ON LTEP Submission
Ontario is developing a new Long-Term Energy Plan. In December, TIK submitted comments on the Plan. Our comments addressed Ontario’s opportunities to reduce fuels demands, as well as noting some issues related to Ontario's transition to economy-wide electrification.
Achieving Ontario’s Climate Change Goals Through Long-Term
The province of Ontario has been a national leader in climate action, having achieved an 80% reduction GHG emissions from the electricity sector since 2005, and more than 40 MT of absolute emissions reductions from 2005 to 2014. The Ontario Climate Change Action Plan1 provides a five-year roadmap to achieve 2020 targeted reductions (15% below 1990 levels) that amount to a further 15.7 MT of emissions reductions between 2014 and 2020.
Beyond 2020, Ontario is committed to more stringent targets through the Climate Change Mitigation and Low Carbon Economy Act, 20162, and must further align with the new Pan-Canadian Framework on Clean Growth and Climate Change3. Measures at least as strong as Ontario’s pledge to reduce emissions to 127.3 MT (37% below 1990 levels) by 2030, and to 36.4 MT (80% below 1990 levels) by 2050, will be required to meet or exceed the Paris Agreement aspiration of holding global temperature rise below 1.5C this century. Many advocate for full decarbonization by 2050 as a more appropriate target to forestall catastrophic warming that exceeds 2C by 2100.4
Ontario’s Long-Term Energy Plan (LTEP) will support the province’s climate targets by guiding the transition off polluting fossil fuels and onto low- and zero-emissions energy sources. Transition Initiative Kenora welcomes this opportunity to provide comment on the proposed LTEP.
Ontario’s Long-Term Energy Plan, 2017
After reviewing the IESO Ontario Planning Outlook, Navigant’s Fuels Technical Report and working through the LTEP Discussion Guide, two clear, interrelated themes emerge. First, Ontario needs to take ambitious action to reduce demand for fossil fuels. At the same time, the province needs to adopt policies and plans that support a managed economy-wide transition to electricity. As both reports forecast, achieving ambitious emissions- and energy-reduction goals is well within the province’s reach.
As a general comment, we recognized that there are potential efficiencies and material savings to be gained through electrification that were not discussed in either of the technical reports commissioned by the Ministry of Energy. A system built upon diverse fuels is inherently inefficient, demanding infrastructure redundancy to meet the specificities of each fuel type. For example, a natural gas heating furnace cannot be adapted to combust liquid heating fuel, just as gasoline and diesel are not interchangeable fuels for internal combustion engines. Electricity, on the other hand, is an end form of energy that can be developed from diverse sources but supplied to the consumer in a single energy form. A system built around electricity as a primary energy commodity will have greater universality and interchangeability, resulting in cost savings and efficiencies across the economy.
Our comments will address Ontario’s opportunities to reduce fuels demands through:
Adopting a conservation program for fuels
Targeting transportation sector fuels reductions
Targeting fuels demands for buildings
Investing in alternative fuels
Supporting infrastructure planning that aligns with fossil fuels demand
As Ontario transitions to economy-wide electrification, we draw attention to the following issues:
Reducing dependency on nuclear power
Investing in bulk transmission infrastructure
Enhancing microgrids and capacity for distributed generation
Reducing Fuels Demands
1. Adopting a conservation program for fuels
While Ontario has long had conservation programs for electricity, to date similar programs do not exist for fuels other than natural gas. A provincial fuel conservation program similar to the Conservation First Framework5 could deliver energy efficiency improvements by amending building codes and equipment standards to reduce fuels consumption for space and water heating, implementing demand-management and dynamic pricing schemes for transportation fuels, and introducing social benchmarking concepts to consumers to encourage a conservation first mindset.
2. Targeting transportation sector fuels reductions
Transportation represents the largest demand sector for fuels in Ontario. As such, this sector should be Ontario’s primary target for fuel demand reductions.
Ontario has established several policies to encourage the adoption of electric vehicles (EVs). The Electric Vehicle Incentive Program6 was introduced in 2010 and revised with significant improvements in 2016. The Climate Change Action Plan mandates new homes, workplaces and public buildings to have EV-charging units.
