IAEA: no major damage to quake-hit plant

Ontario Global Adjustment Appeal spotlights Ontario's electricity fee, regulatory charge vs tax debate, FIT contracts, green energy policy, and constitutional challenge as National Steel Car contests soaring power costs before the Ontario Superior Court.

Key Points

Court challenge over Ontario's global adjustment fee, disputing its status as a regulatory charge instead of a tax.

✅ Challenges classification of global adjustment as tax vs regulatory charge.

✅ Focuses on FIT contracts, renewable energy payments, power cost impacts.

✅ Appeals Ontario ruling; implications for ratepayers and policy.

A manufacturer of steel rail cars is pursuing an appeal after its lawsuit challenging the constitutionality of a major Ontario electricity fee was struck down earlier this year.

Lawyers for Hamilton, Ont.-based National Steel Car Ltd. filed a notice of appeal in July after Ontario Superior Court Justice Wendy Matheson ruled in June that an electricity fee known as the global adjustment charge was a regulatory charge, and not an unconstitutional tax used to finance policy goals, as National Steel Car alleges.

The company, the decision noted, began its legal crusade last year after seeing its electricity bills had “increased dramatically” since the Ontario government passed green energy legislation nearly a decade ago, and amid concerns that high electricity rates are hurting Ontario manufacturers.

Under that legislation, the judge wrote, “private suppliers of renewable energy were paid to ’feed in’ energy into Ontario’s electricity grid.” The contracts for these so-called “feed-in tariff” contracts, or FIT contracts, were the “primary focus” of the lawsuit.

“The applicant seeks a declaration that part of the amount it has paid for electricity is an unconstitutional tax rather than a valid regulatory charge,” the judge added. “More specifically, it challenges part of the Global Adjustment, which is a component of electricity pricing and incorporates obligations under FIT contracts.”

Chiefly representing the difference between Ontario’s market price for power and the guaranteed price owed to generators, global adjustment now makes up the bulk of the commodity cost of electricity in the province. The fee has risen over the past decade, amid calls to reject steep Nova Scotia rate hikes as well — costing electricity customers $37 billion in global adjustment from 2006 to 2014, according to the province’s auditor general — because of investments in the electricity grid and green-energy contracts, among other reasons.

National Steel Car argued the global adjustment is a tax, and an unconstitutional one at that because it violated a section of the Constitution Act requiring taxes to be authorized by the legislature. The company also said the imposition of the global adjustment broke an Ontario law requiring a referendum to be held for new taxes.

The province, Justice Matheson wrote, had argued “that it is plain and obvious that these applications will fail.” In a decision released in June, the judge granted motions to strike out National Steel Car’s applications.

“The Global Adjustment,” she added, “is not a tax because its purpose, in pith and substance, is not to tax, and it is a regulatory charge and therefore, again, not a tax.”

Now, National Steel Car is arguing that the judge erred in several ways, including in fact, “by finding that the FIT contracts must be paid, when they can be cancelled.”

There has been a change in government at Queen’s Park since National Steel Car first filed its lawsuit last year, and that change has put green energy contracts under fire. The Progressive Conservative government of new Premier Doug Ford has already made a number of decisions on the electricity file, such as moving to cancel and wind down more than 750 renewable energy contracts, as well as repealing the province’s Green Energy Act.

The Tories also struck a commission of inquiry into the province’s finances that warned the global adjustment “may be struck down as unconstitutional,” a warning delivered amid cases where Nova Scotia's regulator approved a 14% rate hike in a high-profile decision.

“There is a risk that a court may find the global adjustment is not a valid regulatory charge if shifting costs over a longer period of time inadvertently results in future ratepayers cross-subsidizing today’s ratepayers,” the commission’s report said.

A spokesperson for Ontario’s Ministry of Energy, Northern Development and Mines said in an email that it would be “inappropriate to comment about the specifics of any case before the courts or currently under arbitration.”

National Steel Car is also prepared to fight its case all the way up to the Supreme Court of Canada, according to its lawyer.

“What is clear from our proceeding with the appeal is National Steel Car has every intention of seeing that lawsuit through to its conclusion if this government isn’t interested or prepared to reasonably settle it,” Jerome Morse said.

