PDF of Submission
The Climate Action Council (CAC) is a network of over 40 municipalities from across the Greater Toronto, Hamilton, Eastern and Southern Ontario that work collaboratively on the development and implementation of clean air and climate change mitigation and adaptation actions. Climate Action Partnership, a charitable organization whose mandate is to advance climate action ambition and implementation, serves as the facilitator for the CAC.
We commend the Implementation Directive issued by the Ministry of Energy and Mines which directs the Ontario Energy Board (OEB) to establish a gas-electric coordinator information forum. As the need for electrification, supported by strong energy efficiency measures, continues to grow, alignment between electricity utility, natural gas utility, and municipalities is becoming increasingly critical. Greater coordination will help ensure that energy planning decisions are based on transparent information and shared assumptions that, in turn, can reduce the risk of costly overbuilding or stranded assets that will ultimately affect ratepayers.
The CAC's responses to select questions are provided below.
Current state: What are your views on the successes and limitations of existing gas electric information sharing and co-ordination?
It is through the combined and collective efforts across provincial ministries, IESO, utilities and municipalities that we will be able to deliver to Ontarians the low carbon, affordable, reliable, resilient and flexible energy system that they expect and demand. The current state of information coordination is heavily siloed. A major limitation is that current utility energy reporting occurs at the utility scale rather than the municipal scale. In other words, energy data is aggregated and reported across a utility company's entire service area, making it challenging for municipalities to isolate and analyze community-wide energy use within their own municipal boundaries. As a result, municipal staff frequently spend up to six months manually developing community energy use inventories, which is an inefficient and resource-intensive process that could be avoided with access to consistent, municipality-level electricity and natural gas data.
Information sharing: How should planning information be shared, stored and accessed?
The CAC supports the proposed characteristics of the data repository as described in Table 3 above. More specifically, we support the inclusion of municipalities as both data users and contributors of planning information. Many municipalities have already established energy efficiency, greenhouse gas reduction targets, and local energy strategies. Ensuring municipalities are actively included in regional energy planning discussions and data processes will improve alignment between provincial, regional, and local planning efforts and strengthen the overall quality of energy system decision-making.
Information type: What gas and electricity planning information should be shared?
The CAC recommends that information shared include municipality level data from both electricity utilities and natural gas providers. Consistent, local scale energy data would strengthen planning efforts and support more accurate, community specific decision making. Because many utilities serve multiple municipalities, current reporting practices offer limited value at the local level. Requiring data at the municipal scale would make it far more efficient for municipalities to complete annual community wide electricity and natural gas inventories. While this reporting change would not, on its own, provide the level of granular energy use data needed to develop Municipal Energy Plans that identify the most impactful and applicable community conservation actions, it would still offer meaningful support. Many municipalities undertaking Energy and Climate Plans face significant time and resource constraints during the community energy use inventory stage.
In the longer term, obtaining consistent and more detailed energy data remains a priority for Climate Action Council member municipalities, as it will enable more effective and locally informed energy planning. The above recommendation, however, will likely be easier for utilities to accommodate as no changes would be needed to the reporting classifications (other than the level at which it is reported) and this change will greatly increase the ability of municipalities to track energy use within their community via annual energy use inventories.
Information discussion : How should planning information be discussed among utilities, Indigenous communities and other participants? We commend the Minister's Implementation Directive to the OEB, which calls for changes to ensure meaningful and consistent engagement with stakeholders, including local governments:
"s. 3 of the IESO Directive says the IESO shall report back on planned changes to the processes for regional and bulk electricity planning, to ensure a consistent process for meaningful engagement with municipalities, Indigenous communities and regional Indigenous organizations. This will include consideration of energy plans developed by these groups and with a focus on fostering collaboration throughout the planning process to support timely implementation of projects."
CAC members have a strong desire to work in greater partnership with the various ministries (ex. Energy, Environment and Climate Change, Municipal Affairs) and agencies (ex. IESO, Utilities, OEB) to ensure Ontario can take maximum advantage of existing energy investments while also ensuring municipal participation in the rapidly emerging field of distributed energy. It is by finding the right balance and alignment between our existing energy system and our future energy systems that Ontario can best position itself to meet its economic, environmental and resiliency goals. In order to increase alignment between land use planning and energy planning, municipal planners and utility planners should be more proactive in identifying energy demand from new developments.
It is important to recognize energy limitations and where community energy may be best able to address local energy demand. Increased communication earlier in the process by the necessary stakeholders may also address the challenges distributed energy projects face when connecting to the existing grid and how targeted conservation and distributed renewables can best reduce need for new transmission and distribution infrastructure. This consideration should also be applied to the IESO's Regional Energy Planning exercise through incorporation of a lens for decentralized electricity systems as an alternative to, or complement to, future investments in electrical transmission and distribution infrastructure.
Information application : How should the shared planning information be used?
We support the proposal of a data repository information being compiled and discussion outcomes being summarized in a Regional-Gas-Electric Co-ordination Report that is filed to the OEB. In the past, the CAC has observed and identified a lack of transparency regarding the underlying assumptions and methodologies used in decarbonization studies, more specifically the IESO Decarbonization Pathway study. The CAC advocates for studies that move beyond planning for "where the market is at present" to more dynamic assumptions about where the market is likely to go in the coming decade regarding electrification and distributed energy resources.
As such, we see the Co-ordination Report as a valuable tool to enhance transparency and comparability and ease of review for municipalities. Unlike individual energy plans, which only reflect the perspective of the utility developing it, the Co-ordination Report would incorporate collaborative input from all utilities in the region, offering a more comprehensive and objective view of planning assumptions and forecasts and why divergences between data may exist. The CAC appreciates the opportunity to provide input and would be keen to engage more with the Ministry to answer any questions and provide more information related to this submission.