com

Michael Disano, Manager of Economic Development
mdisano@townofbwg.com

Date: December 13, 2024

The Town of Bradford West Gwillimbury (BWG) appreciates the opportunity to provide input on Ontario's legislative amendments supporting an affordable, reliable, and clean energy future. We commend the Ministry for addressing Ontario’s energy needs with an integrated approach that aligns with the province’s ambitious net-zero objectives.

As a municipality experiencing and planning for significant growth, Bradford West Gwillimbury (BWG) is committed to promoting efficient development and land use patterns that sustain the financial well-being of the Province over the long term. BWG is expected to double its population and add 31,000 jobs by 2051. Our town encompasses extensive provincially designated employment areas and boasts considerable acreage of industrial, commercial, and institutional (ICI) designations, providing for an appropriate mix and range of employment opportunities to meet long-term needs. The future opening of the Bradford By-pass will also contribute to economic investment in BWG. However, we are currently facing municipal-wide hydro constraints that are hindering the town's ability to fully realize our economic potential.
With BWG’s industrial and commercial developments facing current energy constraints, these limitations threaten economic stability and conflict with Ontario’s strategic goals for long-term economic resilience and low-carbon transition.

1. Impacts of Current Energy Constraints

Lost Economic Opportunities:
Current energy constraints mean BWG loses significant investment and development opportunities. Multiple companies, including a multinational transportation and logistics firm and a custom steel manufacturer, withdrew plans due to prohibitive hydro connection costs in the last year alone. It has also impacted a major development in our Highway 400 Prestige Business Park that was slated to bring 4 industrial multi-tenant buildings to the market (over 200,000 square feet total) and create hundreds of high-value local jobs. BWG's economic goals align with the Provincial Policy Statement’s (PPS-2024) aim of providing opportunities for sustainable economic development and maintaining viable, vibrant communities. Enhanced hydro infrastructure would allow BWG to support Ontario's broader objectives for employment, industry growth, and urban expansion.

Increasing Financial Burden on Municipal Revenue:
Stalled developments reduce municipal tax revenue, impacting funds essential for BWG’s services and infrastructure. This growing financial strain not only limits BWG’s fiscal health but also affects Ontario’s economic framework.

Suggestions on the Proposed Amendments

1. Recommendations for Legislative and Policy Support
Direct Funding and Cost-Sharing Initiatives: To address the financial demands of hydro expansion in high-growth areas, Ontario could consider direct funding or cost-sharing agreements for critical infrastructure projects, as these approaches align with PPS-2024’s directives for efficient public service facilities. Leveraging public-private partnerships (PPPs) is another feasible approach that would attract private investment to support and expand BWG’s energy infrastructure. Currently, municipalities have limited options to provide alternative funding sources and by updating the Municipal Act to provide municipalities with additional tools is one way to support industry attraction.

The Ministry has expressed that it would propose regulations that would allow for allocating costs for certain electricity system connection infrastructure, particularly in high-growth areas. BWG is a proposed high-growth area as indicated above. Regulations could include provisions that reduce the cost and financial burden on ‘first mover’ customers and enable more timely development of connection infrastructure to enhance system readiness for industrial and housing development and electrification. BWG wholeheartedly supports this initiative.

Expedited IESO Processes and Planning:
The Independent Electricity System Operator’s (IESO) study timelines do not align with BWG’s growth pressures. We recommend that Ontario prioritize BWG within the IESO’s Integrated Energy Resource Plan to ensure timely assessments and interim solutions, enabling BWG to meet immediate energy demands. Accelerating planning processes would allow municipalities like BWG to leverage Ontario’s existing provincial and federal resources for net-zero targets. The town would be an avid partner with the province and utility power suppliers to support the IESO in capitalizing on attracting businesses.
BWG recommends that IESO and local hydro utilities meet with municipalities to gather information about current and future growth plans as input to IESO and utilities own infrastructure planning.

2. Streamlined Approvals and Regulatory Flexibility:
Providing streamlined regulatory processes for energy projects in BWG would support accelerated development in designated employment areas. In addition, regulatory flexibility would allow BWG to adapt to local conditions, ensuring timely energy access for critical projects and aligning with Ontario’s long-term infrastructure strategies.

3. Integrated Energy Resource Planning:
Utilize the Integrated Energy Resource Plan to address specific hydro constraints identified in ongoing IESO studies, ensuring that local challenges are reflected in provincial planning. This aligns with the PPS-2024's guidance on integrating energy supply considerations into planning processes.

