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  • 7/29/2019 SWITCH LTEP Comments

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    To Whom It May Concern:

    SWITCH and its members appreciate the opportunity to provide input on Ontarios

    Long-Term Energy Plan.

    SWITCH has facilitated sustainable energy development in Southeastern Ontario forover ten years. SWITCH brings together urban and rural businesses, researchers and

    innovators, educational institutions, the public sector, and a variety of community-

    minded people working to create a sustainable energy future. Our members are

    engaged in designing, building, operating and researching sustainable energy solutions

    in Ontario.

    The collective energy sector experience of SWITCH and our membership has assisted

    us in recognizing the following factors as having created unprecedented change in

    Ontarios electricity system over the past decade:

    New technologies

    Volatile pricing

    Demand that has not met growth expectations

    The emergence of renewables and conservation as cost effective options

    Extreme costs of nuclear refurbishment and gas plant re-location

    Emergence of Not In My Backyard (NIMBY) as a powerful force

    Extreme weather caused by climate change

    Challenges for peak supply

    Potential for significant growth in the north

    Due to these factors, it is clear that Ontario should be making investments that will

    increase the ability of its power system to adapt to constantly changing conditions. The

    options that will most effectively provide this flexibility are:

    Conservation

    Renewables

    Gas combined heat and power (CHP)

    Increased transmission capacity

    SWITCH and its members believe that the following suggestions, if integrated into the

    Long Term Energy Plan, will help to ensure that our provinces power needs are met

    sustainably and cost-effectively :

    Conservation

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    As proposed in the Green Energy and Green Economy Act, require an energy

    assessment and rating for the sale of each property to allow buyers to make well-

    informed decisions about the operating costs and energy performance of a

    property before it is purchased, while creating a market-based incentive to invest

    in conservation measures at all Ontario properties.

    Make energy bills easier for customers to understand by including only delivery,

    electricity, and fixed charges. Currently, it is difficult for customers to understand

    what the true variable cost of energy is by reading a bill. Simplifying the bill and

    providing comparisons to peers (customers of a similar class) can help to motivate

    Ontarians to conserve. Roll all costs into the commodity charge so that the

    incentives for conservation are amplified.

    Increase the difference between on and off peak rates so there is more incentive

    for residential customers to change their consumption habits

    Commit to long-term, stable funding of conservation at local distribution companies

    (LDCs) to ensure continuity of programs and personnel. Great gains can be made,but any gap in funding after the 2014 target period will lead to layoffs and

    elimination of capacity to administer conservation programs.

    Allow LDCs or their contractors to quickly adapt Province-wide programs to fit the

    needs of their customers. The current process for incremental change and

    adaptation of OPA conservation programs is bureaucratic and too slow to react to

    market conditions.

    Ensure the continuance of the Ontario Power Authority SaveOnEnergy programs

    Support and replicate the innovations of regional utilities like PowerStream and

    scaled utilities like Utilities Kingston/Kingston Hydro who have been leaders in

    increasing conservation Explore multi-utility options for increasing integration of conservation programs

    Support third party service providers to engage with information provided from new

    smart meters

    Encourage funding organizations to provide support to companies that havedeveloped innovative conservation technologies and solutions

    Continue to make energy efficiency a priority in building code updates

    Renewables

    Lift the moratorium on offshore wind to allow for the expansion of this proven

    technology

    Increase policy stability by setting policies and only changing them according to a

    pre-determined schedule (long term, high capital cost investments like power

    systems require stable policy and procurement environment)

    Create a process for municipal concerns about renewable energy projects to be

    worked out with developers outside of the environmental assessment process

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    Allow for local engagement early in the project planning process to avoid allocation

    of resources to communities that do not support development

    Address generators concerns regarding Hydro Ones high connection costs, long

    lead times, lack of customer service help, and perceived obstructionist attitude

    Require buildings to be solar ready with low-cost conduit and supports as a

    building code requirement in urban areas. Work with Municipalities to create

    incentives for builders to site and orient buildings so as to maximize thermal or PV

    solar applications.

    Provide incentives for solar hot water systems, both as retrofits and in new build.

    Create a map of the province identifying areas with potential for large-scale

    renewable energy development such as wind and solar farms. This will provide

    local municipalities and residents advance notice that development is a future

    possibility, reducing the surprise and negative reaction that comes with it.

    Gas Combined Heat and Power (CHP)

    Provide a fixed price for power from CHPs to allow development of district energy

    systems

    Increased Transmission Capacity

    Consider stronger transmission interties with neighbouring jurisdictions to access

    clean hydro power and reduce need for expensive nuclear refurbishment

    Move toward a true linking of grids in northern Ontario and southern Ontario to

    enable the north to supply the south with power at a fair price Connect Ontario to the Manitoba grid with a major transmission line allowing

    import of clean energy from Manitoba

    Thank you again for the opportunity to provide input on the Ministry of Energys Long-

    Term Energy Plan and help move Ontario closer to a sustainable energy future.

    Regards,

    Tyson Champagne

    Executive Director, SWITCH