Standing Committee on Social Policy
Att'n: Anne Stokes, Clerk
Room 1405, Whitney Block
Queen's Park, Toronto, ON, M7A 1A2

August 24, 2004

Dear Chair and Members of the Committee

This submission on Bill 100, The Electricity Restructuring Act, is made on behalf of the members and directors of Citizens For Renewable Energy (CFRE), a not-for-profit organization, incorporated in Ontario in 1996.

We might sound like a broken record in once again pointing to energy conservation and efficiency as going a long way toward solving Ontario's energy supply problems. After appearing before the Standing Committee on Resources Development hearing submissions on the Energy Competition Act, in 1998 and presenting to the Select Committee on Alternative Fuel Sources in 2002 our message is still the same: ENERGY CONSERVATION PAYS FOR ITSELF - GIVES THE BIGGEST BANG FOR THE GOVERNMENT'S BUCK!!

Up until now the previous governments have only taken baby steps toward demand management. They even undercut to a large extent what was being accomplished by capping electricity rates to the point where consumers didn't have any incentive to conserve. We welcome the announcement by the Parliamentary Assistant to the Energy Minister, Donna Cansfield, appointed Leader of the Conservation Action Team, as she is quoted in the January 16/04 Ministry of Energy Press release: "The McGuinty government is acting to protect the interests of Ontarians by ensuring a sustainable and reliable supply of electricity...For too long conservation has been ignored. Government has a responsibility to make people aware of the need to conserve, but it also has to lead by example by ensuring that its own policies and programs don't put roadblocks in the way of conservation." Right on Ms. Cansfield - no more baby steps on energy conservation by this government!!

We now have two recent studies to support our push for concerted government action on energy conservation policies: The Ralph Torrie study report released in July 2003 and the Pembina Institute report of May this year. The latter puts the energy savings possible at an amazing 40% within the next 15 years (Power for the Future 3.4.1, page 16) if the right measures and initiatives are in place. "[T]he savings in energy costs resulting from reductions in energy consumption will pay for more than 96% of the capital costs of the adoption of more energy efficient technologies over the long term." "The net effect would be that even in the context of rising electricity and gas prices, the electricity costs to households and businesses would remain roughly the same as they are now, provided that consumers make the necessary investments in more energy efficient technologies and practices." Now wouldn't that be where the government should get involved and greatly enhance consumers' decision making by offering tax reductions or rebates or other incentives?

It needs to be pointed out that energy conservation also benefits grid stability to a great extent - our grid system is fragile and in dire need of upgrading. Of course the other part of the equation is the role DISTRIBUTED ENERGY GENERATION (DEG) can play cutting stress on the high voltage transmission grid. Much emphasis has been placed in previous submissions to the Committee on power generation from large scale wind projects. While larger scale wind projects can provide a substantial amount of clean power and might therefore be desirable, they again need long distance transmission grid to deliver the electricity to the user. The system benefit from distributed smaller scale wind generation is greater than from large scale projects. The system should allow developers of small scale projects to monetize these benefits, and cover the higher cost of small projects through higher prices. A well designed Advanced Renewable Tariff can accomplish this objective.

We see a major benefit from the government supporting solar power systems, installed on south-facing roofs of residences, arenas, commercial and institutional buildings and, most importantly, on government buildings to supply solar heated water and also electricity right where it is consumed. Especially solar water heating systems have seen major improvements in design and efficiency, making them the most economic investment with the fastest return rate. Consumers with electric water heaters could see as much as 30% reduction in their hydro bills. Naturally this would reflect in a major reduction in electricity demand that would normally come from polluting generating sources! Rooftop photovoltaic panels (PV solar) would provide electricity without depending on the grid system and thereby foregoing transmission losses. These panels, properly installed, are maintenance-free and many models carry a 25-year warranty!

The benefit of these systems to alleviate demand for more conventnional generation sources which depend on fuels with rising costs and deadly waste, cannot be overstated! Solar PV's value to the system exceeds the kWh's produced by a wide margin. PV produces power only during the day, the peak demand period, and produces at its maximum on sunny hot summer days when system demand is at its highest.

Strategically concentrating photovoltaic panels in areas with transmission constraint may allow deferral of costly transmission and substation upgrades. The Ontario government needs to aggressively support and assist energy users in putting these clean and SAFE renewable energy systems into residences, universities and schools, hospitals and commercial buildings. It should set an example by installing them on all government buildings! The Electricity Conservation & Supply Task Force (ECSTF), established last year, has recognized the many benefits of Distributed Generation Systems. At least 9 of their 30 Related Recommendations support employment and special treatment of DGS!

We strongly recommend, as an additional incentive for small distributed generators, for the government to direct utilities to buy back their surplus power by paying a considerable premium for this clean and renewable energy.

The much promoted Advanced Renewable Tarrif (ART) provision, fashioned after the European example, would go a long way towards alleviating Ontario's future power supply problems!! A resolution sponsored by CFRE and adopted by the general membership of Great Lakes United (GLU), a 20-year old international coalition of about 160 organizations, at their 2004 AGM in Erie, PA, urges the Ontario government to adopt the concept and introduce as policy with due speed. (Resolution "Enabling Advanced Renewable Tariffs in Ontario" is attached.)

On behalf of the members and directors of Citizens For Renewable Energy we thank you for the opportunity to make this submission and hope that it receives detailed study and serious consideration regarding adopting our recommendation.

Respectfully submitted,
[original signed]
Siegfried (Ziggy) Kleinau, Coordinator, CFRE

Whereas the RFP tendering or bidding process is a cumbersome, expensive, and often non-transparent mechanism for developing local, community-owned renewable power projects and

Whereas farmers and community cooperatives cannot raise capital to build renewable power projects without a firm contract for their electricity generation sufficient to repay debt and operating costs and

Whereas farmers and community-based projects also face disproportionate barriers in gaining access to the grid and

Whereas, for all practical purposes, farmers and cooperatives are prohibited from participating in and benefiting from the development of renewable energy in Ontario and

Whereas farmers, cooperatives and other forms of community power projects can bake a substantial contribution to the supply of electricity in the province and

Whereas Advanced Renewable Tarrifs have successfully stimulated rapid development of renewable energy in Europe and

Whereas there is a need for a simple, clear, and transparent mechanism separate from any bidding or tendering for renewable power development, a mechanism that will enable farmers and cooperatives to develop renewable power projects in Ontario, and

Whereas the development of legislation to create the Ontario Power Authority, the ONtario Conservation Secretariat, and related initiatives offers an unparalleled opportunity for the province and its citizens,

Be it therefore resolved that Great Lakes United call on the Government of the Province of Ontario to:

• Introduce Advanced Renewable Tarrifs as a mechanism to foster the rapid development of farmer-, cooperative-, and locally owned renewable powere projects; and
• Direct the Lieutenant Governer in Council to:
• Define qualifying projects by capacity, technology, and form of ownership or capital structure;
• Institute Advanced Renewable Tariffs that guarantee a minimum price for a minimum term to qualifying projects;
• Set allowable charges and requirements applicable to transmitters and distributors for evaluating, connecting to, and providing service to qualifying projects;
• Direct transmitters and distributors to:
• Issue standard contracts for interconnection written in clear language; and
• Guarantee the right of interconnection within a maximum of three months from receipt of a request for interconnection.

I HEREBY CERTIFY THAT THIS IS A TRUE COPY OF A RESOLUTION ADOPTED BY GREAT LAKES UNITED AT THE JUNE 6, 2004 ANNUAL GENERAL MEETING IN NORTH EAST, PENNSYLVANIA.

Loretta Michaud, Secretary