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-2021-0004

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.

Ontario Power Generation’s (OPG) 2022-2026 Payment Amounts Application – EB-2020- 0290

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.

OSEA 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 Gas Inc.’s Integrated Resource Planning (IRP) Proposal – EB-2020-0091

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:

    • 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 Gas Inc.’s 2021 Demand Side Management (DSM) Plan – EB-2019-0271

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

    • 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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