To further support these incentive programs, the province should develop and market educational consumer resources related to EVs to encourage adoption and to dispel myths that may prohibit consumers embracing EVs. These should include a cost-benefit economic analysis that demonstrates the savings a consumer might expect for EVs as compared to conventional internal combustion engine vehicles. Particularly in rural and remote areas where electricity delivery costs are very high, the province and LDCs should work to develop pricing schemes that ensure EV charging is at least as affordable as conventional liquids fuelling. For example, overnight residential charging practices could be encouraged through appropriate time-of-use pricing schedules for EV charging units.
While the $20 million Green Building Fund investment into EV charging stations is an important step forward, there are vast regions in the northern and western portions of the province where low- and zero-emissions vehicle infrastructure remains woefully inadequate. Municipalities should be encouraged and supported in investing in EV charging infrastructure. At the same time, provincial incentives to support trades training and private enterprise to support EV maintenance would further stimulate their adoption.
Ontario should consider even more ways to support trends toward transportation alternatives that challenge the long-standing norm of private vehicle ownership. Particularly in large urban centres, other transportation options such as public transit, active transportation, car cooperatives and rideshares often make more economic sense for consumers. Incentivizing these transportation options could have enormous impacts on reducing fuels demands in Ontario.
Finally, in line with social trends towards reducing private vehicle ownership, rather than promoting a target 2020 benchmark of 5% of vehicle sales being EVs, framing that benchmark around fleet replacement rather than new vehicle sales could tacitly promote a conservation ethos rather thanreinforcing consumptive growth. While the auto manufacturing and sales sector would balk at fuels demand reduction policies that
overtly constrain auto sales, encouraging fleet replacement allows auto manufacturers ample opportunities to manufacture and market new vehicles without increasing the absolute number of cars on Ontario’s roads.
3. Targeting fuels demands for buildings
After transportation, space and water heating for residential, commercial and industrial buildings is probably the next most obvious target for Ontario to reduce fuels demands. Ontario has devised many policies that will aid in improving building efficiencies, from building code amendments to energy audit policies for home purchases.
In the past, while fossil energy was cheap and plentiful and its climate impacts unrecognized, the thermal performance of buildings was often not prioritized to the extent that it should have been during new construction or renovation. In the past, added heating costs were an allowable trade-off to build quickly and cheaply. In the case of residential building, it has not been the Canadian norm to consider siting or orientation for passive solar heat gain, for example, and until recently, few homes were built with an aim to minimize emissions or energy demand.
Similarly, consumers’ home heating choices are typically driven first by availability and convenience, and second by cost. Again, few consumers make heating choices based on emissions or energy intensity of fuels.
First, in order to reduce space heating energy demands, buildings must be constructed to superior thermal performance standards. Code amendments should require high minimum standards for thermal insulation in walls, roofs and foundations, stringent air- tightness and air flow management, and siting and building design guidelines to maximize passive solar heat gain in winter and passive cooling (shading, airflow) in summer. Such amendments should apply to new construction as well as retrofitting and renovation. The province should develop policies that support scheduled energy efficiency retrofitting for all buildings in the province to make them code-compliant within a fixed timeframe.
Second, where possible, buildings should become net-zero emitters and energy users. This could involve making distributed energy generation capability a mandatory feature of all buildings. Such a policy, which could be applied immediately to new construction and phased in as part of scheduled retrofits for existing buildings, has been pioneered in France, where all rooftops must either produce solar photovoltaic energy or feature a rooftop food garden. Energy demand reduction policies could be developed to encourage the installation of rooftop or ground-mounted solar PV, air exchange heat pumps, geothermal systems or other heating and cooling technologies that reduce fossil fuels demands. Each building site presents unique opportunities and limitations with regard to distributed energy generation, which is again a good reason to amend codes and develop guidelines to support optimizing siting and building design for energy efficiency and emissions reductions.
Finally, there are significant research and development opportunities in the alternative energy sector in which Ontario should be investing. One option would be to recycle carbon pricing revenue into enhancing efficiency and deployment of solar PV and solar heating technologies, for example.