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Solar ITC Impact on U.S. Wind frames how a 30% solar investment tax credit could undercut wind PTC economics, shift corporate procurement, and, without transmission and storage, slow onshore builds despite offshore wind momentum.

Key Points

It is how a solar ITC extension may curb U.S. wind growth absent PTC parity, transmission, storage, and offshore backing.

✅ ITC at 30% risks shifting corporate procurement to solar.

✅ Post-PTC wind faces grid, transmission, and curtailment headwinds.

✅ Offshore wind, storage pairing, TOU demand could offset.

The booming U.S. wind industry, amid a wind power surge, faces an uncertain future in the 2020s. Few factors are more important than the fate of the solar ITC.

An extension of the solar investment tax credit (ITC) at its 30 percent value would be “devastating” to the future U.S. wind market, according to a new Wood Mackenzie report.

The U.S. is on track to add a record 14.6 gigawatts of new wind capacity in 2020, despite Covid-19 impacts, and nearly 39 gigawatts during a three-year installation boom from 2019 to 2021, according to Wood Mackenzie’s 2019 North America Wind Power Outlook.

But the market’s trajectory begins to look highly uncertain from the early 2020s onward, and solar is one of the main reasons why.

Since the dawn of the modern American renewables market, the wind and solar sectors have largely been allies on the national stage, benefiting from many of the same favorable government plans and sharing big-picture goals. Until recently, wind and solar companies rarely found themselves in direct competition.

But the picture is changing as solar catches up to wind on cost and the grid penetration of renewables surges. What was once a vague alliance between the two fastest growing renewables technologies could morph into a serious rivalry.

While many project developers are now active in both sectors, including NextEra Energy Resources, Invenergy and EDF, the country’s thriving base of wind manufacturers could face tougher days ahead.

The ITC's inherent advantage

At this point, wind remains solar’s bigger sibling in many ways.

The U.S. has nearly 100 gigawatts of installed wind capacity today, compared to around 67 gigawatts of solar. With their substantially higher capacity factors, wind farms generated four times more power for the U.S. grid last year than utility-scale solar plants, for a combined wind-solar share of 8.2 percent, according to government figures, even as renewables are projected to reach one-fourth of U.S. electricity generation. (Distributed PV systems further add to solar’s contribution.)

But it's long been clear that wind would lose its edge at some point. The annual solar market now regularly tops wind. The cost of solar energy is falling more rapidly, and appears to have more runway for further reduction. Solar’s inherent generation pattern is more valuable in many markets, delivering power during peak-demand hours, while the wind often blows strongest at night.

And then there’s the matter of the solar ITC.

In 2015, both wind and solar secured historic multi-year extensions to their main federal subsidies. The extensions gave both industries the longest period of policy clarity they’ve ever enjoyed, setting in motion a tidal wave of installations set to crest over the next few years.

Even back in 2015, however, it was clear that solar got the better deal in Washington, D.C.

While the wind production tax credit (PTC) began phasing down for new projects almost immediately, solar developers were given until the end of 2019 to qualify projects for the full ITC.

And critically, while the wind PTC drops to nothing after its sunset, commercially owned solar projects will remain eligible for a 10 percent ITC forever, based on the existing legislation. Over time, that amounts to a huge advantage for solar.

In another twist, the solar industry is now openly fighting for an extension of the 30 percent ITC, while the wind industry seemingly remains cooler on the prospect of pushing for a similar prolongation — having said the current PTC extension would be the last.

Plenty of tailwinds, too

Wood Mackenzie's report catalogues multiple factors that could work for or against the wind market in the "uncharted" post-PTC years, many of them, including the Covid-19 crisis, beyond the industry’s direct control.

If things go well, annual installations could bounce back to near-record levels by 2027 after a mid-decade contraction, the report says. But if they go badly, installations could remain depressed at 4 gigawatts or below from 2022 through most of the coming decade, and that includes an anticipated uplift from the offshore market.

An extension of the solar ITC without additional wind support would “severely compound” the wind market’s struggle to rebound in the 2020s, the report says. The already-evident shift in corporate renewables procurement from wind to solar could intensify dramatically.

