Electricity Pricing
| In June, 2011, the ECO released volume 1 of its 2010 Annual Report on the progress of activities in Ontario to reduce or make more efficient use of electricity, natural gas, propane, oil and transportation fuels. Click here for more information on this report, including videos and communications materials. | |||||
The cost of electricity became front page news across Ontario in 2010. A combination of factors, including the roll-out of timeof-
use (TOU) pricing, the application of the Harmonized Sales Tax (HST), and questions about the cost of new renewable power,
raised concern about electricity prices among Ontario residents. The Ontario government was forced onto the defensive in
explaining why and how much Ontario electricity prices will rise in the future.
The government’s LTEP estimates that “all-in” electricity prices will rise by just over 30 per cent (in real terms) between 2010 and 2014. The government attributes these cost increases to investments in new renewable energy generation, transmission and distribution upgrades, and improvements to nuclear and gas capacity. After 2014, prices are expected to stabilize, with the bulk of investments in new capacity complete.
Figure 3: Projected Monthly Residential Electricity Bill, 2010 – 2030
Note: All-in, after-tax bill, assumes monthly consumption of 800 kWh. Source: Government of Ontario, Ontario’s Long Term Energy Plan, Building Our Clean Energy Future.
In Ontario, the government has significant power to influence the price of electricity. Levers of influence include government taxation and expenditures, and policy direction to the electricity agencies. The government must consider multiple policy objectives, which could include the following:
- Recovering the costs of operating the electricity system;
- Keeping pricing fair by ensuring that the electricity bill paid by each consumer (and each class of consumers) closely matches their share of the system costs (known as cost causality);
- Minimizing negative social and economic impacts, particularly for groups especially sensitive to price changes, such as lowincome consumers and energy-intensive industries; and,
- Promoting other societal objectives, such as environmental protection, energy conservation, or job creation.
It is impossible to fully achieve all four objectives, and the government must make tough decisions when they come into conflict. Keeping in mind these levers of influence and the trade-offs that are made, the changes made to electricity pricing policy in Ontario in 2010 are discussed below.
Contents |
Changing the Cost of Energy Through Fiscal Policy
As part of the harmonization of the provincial sales tax with the federal Goods and Services Tax (GST), electricity (along with gasoline and home heating fuels) became subject to the 13 per cent HST beginning on July 1, 2010. Previously, these energy sources had only been subject to the 5 per cent GST. It is important to note that provincial taxation was a deliberate choice, not an inevitable consequence of harmonization, as the Ontario government instituted point-of-sale rebates for the provincial portion of the HST for several other categories of goods and services.
In the 2010 Ontario Budget, the government also announced two energy-related tax relief measures – the Northern Ontario Energy Credit (“to help with home energy costs, which are often higher in the north due to more severe winters”[1]), and the Ontario Energy and Property Tax Credit (to “help you with the sales tax you pay on energy”[2]). However, these credits are not directly tied to the amount of energy that a household consumes. Rather, they are income-adjusted credits that provide general tax relief for northern residents and low- to middle-income householders that pay rent or property tax.
With these two tax credits only six months old, the government introduced a third energy-related credit through 2010’s Fall Economic Statement: the Ontario Clean Energy Benefit (OCEB). The stated purpose of the OCEB is to serve as a transitional measure to help Ontarians deal with the increased costs of investments in the electricity system. Unlike the two other tax credits, the OCEB rises in direct proportion to actual electricity consumption. Eligible consumers (residential, farm, small business, and other small consumers) receive a 10 per cent rebate off their after-tax all-in electricity bill. The OCEB is proposed to be in effect for five years. In 2011, the financial impact of the OCEB will be to transfer $1.1 billion from Ontario taxpayers to electricity ratepayers.
ECO Comment
The actions on energy pricing in 2010 show a government being pulled in several directions.