4. Investing in alternative fuels
While electricity is poised to become the energy standard of the near future, demand for liquid fuels will persist for industrial and manufacturing feedstocks and for meeting the energy needs of remote and off-grid regions. Ontario should be focused on transitioning these processes and applications off of fossil fuels sources and onto renewable and alternative fuels, while at the same time working to optimize the production and manufacturing of these alternative energy sources.
One valuable source of alternative fuels is biogas or renewable natural gas, including methane tapped from municipal landfills and agricultural waste. Processes to harvest and refine these small, distributed point sources of non-fossil natural gas will have to be optimized to ensure their economic and energy viability. For instance, it probably will not make sense to construct elaborate networks of pipelines to connect widely dispersed and relatively ephemeral sources of renewable natural gas, but it may become more plausible to develop mobile harvesting and refinery technology scaled to suit these applications.
Biofuels and biomass present another potential source of alternative fuels. Here we caution that the production of raw fuels should never compete with foods production nor should it result in the stripping of forests, whose role in providing valuable carbon sinks almost certainly outweighs their commercial biomass value. While such an activity may not be promoted by the province, in practice we have observed local forestry companies clearcutting black spruce forests and chipping whole trees to manufacture hogfuel for nearby industrial plants. We have been told (but have not verified) that one of the purchasers of this virgin hogfuel has been the Atikokan biomass generating station. We would hope this is a practice that is not condoned by the province, and certainly going forward we hope to see very stringent policies to protect forests and agricultural soils from depletion for the sake of generating biomass fuel stocks.
5. Supporting infrastructure planning that aligns with fossil fuels demand reductions
A final element of ensuring Ontario succeeds in vastly reducing its fossil fuels use is to plan for infrastructure that supports its declining demand.
At present, Ontario’s supply needs are met through the existing pipeline, rail, roads, and marine infrastructure that deliver western Canadian and U.S. fuels to the province. Giventhat energy demand scenarios that are compliant with climate policy forecast only declines for fuels demand, it follows that no further new infrastructure expansion is necessary. Indeed, pursuing expansion at this time would not only be contrary to aims of constraining demand, but it would lock in costly capital investments that may never achieve financial returns. Ontario’s LTEP should explicitly reject new fossil fuel infrastructure expansion within the province.
Transitioning to Economy-Wide Electrification
6. Reducing dependency on nuclear power
As the province shifts toward an economy powered by electricity rather than liquid fuels and coal, the mix of electricity supply should be tailored to include only genuinely clean energy sources. Nuclear power is not a clean energy source.
Nuclear power is often touted as a zero-emissions energy source, but this, too, is a falsehood. There are significant upstream emissions associated with uranium mining, as well as with the construction and maintenance of costly nuclear power plants.
Downstream, spent uranium fuel rods become some of the most toxic and long-lasting waste products on Earth. Ontario has yet to devise a suitable process for nuclear waste disposal that is guaranteed not to result in catastrophic environmental and human health disasters in the event of containment failure. Few are the communities that would willingly house toxic nuclear waste repositories. Even fewer are the sites that are physically suitable for receiving and storing waste without jeopardizing massive portions of the province while waste is en route from the nuclear facility.
Finally, for the exorbitant cost of refurbishing nuclear plants, Ontario could make far better investments in ensuring the long-term viability and adequacy of renewable energy sources like solar PV, wind, and microhydro. At the same time, the province should be supporting research and development into made-in-Ontario innovations in new and emerging technologies like artificial photosynthesis, water electrolysis hydrogen generation, and even nuclear fusion.
7. Investing in bulk transmission infrastructure
While the future of energy in Ontario is undoubtedly electric, the current system of a massive, interconnected intraprovincial grid is unwieldy, inefficient, costly, and inadequate. Functionally, northwestern Ontario is isolated from the rest of the province on a regional grid that lacks robust interties to the south. While this region is, on average, self-sufficient in electricity generation, its ability is limited to dynamically meet demand variability.
Interprovincial and international interties exist, but procurement policies do not necessarily align across jurisdictions to make the purchasing or sale of electricity feasible between Ontario, Manitoba and Minnesota. Ontario has made excellent progress in negotiating electricity trade agreements with Québec, and similar efforts must be applied to ensure all bordering jurisdictions are able to enjoy dynamic clean electricity sharing opportunities with Ontario.
