2021
Ontario Sustainable Energy Association
Accomplishments
- OSEA held its first Sustainable Finance Webinar in January, moderated by VCIB, with Springlane Capital, NRSTOR Inc., and Co-Power. The Webinar focused on different types of clean capital available from equity to debt.
- OSEA established a strategic partnership with Public Service Canada (formerly Ontario Small Medium Enterprises or OSME) and held three separate webinar events: “Doing Business with Government Information Clinic”in June, “How to sell Cleantech to the Federal Government” in July, and “Myth Busting Federal Procurement” in August.
- OSEA partnered with the World Trade Centre in Toronto in September to offer a virtual Cleantech Export Business Mission to Mexico.
- OSEA held its 11thGreen Energy Doors OpenTMevent in October in partnership with Centennial College and sponsored by Enbridge and the Accelerator Centre. OSEA was pleased to have the Hon. Todd Smith, Minister of Energy as its keynote speaker, with an expert Sustainability Panel composed of TD Bank, Alectra Utilities GRE&T Centre, Enbridge, and Power Advisory LLC.OSEA then held a Virtual Award for the Best in Class across 10 sustainability categories. OSEA had some 150 plus registrants for the event.
- OSEA held its AGM in November to announce new strategic directions.
- OSEA organized a first of its kind Greener Homes Grant Program Webinarin December,in partnership with NRCan, the Canadian Association of Consulting Energy Advisors, an expert Energy Retrofit Expert Round Table featuring Fenestration Canada, Heating Refrigeration and Air Condition Institute Canada (HRAI), and the Siding and Window Distributors Association of Canada (SAWDAC).
- On Advocacy, OSEA provided input into the Hydrogen Technology Roadmap, requested a Provincial engagement process to amend Regulation 98-12 for Geothermal, and consulted the MOE on Virtual Net Metering and Community Net Metering.
OSEA is a recognized intervenor before the Ontario Energy Board. OSEA is assisted by Willms & Shier LLP and Power Advisory LLC. Below is a bullet list of the activities that OSEA accomplished with the OEB in 2021:
- Participated in the Natural Gas Integrated Resource Plan (IRP) (EB-2020-0091) and advocated for enhanced planning activities to support Demand-Side Management (DSM) programs, integrating non-pipeline alternatives (NPAs), and consideration for future climate change policy impacts.
- Advocated adjustment to the annual supply plan for Enbridge (EB-2021-0004) to ensure gas supply from neighbouring jurisdictions accurately reflect Ontario’s carbon price regime in the future through the blind procurement.
- Active participation in the Ontario Power Generation (OPG) rate application for 2022-2026 payments for prescribed facilities (EB-2020-0290). OSEA was instrumental in deferring $40M of variance account payments related to Surplus Baseload Generation until further analysis is completed. The deferral was part of the largest settlement agreement in OEB history, where intervenors and OPG agreed to reduce funds by over $500M over the rate-application time-period.
- Activate participation in the Independent Electricity System Operator (IESO) fee application (EB-2020-0230). OSEA, through the settlement agreement and its actions, was able to secure commitment by IESO to release more planning data on the electricity sector to support local communities understand their electricity infrastructure capabilities and options to meet sustainability goals. In addition, OSEA was able to defer the implementation of a higher application fee until the impact on competition was assessed by the IESO; helping ensure small-scale generation is not unfairly harmed by the higher application fee.
- Prepared comments on the OEB Staff Discussion Paper on CDM Activities; advocating for enhanced planning approach to CDM activities, expanded definition of CDM and support for many of the Staff’s recommendations.
- Ongoing participation in the following procedures;
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- Multi-year DSM program application from Enbridge (EB-2021-0002)
- Hydro One Joint Rate Application 2023-2027 (EB-2021-0110)
2020
Ontario Sustainable Energy Association
Accomplishments
OSEA Accomplishments in 2021
OSEA held its first Sustainable Finance Webinar in January, moderated by VCIB, with Springlane Capital, NRSTOR Inc., and Co-Power. The Webinar focused on different types of clean capital available from equity to debt.
OSEA established a strategic partnership with Public Service Canada (formerly Ontario Small Medium Enterprises or OSME) and held three separate webinar events: “Doing Business with Government Information Clinic” in June, “How to sell Cleantech to the Federal Government” in July, and “Myth Busting Federal Procurement” in August.
