Report cautions against radical change

Site C Dam Injunction signals Ottawa's neutrality while B.C. reviews a hydroelectric dam project on the Peace River, amid First Nations treaty rights claims, federal approval defenses, and scrutiny of environmental assessment and Crown consultation.

Key Points

A legal request to pause Site C while courts weigh First Nations treaty rights, environmental review, and approvals.

✅ Ottawa neutral on injunction; still defends federal approvals

✅ First Nations cite treaty rights over Peace River territory

✅ B.C. jurisdiction, environmental assessment and Crown consultation at issue

The federal government is not going to argue against halting construction of the controversial Site C hydroelectric dam in British Columbia while a B.C. court decides if the project violates constitutionally protected treaty rights.

Work on Site C suspended prior to First Nations lawsuit

However a spokeswoman for Environment Minister Catherine McKenna said Monday the government will continue to defend the federal approval given for the project in December 2014, even though that approval was given using an environmental review process McKenna herself has said is fundamentally flawed.

The Site C project is an 1,100-megawatt dam and generating station on the Peace River in northern B.C. that will flood parts of the traditional territory of the West Moberly and Prophet River First Nations.

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In January, they filed a civil court case against the provincial government, B.C. Hydro and the federal government asking a judge to decide if their rights were being violated by the dam. A few weeks later, West Moberly asked the court for an injunction to halt construction pending the outcome of the rights case, similar to other contested transmission projects like the Maine electricity corridor debate in New England.

On May 11, lawyers for Attorney General Jody Wilson-Raybould filed a notice that Canada would remain neutral on the question of the injunction, meaning Canada won't argue against the idea of postponing construction for months, if not years, while the rights case winds through the court.

Wilson-Raybould has been silent on Site C since being named Canada's minister of justice in 2015, but in 2012, when she was the B.C. regional chief for the Assembly of First Nations, she said the project was "running roughshod" over treaty rights. The Justice Department on Monday directed questions to Environment and Climate Change Canada.

Defence of environmental assessment

McKenna's spokeswoman, Caroline Theriault, said the injunction request is just a procedural step regarding construction and that it is B.C. jurisdiction not federal.

However, she said Canada will defend the environmental assessment and Crown consultation processes and the federally issued permits required for construction.

B.C. auditor general set to scrutinize Site C dam project

McKenna has legislation before the House of Commons to overhaul the process for environmental assessment of major projects like hydro dams and pipelines, arguing the former government's procedures had skewed too far towards proponents. The overhaul includes requiring traditional Indigenous knowledge be taken into account, a consideration also central to the Columbia River Treaty talks underway on both sides of the border.

However, Theriault said the commitment to overhaul the process also included a promise not to revisit projects that had already been approved, such as Site C.

"The federal environmental assessment process for the Site C project has already been upheld in other court actions," said Theriault.

'It feels kind of odd'

West Moberly Chief Roland Wilson said he was both excited and yet concerned by Canada's decision last week not to oppose the injunction.

"It feels kind of odd and makes me wonder what they're up to," Wilson said.

However he said all he has ever wanted was for the project to be stopped until the question of rights can be answered. Wilson said two previous dams on the Peace River already flooded 80 per cent of the functional land within West Moberly's territory and that Site C will flood half of what's left. That land is used for fishing and hunting and there is also concern the dam will allow mercury to leak into Moberly Lake, he said.

Retiree undaunted by steep odds against his petition to stop Site C dam

Construction began in 2015 and more than $2.4 billion has already been spent on a project that will at the earliest, not be completed until 2024 and will cost an estimated $10 billion total, with cost overrun risks underscored by the Muskrat Falls ratepayer agreement in Atlantic Canada.

The province continues to argue against the injunction and will also fight the rights case, even as Alberta suspends power purchase talks with B.C. over energy disputes. Premier John Horgan campaigned on a promise to review the Site C approval. A B.C. Utilities Commission report in November found there are alternatives to building it and that it will go over budget. Nevertheless Horgan in December said he had to let construction continue because cancelling the project would be too costly both for the province and its electricity consumers, despite the B.C. rate freeze announced around the same period.

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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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OPG Credit Rating affirmed by DBRS at A (low) issuer and unsecured debt, R-1 (low) CP, Stable trends, backed by a supportive regulatory regime, strong leverage metrics, and provincial support; monitor Darlington Refurbishment costs.

Key Points

It is DBRS's confirmation of OPG at A (low) issuer and unsecured, R-1 (low) CP, with Stable outlooks.