The other big challenge for wind in the 2020s is the lack of progress on transmission infrastructure that would connect potentially massive low-cost wind farms in interior states with bigger population centers. A hoped-for national infrastructure package that might address the issue has not materialized.

Even so, many in the wind business remain cautiously optimistic about the post-PTC years, with a wind jobs forecast bolstering sentiment, and developers continue to build out longer-term project pipelines.

Turbine technology continues to improve. And an extension of the solar ITC is far from assured.

Other factors that could work in wind’s favor in the years ahead include:

The nascent offshore sector, which despite lingering regulatory uncertainty at the federal level looks set to blossom into a multi-gigawatt annual market by the mid-2020s, in line with an offshore wind forecast that highlights substantial growth potential. Lobbying efforts for an offshore wind ITC extension are gearing up, offering a potential area for cooperation between wind and solar.

The potential linkage of policy support for energy storage to wind projects, building on the current linkage with solar.

Growing electric vehicle sales and a shift toward time-of-use retail electricity billing, which could boost power demand during off-peak hours when wind generation is strong.

The land-use advantages wind farms have over solar in some agricultural regions.

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Germany Solar Cap Removal would accelerate photovoltaics, storage, and renewables, replacing coal and nuclear during phaseout with 10GW per year toward 162GW by 2030, boosting grid resilience, O&M jobs, and domestic clean energy growth.

Key Points

A policy change to scrap the 52GW limit, enabling 10GW/year PV and storage to replace coal and nuclear capacity.

✅ Scrap 52GW cap to prevent post-2020 market slump

✅ Add 10GW PV annually; scale residential, commercial, grid storage

✅ Create jobs in planning, installation, and O&M through 2030

The German Solar Association (BSW) has called on the government to remove barriers to the development of new solar power capacity in Germany and storage capacity needed to replace coal and nuclear generation that is being phased out.

A 52GW cap should be scrapped, otherwise there is a risk that a market slump will occur in the solar industry after 2020, BSW said, especially as U.S. solar expansion plans signal accelerating global demand.

BSW managing director Carsten Körnig said: “Time is running out, and further delays are irresponsible. The 52GW mark will already be reached within a few months.”
A new report from BSW, in cooperation with Bonn-based marketing and social research company EuPD Research and The smarter E Europe initiative, said 10GW a year is needed as well as an increase in battery storage capacity.

This would lead to cumulative photovoltaic capacity of 162GW and 15GW residential, commercial and grid storage systems by 2030, in line with global renewable records being set, leading to new job opportunities.

The number of jobs in the domestic photovoltaic and storage industries could increase to 78,000 by the end of the next decade from today’s level of 26,400, aligning with forecasts of wind and solar reaching 50% by mid-century, said 'The Energy Transition in the Context of the Nuclear and Coal Phaseout – Perspectives in the Electricity Market to 2040' study.

Job growth would take place for the most part in the fields of planning, installation and operations and maintenance of PV systems, as solar uptake in Poland increases, the report said.

In maintenance alone, employment would increase from 9,200 to 26,000, with additional opened up by tapping into the market potential of medium- to long-term storage systems, alongside changing electricity prices in Northern Europe that favor flexibility, it said.

The report added that industry revenue could grow from €5bn to €12.5bn in the coming decade.

The report was supported by BayWa Re E3/DC, Fronius, Goldbeck Solar, IBC Solar, Panasonic, Sharp, Siemens, Sonnen, Suntech, Tesvolt and Varta.

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Clean Electricity Standard (CES) sets utility emissions targets, uses tradable credits, and advances decarbonization via technology-agnostic benchmarks, carbon capture, renewable portfolio standards, upstream methane accounting, and cap-and-trade alternatives in reconciliation policy.

Key Points

CES sets utility emissions targets using tradable credits and benchmarks to drive power-sector decarbonization.

✅ Annual clean energy targets phased to 2050

✅ Tradable credits for compliance across utilities

✅ Includes upstream methane and lifecycle emissions

The Biden Administration and Democratic members of Congress have supported including a clean electricity standard (CES) in the upcoming reconciliation bill. A CES is an alternative to pricing carbon dioxide through a tax or cap-and-trade program and focuses on reducing greenhouse gas emissions produced during electricity generation by establishing targets, while early assessments show mixed results so far. In principle, it is a technology-agnostic approach. In practice, however, it pushes particular technologies out of the market.