OSEA partnered with the World Trade Centre in Toronto in September to offer a virtual Cleantech Export Business Mission to Mexico.
OSEA held its 11th Green Energy Doors OpenTM event in October in partnership with Centennial College and sponsored by Enbridge and the Accelerator Centre. OSEA was pleased to have the Hon. Todd Smith, Minister of Energy as its keynote speaker, with an expert Sustainability Panel composed of TD Bank, Alectra Utilities GRE&T Centre, Enbridge, and Power Advisory LLC. OSEA then held a Virtual Award for the Best in Class across 10 sustainability categories. OSEA had some 150 plus registrants for the event.
OSEA held its AGM in November to announce new strategic directions.
OSEA organized a first of its kind Greener Homes Grant Program Webinar in December, in partnership with NRCan, the Canadian Association of Consulting Energy Advisors, an expert Energy Retrofit Expert Round Table featuring Fenestration Canada, Heating Refrigeration and Air Condition Institute Canada (HRAI), and the Siding and Window Distributors Association of Canada (SAWDAC).
On Advocacy, OSEA provided input into the Hydrogen Technology Roadmap, requested a Provincial engagement process to amend Regulation 98-12 for Geothermal, and consulted the MOE on Virtual Net Metering and Community Net Metering.
OSEA is a recognized intervenor before the Ontario Energy Board. OSEA is assisted by Willms & Shier LLP and Power Advisory LLC. Below is a bullet list of the activities that OSEA accomplished with the OEB in 2021:
Participated in the Natural Gas Integrated Resource Plan (IRP) (EB-2020-0091) and advocated for enhanced planning activities to support Demand-Side Management (DSM) programs, integrating non-pipeline alternatives (NPAs), and consideration for future climate change policy impacts.
Advocated adjustment to the annual supply plan for Enbridge (EB-2021-0004) to ensure gas supply from neighbouring jurisdictions accurately reflect Ontario’s carbon price regime in the future through the blind procurement.
Active participation in the Ontario Power Generation (OPG) rate application for 2022-2026 payments for prescribed facilities (EB-2020-0290). OSEA was instrumental in deferring $40M of variance account payments related to Surplus Baseload Generation until further analysis is completed. The deferral was part of the largest settlement agreement in OEB history, where intervenors and OPG agreed to reduce funds by over $500M over the rate-application time-period.
Activate participation in the Independent Electricity System Operator (IESO) fee application (EB-2020-0230). OSEA, through the settlement agreement and its actions, was able to secure commitment by IESO to release more planning data on the electricity sector to support local communities understand their electricity infrastructure capabilities and options to meet sustainability goals. In addition, OSEA was able to defer the implementation of a higher application fee until the impact on competition was assessed by the IESO; helping ensure small-scale generation is not unfairly harmed by the higher application fee.
Prepared comments on the OEB Staff Discussion Paper on CDM Activities; advocating for enhanced planning approach to CDM activities, expanded definition of CDM and support for many of the Staff’s recommendations.
Ongoing participation in the following procedures;
Multi-year DSM program application from Enbridge (EB-2021-0002)
Hydro One Joint Rate Application 2023-2027 (EB-2021-0110)
OSEA advocates on behalf of its members for a prosperous Ontario with a thriving sustainable energy sector, good jobs, resilient communities and healthy environments powered, heated, cooled, and moved by portfolios of sustainable energy.
Our collaborative approach and ground breaking work on policy and regulatory best practices has resulted in successes that include:
- OSEA initiated and led the highly successful campaign for a Green Energy Act for Ontario, which was passed in May 2009.
- OSEA was also instrumental in the introduction in 2004 of the Renewable Standard Offer Program, the precursor to the current feed-in tariff program offered by the Ontario Power Authority
OSEA advocates community ownership of clean, green power
As an advocate of sustainable, clean energy generated and owned by communities throughout Ontario, OSEA acts on behalf of all residents of the province who want to breathe clean air and protect the environment. OSEA does this by educating people about the benefits of community power – skilled jobs, a source of local revenue and a reduction of greenhouse gases – and encourages to become actively involved by establishing or joining community power groups or working with their municipality or economic development organization. OSEA also advocates government policies and programs that will advance the generation of sustainable energy and resolve the administrative and regulatory hurdles that are obstructing the development of community-owned sustainable energy projects.
On this front, OSEA has been extremely successful with the passage in 2009 of Ontario’s Green Energy and Green Economy Act. As a founding member of the Green Energy Act Alliance, OSEA played a major role in the creation of this legislation, which, with its program of advanced feed-in tariffs, is the most progressive in North America.