The historical argument for not taxing electricity was that it is a “necessity of life” and that taxation of such basic necessities is unfair to low-income individuals. By adding the HST to energy bills, while introducing tax credits that reduce or eliminate the income impact for low- and middle-income individuals, the government is now treating electricity like other goods and services and sending a more accurate price signal to all consumers about its cost, while maintaining the progressive nature of the tax system. The ECO believes this is a positive change that will further conservation.
On the other hand, the OCEB essentially reverses the impact of the HST and restores an artificial price subsidy on electricity. Since the rebate is funded from government revenue and the size of the rebate is proportional to the amount of electricity consumed, it uses the tax system to indirectly transfer wealth from low-volume energy consumers to higher volume consumers. There are other approaches that the government could consider if it believes that transitional assistance is necessary. The amount of the on-bill rebate could be a fixed amount,[3] instead of being tied to electricity consumption levels. Alternatively, the subsidy could be used to reduce the price of energy only in off-peak hours, creating a larger price differential between peak and off-peak prices and encouraging customers to shift their consumption to the off-peak period (see section 4.2 for more discussion of time-of-use pricing). The subsidy could perhaps also be reduced over the five-year period to transition consumer behaviour back to the need to conserve energy.
Subsidizing the price of electricity is a perverse incentive that undermines conservation. As with most goods or services, the price of electricity is inversely related to the amount that will be consumed. According to one estimate, the artificial 10 per cent reduction in electricity price provided by the OCEB could have the near-term impact of increasing total electricity consumption in Ontario by 1.3 per cent. This amount is equal to one-third of the electricity that is expected to be saved through utility conservation programs between 2011 and 2014.[4]
In the near term, consumers respond to price increases by reducing discretionary consumption through behavioural actions (e.g., turning the lights off, using less air conditioning). Options for action are limited and consumers may simply have to endure higher prices. However, over time, people also adapt through technological change and investment in conservation measures. The payback period for a house retrofit or an energy-efficient appliance becomes more attractive in light of higher energy prices. This means that the long-term conservation response to price changes is much greater than in the short term. A 10 per cent rise in residential prices could lead, over the long-term, to a 9 per cent drop in consumption.[5] The OCEB reduces this impact and hinders investment in conservation.
The ECO recommends that the Ministries of Energy, Revenue, and Finance improve the design of the Ontario Clean Energy Benefit so that any transitional assistance on electricity bills does not act as a disincentive to conservation.
Variable Pricing
As is well known, Ontario is moving towards variable electricity pricing. In 2010, regulatory changes were made that increased the time-sensitivity of electricity prices for large electricity consumers. Changes have also been considered for smaller consumers, even though time-of-use pricing is still in the process of being rolled out for this group.
To assess the impact of variable pricing, it is necessary to understand how electricity supply costs, which do not include transmission and distribution costs, are recovered through prices for large and small customers.
Understanding Electricity Supply Costs
To assess the impact of variable pricing, it is necessary to understand how electricity supply costs, which do not include transmission and distribution costs, are recovered through prices for large and small customers.
Electricity supply costs are composed of:
- Costs payable to electricity suppliers (generators, importers, and demand-side resources) through the wholesale electricity market; and,
- Additional contract costs payable to suppliers through the Global Adjustment.
The wholesale market price closely follows the variable cost of electricity production. It is low when nuclear or baseload hydroelectric are able to supply all demand, rises to track the cost of fuel when coal or gas plants are needed, and rises even higher when options such as peaking gas and hydroelectric or demand response (consumers being compensated to reduce their electricity consumption) are called on.
Varieties of Variable Pricing |
| Variable pricing includes several different pricing schemes. All of these differ from fixed pricing, where the charge per unit of electricity consumed remains the same at all times. |
Unfortunately, the wholesale market in Ontario has proven inadequate for new generators to recover their fixed capital costs. To ensure that investments in new and refurbished generation are viable, almost all electricity generators (including most gas, renewables, and nuclear) are provided support payments through the Global Adjustment. Without this assistance, it is unlikely that sufficient supply would be provided by the market to meet Ontario demand. In recent years, many new generators with long-term contracts have come on-line, and the percentage of the supply cost that is due to the Global Adjustment has risen dramatically while the wholesale market price has simultaneously fallen. Funding for electricity conservation programs also comes from the Global Adjustment.
