Ontario Climate Change Solutions Deployment Corporation

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1 Katie Zwick Senior Policy Coordinator Ministry of the Environment and Climate Change Climate Change and Environmental Policy Division Air Policy and Climate Change Branch 77 Wellesley Street West - Floor 10 Toronto, ON M7A2T5 Re: EBR Registry No Draft regulation establishing the Ontario Climate Change Solutions Deployment Corporation Ontario Climate Change Solutions Deployment Corporation Recommendations The following submission provides the s response to the draft regulation establishing the Ontario Climate Change Solutions Deployment Corporation. The (CEA, or the Alliance) is a group of over 100 organizations representing a broad cross-section of Ontarians that united in 2015 to urge Ontario to show leadership in addressing the crucial issue of climate change. The CEA includes prominent Ontario businesses, industry associations, labour unions, farmers groups, health advocates, and environmental organizations. The Alliance supports the Ontario government s commitments to develop and implement a climate change strategy and action plan, including the creation of the Ontario Climate Change Solutions Deployment Corporation (OCCSDC). A low-carbon service provider and financing entity - if correctly structured - will significantly increase deployment of energy efficiency and fuel switching opportunities that will reduce greenhouse gas emissions (GHGs), and achieve economic savings, resilient communities, and job creation. The Alliance firmly believes the OCCSDC has a strong role to play in shifting Ontario to a thriving, low-carbon province. We offer the following recommendations to help the Ministry of Environment and Climate Change move forward in achieving this goal. These recommendation offer feedback on the posted regulation, and include a general set of comments designed to 1 P a g e

2 ensure the structure and function of the OCCSDC enables Ontario to secure its energy future and help the province meet its legislated GHG reduction targets. Clarify Overriding Goal of Reducing GHG Emissions The Draft regulation establishing the OCCSDC states that the corporation will determine an appropriate balance between a variety of priorities including maximizing absolute greenhouse gas reductions, stimulating the use of technology that supports fuelswitching, energy storage and deep energy retrofits, and stimulating private sector financing. The priorities listed are all important and should remain as priorities for the Corporation, however, the Alliance strongly recommends the OCCSDC have an overriding objective of reducing provincial GHG emissions. Maximizing GHG reductions should clearly supersede all other priorities. All decisions pertaining to the function of the Corporation should work to further this overriding objective. One Stop Climate Solutions Shop: Make It Simple The OCCSDC should become a one stop shop that would help residents, businessowners and commercial operations understand and determine what emission reduction programs and financial mechanisms are available for prospective projects. The OCCSDC needs to make it easy for people to find the solutions that work for them, and to get projects moving and financing secured. The Corporation should be able to provide information on a variety of potential solutions, their return on investment and emission reduction impact. These solutions should span the range of activities supported in the Climate Change Action Plan (CCAP), including energy efficiency and transportation as it pertains to homes. For example, the Corporation should be able to help connect homeowners to existing retrofit programs and EV charging incentives, in addition to its own programs focused on fuel switching and deep retrofits. Beyond identifying programs, incentives and financing mechanisms, the OCCSDC should provide support to customers at every stage of project identification, delivery, and financing. According to Efficiency Vermont the driving force of the sustainable energy utility concept is the recognition that total energy efficiency and renewable energy have to be easy for customers to learn about, understand, and adopt 1. The OCCSDC must take care of all of the complexity that the customer is likely to encounter, and take every step to increase ease of use for potential customers. Needs, products, technologies, contractors, incentives, financing, and quality control procedures should all appear to be 1 (2017). Designing Ontario s Green Bank - Webinar on Ontario Climate Change Solutions Deployment Corporation. 2 P a g e