In its campaign for a Green Energy Act, OSEA pushed hard for a system of feed-in tariffs. These premium prices for renewable energy are credited with spurring the rapid deployment of renewable energy in Europe. Characterized as the best mechanism for combating climate change, feed-in tariffs act as financial incentives for everyone to produce electricity from green energies such as solar, wind, biogas and run-of-the-river hydro power plants that is fed into the provincial electricity grid.
OSEA Ontario Low Carbon Strategy Discussion Paper – Final.pdf
Regulation 98-12-Letter- V7-O30221.pdf
Ontario Low-Carbon Hydrogen Strategy – discussion paper (November 2020).pdf
OSEA Gvmt of Canada Office of Small Medium Enterprises OSME Ontario Region Introduction Followup.pdf
OSEA IRs EB-2020-0290 (OPG 2022-2026) – March 22, 2021_1920387 (2).pdf
OSEA_IR_EGI_20210112_1875165 (1).pdf
OSEA_Stakeholder_Comments_30032020_1708829 (1).pdf
Reports, Tools, and Guides
Policy Issues & Submissions
Net Metering & Self-consumption
- [NEW] MOE Questionnaire NET Metering (TPO & VNM) – OSEA Reply (February 2017)
- OSEA Submission regarding the Amendment of Ontario Regulation 541/05: Net Metering, made under the Ontario Energy Board Act, 1998 (EBR 012-8435) (October 2016)
- OSEA Input on Net-metering and Self-Consumption (October 2015)
Long-term Energy Plan (LTEP) 2017
- OSEA’s Long-term Energy Plan Submission (December 2016)
- OSEA Letter to Minister of Energy, The Honourable Glenn Thibeault, on the Long-term Energy Plan (November 2016)
- OSEA LTEP 2016 Pre-Planning Submission – Cover Letter (June 2016)
- OSEA LTEP 2016 Pre-Planning – OSEA Survey Executive Summary Report (June 2016)
Cap & Trade Regulation
- OSEA Submission on Offset Protocols (Dec 2016)
- OEB: Consultation to Develop a Regulatory Framework for Natural Gas Distributors’ Cap and Trade Compliance Plans (Board File No. EB-2015-0363) OSEA Comments on Staff Discussion Paper (June 2016)
Recommendations for Community Participation in Renewable Procurement
- OSEA Letter to Deputy Minister Serge Imbrogno – Recommendations regarding Community Participation in the Development of Renewable Energy Projects in Ontario (July 2016)
- FCPC – OSEA Joint Letter – LRP II and LTEP recommendations to support participation of Ontario citizens and community groups in Ontario’s low carbon transition (July)
- FCPC – OSEA Joint Submission – Submission to the Minister of Energy and the IESO for Community Participation Projects in LRP II (July 2016)
- Supporting Documentation: “The Power of Communities – How community-owned renewable energy can help Ontario create a powerful economic advantage”, TREC
IESO Application for Approval of 2016 Revenue Requirement, Expenditures and Fees
Northern Gas Grid Expansion
Bill 135, Energy Statute Law Amendment Act, 2015
- OSEA Submission to the Standing Committee on General Government regarding Bill 135, Energy Statute Law Amendment Act, 2015 (February 2016)
Auditor-General’s Report 2015
FIT 4.0
- OSEA Response to IESO on FIT application window (March 2016)
- OSEA Letter to the IESO on FIT4.0 Timestamp issue (December 2015)
- OSEA’s Input on FIT4.0 Price Review (August 2015)
Darlington 13-year License Extension
Home Energy Rating and Disclosure (HER&D)
Ontario Climate Change Strategy
- OSEA has been active as usual at the Ontario Energy Board (OEB) with the following interventions on key issues to both residents and businesses in Ontario. More details on each of these will be forthcoming shortly:
- IESO 2019 Expenditure and Revenue Requirement Submission – EB-2019-0002
- Post – 2020 Natural Gas Demand Side Management Framework – EB-2019-0003
- Request re Rate Design for Electricity – Commercial and Industrial Consumer – EB-2015-0043
- Utility Remuneration and Responding to Distributed Energy Resources– EB-2018-0287 & EB-2018-0288
- Distributed Energy Resources Connections Review – EB-2019-0207
- Hydro One Motion To Review – EB-2019-0122
- Enbridge 2021 DSM Plan – EB-2019-0271
- Ontario Energy Board 2019 intervenor results:
IESO 2019 Expenditure and Revenue Requirement Submission – EB-2019-0002Status: Completed. The parties attended a settlement conference and submitted a settlement proposal on most of the issues to the Board. The Board accepted the settlement proposal. The Board issued a decision on the remaining issues after written submissions. Purpose: The Board initiated a consultation process to develop a post-2020 Demand Side Management (“DSM”) Framework for natural gas distributors.OSEA involvement: OSEA submitted comments to the Board about:o supporting that DSM province wide programs and geographically targeted DSM programs should be considered in infrastructure planning to inform system planning and provide expertise for DSM implementation, and Purpose: The Board commenced a consultation on the Board’s Staff Report that provided staff’s recommendations for new rate designs for electricity commercial and industrial rate classes.OSEA involvement: OSEA submitted comments to the Board about aligning the interests of customers and distributors, supporting the Board’s stated objectives for the design of new rate structures, and advocating that the Board integrate this consultation with its other related consultations on Utility Renumeration, Responding to DERs, and Alternative Approaches to Allocating the Global Adjustment.Utility Remuneration and Responding to Distributed Energy Resources– EB-2018-0287 & EB-2018-0288Purpose: The Board commenced a consultation on utility remuneration and distributed energy resources and associated changes to the Board regulatory framework.OSEA involvement: OSEA participated in the stakeholder session. OSEA’s position is to advocate for sector transformation to a more sustainable energy economy through the use of DERs. OSEA encourages utilities and other market participants to embrace innovation in their operations and the products they offer to consumers, including innovation relating to energy efficiency, storage, smart grid technology and other technologies that promote sustainability and renewable energy generation. Purpose: The OEB commenced a related DER consultation on its technical requirements in regard to the connection of DERs by electricity distributors.OSEA involvement: OSEA commented on the OEB’s rationale for the proceeding, and commented that a clear enunciation of a preference for DERs with fundamental principles will expand the opportunities for DERs and enable local decision makers (utilities, municipalities, customers, service providers) to have the flexibility they require to maximize the value of DERs. Purpose: Hydro One commenced a Motion to Review the Board’s decision in the previous Hydro One 2018 -2022 Distribution Rates proceeding.OSEA involvement: OSEA is monitoring this proceeding because OSEA intervened in the Hydro One 2018 -2022 Distribution Rates proceeding. The issues raised by Hydro One in this Motion to Review did not require comment by OSEA.Enbridge 2021 DSM Plan – EB-2019-0271Status: The Board has not initiated a proceeding yet.
- OSEA involvement: OSEA submitted a letter in support of Environmental Defence’s request for a hearing, and sought intervenor status and cost eligibility.
- Purpose: Enbridge applied for approval of its 2021 DSM Plan, since the Board did not conclude the Board’s DSM Framework proceeding in time. Enbridge requested that the Board approve its DSM Plan without a hearing. Environmental Defence responded and requested a hearing on the basis that Enbridge’s DSM Plan was not compliant with various government policies and directives.
- Status: In progress. Parties have made submissions and are waiting on a Board decision.
- Hydro One Motion To Review – EB-2019-0122
- o OSEA also attended the first meeting of the working group.
- Status: In progress. The Board invited parties to comment on the issues for review and proposed solutions, and invited participation in a working group.
- Distributed Energy Resources Connections Review – EB-2019-0207
- o OSEA did not submit written comments, as OSEA had already commented in the related DER Connections Review proceeding.
- Status: In progress. Parties participated in a Stakeholder session in Fall 2019. The Board invited comments from participants.
- Status: Completed. Parties attended a stakeholder meeting and submitted comments to the Board.
- Request re Rate Design for Electricity – Commercial and Industrial Consumer – EB-2015-0043
- o advocating that natural gas plus DSM should be considered in energy infrastructure planning at the regional and local levels.
- o advocating for the introduction of Performance-Based Conservation in the next generation DSM framework,
- Status: Completed. Parties attended a stakeholder meeting and submitted comments to the Board. The Board stated that it will undertake a comprehensive review of the current 2015-2020 DSM framework for the purposes of establishing a new framework for the future. The OEB expects to continue its policy consultation on a new DSM framework into 2020.