4. Leveraging Provincial Commitments and Resources: Invest Ontario Collaboration: Strengthen collaboration with Invest Ontario for site selection and investment attraction, leveraging their support to address energy infrastructure needs in designated employment areas. This supports the PPS-2024 objective of long-term economic prosperity.

5. Investment in Renewable and Diverse Energy Sources
Renewables with Energy Storage Solutions: Deploying wind and solar with battery storage has demonstrated cost-competitiveness over traditional gas-powered sources, especially as battery technology costs continue to decline. BWG supports provincial investments in renewables with integrated storage, as these measures improve grid reliability, reduce energy costs, and advance Ontario’s commitment to a sustainable and clean energy future.

 Economic and Environmental Advantages of Expanding Renewable Capacity
Cost-Efficiency of Renewable Energy: Clean Energy Canada’s recent report reveals that by 2030, wind and solar energy combined with battery storage could be 40% cheaper than gas-fired power, which is a significant consideration given BWG’s need for cost-effective energy solutions to support businesses. Renewables also shield consumers from volatile fossil fuel prices, providing energy price stability and supporting Ontario’s goal of an affordable energy future.

Alignment with Net-Zero and Green Energy Goals: To meet Ontario’s net-zero grid targets by 2035, investing in hydro and other renewables in BWG supports Ontario’s decarbonization goals, while enabling BWG to serve as a model for integrating clean energy into high-growth regions. The Clean Energy Canada forecast underscores the role of renewables in Canada’s economic advantage, particularly as international markets favour low-carbon products.

Localized Energy Projects for Economic Growth: Implementing localized energy projects in constrained areas like BWG would alleviate grid pressure, creating tailored energy solutions that support specific community needs. This approach fosters both provincial and municipal economic goals, as reliable energy infrastructure is crucial to attracting and retaining businesses.

6. Supporting EV Infrastructure and Economic Resilience
Electric Vehicle (EV) Integration and Clean Energy: BWG’s energy strategy includes robust support for electric vehicle infrastructure, crucial to meeting Ontario’s transportation electrification and climate goals. A reliable hydro supply in BWG will enable the town to facilitate EV adoption while contributing to emission reductions across Ontario’s growing transport sector.
The Town of Bradford West Gwillimbury is committed to Ontario’s clean, affordable energy future. Ontario can reduce costs, boost economic development, and progress toward its net-zero goals by improving hydro infrastructure and integrating renewable energy solutions. Achieving this goal requires alignment among Provincial Ministries, with intergovernmental cooperation across all four levels of government playing a critical role in addressing this critical concern. We appreciate the Ministry's attention to these recommendations and look forward to continued collaboration.

Sincerely,
Mahesh Ramdeo
Deputy CAO
P: 289-383-6398
E: mramdeo@townofbwg.com

Jenn Best
Director of Growth Services
P: 289-383-6957
E: jbest@townofbwg.com

Michael Disano
Manager of Economic Development
289-231-3829
E: mdisano@townofbwg.com

Research Sources

1. Understanding the Changes in Ontario’s Electricity Markets (Fraser Institute)
Fraser Institute’s analysis of Ontario’s electricity market, focusing on rising electricity costs and their economic impact.
Cited in Document as: Fraser Institute, 2024

2. Commentary No. 659: "Mind the Gap: The Impact of Budget Constraints on Ontario’s Net Zero Plans" (C.D. Howe Institute)
C.D. Howe Institute report on Ontario’s financial challenges in achieving net-zero goals, emphasizing the need for cost-effective energy strategies.
Cited in Document as: C.D. Howe Institute Commentary No. 659, 2024

3. Renewable Cost Report (Clean Energy Canada, Feb 2023)
Report on declining wind and solar costs in Ontario and Alberta, highlighting the affordability of renewables compared to natural gas by 2030.
Cited in Document as: Clean Energy Canada Renewable Cost Report, 2023

4. Renewable Cost Forecasts (Dunsky Energy + Climate Advisors for Clean Energy Canada, 2023)
Provides localized forecasts for renewable energy costs in Ontario, supporting renewable energy integration in high-growth areas.
Cited in Document as: Dunsky Energy + Climate Advisors, Renewable Cost Forecasts, 2023

5. Capturing Canada’s Electric Vehicle Opportunity (Clean Energy Canada, April 2024)
Examines Canada’s potential to lead in the EV market and the importance of low-carbon energy for EV infrastructure.
Cited in Document as: Clean Energy Canada, Capturing Canada’s EV Opportunity, 2024