✅ Stable trends; strong cash flow-to-debt and capital ratios

✅ Provincial financing via OEFC; Fair Hydro Trust ring-fenced

✅ Darlington Refurbishment on budget; cost overruns remain risk

DBRS Limited (DBRS) confirmed the Issuer Rating and the Unsecured Debt rating of Ontario Power Generation Inc. (OPG or the Company) at A (low) and the Commercial Paper (CP) rating at R-1 (low), amid sector developments such as Hydro One leadership efforts to repair government relations and measures like staff lockdowns at critical sites.

All trends are Stable. The ratings of OPG continue to be supported by (1) the reasonable regulatory regime in place for the Company's regulated generation facilities, including stable pricing signals for large users, (2) strong cash flow-to-debt and debt-to-capital ratios and (3) continuing financial support from its shareholder, the Province of Ontario (the Province; rated AA (low) with a Stable trend by DBRS). The Province, through its agent, the Ontario Electricity Financial Corporation (rated AA (low) with a Stable trend by DBRS), provides most of OPG's financing (approximately 43% of consolidated debt). The Company's remaining debt includes project financing (31%), including projects such as a battery energy storage system proposed near Woodstock, non-recourse debt issued by Fair Hydro Trust (Senior Notes rated AAA (sf), Under Review with Negative Implications by DBRS; 11%), CP (2%) and Senior Notes issued under the Medium Term Note Program (12%).

In March 2019, the Province introduced 'Bill 87, Fixing the Hydro Mess Act, 2019' which includes winding down the Fair Hydro Plan, and later introduced electricity relief to mitigate customer bills during the COVID-19 pandemic. OPG will remain as the Financial Services Manager for the outstanding Fair Hydro Trust debt, which will become obligations of the Province. DBRS does not expect this development to have a material impact on the Company as (1) the Fair Hydro Trust debt will continue to be bankruptcy-remote and ring-fenced from OPG (all debt is non-recourse to the Company) and (2) the credit rating on the Company's investment in the Subordinated Notes (rated AA (sf), Under Review with Negative Implications by DBRS) will likely remain investment grade while the Junior Subordinated Notes (rated A (sf), Under Review with Developing Implications by DBRS) will not necessarily be negatively affected by this change (see the DBRS press release, 'DBRS Maintains Fair Hydro Trust, Series 2018-1 and Series 2018-2 Notes Under Review,' dated March 26, 2019, for more details).

OPG's key credit metrics improved in 2018, following the approval of its 2017-2021 rates application by the Ontario Energy Board in December 2017, alongside the Province's energy-efficiency programs that shape demand. The Company's profitability strengthened significantly, with corporate return on equity (ROE) of 7.8% (adjusted for a $205 million gain on sale of property; 5.1% in 2017) closer to the regulatory allowed ROE of 8.78%. However, DBRS continues to view a positive rating action as unlikely in the short term because of the ongoing large capital expenditures program, including the $12.8 billion Darlington Refurbishment project, amid ongoing oversight following the nuclear alert investigation in Ontario. However, a downgrade could occur should there be significant cost overruns with the Darlington Refurbishment project that result in stranded costs. DBRS notes that the Darlington Refurbishment project is currently on budget and on schedule.

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Nova Scotia Biomass Energy faces scrutiny as hydropower from Muskrat Falls via the Maritime Link increases, raising concerns over carbon emissions, biodiversity, ratepayer costs, and efficiency versus district heating in the province's renewable mix.

Key Points

Electricity from wood chips and waste wood in Nova Scotia, increasingly questioned as hydropower from the Maritime Link grows.

✅ Hydropower deliveries reduce need for biomass on the grid

✅ Biomass is inefficient, costly, and impacts biodiversity

✅ District heating offers better use of forestry residuals

The Ecology Action Centre's senior wilderness coordinator is calling on the Nova Scotia government to reduce the use of biomass to generate electricity now that more hydroelectric power is flowing into the province.

In 2020, the government of the day signed a directive for Nova Scotia Power to increase its use of biomass to generate electricity, including burning more wood chips, waste wood and other residuals from the forest industry. At the time, power from Muskrat Falls hydroelectric project in Labrador was not flowing into the province at high enough levels to reach provincial targets for electricity generated by renewable resources.

In recent months, however, the Maritime Link from Muskrat Falls has delivered Nova Scotia's full share of electricity, and, in some cases, even more, as the province also pursues Bay of Fundy tides projects to diversify supply.

Ray Plourde with the Ecology Action Centre said that should be enough to end the 2020 directive.

Ray Plourde is senior wilderness coordinator for the Ecology Action Centre. (CBC)
Biomass is "bad on a whole lot of levels," said Plourde, including its affects on biodiversity and the release of carbon into the atmosphere, he said. The province's reliance on waste wood as a source of fuel for electricity should be curbed, said Plourde.

