Dear Mr. Motluk: Thank you…

Dear Mr. Motluk:

Thank you for the opportunity to comment on Proposed Amendments to the Ontario Energy Board Act, 1998 to provide the government with the authority to ensure fair and informed decision-making at the OEB to foster affordable communities.
(ERO 019- 8307).

While Peel Region supports efforts to rebuild Ontario’s economy while keeping costs down for people and businesses and build homes for our growing province, it is important to properly assess costs and take into consideration other Provincial priorities related to climate change.

Peel Region appreciates that the decision of the Ontario Energy Board (OEB) to reduce the natural gas utilities’ revenue horizon for new connections from 40-years to zero could increase the cost of a new home and for small businesses. However, giving the Minister time-limited authority to regulate or reverse this decision could negatively impact energy utility market competition, defer infrastructure costs to future generations and incentivize the use of higher greenhouse gas emitting natural gas. The OEB decision in December 2023 had set forth a direction that would address these concerns while still enabling Enbridge and market forces to address housing affordability concerns.

Specifically, the OEB decision:

(i) Supports Healthy Competitive Markets:
• Provides fair and competitive markets and transparency that will allow the consumer to make informed decisions based on true costs.
• Avoid lost economic opportunity from investing in imported natural gas instead of locally generated energy.

(ii)_Avoids Deferring Costs and Promotes Customer Fairness:
• Avoids incentivizing the expansion of natural gas infrastructure that could be stranded prior to end of life due to the move to lower carbon technologies and energy sources.
• Avoids incentivizing consumer energy decisions that could be cost prohibitive for the consumer in the future.
• Addresses inequities and cross subsidization that require existing and future customers to pay for new homes and buildings to connect to natural gas infrastructure installed today.

(iii) Helps Transition to Cleaner Energy & Mitigates Climate Change:
• Supports the provincially appointed Electrification and Energy Transition Panel’s report recommendation for the Province to implement reforms that support electrification and energy transition while appropriately managing overall costs to consumers.
• Decarbonizes Ontario’s energy system, in alignment with Peel Region Council’s position to phase out natural gas from the Ontario electricity grid and enable the transition to clean technology innovation and thriving green economy
• Aligns with climate change plans and targets set by the municipalities, such as Peel Region, to reduce greenhouse gas (GHG) emissions.

If the Province moves forward with its proposal to give the Minister authority to prescribe the revenue horizon and subsequently propose regulations to restore the revenue horizon to a 40-year period or shorter, Peel Region suggests that the Province provide incentive programs for homeowners and businesses for investing in energy efficient technologies (e.g., heat pumps). Such an incentive program would help reduce energy consumption, reduce GHG emissions as the grid is decarbonized, and level the playing field for customers.

QUESTIONS FOR CONSIDERATION

There are a number of provisions in the proposal which would benefit from greater detail and give rise to some questions. These questions are listed below for your consideration:

1) In light of the Minister’s decision to intervene on the Ontario Energy Board’s revenue horizon decision , how will the Province ensure the independence of the OEB as a regulator for future decisions and its ability to serve in the public interest?
2) How will the proposed amendments to the Ontario Energy Board Act, 1998 address costs being passed onto current and future natural gas customers and future generations of new home buyers?
3) Has consideration been given to how the Minister’s decision to intervene will influence customers’ purchasing decisions (ex. natural gas equipment) that may result in rising operating costs in the future?
4) What options have been explored for gas utilities to have a more active role in supporting provincial and municipal housing affordability mandates?