The details of the CES are still being developed, but recent legislation may provide insight into how the CES could operate. In May, Senator Tina Smith and Representative Ben Ray Luján introduced the Clean Energy Standard Act of 2019 (CESA), while Minnesota's 100% carbon-free mandate offers a state-level parallel, and in January 2020, the House Energy and Commerce Committee released a discussion draft of the Climate Leadership and Environmental Action for our Nation’s (CLEAN) Future Act. Both bills increase the clean energy target annually until 2050 in order to phase out emissions. Both bills also create a credit system where clean sources of electricity as determined by a benchmark, carbon dioxide emitted per kilowatt-hour, receive credits. These credits may be transferred, sold, and auctioned so utilities that fail to meet targets can procure credits from others, as large energy customers push to accelerate clean energy globally.

The bills’ benchmarks vary, and while the CLEAN Future Act allows natural gas-fired generators to receive partial credits, CESA does not. Under both bills, these generators would be expected to install carbon capture technology to continue meeting increasing targets for clean electricity generation. Both bills go beyond considering the emissions resulting from generation and include upstream emissions for natural gas-fired generators. Natural gas, a greenhouse gas, that is leaked upstream of a generator during transportation is to be included among its emissions. The CLEAN Future Act also calls for newly constructed hydropower generators to account for the emissions associated with the facility’s construction despite producing clean electricity. These additional provisions demonstrate not only the CES’s inability to fully address the issue of emissions but also the slippery slope of expanding the program to include other markets, echoing cost and reliability concerns as California exports its energy policies across the West.

A majority of states have adopted clean energy, electricity, or renewable portfolio standards, with some considering revamping electricity rates to clean the grid, leaving legislators with plenty of examples to consider. As they weigh their options, legislators should consider if they are effectively addressing the problem at hand, economy-wide emissions reductions, and at what cost, drawing on examples like New Mexico's 100% clean electricity bill to inform trade-offs.

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Waste-to-Graphene uses flash joule heating to convert carbon-rich trash into turbostratic graphene for composites, asphalt, concrete, and flexible electronics, delivering scalable, low-cost, high-quality material from food scraps, plastics, and tires with minimal processing.

Key Points

A flash heating method converting waste carbon into turbostratic graphene for scalable, low-cost industrial uses.

✅ Converts food scraps, plastics, and tires into graphene

✅ Produces turbostratic flakes that disperse well in composites

✅ Scalable, low-cost process via flash joule heating

Science doesn’t usually take after fairy tales. But Rumpelstiltskin, the magical imp who spun straw into gold, would be impressed with the latest chemical wizardry. Researchers at Rice University report today in Nature that they can zap virtually any source of solid carbon, from food scraps to old car tires, and turn it into graphene—sheets of carbon atoms prized for applications ranging from high-strength plastic to flexible electronics, and debates over 5G electricity use continue to evolve. Current techniques yield tiny quantities of picture-perfect graphene or up to tons of less prized graphene chunks; the new method already produces grams per day of near-pristine graphene in the lab, and researchers are now scaling it up to kilograms per day.

“This work is pioneering from a scientific and practical standpoint” as it promises to make graphene cheap enough to use to strengthen asphalt or paint, says Ray Baughman, a chemist at the University of Texas, Dallas. “I wish I had thought of it.” The researchers have already founded a new startup company, Universal Matter, to commercialize their waste-to-graphene process, while others are digitizing the electrical system to modernize infrastructure.

With atom-thin sheets of carbon atoms arranged like chicken wire, graphene is stronger than steel, conducts electricity and heat better than copper, and can serve as an impermeable barrier preventing metals from rusting, while advances such as superconducting cables aim to cut grid losses. But since its 2004 discovery, high-quality graphene—either single sheets or just a few stacked layers—has remained expensive to make and purify on an industrial scale. That’s not a problem for making diminutive devices such as high-speed transistors and efficient light-emitting diodes. But current techniques, which make graphene by depositing it from a vapor, are too costly for many high-volume applications. And higher throughput approaches, such as peeling graphene from chunks of the mineral graphite, produce flecks composed of up to 50 graphene layers that are not ideal for most applications.