Figure 4: Wholesale Electricity Price and Global Adjustment in Ontario, 2005 - 2010 Source: Independent Electricity System Operator.
All Ontario electricity consumers pay the Global Adjustment. However, for small-volume customers on the Regulated Price Plan (RPP), which includes virtually all residential customers and some small businesses and institutions, the Global Adjustment charge is bundled inside the regulated rate determined by the OEB, and does not appear on bills as a separate line charge. Under TOU pricing, the cost of electricity as determined from both the wholesale market and the Global Adjustment is split into three buckets – off-peak, mid-peak and on-peak. The share of costs that is assigned to each bucket determines the three TOU prices. It is a straightforward calculation to assign the appropriate portion of the wholesale market costs to each bucket, but judgements need to be made about how to assign the Global Adjustment costs. For example, support payments for nuclear, baseload hydro, and energy efficiency are assigned equally across all periods. Support payments for gas generators are assigned based on the proportion of time that the plants run, and support payments for demand response programs are assigned only to on-peak hours.[6] Changing the way these costs are allocated would change the TOU prices. Large-volume electricity consumers, such as manufacturers, schools, and hospitals, are not billed on the basis of rates set under the RPP. They are exposed to the wholesale electricity market and pay a real-time market price that changes hourly or even more frequently, and a Global Adjustment charge that (until 2011) was fixed in proportion to their total electricity consumption.
Large-volume electricity consumers, such as manufacturers, schools, and hospitals, are not billed on the basis of rates set under the RPP. They are exposed to the wholesale electricity market and pay a real-time market price that changes hourly or even more frequently, and a Global Adjustment charge that (until 2011) was fixed in proportion to their total electricity consumption.
Critical Peak Pricing for the Global Adjustment
In October 2010, the government amended O. Reg. 429/04, made under the Electricity Act, 1998, changing the way that the Global Adjustment would be calculated. Under the new rules, customers are divided into two groups.
- Very large consumers (e.g., major industrial facilities, universities) with an average monthly peak demand of more than 5 MW are defined as Class A consumers. These consumers will be billed a Global Adjustment charge that is proportional to their share of provincial electricity consumption during the five highest hours of Ontario demand in the entire year.[7]
- Smaller consumers are defined as Class B consumers and will continue to be billed the Global Adjustment on a volumetric basis, that is, a Global Adjustment amount is applied according to the total amount of electricity consumed.
This change essentially acts as a form of critical peak pricing. It provides a powerful incentive for Class A consumers to reduce their consumption during periods of system peak, by assigning roughly 50 per cent of their yearly electricity commodity cost based on their consumption during only a few peak hours of the year.
Crucially, the exact hours of yearly system peak are not known in advance because demand will vary with factors like weather and economic activity. This will likely lead Class A consumers to reduce their consumption during a larger number of hours (perhaps 50 to 100 hours), in order to be assured of lower consumption during the critical five hours. The Independent Electricity System Operator (IESO) estimates that the change brought in by the amendment to O. Reg. 429/04 could reduce Ontario peak demand by 450 to 500 MW, potentially avoiding some $450 million in capital costs for new facilities, and reducing the average electricity supply price (Global Adjustment plus wholesale price) by about 0.4 cents per kWh.[8]
The price paid by smaller consumers will be indirectly impacted. Prior to this regulatory change, Class A consumers had a much higher percentage of their electricity consumption in off-peak hours than did smaller consumers, as many Class As are large industrial firms that run 24 hours a day. In January 2011, Class A consumers accounted for 15 per cent of total Ontario electricity consumption, but only 11 per cent of peak demand for the corresponding base period.[9] Under the old rules, Class A consumers would have paid 15 per cent of the Global Adjustment costs, under the new rules they will pay 11 per cent. Over the course of a year, this represents a shift of electricity costs of approximately $150 million from Class A consumers to smaller Class B consumers.[10] This amount could increase if Class A consumers act as expected and find ways to reduce their consumption during peak hours.
