Housing Services Corporation 30 Duncan Street, Suite 500 | Toronto, ON Canada | M5V 2C3 t. 416 594 9325 | tf. 1 866 268 4451 | f. 416 594 9422 | www.hscorp.ca December 15, 2016 Minister Glenn Thibeault Ministry of Energy 4th Floor, Hearst Block 900 Bay Street Toronto, ON M7A 2E1 RE: Ontario’s next Long Term Energy Plan - EBR Registry Number (012-8840) Dear Minister Thibeault: I am writing today to submit input on the Government of Ontario’s Long-Term Energy Plan (LTEP) on behalf of the undersigned social housing providers and Service Managers. The Housing Services Corporation (HSC) is focused on the long-term health of Ontario’s social housing asset. Alongside the Province’s 1,400 housing providers and 47 Service Managers, we have worked to improve the energy efficiency and sustainability of Ontario’s housing stock. Energy is typically the largest operational cost for social housing operators. As such, the future LTEP will have a significant impact on our sector and our ability to meet our community goals. As you work on refining the LTEP, we invite you to consider the impacts and opportunities in social housing. We believe it is critical to develop stronger conservation programs and appropriate infrastructure. For the housing sector to increase its contribution to a conservation-driven LTEP, we recommend: Stronger Conservation Demand Management and Demand Side Management (CDM/DSM) Programs • Expand and improve CDM/DSM programs for social and affordable housing including solutions to address consumption and utility access issues in northern and rural communities. • Set provincial targets for DSM programs to maximize conservation potential. • Integrate greenhouse gas (GHG) emissions in CDM/DSM program evaluation to improve the alignment of the LTEP with Ontario’s climate change initiatives. Pursuing Innovation and Data Driven Conservation Opportunities • Encourage the use of new energy-efficient technologies by providing incentives in existing and future funding and financing programs for development, redevelopment and capital repair. • Leverage HSC’s reach and established energy and asset management expertise to support and inform initiatives that promote conservation in this sector. Creating Appropriate Infrastructure and Clear Pricing Signals • Account for Ontario’s conservation potential when planning and developing the provincial supply, transmission and distribution infrastructure. An infrastructure that is too large will be extremely costly over the long-term. These costs would result in greater regulated charges and would negatively impact housing providers in the form of higher overall utility costs. • • Develop open, transparent energy markets where the price signals will reward efficiency gains and incent housing providers to conserve and take action to mitigate costs. Such price signals need to be easy to understand and clearly separated on customers’ utility bills. Account for the total lifecycle costs and emissions of energy sources including conservation in planning. The assessment of cost effectiveness should factor in the social, economic, and environmental costs of options from the beginning to end of their lifecycle. We would be pleased to meet with you to provide further information. Please contact me at (416) 5949325 ext. 252 or [email protected], or Myfanwy Parry, Manager of Energy Services, at ext. 308 or [email protected], to discuss this submission. Sincerely, Howie Wong Chief Executive Officer Housing Services Corporation Cc: Hon. Chris Ballard, Minister of Housing Nathalie Des Rosiers, Parliamentary Assistant to the Housing Minister 2
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