OSPE - The Voice - Fall 2019 - 8

ADVOCACY IN ACTION

GOVERNMENT RELATIONS
AND SUBMISSIONS

In the last several months OSPE has been working with
government to influence policy in Ontario. Some of our most
recent submissions include:

Letter sent to the Minister of the Environment,
Conservation and Parks, Hon. Rod Phillips

In this letter OSPE calls on the Government of Ontario to
reverse its decision to eliminate the Office of the Environmental
Commissioner of Ontario (ECO).
The ECO has been characterized as an independent, nonpartisan body that has produced numerous in-depth reports
on several key issues affecting Ontario, from energy to climate
change. A body such as the ECO is vital in highlighting
whether government policies and programs are having a
positive outcome on our environment. All Ontarians are
better off with the existence of the Office of the Environmental
Commissioner.
OSPE and its membership base truly values the importance
of an independent office that reports on government progress
on climate change, energy and other environmental issues.
OSPE has had the opportunity of working with both the
Environmental Commissioner and the Auditor General, and
we believe the environment would be better safeguarded under
the watch of an independent office such as the Environmental
Commissioner of Ontario.

Consultation on Industrial Electricity Prices

OSPE provided a submission to the Ministry of Energy,
Northern Development and Mines providing feedback on
Ontario's current industrial electricity pricing mechanism
and system.
OSPE believes that the following general principles should
be used in setting electricity rates:
* Ratepayers should pay for the services they use with rates
that are as close as possible to the actual cost to provide those
services.
* Government programs to assist low income ratepayers,
trade exposed businesses or for economic development or
social benefit reasons should be financed by government tax
accounts and not by raising the rates for other ratepayers
* Government programs to meet international obligations
should be included in the cost of electrical service.
* Rather than exporting this surplus at low wholesale prices
or curtailing (wasting) it, provisions should be available to
ratepayers on a voluntary basis to purchase that surplus at its
wholesale market energy price
OSPE recommends that electricity be considered as part of
8

THE VOICE

Fall 2019

a larger energy portfolio. There are opportunities to reduce
total energy costs for ratepayers if the larger portfolio of energy
uses is considered and surplus electricity is used to displace
other energy sources especially fossil fuels. That will also help
ratepayers to reduce their greenhouse gas emissions at no cost.

Fixing the Hydro Mess Act - Bill 87

OSPE released a statement highlighting the positive and
negative aspects of Bill 87, Fixing the Hydro Mess Act. The major
changes in this Bill include the following:
* Overhaul of the Ontario Energy Board (OEB)
* Upload of electricity conservation programs to the
Independent Electricity System Operator (IESO)
* Hold residential electricity bills to the rate of inflation
OSPE welcomes the governance changes to the Ontario
Energy Board, and strongly believes that the government is
making the right decision in implementing most of the OEB
Modernization Panel's best practice recommendations.
Minister Rickford mentioned that by uploading the delivery
of conservation programs to the IESO, the province is ensuring
a consistent approach to conservation across the province and
avoiding unnecessary duplication in administration costs.
OSPE believes that conservation programs provide Ontario a
great opportunity to achieve its climate change targets. Overall
these programs were achieving results that were much better
than the intended target. Successful programs like these
should be kept. Decision making should be evidence-based
and programs that are successful in reducing greenhouse gas
emissions should be financed properly.
OSPE welcomes the intention of holding residential
electricity bills to the rate of inflation. However, the lack of a
concrete plan on how to achieve this, as well as the reduction
of electricity bills by 12% is worrisome. OSPE will continue to
engage with government to ensure engineers are appropriately
consulted through this process, as they are able to provide the
technical expertise required.

ERO 013-5101 Discussion Paper: Modernizing
Ontario's Environmental Assessment Program

OSPE provided a submission to the government's consultation
on Ontario's Environmental Assessment Program. OSPE's
recommendations include:
* Provide the protocols for determining "low-risk" versus
"high-risk" for public review
* Ensure that the "one-time" assessments are done rigorously
* Require technical studies to be conducted, signed-off and
peer-reviewed by licensed professionals only
* Decrease the lengthy timeliness of Part II Order Decisions
* Go digital by permitting online submissions

OSPE - The Voice - Fall 2019

Table of Contents for the Digital Edition of OSPE - The Voice - Fall 2019