Graphene comes in many forms. Single sheets, which are ideal for electronics and optics, can be grown using a method called chemical vapor deposition. But it produces only tiny amounts. For large volumes, companies commonly use a technique called liquid exfoliation. They start with chunks of graphite, which is just myriad stacked graphene layers. Then they use acids and solvents, as well as mechanical grinding, to shear off flakes. This approach typically produces tiny platelets each made up of 20 to 50 layers of graphene.

In 2014, James Tour, a chemist at Rice, and his colleagues found they could make a pure form of graphene—each piece just a few layers thick—by zapping a form of amorphous carbon called carbon black with a laser. Brief pulses heated the carbon to more than 3000 kelvins, snapping the bonds between carbon atoms; for comparison, researchers have also generated electricity from falling snow using triboelectric effects. As the cloud of carbon cooled, it coalesced into the most stable structure possible, graphene. But the approach still produced only tiny qualities and required a lot of energy.

Two years ago, Luong Xuan Duy, one of Tour’s graduate students, read that other researchers had created metal nanoparticles by zapping a material with electricity, creating the same brief blast of heat behind the success of the laser graphene approach. “I wondered if I could use that to heat a carbon source and produce graphene,” Duy says. So, he put a dash of carbon black in a clear glass vial and zapped it with 400 volts, similar in spirit to electrical weed zapping approaches in agriculture, for about 200 milliseconds. Initially he got junk. But after a bit of tweaking, he managed to create a bright yellowish white flash, indicating the temperature inside the vial was reaching about 3000 kelvins. Chemical tests revealed he had produced graphene.

It turned out to be a type of graphene that is ideal for bulk uses. As the carbon atoms condense to form graphene, they don’t have time to stack in a regular pattern, as they do in graphite. The result is a material known as turbostatic graphene, with graphene layers jumbled at all angles atop one another. “That’s a good thing,” Duy says. When added to water or other solvents, turbostatic graphene remains suspended instead of clumping up, allowing each fleck of the material to interact with whatever composite it’s added to.

“This will make it a very good material for applications,” says Monica Craciun, a materials physicist at the University of Exeter. In 2018, she and her colleagues reported that adding graphene to concrete more than doubled its compressive strength. Tour’s team saw much the same result. When they added just 0.05% by weight of their flash-produced graphene to concrete, the compressive strength rose 25%; graphene added to polydimethylsiloxane, a common plastic, boosted its strength by 250%.

As digital control spreads across energy networks, research to counter ransomware-driven blackouts is increasingly important for grid resilience.

Those results could reignite efforts to use graphene in a wide range of composites. Researchers in Italy reported recently that adding graphene to asphalt dramatically reduces its tendency to fracture and more than doubles its life span. Last year, Iterchimica, an Italian company, began to test a 250-meter stretch of road in Milan paved with graphene-spiked asphalt. Tests elsewhere have shown that adding graphene to paint dramatically improves corrosion resistance.

These applications would require high-quality graphene by the ton. Fortunately, the starting point for flash graphene could hardly be cheaper or more abundant: Virtually any organic matter, including coffee grounds, food scraps, old tires, and plastic bottles, can be vaporized to make the material. “We’re turning garbage into graphene,” Duy says.

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Ontario Global Adjustment and ICI balance hydro rates, renewable cost shift, and peak demand. Class A and Class B customers face demand response decisions amid pandemic occupancy uncertainty and volatile GA charges through 2022.

Key Points

A pricing model where GA costs and ICI peak allocation shape Class A/B bills, driven by renewables cost shifts.

✅ Renewable cost shift trims GA; larger Class A savings expected.

✅ Class A peak strategy returns; occupancy uncertainty persists.

✅ Class B faces volatile GA; limited levers beyond efficiency.

Ontario’s large commercial electricity customers can approach the looming annual decision about their billing structure for the 12 months beginning July 1 with the assurance of long-term relief on a portion of their costs, amid changes coming for electricity consumers that could affect planning. That’s to be weighed against uncertainties around energy demand and whether a locked-in cost allocation formula that looked favourable in pre-pandemic times will remain so until June 30, 2022.

