Integrated Energy Resource Plan Consultation

Overview of Comments 

A total of 136 submissions were received during the consultation period. Organizations and individuals who submitted comments via email and through the Environmental Registry include generators, transmitters, industry associations, natural gas utilities, environmental organizations, Indigenous communities, transit agencies and municipalities, and the general public.  

Many comments were supportive of the government releasing an integrated energy plan, acknowledging it as a necessary step to ensure energy demand is met in the long term and to manage the energy transition. Comments indicated a plan would bring policy clarity and predictability and continue to provide transparency on the province’s priorities for the energy sector.  

Energy Affordability  

A wide range of comments acknowledged the importance of affordability in energy planning going forward, and recommended actions such as prioritizing energy efficiency, continuing and enhancing rate mitigation programs, focusing on competitive procurements and distributed energy resources (DER) to drive down and defer costs, and exploring different ways (beyond traditional rate-funding approaches) to fund expansion of the grid.  

In consideration of these comments, the government made affordability a central principle of the Plan and included several initiatives and actions to support affordable energy. This is highlighted through its commitment to Ontario’s new 12-year, $10.9B energy efficiency framework, aimed at reducing energy use as one of the most cost-effective and immediate way to address Ontario’s growing energy needs. The Plan also highlights new and continued initiatives to drive customer choice, including establishing a DER strategy, procuring energy resources competitively, and continuing the province’s Clean Energy Credit registry and rate mitigation programs to keep rate payer costs down. The Natural Gas Policy Statement highlights the importance of natural gas as an affordable, reliable energy source in home heating, industry and agriculture. 

Planning for Growth and Reliable Electricity Supply 

Many comments suggested that the province’s energy planning framework could be better oriented towards supporting growth. For example, it was recommended that demand forecasts incorporate a wider range of scenarios, including high growth scenarios, and that planning processes could be more flexible to better align with the pace of growth. It was argued that improved engagement, revised regulatory frameworks to remove financial barriers to timely new connections, and more streamlined approvals processes are needed. This would lead to more accurate forecasting, faster project implementation, and ensure the electricity system can support growth and electrification.  

In consideration of these comments, the Plan introduces enhancements to system planning processes to better support high growth areas, including through new requirements for demand forecasts to be informed by multiple scenarios and through more frequent and formalized input from a broader range of stakeholders.  

To ensure long-lead clean energy resources are developed proactively, the Plan highlights the ongoing work to build out nuclear and hydro projects as well as the intention to advance several new major transmission lines.  

Regarding streamlining approvals, the plan commits to continue work to streamline provincial permitting and approval processes for priority energy projects to support housing, job creation, and long-term economic security. 

Finally, the Plan signals how the government intends to consult on proposed regulations to change cost responsibility rules for certain electricity transmission connection infrastructure for high-growth areas to enable more pro-active and anticipatory development of system connection infrastructure. 

Integrated Energy Planning  

Many of the comments received were supportive of more integrated energy planning between electricity and other energy sources, and between provincial electricity planning and other related sectors or levels of government. These comments suggested that integrated planning would provide clear policy signals to support decision making and investment, and a well-paced and coordinated energy transition that continues to be affordable and accessible.  

In consideration of these comments, the Plan reflects the beginning of a new integrated energy planning process, which will include the development of subsequent plans on a five-year cycle to provide predictability and transparency to the sector while ensuring an affordable, secure, reliable, and clean energy system. It also includes specific measures to initiate more coordination across electric and gas system planning through enhanced information sharing, participation from relevant stakeholders and coordinated modelling across fuel types. This will include improved processes for engagement in electricity system planning processes by gas utilities, municipalities and Indigenous communities. In addition, the Plan also signals the government’s intent to review the Municipal Energy Program for further opportunities to support municipalities in taking a leadership role in integrated energy planning in their communities.  

Clean Energy  

A number of comments advocated for explicit commitments or targets for emissions reduction, including to support better alignment with municipal energy and climate actions plans. Specifically, comments have suggested the government should develop policies that would achieve long term emissions targets. Some stakeholders also noted buildout of renewable energy generation where possible, such as solar, wind, geothermal, and systems that can capture energy from waste. Advancing nuclear energy generation was also raised as a key clean energy source in a number of comments due to both its environmental and economic benefits, with stakeholders noting how development of a clean electricity grid can help meet climate change goals.  

In consideration of the comments, the Plan has clean, reliable energy as a key guiding principle and contains a number of actions that support the buildout of clean energy resources. For instance, the Plan presents information from the Independent Electricity System Operator on what the future electricity supply mix could be, and this shows the potential for a near-zero emissions grid by 2050 as driven by nuclear, hydroelectric, and other non-hydro renewables.  The commitment to clean energy is further demonstrated in the Plan through the commitment to energy efficiency, distributed energy resources, and initiatives such as the province’s phased approach to increasing renewable content in transportation fuels. By undertaking regular integrated planning, future plans will continue to track progress on the implementation of a clean, reliable energy system over the planning period. This approach will allow for decisions to be informed by the results of competitive procurements, technological innovation and changing cost parameters for different energy sources. 

