• Below is a summary of OSEA's participation in OEB proceedings and consultations in 2020 and 2021.

  
  

  Enbridge Gas Inc.'s Annual Update to its Gas Supply Plan (GSP) – EB-2021-0004

  The OEB commenced a consultation to review Enbridge's Annual Update to its five-year GSP. OSEA submitted interrogatories to Enbridge, participated in a Stakeholder Conference, and submitted comments on Enbridge's Annual Update. OSEA requested that Enbridge (i) revisit its demand forecast to address the federal government's intention to increase the price of carbon, and other legal and policy developments, and (ii) alter its Blind Request for Proposal process related to carbon costs. In particular, OSEA requested that Enbridge implement a carbon price border adjustment to ensure that Enbridge's Blind RFP process does not indirectly lead to higher carbon emissions in other jurisdictions.

  Ontario Power Generation's (OPG) 2022-2026 Payment Amounts Application – EB-2020- 0290

  OPG applied for approval of payment amounts for prescribed generating facilities, as well as approval for disposition of various deferral and variance accounts balances. OSEA submitted interrogatories to OPG, and provided comments on OPG's draft issues list.

  OSEA participated in an interrogatory refusals hearing and a lengthy technical conference, and most recently attended an issues list hearing. OSEA's comments and questions in the proceeding have been focused on determining whether the amounts OPG is claiming in its Hydroelectric Surplus Baseload Generation (SBG) Variance Account are reasonable and appropriate. OSEA's position is that OPG should be operating its Pump Generating Station (PGS) to minimize SBG. OSEA will be participating in the OEB's Settlement Conference in June 2021.

  Enbridge Gas Inc.'s Integrated Resource Planning (IRP) Proposal – EB-2020-0091

  Enbridge applied for approval of its IRP proposal. OSEA submitted interrogatories about the IRP proposal, and participated in the OEB's technical conference, and oral hearing. In its final submission, among other thigs, OSEA

• ·        requested that the OEB direct Enbridge to conduct an analysis of customer response based on the difference between firm and interruptible rates as part of Enbridge's 2024 re-basing application. In its reply argument, Enbridge indicated that it is prepared to investigate the drivers for recent declines in interruptible services as well as potential for changes to interruptible rates as part of its 2024 rebasing application.

• ·        requested that the OEB direct Enbridge to prepare or commission a summary report of Enbridge's review of Demand Response (DR) programs in other jurisdictions, in advance of the stakeholder consultation process for Enbridge's IRP pilot projects. In its reply argument, Enbridge acknowledged OSEA's request and agreed that such research and reporting would be helpful to evaluate how to proceed with a DR pilot project in Ontario.
• ·        argued that Advanced Metering Infrastructure (AMI) would better support IRPA decision-making. OSEA requested that the OEB direct Enbridge to bring forward an AMI deployment proposal as part of Enbridge's 2024 rebasing application. Enbridge indicated in its reply that it is planning to include an AMI deployment request in its rebasing case.

• The OEB has yet to make a decision on Enbridge's IRP proposal.

  Enbridge Gas Inc.'s 2021 Demand Side Management (DSM) Plan – EB-2019-0271

  Enbridge applied for approval of its 2021 DSM Plan. OSEA submitted interrogatories and made a written submission about the DSM Plan. OSEA supported Enbridge’s request to roll over the DSM program to 2021, but requested that

• ·        the OEB require Enbridge to provide a revised estimate for 2020 and forecast for 2021 in light of the COVID-19 pandemic
• ·        Enbridge utilize flexible spending mechanisms within the DSM Variance Account to fund shovel-ready projects and programs and focus 2021 programming on municipal energy plans, research on sustainable heating technologies, and benchmarking
• ·        the OEB require Enbridge to report on customer participation numbers to evaluate the success of Enbridge’s efforts to increase customer participation, and
• ·        the OEB expedite the consultation on the Post-2020 DSM Framework.

• The OEB approved Enbridge’s 2021 DSM Plan.

  Distributed Energy Resources (DER) Connections Review – EB-2019-0207

  The OEB commenced a DER consultation on its technical requirements in regard to the connection of DERs by electricity distributors. The Board invited parties to comment on the issues for review and proposed solutions, and invited participation in a working group. OSEA commented on the Board’s rationale for the proceeding, and commented that a clear enunciation of a preference for DERs with fundamental principles will expand the opportunities for DERs and enable local decision makers (utilities, municipalities, customers, service providers) to have the flexibility they require to maximize the value of DERs. OSEA attended working group meetings starting in 2019, and throughout 2020.

  Post-2020 Natural Gas Demand Side Management (DSM) Framework - EB-2019-0003

  The OEB initiated a consultation process to develop a post-2020 DSM Framework for natural gas distributors. OSEA participated in two Stakeholder Sessions. OSEA submitted comments to the OEB about:

• ·        advocating for the introduction of Performance-Based Conservation in the next generation DSM framework supporting that DSM province wide programs and geographically targeted DSM programs should be considered in infrastructure planning to inform system planning and provide expertise for DSM implementation, and

• ·        advocating that natural gas plus DSM should be considered in energy infrastructure planning at the regional and local levels.