IESO has established reasonable guidelines for enhancing bulk transmission and electricity distribution in our region. Enhancing regional interties like the East-West Tie Expansion to connect northeastern and northwestern Ontario should be prioritized. Improvements to the regional bulk distribution system should be made with regard to the changing demands on the grid as distributed generation increases and the grid moves toward becoming a reciprocal storage and supply reservoir rather than simply a delivery conduit.
8. Enhancing microgrids and capacity for distributed generation
A robust bulk transmission network is essential for connecting regional microgrids to one another to allow for dynamic demand management across Ontario and neighbouring jurisdictions. However, the future of electricity generation and distribution in Ontario is rapidly shifting away from centralized generation and delivery to the consumer to distributed local generation and a two-way flow of electricity on the grid.
In this scenario, regional and local microgrids must be designed with capabilities to dynamically balance loads. They must be capable of accepting energy input during peak generation times, for example on bright sunny days for solar PV generation or on windy days for wind power generation. The local grid would need to be able to equalize fluctuating capacity to provide consistent quality power to consumers. Such a system may necessitate having excess capacity dumped from the regional grid onto the bulk transmission system through robust regional tie-in nodes. Conversely, on low generation days, a regional microgrid may need to draw capacity from neighbouring jurisdictions if local storage is inadequate.
Optimizing distributed generation technology and logistics should be a priority for the province. At the same time, the province should also be supporting Ontarians in achieving personal and community energy security by incentivizing renewable generation capacity from the household level through to the local community scale. Distributed generation augments Ontario’s energy security by creating local sources of energy, adding redundancy to the supply so that Ontarians are better protected from system-wide failures. Distributed generation also enables Ontario to phase out reliance on polluting energy forms such as nuclear and natural gas. And finally, distributed generation puts production in the hands of the consumer, helping to make the connections between energy supply and demand more tangible and thus supporting greater energy conservation.
Although IESO has remarked that energy decentralization has the potential to erode the revenue necessary to maintain the bulk transmission system and other centralized energy services, there are ways to devise a distributed / microgrid system that ensures public support for ongoing maintenance, repair and replacement. The potential benefits of a widely distributed generation system vastly outweigh the potential drawbacks of decentralization.
Ontario’s Long-Term Energy Plan 2017 offers tremendous opportunities for the province to enhance its climate change and energy leadership. Already a trailblazer in Canada both in policy and action, Ontario’s actions today will set the province up to be a strong contender in the 21st Century global clean energy economy. The province is well positioned not only to attain its intended 2020, 2030 and 2050 emissions goals, but indeed to exceed them with ambitious policies and action, starting with the 2017 LTEP.
Ontario can support a rapid transition to clean, safe, renewable energy sources through research and development to support technological innovation. The province’s demand for all fuels, but especially carbon-intensive fossil fuels, will be vastly diminished through the electrification of our passenger vehicle fleet and switching to electric sources for space and water heating. Infrastructure planning and policy must reflect the province’s commitments to see fossil fuels demands decline, while boosting support for decentralized distributed energy generation throughout the province. Finally, and most crucially, the province must work to ensure that Ontarians have a sophisticated understanding of energy supply and demand and are eager to adopt a culture of conservation first.
We thank you for this opportunity to provide comment and feedback on the proposed LTEP, and we look forward to working with our fellow Ontarians to make our energy future clean and secure.
1 Ontario Climate Change Action Plan (June 2016). https://www.ontario.ca/page/climate-change- action-plan
2 Ontario Ministry of Energy (May 2016). “Ontario Passes Landmark Climate Change Legislation.” https://news.ontario.ca/ene/en/2016/05/ontario-passes-landmark-climate-change- legislation.html
3 Pan-Canadian Framework on Clean Growth and Climate Change (December 2016). https://www.canada.ca/en/services/environment/weather/climatechange/pan-canadian- framework.html
4 The Solutions Project (2016). http://thesolutionsproject.org/
5 Conservation First: A Renewed Vision for Energy Conservation in Ontario (August 2013). http://www.energy.gov.on.ca/en/conservation-first/
6 Modernized Electric Vehicle Incentive Program (February 2016). http://www.mto.gov.on.ca/english/vehicles/electric/electric-vehicle-incentive-program.shtml