“The biggest unknown is we just don’t know when the people are coming back,” Jon Douglas, director of sustainability with Menkes Property Management Services, reflected during a webinar sponsored by the Building Owners and Managers Association (BOMA) of Greater Toronto last week. “The occupancy in our office buildings this fall, and going into the new year, could really impact the outcome of the decision.”

After a year of operational upheaval and more modifications to provincial electricity pricing policies, BOMA Toronto’s regularly scheduled workshop ahead of the June 15 deadline for eligible customers to opt into the Industrial Conservation Initiative (ICI) program had a lot of ground to cover. Notably, beginning in January, all commercial customers have seen a reduction in the global adjustment (GA) component of their monthly hydro bills after the Ontario government shifted costs associated with contracted non-hydroelectric renewable supply to reduce the burden on industrial ratepayers from electricity rates to the general provincial account — a move that trims approximately $258 million per month from the total GA charged to industrial and commercial customers. However, they won’t garner the full benefit of that until 2022 since they’re currently repaying about $333 million in GA costs that were deferred in April, May and June of 2020.

Renewable cost shift pares the global adjustment
For now, Ontario government officials estimate the renewable cost shift equates to a 12 per cent discount relative to 2020 prices, even as typical bills may rise about 2% as fixed pricing ends in some cases. Once last year’s GA deferral is repaid at the end of 2021, they project the average Class A customer participating in the ICI program should realize a 16 per cent saving on the total hydro bill, while Class B customers paying the GA on a volumetric per kilowatt-hour (kWh) basis will see a slightly more moderate 15 per cent decrease.

“This is the biggest change to electricity pricing that’s happened since the introduction of ICI,” Tim Christie, director of electricity policy, economics and system planning for Ontario’s Ministry of Energy, Northern Development and Mines, told online workshop attendees. “The government is funding the out-of-market costs of renewables. It does tail off into the 2030s as those contracts (for wind, solar and biomass generation) expire, but over the next eight-ish years, it’s pretty steady at around just over $3 billion per year.”

Extrapolating from 2020 costs, he pegged average electricity costs at roughly 9.1 cents/kWh for Class A commercial customers and 13.2 cents/kWh for Class B, a point of concern for Ontario manufacturers facing high rates as well. However, energy management specialists suggest actual 2021 numbers haven’t proved that out.

“In commercial buildings, we’re averaging 10 to 12 cents for Class A in 2021, and we’re seeing more than that for about 14, 15 cents for Class B,” reported Scott Rouse, managing partner with the consulting firm, Energy@Work.

GA costs for Class B customers dropped nearly 30 per cent in the first four months of 2021 compared to the last four months of 2020, when they averaged 11.8 cents/kWh. Thus far, though, there have been significant month-to-month fluctuations, with a low of 5.04 cents/kWh in February and a high of 10.9 cents/kWh in April contributing to the four-month average of 8.3 cents/kWh.

“In 2020, system-wide GA very often averaged more than $1 billion per month,” Rouse said. “This February it dropped to $500 million, which was really quite surprising. So it is a very volatile cost.”

Although welcome, the renewable cost shift does alter the payback on energy-saving investments, particularly for demand response mechanisms like energy storage. When combined with pandemic-related uncertainty and a series of policy and program reversals alongside calls to clean up Ontario’s hydro policy in recent years, the industry’s appetite for some more capital-intensive technologies appears to be flagging.

“Volatility puts a pause on some of the innovation,” said Terry Flynn, general manager with BentallGreenOak and chair of BOMA Toronto’s energy committee. “It could be a leading edge, but it might be a bleeding edge that won’t bear any fruit because the way the commodity costs are structured will change.”

“There’s kind of a wait-and-see approach on some of these bigger investments,” Douglas concurred.

Industrial Conservation Initiative underpins commercial class divide
Turning to the ICI, Class A customers — defined as those with average monthly energy demand of at least 1 megawatt (MW) — encountered some unexpected changes to the program rules during 2020. Meanwhile, Class B customers — encompassing the vast share of commercial properties smaller than about 350,000 square feet — confront the persistent reality of electricity cost allocation that offloads the burden from larger players onto them.