Natural Gas and Other Fuels 

The role of natural gas was raised, with some commenters believing natural gas must continue to play a role in the energy system to ensure reliable, affordable energy. Some commenters argued that Ontario needs an “all-of-the-above” approach to ensure a resilient, affordable, and reliable energy system. Others advocated to see natural gas phased out to reduce emissions. It was also noted that petroleum-based fuels are a major component of Ontario’s current energy mix and that certain commercial transportation and industrial sectors will have a continued need for liquid fuels, underscoring the importance of rapid scaling of emerging technologies such as biofuels, carbon capture and storage, and hydrogen to continue reducing emissions.  

In consideration of these comments, as well as comments received through a separate posting on the role of natural gas [ERO 019-9501], the Plan contains a Natural Gas Policy Statement that sets a clear vision of the future role of natural gas in Ontario’s energy sector and broader economy. The statement balances the continued role of natural gas in ensuring system affordability, reliability, and resiliency while integrating cleaner fuels in the future as the province moves towards a clean energy future. The Plan also reaffirms the role of other fuels, including laying out Ontario’s Pipeline Principles to signal its support and help advance discussions on nation-building, job-creating infrastructure such as energy corridors and pipelines. Finally, the Plan supports the development of emerging energy sources such as hydrogen, district energy, renewable fuels and carbon capture and storage.  

Indigenous Leadership and Partnerships 

Indigenous communities emphasized the need for early engagement on energy projects, while comments from organizations representing energy proponents expressed interest in partnering with communities or advancing reconciliation through energy plans and projects. Indigenous communities were favourable of an Integrated Energy Plan that enhanced consultation, partnership and economic opportunities and the chance to meet sustainability goals, while increasing access to electricity.  

In consideration of the comments, the Plan includes recognition of the continued need for early and meaningful engagement and consultation with Indigenous communities on energy projects. It also encourages Indigenous communities to participate in energy project opportunities by expanding the Indigenous Energy Support Program administered by the Independent Electricity System Operator. The Plan also reiterates the government’s recent $3B commitment to the Indigenous Opportunities Financing Program (formerly the Aboriginal Loan Guarantee Program). The Plan encourages the energy sector, including Ontario Power Generation (OPG), to explore commercial partnership opportunities in new generation developments, and commits to working with Hydro One to assess opportunities to expand and accelerate access to three-phase power on-reserve, and committing to exploring and enabling further off-diesel opportunities for remote First Nation communities. 

Electricity Grid Modernization  

The comments received addressed a wide range of issues related to modernizing the grid to reduce costs, empower consumers, improve security and resiliency, and support new technologies. For example, the role of DER in the future of the electricity system was of interest to stakeholders, with many organizations and individuals believing DER could play a crucial role in the energy transition, driving customer choice, reducing infrastructure costs, and providing grid resilience. Stakeholders emphasized the importance of firm government policy direction and support for foundational grid modernization investments. Many comments highlighted the need for education of energy consumers on various aspects of the energy transition to support participation, as well as additional commitments to support uptake of certain technologies, such as Electric Vehicles (EVs).  

In consideration of the comments, the Plan addresses the future of Ontario’s electricity grid including through the launch of a DER Strategy that includes coordinated policy actions to effectively integrate DER into system planning and decision making, expand market and program opportunities for customer-sited DER, and expand investment in DER at scale. The Plan also sets out the need for high performing Local Distribution Companies (LDCs) to have access to capital so they can build at the pace of growth. A definition of grid modernization is set out in the Plan to aid in a consistent regulatory approach to support LDCs as they plan for and invest in modernization. Finally, the Plan highlights the government’s commitment to grid resiliency and supporting the adoption of EVs.  

Becoming an Energy Superpower 

Several comments supported exploring ways to advance Ontario’s energy leadership though exports of electricity, medical isotopes, and engineering expertise. Some emphasized the importance of greater cooperation with other jurisdictions, and in particular other provinces such as by expanding interties with Quebec and Manitoba. Others noted risks associated with growing electricity exports such as greater exposure the regional market fluctuations and political shifts, emphasizing that Ontario should only expand export infrastructure when there is clear, reliable, and predictable demand from external markets – coupled with firm bilateral agreements.  

In consideration of these comments, the Plan sets out how the Independent Electricity System Operator will continue to investigate electricity exports and trade opportunities with Quebec and Manitoba, while continuing to explore Ontario-US electricity trade and exports, pending normalized trade relations. Beyond the expansion of electricity interties, the Plan outlines the desire to advance national energy corridors to connect Canadian products to new domestic and international markets. In addition, the Plan highlights ongoing work to grow Ontario’s global leadership in life-saving medical isotope production and nuclear expertise.  

Conclusion 

As the priorities and commitments outlined in the Plan are implemented, comments from stakeholders, the public and Indigenous communities will continue to be considered. This will include through further postings to the Environmental Registry, when appropriate. Continuous feedback will help ensure the Plan remains responsive to the needs and concerns of sector participants.