- Post – 2020 Natural Gas Demand Side Management Framework – EB-2019-0003
- OSEA involvement: OSEA submitted written interrogatories relating to IESO’s engagement with small generators, IESO’s renewable distributed generation demonstration projects, IESO’s research on barriers to energy storage, and IESO’s development of pilot projects that evaluate the use of electricity to create hydrogen.
- Purpose: The IESO sought Board approval of IESO’s proposed 2019 expenditures, revenue requirement and fees. IESO proposed a net revenue requirement of $190.8 million (same as 2018 and 2017).
- Below is a summary of OSEA’s participation in OEB proceedings and consultations in 2021.Enbridge Gas Inc.’s Annual Update to its Gas Supply Plan (GSP) – EB-2021-0004Ontario Power Generation’s (OPG) 2022-2026 Payment Amounts Application – EB-2020- 0290OSEA participated in an interrogatory refusals hearing and a lengthy technical conference, and most recently attended an issues list hearing. OSEA’s comments and questions in the proceeding have been focused on determining whether the amounts OPG is claiming in its Hydroelectric Surplus Baseload Generation (SBG) Variance Account are reasonable and appropriate. OSEA’s position is that OPG should be operating its Pump Generating Station (PGS) to minimize SBG. OSEA will be participating in the OEB’s Settlement Conference in June 2021.Enbridge applied for approval of its IRP proposal. OSEA submitted interrogatories about the IRP proposal, and participated in the OEB’s technical conference, and oral hearing. In its final submission, among other things, OSEA:
- Enbridge Gas Inc.’s Integrated Resource Planning (IRP) Proposal – EB-2020-0091
- OPG applied for approval of payment amounts for prescribed generating facilities, as well as approval for disposition of various deferral and variance accounts balances. OSEA submitted interrogatories to OPG, and provided comments on OPG’s draft issues list.
- The OEB commenced a consultation to review Enbridge’s Annual Update to its five-year GSP. OSEA submitted interrogatories to Enbridge, participated in a Stakeholder Conference, and submitted comments on Enbridge’s Annual Update. OSEA requested that Enbridge (i) revisit its demand forecast to address the federal government’s intention to increase the price of carbon, and other legal and policy developments, and (ii) alter its Blind Request for Proposal process related to carbon costs. In particular, OSEA requested that Enbridge implement a carbon price border adjustment to ensure that Enbridge’s Blind RFP process does not indirectly lead to higher carbon emissions in other jurisdictions.
- · requested that the OEB direct Enbridge to conduct an analysis of customer response based on the difference between firm and interruptible rates as part of Enbridge’s 2024 re-basing application. In its reply argument, Enbridge indicated that it is prepared to investigate the drivers for recent declines in interruptible services as well as potential for changes to interruptible rates as part of its 2024 rebasing application.
- · requested that the OEB direct Enbridge to prepare or commission a summary report of Enbridge’s review of Demand Response (DR) programs in other jurisdictions, in advance of the stakeholder consultation process for Enbridge’s IRP pilot projects. In its reply argument, Enbridge acknowledged OSEA’s request and agreed that such research and reporting would be helpful to evaluate how to proceed with a DR pilot project in Ontario.
- · argued that Advanced Metering Infrastructure (AMI) would better support IRPA decision-making. OSEA requested that the OEB direct Enbridge to bring forward an AMI deployment proposal as part of Enbridge’s 2024 rebasing application. Enbridge indicated in its reply that it is planning to include an AMI deployment request in its rebasing case.
- The OEB has yet to make a decision on Enbridge’s IRP proposal.Enbridge applied for approval of its 2021 DSM Plan. OSEA submitted interrogatories and made a written submission about the DSM Plan. OSEA supported Enbridge’s request to roll over the DSM program to 2021, but requested that
- Enbridge Gas Inc.’s 2021 Demand Side Management (DSM) Plan – EB-2019-0271
- · the OEB require Enbridge to provide a revised estimate for 2020 and forecast for 2021 in light of the COVID-19 pandemic
- · Enbridge utilize flexible spending mechanisms within the DSM Variance Account to fund shovel-ready projects and programs and focus 2021 programming on municipal energy plans, research on sustainable heating technologies, and benchmarking
- · the OEB require Enbridge to report on customer participation numbers to evaluate the success of Enbridge’s efforts to increase customer participation, and
- · the OEB expedite the consultation on the Post-2020 DSM Framework.
- The OEB approved Enbridge’s 2021 DSM Plan.
-
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