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Table of Contents Table of Contents Formal Submissions E Electricity Distributors Association Organization Name Enbridge Gas Distribution A Enniskillen Environmental Association Enniskillen Township Association of Municipalities of Ontario Enwin Utilities Association of Power Producers of Ontario Association to Protect Amherst Island H Ashfield-Colborne-Wawanosh Residents’ Group H.A.R.M. B (sub-group of Central Bruce Grey Wind Concerns) BayNiche Conservancy Biogas Association I Bruce Peninsula Wind Turbine Action Group Innergex Renewable Energy Inc. C International Association for Public Participation IPC Energy White Paper on Large FIT Procurement C4CA Canadian Nuclear Association K Canadian Solar Industries Association Canadian Union of Public Employees Ontario King Township Canadian Wind Energy Association L Cavan Monaghan Township Central Bruce-Grey Wind Concerns Ontario Lake Superior Action Research Conservation Chartwell-Maple Grove Residents Association Legacy Holsteins City of Barrie City of Burlington M City of Guelph City of Kawartha Lakes Mississauga Residents’ Associations Network City of Toronto and Toronto Hydro Multi Municipal Wind Turbine Working Group Common Voice Northwest Energy Task Force Municipality of Grey Highlands County Coalition for Safe and Municipality of Kincardine Appropriate Green Energy Municipality of North Perth Municipality of Northern Bruce Peninsula D N Durham Region Natural Resources Canada NextEra Energy Niagara Region Northland Power NRStor Ontario Dialogue on Regional Planning and Siting Large Energy Infrastructure A Discussion about Energy Planning & Infrastructure Siting in Ontario Follow-Up Meeting with C4CA, CHIP and MIRANET and OPA & IESO Nancy Robertson, Frank Clegg, Lee Battiston Pauline Watson, Susan Hyatt, Dr. Boyd Upper July 29, 2013 Oakville/Mississauga We support (7 and 10) We strongly support community engagement in Municipal and Regional electricity planning •It has to be meaningful and substantive and involve the right people with appropriate resource support. •Caution in whom you chose make sure it is a true cross-section representation; Balsillie report as an example (Lee to provide either at the meeting or within 24 hours) Location: (15) •Real estate decision should be a jointly derived between the municipality and the OPA before procurement •Siting regulations need to be developed and implemented before any new large natural gas plants are approved (excluding co-gen plants). Community consultation is necessary to make these guidelines effective based on scientific studies; Community consultation is advised for site selection amongst similar alternatives (17) – more transparency and accountability about the total process from end to end Improvements Lack of provincial long term energy plan (IPSP) makes it difficult to plan at the region and municipal level •Issues such as proximity of power to use of power need to be debated •Use calculator as example to show trade-offs •Where it says plan, should say approved plan •(11 and 12) – cost sharing/allocation discussions should only occur after there is agreement on the principles. (17-19)Procurement and siting •Process has not been re-engineered •Concern is that safety is being passed off to MOE; D2, D4, D6 guidelines are useful but black swan events do occur (often due to human error) (18) – Should engage and consult with the community, not run information sessions (reference Mowat Energy; Getting the Green Light report, Nicole Swerhun book “Discuss, Decide, Do”.) (19) – Safety and health must be included in the criteria; An inherently flawed site overrides any proponent’s efforts Appendix A - Risk assessment should not be done by the proponent after contract award (21) – Unclear what this means? Isn’t an alternative of a centralized approach seems counter to a regional approach (20) – Appeals process is critical and it should be very clear and understandable to the average citizen 3 Quick Wins Publish siting criteria and guidelines o provide certainty to communities and power planners; o address the legitimate safety and health concerns of residents; o level the playfield for power developers; o ensure consistency with siting policies and requirements for other types of sensitive developments, including wind farms, railway corridors, propane stations, landfills, etc. Implement cumulative air-shed management o Accelerate Balsillie task force o Making this work will be a huge win for everyone OPA and municipalities choose location site before procurement Implement IRRP Advisory committee 4 Next Steps • Minister to act promptly on recommendations with appropriate allocation of resources • OPA publicly supports • Identify timelines, accountability framework, budget and responsibility of senior execs • Community