"It's highly inefficient," he said. "It's the most expensive electricity on the power grid for ratepayers."

A spokesperson for the provincial Natural Resources and Renewables Department said that although the Maritime Link has "at times" delivered adequate electricity to Nova Scotia, "it hasn't done so consistently," a context that has led some to propose an independent planning body for long-term decisions.

"These delays and high fossil fuel prices mean that biomass remains a small but important component of our renewable energy mix," Patricia Jreiga said in an email, even as the province plans to increase wind and solar projects in the years ahead.

But to Plourde, that explanation doesn't wash.

The Nova Scotia Utility and Review Board recently ruled that Nova Scotia Power could begin recouping costs of the Maritime Link project from ratepayers. As for the rising cost of fossil fuels, Ploude noted that the inefficiency of biomass means there's no deal to be had using it as a fuel source.

"Honestly, that sounds like a lot of obfuscation," he said of the government's position.

No update on district heating plans
At the time of the directive, government officials said the increased use of forestry byproducts at biomass plants in Point Tupper and Brooklyn, N.S., including the nearby Port Hawkesbury Paper mill, would provide a market for businesses struggling to replace the loss of Northern Pulp as a customer. Brooklyn Power has been offline since a windstorm damaged that plant in February, however. Repairs are expected to be complete by the end of the year or early 2023.

Ploude said a better use for waste wood products would be small-scale district heating projects, while others advocate using more electricity for heat in cold regions.

Although the former Liberal government announced six public buildings to serve as pilot sites for district heating in 2020, and a list of 100 other possible buildings that could be converted to wood heat, there have been no updates.

"Currently, we're working with several other departments to complete technical assessments for additional sites and looking at opportunities for district heating, but no decisions have been made yet," provincial spokesperson Steven Stewart said in an email.

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European Power Crisis intensifies as record electricity prices, nuclear output cuts, gas supply strain, heatwave drought, and Rhine shipping bottlenecks hit Germany, France, and Switzerland, tightening winter storage and driving long-term contracts higher.

Key Points

A surge in European power prices from heatwaves, nuclear curbs, Rhine coal limits, and reduced Russian gas supply.

✅ Record year-ahead prices in Germany and France

✅ Nuclear output curbed by warm river cooling limits

✅ Rhine low water disrupts coal logistics and generation

Benchmark power prices in Europe hit fresh records Friday as utilities are increasingly reducing electricity output in western Europe because of the hot weather. 

Next-year contracts in Germany and France, Europe’s biggest economies rose to new highs after Switzerland’s Axpo Holding AG announced curbs at one of its nuclear plants. Electricite de France SA is also reducing nuclear output because of high river temperatures and cooling water restrictions, while Uniper SE in Germany is struggling to get enough coal up the river Rhine. 

Europe is suffering its worst energy crunch in decades, and losing nuclear power is compounding the strain as gas cuts made by Russia in retaliation for sanctions drive a surge in prices. The extreme heat led to the driest July on record in France and is underscoring the impact that a warming climate is having on vital infrastructure.

Water levels on Germany’s Rhine have fallen so low that the river may effectively close soon, impacting supplies of coal to the plants next to it. The Rhone and Garonne in France and the Aare in Switzerland are all too warm to be used to cool nuclear plants effectively, forcing operators to limit energy output under environmental constraints. 

Northwest European weather forecast for the next two weeks:
relates to European Power Hits Records as Plants Start to Buckle in Heat
  
The German year-ahead contract gained as much as 2% to 413 euros a megawatt-hour on the European Energy Exchange AG. The French equivalent rose 1.9% to a record 535 euros. Long-term prices are coming under pressure because producing less power from nuclear and coal will increase the demand for natural gas, which is badly needed to fill storage sites ahead of the winter.  

France to Curb Nuclear Output as Europe’s Energy Crisis Worsens
Uniper SE said on Thursday that two of its coal-fired stations along the Rhine may need to curb output during the next few weeks as transporting coal along the Rhine becomes impossible. 

Plants on the river near Mannheim and Karlsruhe, operated by Grosskraftwerk Mannheim AG and EnBW AG, have previously struggled to source coal because of the shallow water, even as German renewables deliver more electricity than coal and nuclear at times. Both companies said generation hasn’t been affected yet. 

“The low tide is not currently affecting our generation of energy because our plants do not have the need for continuous fresh water,” a Steag GmbH spokesman said on Friday. “But the low tide level can make running plants and transporting coal more complicated than usual.”

The spokesman said though that there is slight reduction in output of about 10 to 15 megawatts, which would equate to a few percent, because of the hot temperatures. “This has been happening over some time now and is a problem for everyone because the plant system is not designed to withstand such hot temperatures,” he said.

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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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