In December 2020, the OEB concluded the policy consultation process, and decided that the best approach for approving a post-2021 DSM plan is for the Board to consider it through an application process.

Utility Remuneration and Responding to Distributed Energy Resources (DER) – EB- 2018-0287 & EB-2018-0288

The OEB commenced a consultation on utility remuneration and DER and associated changes to the Board regulatory framework. OSEA participated in a Stakeholder Session and submitted comments on OEB Staff's proposals in 2020. OSEA’s position is to advocate for sector transformation to a more sustainable energy economy through the use of DERs. OSEA encourages utilities and other market participants to embrace innovation in their operations and the products they offer to consumers, including innovation relating to energy efficiency, storage, smart grid technology and other technologies that promote sustainability and renewable energy generation.

Ontario Energy Board 2019 intervenor results:

IESO 2019 Expenditure and Revenue Requirement Submission – EB-2019-0002

Purpose: The IESO sought Board approval of IESO’s proposed 2019 expenditures, revenue requirement and fees.  IESO proposed a net revenue requirement of $190.8 million (same as 2018 and 2017).

Status: Completed.  The parties attended a settlement conference and submitted a settlement proposal on most of the issues to the Board.  The Board accepted the settlement proposal.  The Board issued a decision on the remaining issues after written submissions.

OSEA involvement:  OSEA submitted written interrogatories relating to IESO’s engagement with small generators, IESO’s renewable distributed generation demonstration projects, IESO’s research on barriers to energy storage, and IESO’s development of pilot projects that evaluate the use of electricity to create hydrogen.

Post - 2020 Natural Gas Demand Side Management Framework - EB-2019-0003

Purpose: The Board initiated a consultation process to develop a post-2020 Demand Side Management (“DSM”) Framework for natural gas distributors.

Status: Completed.  Parties attended a stakeholder meeting and submitted comments to the Board.  The Board stated that it will undertake a comprehensive review of the current 2015-2020 DSM framework for the purposes of establishing a new framework for the future.  The OEB expects to continue its policy consultation on a new DSM framework into 2020.

OSEA involvement:  OSEA submitted comments to the Board about:

o   advocating for the introduction of Performance-Based Conservation in the next generation DSM framework,

o   supporting that DSM province wide programs and geographically targeted DSM programs should be considered in infrastructure planning to inform system planning and provide expertise for DSM implementation, and

o   advocating that natural gas plus DSM should be considered in energy infrastructure planning at the regional and local levels.

Request re Rate Design for Electricity – Commercial and Industrial Consumer – EB-2015-0043

Purpose: The Board commenced a consultation on the Board’s Staff Report that provided staff’s recommendations for new rate designs for electricity commercial and industrial rate classes.

Status: Completed.  Parties attended a stakeholder meeting and submitted comments to the Board.

OSEA involvement:  OSEA submitted comments to the Board about aligning the interests of customers and distributors, supporting the Board’s stated objectives for the design of new rate structures, and advocating that the Board integrate this consultation with its other related consultations on Utility Renumeration, Responding to DERs, and Alternative Approaches to Allocating the Global Adjustment.

Utility Remuneration and Responding to Distributed Energy Resources– EB-2018-0287 & EB-2018-0288

Purpose: The Board commenced a consultation on utility remuneration and distributed energy resources and associated changes to the Board regulatory framework.

Status: In progress.  Parties participated in a Stakeholder session in Fall 2019.  The Board invited comments from participants.

OSEA involvement:  OSEA participated in the stakeholder session.  OSEA’s position is to advocate for sector transformation to a more sustainable energy economy through the use of DERs.  OSEA encourages utilities and other market participants to embrace innovation in their operations and the products they offer to consumers, including innovation relating to energy efficiency, storage, smart grid technology and other technologies that promote sustainability and renewable energy generation.   

o   OSEA did not submit written comments, as OSEA had already commented in the related DER Connections Review proceeding. 

Distributed Energy Resources Connections Review -  EB-2019-0207

Purpose: The OEB commenced a related DER consultation on its technical requirements in regard to the connection of DERs by electricity distributors.

Status: In progress.  The Board invited parties to comment on the issues for review and proposed solutions, and invited participation in a working group.

OSEA involvement: OSEA commented on the OEB’s rationale for the proceeding, and commented that a clear enunciation of a preference for DERs with fundamental principles will expand the opportunities for DERs and enable local decision makers (utilities, municipalities, customers, service providers) to have the flexibility they require to maximize the value of DERs.

o   OSEA also attended the first meeting of the working group.

Hydro One Motion To Review -  EB-2019-0122

Purpose: Hydro One commenced a Motion to Review the Board’s decision in the previous Hydro One 2018 -2022 Distribution Rates proceeding.

Status: In progress.  Parties have made submissions and are waiting on a Board decision.