support follows above 5 Appendix 6 From July 10th RECOMMENDATIONS relating to PROCUREMENT • Limit the use of Ministerial directives • Real estate, engineering and finance should not be the sole drivers of this process • Environmental impacts and need for IEA must be included • Safety and Black Swan risks cannot be ignored • An objective risk assessment is critical • Provide full transparency regarding deadlines, contract dates and planning assumptions and calculations 7 July 15, 2013 Bruce Campbell, CEO Independent Electricity System Operator Station A, Box 4474 Toronto, ON M5W 4E5 And Colin Andersen, CEO Ontario Power Authority Suite 1600 120 Adelaide Street West Toronto, ON M5H 1T1 DELIVERED VIA EMAIL RE: Regional Energy Planning and Siting Dialogue Dear Mr. Campbell and Mr. Andersen, Thank you for the opportunity to provide this submission regarding regional energy planning and siting of large scale energy infrastructure. CanSIA was pleased to be invited to the information session at the OPA offices on July 4th. We found the conversation to be informative and it helped us put into context the approaches and perspectives of different stakeholders involved. The following submission will address several of the key questions you have outlined in your discussion guidelines, specifically from the perspective of the solar industry. Solar is unlike other sources of generation, with a variety of favourable characteristics, notably: High public support: Solar energy enjoys the strongest and most widespread support of any electricity generation source with 98% of Ontarians supporting the technology (70% strongly support, 28% somewhat support). Empowered Consumers: Distributed solar is a core component of the smart grid and smart home future that is being enabled by Ontario’s investment in smart meters. As the electricity consumers of tomorrow will be able to interactively manage their electricity consumption through smart grid and smart home technologies, they will also have choices to ‘self-supply’ their energy needs by installing solar systems. The Canadian Solar Industries Association Page 1 Municipalities as Willing Hosts: Solar is easily integrated into communities, both urban and rural. It is scalable and can be located close to electricity consumers. As an embedded resource, solar can be developed in strategic locations to help meet local needs, similar to strategic implementation of CDM programs which provide longer term stability to the grid. Solar can be deployed quickly due to short permitting and construction schedules. Greenest Form of Energy: Solar has the lowest environmental footprint of any electricity resource. It has zero airborne emissions, zero hazardous waste emissions, almost zero noise. Further, it is inexpensive to decommission and land can be returned to previous use. Decreasing Costs: Unlike other forms of generation, solar electricity has and continues to decline in cost. The fact that the fuel source is free ensures that input costs will never rise. Peak Shaving Capabilities: Solar is peak load shaving and reduces the occurrence and cost of extreme summer peak prices. Energy production from solar is highly correlated with the peak times of energy consumption, therefore effectively reducing peak demand. Deferred Transmission & Distribution Investments: Distributed solar, like other sources of distributed generation and conservation demand management (CDM) measures, helps to defer capital outlay for transmission and distribution infrastructure expansion and therefore resulting in overall cost savings for consumers. The Ontario Energy Board’s Regional Planning for Electricity Infrastructure is expected to address how utilities can best capture this benefit. Price Hedge and Predictability: The development of solar in the near term can help to mitigate delays with the commencement of nuclear refurbishment and/or nuclear new build. Since solar is a front loaded capital investment, resulting in predictable long term cost, it is integral in the energy supply mix as a hedge against other long term fuel costs. Employment and Solar: Solar supports more jobs than any other energy source. The distributed nature of solar generation ensures that it produces high-quality local jobs such as engineering, design and installation. Land reclamation solution: Solar can be developed on brownfields and can be a productive use for exhausted mining, oil and gas exploration sites and other industrial sites which may otherwise have no useful life. It also provides income for community members that may no longer be able to farm or use their property as productive land. Our recommendations and suggestions put forward in this submission are made with these benefits in mind. Overall, CanSIA recognizes the need for the continued
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