3 part of a straightforward process, even though many different vendors and experts might be involved in a single project. For example, the OCCSDC could offer a dedicated website with built in customer service support, and a dedicated customer service phone line,, adequately staffed with well-trained knowledgeable workers. In addition to ensuring that the OCCSDC is a clearing house for any existing municipal and federal GHG reduction programs, outreach to municipalities and regional governments should be prioritized to ensure these stakeholders are fully aware of the OCCSDC and can refer potential customers to it. The burden of navigating through all of those steps should be easy, straight-forward and supported by the OCCSDC. To fulfill this vision of a one stop shop the OCCSDC should also build on and leverage existing programs, providing support and linkages to government and utility climate programs and incentives that may not be offered by the corporation, including transportation incentives that are integrated with buildings, such as those for residential and workplace electric vehicle chargers. Beyond Technology Deployment Currently, the OCCSDC mandate is focused on supporting technology deployment to support fuel-switching, energy storage and deep energy retrofits. However, technology deployment, while important, is but one of many building-related climate solutions. Consistent with the above points about connecting Ontarians with a wide-variety of solutions and prioritizing GHG reductions above all else, the Corporation should be focused on delivering the solution that works best based on an assessment of the individual circumstances. In many cases, those solutions may be relatively simple such as adding insulation or sealing a building envelope. We understand that there are currently programs that support and encourage energy efficiency and agree that the corporation should not duplicate those programs. It makes sense for the corporation to focus some energy on developing programs for activities that are not currently supported, such as energy storage and fuel switching. However, the corporation should have a comprehensive view of the many programs offered in Ontario and match individuals and businesses with the program that best matches their situation. In the interests of supporting innovation, as well, the corporation should aim to be technology agnostic, and support solutions based on their ability to reduce emissions, in a cost-effective manner. 3 P a g e

4 Support Commercial Buildings, Too To ensure GHG emission reductions are sufficiently captured in the building sector, the alliance suggests the clear inclusion of both existing and new multi-residential and commercial buildings in the scope of the corporation. Partnerships with Other Organizations The Alliance believes that the OCCSDC must work closely with existing utilities, local government agencies and non-profit groups to ensure equal access to efficiency services for Ontarians, and the avoidance of program or delivery duplication. In addition to ensuring access to these programs, the OCCSDC must also make significant investment in education and outreach of its services, so that market participants are educated and informed about the choices available to them to pursue low carbon options. Partnerships with other jurisdictions should also be pursued, to share best practices on corporation programs, performance, and achievement of outreach objectives. Create Programs to Support Low-Income Ontarians The section on Program Development makes reference to developing programs to stimulate the use of technology to address specific needs of low-income households. We would like to emphasize the need for the Corporation to follow through on this aim, and to prioritize programs for low-income households above some of the other program areas contemplated. Low-income Ontarians are struggling with rising energy bills. Low-income Ontarians also face unique challenges securing financing needed to undertake building retrofits. And retrofits to low-income households have a greater chance of being additive, in that without assistance they would not have been done otherwise. The creation of a novel service deployment organization offers a unique opportunity to embed customer equity and social justice deeply within Ontario s energy system. Without a clear commitment within the mandate of OCCSDC, this will likely not be achieved. Investments in increasing the affordability and reliability of energy access to vulnerable populations, and deepening overall system resilience should be a central pillar of the corporation, enabling energy security for all residents. 4 P a g e

5 Investments in Employment Where possible, the Corporation should look to ensure that the programs it operates and supports in turn support good jobs in the province of Ontario. The Clean Economy Alliance believes that Ontario s Climate Change Action Plan can be a good jobs plan, but it will only be so if such a goal is explicitly stated. Contact Information Thank you for your consideration in reviewing the CEA s recommendations. The CEA looks forward to continuing to work with the Province on developing the Ontario Climate Change Solutions Deployment Corporation and related climate change strategy. If you have any questions or require any clarification on the contents of this submission, please contact: Mikayla Wujec Clean Economy Program Coordinator 116 Spadina Ave, Suite 300 Toronto, ON M5V 2K6 Phone: X mwujec@environmentaldefence.ca Please visit for a full membership list. Please note the NEI Investments do not endorse this submission. 5 P a g e

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