Environmental Commissioner has guarded praise for conservation policy

 

Ontario’s Environmental Commissioner said January 13 that he has adopted a wait-and-see attitude towards the government’s Conservation First philosophy.

          In releasing his 2014 Energy Conservation Progress Report, “Planning to Conserve,” Gord Miller praised the shift to considering cost-effective conservation before building new generation or transmission facilities: “Conservation has long been undervalued, and last year the government made significant progress in changing that by reorienting its energy policy.”

          Miller pointed to a number of positive changes in conservation-related policy:

• The government adopted a new Long-Term Energy Plan that put Conservation First.

• It began work on a new conservation framework for electricity utilities, and set a new goal for their reduction in consumption: 7 terawatt-hours by 2020.

• The Ontario Energy Board established a new conservation framework for natural gas distributors.

• Ontario’s Independent Electricity System Operator is adding in environmental benefits, like the cost of carbon, when doing its cost-benefit test to approve electricity conservation programs. The Ontario Energy Board has announced it will do the same thing for natural gas conservation programs.

          “These are all good improvements and will help the government put flesh on the bones of its Conservation First philosophy,” says Miller. “But I have to point out a couple of developments that give me pause, and hold me back from an unqualified endorsement of the government’s new conservation policy.

• The vast majority of local electricity distribution utilities will miss their target for peak reduction. About half are expected to miss their target for reducing overall consumption.

• The government has eliminated all of the interim electricity conservation targets that were used to measure the progress towards meeting its overall goals.

• The Conservation First philosophy is not backed up with legal authority, as was done with previous power system plan directives.

• The government has reduced the involvement of the public in reducing peak electricity demand.  

          “The government has spent the last decade trying to encourage the public to adopt a ‘Culture of Conservation’,” says the Environmental Commissioner. “Now, with its new approach to peak demand reduction, it appears to have forgotten that effort. A recent study shows that public interest and engagement in conservation in Ontario has hit an all-time low. That should concern all of us in the long run.”

 

If all technically feasible savings were realized, the study forecast that conservation could reduce Ontario’s electricity consumption by up to 24 per cent (41 TWh) in 2032 relative to the reference case. Even taking into account technical, economic and market barriers, conservation could realistically reduce electricity consumption by up to 18 per cent in 2032 relative to the reference case, based on the upper achievable potential estimate. The 18 per cent estimate is equivalent to 30.7 TWh and provided the foundation upon which the 2013 Long-Term Energy Plan electricity conservation target (30 TWh in 2032) was developed. These estimates include the conservation potential of conservation programs, as well as the impacts of past and expected changes to Ontario’s building code and product standards based on OPA’s estimates.

          The study identified 17.6 TWh of total upper achievable savings in 2020. This estimate includes several categories of conservation that are not covered by LDC conservation programs. These were subtracted to obtain 8.6 TWh of upper achievable conservation from LDC programs between 2015 and 2020. The ministry then determined the Conservation First target for LDC programs (7 TWh in 2020) based on a “moderate point between the upper and lower achievable potential” identified in the study.