OSEA involvement: OSEA is monitoring this proceeding because OSEA intervened in the Hydro One 2018 -2022 Distribution Rates proceeding.  The issues raised by Hydro One in this Motion to Review did not require comment by OSEA.

Enbridge 2021 DSM Plan – EB-2019-0271

Purpose:  Enbridge applied for approval of its 2021 DSM Plan, since the Board did not conclude the Board’s DSM Framework proceeding in time.  Enbridge requested that the Board approve its DSM Plan without a hearing.  Environmental Defence responded and requested a hearing on the basis that Enbridge’s DSM Plan was not compliant with various government policies and directives.

Status: The Board has not initiated a proceeding yet.

OSEA involvement: OSEA submitted a letter in support of Environmental Defence’s request for a hearing, and sought intervenor status and cost eligibility.

EB-2018-0143: IESO Application for Approval of 2018 Expenditure, Revenue Requirement, and Fees

• Purpose: The IESO sought Board approval of IESO’s proposed 2018 expenditures, revenue requirement and fees.  IESO proposed a net revenue requirement of $190.8 million (same as 2017) and a usage fee of $1.2187/MWh for domestic customers and $0.9872/MWh for export customers (same as 2017).
• Status: Completed.  The parties attended a settlement conference and submitted a settlement proposal to the Board.  The Board accepted the settlement proposal.
• OSEA involvement:  OSEA submitted written interrogatories relating to the implications of the government’s decision to cancel 758 renewable energy contracts, the status and potential improvements to the Conservation First Framework and Industrial Accelerator Program.  

 

EB-2017-0319: Enbridge Renewable Natural Gas Enabling Program and Geothermal Energy Service Program

• Purpose:  Enbridge sought a Board approval of its Renewable Natural Gas Enabling Program and Geothermal Energy Service Program.  Enbridge later withdrew its application for the Geothermal Energy Service Program because of the Government of Ontario cancellation of GreenOn.
• Status: Completed.  The Board released its decision on October 18, 2018 approving Enbridge’s application for its RNG Enabling Program.
• OSEA involvement:  OSEA submitted written interrogatories relating to Enbridge’s Geothermal Energy Service Program before the program was withdrawn from the application.  OSEA submitted written submissions in support of Enbridge’s proposed RNG Enabling Program.  OSEA stated that it supports market development to supply RNG, and Enbridge’s use of the EBO-188 methodology to ensure there is no cross-subsidization by existing ratepayers.

 

EB-2017-0323/EB-2017-0324-2015: Union and Enbridge 2015 DSM Deferral and Variance Accounts

• Purpose:  Enbridge and Union sought Board approval for the final disposition and recovery of their respective 2015 Demand Side Management deferral and variance accounts.
• Status: Completed.  The Board released its decisions on August 30, 2018.
• OSEA position:  OSEA’s position was that it agreed with both Enbridge and Union’s submissions and request for the Board to approve the disposition of the accounts in the amounts sought.  OSEA provided comments on the evaluation and audit process of the DSM programs.

 

EB-2017-0255/EB-2017-0224/ EB-2017-0275: Cap and Trade 2018 Compliance Plans

• Purpose:  Enbridge, Union, and EPCOR Natural Gas (the Utilities) sought Board approval of their respective 2018 Cap and Trade Compliance Plans
• Status: Completed.   Government repealed Cap and Trade Program.
• OSEA position: OSEA’s position was that it generally supported the Utilities’ 2018 Compliance Plans.  OSEA expected future compliance plans to provide clearer timelines in order to develop cost-effective abatement measures, and to better include incremental energy efficient abatement measures.  OSEA supported the Utilities’ progress in developing the Abatement Construct, and the Utilities’ request for up to $2 million for the Low Carbon Initiative Fund to support investigations, studies and pilot programs for new customers and facility abatement measures.

 

EB-2017-0049: Hydro One 2018-2022 Distribution Rates

• Purpose: Hydro One is seeking approval of its electricity distribution rates and service charges such as for access to power poles.
• Status: Incomplete. 

• OSEA position: OSEA’s written reply submissions requested that the Board require Hydro One to:

 

EB-2017-0127/EB-2017-0128: DSM Mid-Term Review

·         Purpose: Board is undertaking a review of the 2015-2020 DSM Framework for Natural Gas Distributors.  Subsequent to the Board’s approval of the Utilities’ 2015-2020 DSM Plans, the government of Ontario created the Cap and Trade Program, which had the potential to overlap with DSM programming.  The Government of Ontario has now cancelled its Cap and Trade Program and associated funding.

• Status: Completed.  
• OSEA position:  OSEA’s position is that it supports DSM programming and the ultimate goal of reducing natural gas consumption in Ontario. In its submissions, OSEA emphasized that the DSM Framework and Utilities’ DSM plans should continue to provide programs, in light of the government of Ontario’s decision to cancel the Cap and Trade Program and associated funding.  OSEA also submitted that the Utilities should shift towards the use of metered consumption data versus the use of engineering assumptions.