Through the ICI, participating Class A customers pay a share of the global adjustment that’s prorated to their energy use during the five hours of the period from May 1 to April 30 when the highest overall system demand is recorded. This gives Class A customers the opportunity to lock in a favourable factor for calculating their share of monthly system-wide global adjustment costs if they can successful project and curtail energy loads during those five hours of peak demand. On the flipside, Class B customers pay the remainder of those system-wide costs, on a straightforward per-kWh basis, once Class A payments have been reconciled.

“Class B has sometimes been regarded as the forgotten middle child of the customer classes in Ontario where all the shifted costs in the system kind of pile up,” acknowledged Mark Olsheski, vice president, energy and environment, with Sussex Strategy Group. “Likewise, there can be big unpredictable and uncontrollable swings in the global adjustment rate from month to month and, outside of pure energy efficiency, there really is precious little opportunity or empowerment for a Class B customer to take actions to lower their bills.”

Nevertheless, COVID-19 presents a few extra hiccups for Class A customers this year. Conventionally, late May is when they receive notification of the cost allocation factor that would be used to determine their GA for the upcoming July 1 to June 30 period. This year, though, all current ICI participants will retain the factor they secured by responding to the five hours of peak demand during the 12 months from May 1, 2019 to April 30, 2020 after the Ontario government placed a temporary halt on the peak demand response aspect of the program last summer. Regardless, eligible ICI participants must formally opt into the program by June 15 or they will be billed as Class B customers.

Peak chasing resumes for summer 2021
Since peak demand hours conventionally occur from June to September, Class A customers will once again be studying forecasts intently and preparing to respond via Peak Perks as the heat wave season sets in. That should help alleviate some of the system stresses that arose last summer — prompting policy-makers to reject lobbying for a continued pause on peak demand response.

“The policy rationale was to allow consumers to focus on their operations when recovering from COVID as opposed to reducing peaks. The other issue was that we did not expect the peaks to be high last summer given COVID shutdowns,” Christie recounted. “But due to some hot weather, more people at home and also the lack of ICI response, we saw peaks we haven’t seen in many, many years come up last summer. So the peak hiatus has ended and this summer we’ll be back to responding to ICI as per normal.”

Among Class A customers, owners/managers of office and retail facilities generally have the most to lose from a billing formula tied to the energy demand of more densely occupied buildings in the summer of 2019. However, they could be much more competitively positioned for 2022-23 if their buildings remain below full occupancy and energy demand stays lower than usual this summer.

“Where we can improve is the IESO (Independent Electricity System Operator) and the LDCs (local distribution companies) need to help customers get their real-time data, especially in light of the phantom demand issue, interpret their bills and their Class A versus B scenarios much more easily and comprehensively,” urged Lee Hodgkinson, vice president, technical services, sustainability and ESG, with Dream Unlimited. “ I look for APIs (application programming interface) and direct data flow from the LDCs to the building owners so that we can access that data really easily.”

Given Class A’s historic advantages, few eligible ICI participants are expected to migrate out to Class B. From a sustainability perspective, there’s perhaps more cause to question how the ICI’s 1-MW threshold encourages strategies to move in the other direction.

“You could jack up demand in some buildings and get them into Class A basically by firing up the chillers on the weekend and then pouring cooling outside to get rid of it,” Douglas noted. “That has nothing to do with climate change strategy or sustainability, but it’s a cost- saving strategy, and, sometimes, when you look at the math, it’s hundreds of thousands of dollars you can save.”

Brian Hewson, vice president, consumer protection and industry performance with the Ontario Energy Board (OEB), confirmed the OEB is currently scrutinizing the discrepancy that leaves Class B as the only consumer group with no flexibility to curtail energy load during higher-priced periods, and will be providing advice to the Ministry of Energy. In the interim, that status does, at least, simplify tactics.

“Just reduce your kWh and it doesn’t matter what time of day because you’re paying that fixed rate for 24 hours a day. So if you can curb your demand at night, you get a big bang for your dollar,” Rouse advised.

“We do talk about rates a lot, but if you’re not using it, you’re not paying for it,” Flynn agreed. “A lot of our focus is still on really to try to reduce the number of kilowatts that we use. That seems to be the best thing to do.”

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