Time-of-Use Prices for Small Consumers: Reviewing the Price Spread
At the end of 2010, more than 1.6 million small Ontario consumers billed under the RPP were now paying TOU prices for their electricity, as several large distributors, like Toronto Hydro, had converted the bulk of their customer base to TOU pricing.
With TOU pricing just coming into effect for most RPP consumers, the government passed a regulation[11] that requires the daily off-peak price period to begin no later than 7:00 p.m., starting May 1, 2011 (the off-peak period had previously started at 9 p.m. on weekdays). At the same time, the OEB began a review of the price structure of time-of-use prices.
The ECO has previously noted that the price differential between on-peak and off-peak prices for RPP customers may be insufficient to lead to significant load shifting.[12] A study conducted as part of the OEB review reached a similar conclusion, estimating that the thencurrent peak price/off-peak price ratio of 1.9:1 (9.9 cents per kWh during peak periods, compared to 5.1 cents per kWh during off-peak periods) could deliver approximately a 1 per cent drop in the average consumer’s peak demand. According to the study, a greater peak/off-peak ratio of 4:1 could potentially deliver three times as great a drop in peak demand.[13]
The study also suggested several options that would increase the peak/off-peak price ratio. However, following stakeholder consultation, the OEB noted in March 2011 that there was little support from stakeholders for any of these options, particularly as they would deviate from cost causality. The OEB concluded that it would be premature to make any changes to the TOU pricing structure at this time, and also announced that it would initiate a data collection process on customer response to TOU pricing, which could be used to support further analysis of the TOU pricing structure in the future.[14]
ECO Comment on Variable Pricing
In light of Ontario’s proposed supply mix for the next twenty years (see section 3), two goals appear desirable for variable electricity pricing: price should reflect the real-time marginal cost of power; and price should send a signal to avoid extreme price events. These are discussed below.
- Prices should reflect the real-time marginal cost of power. The marginal cost of power reflects the balance between supply and demand and has predictable and unpredictable components. The daily rise and fall in electricity demand is predictable and can be well-approximated with TOU pricing. Generator outages and varying supply from intermittent renewable electricity sources (wind and solar) add an unpredictable element. This will become more important in the future, as the percentage of intermittent sources in Ontario’s supply mix will increase dramatically. Only real-time pricing can respond to this unpredictability.
Therefore, the ECO suggests that Ontario conservation programs should provide opportunities for RPP consumers to respond to real-time price signals. This could take several forms. For example, a voluntary opt-in program could pass through real-time prices to customers willing and able to respond to price variation (e.g., customers with smart appliances, consumption monitors). Another approach is to link the activation of programs such as peaksaver® (a residential load control program) directly to price signals from the wholesale market. Currently, utilities activate this program by reducing the energy use of consumer appliances at times of high system demand, but it is not directly based on real-time prices. - Prices should send a signal to avoid extreme peak events. Ontario’s electricity system is sized to meet the highest demand of the year. Reducing this seasonal peak may deliver significant cost savings by eliminating the need for new power plants or transmission lines. Crucially, because these are future costs that may be avoided, they are not fully accounted for in any price signal that is based only on recovering existing system costs. For this reason, the ECO believes that the peakto- off-peak price differential for TOU rates for RPP customers should be raised in order to reduce peak demand and avoid these future costs, even if this deviates from cost causality. However, the OEB’s reluctance to tinker with the TOU structure at this time is understandable for two reasons: consumers are still becoming familiar with the time periods and prices for TOU pricing; and, the Ontario-specific evidence as to how TOU pricing affects consumer behaviour is still very preliminary.[15]
ECO Comment on Critical Peak Pricing
With the Global Adjustment regulation, the government has clearly broken from cost causality in order to provide a strong incentive to reduce peak demand. The ECO supports this approach and notes the economic and environmental benefits that will result from making more efficient use of our existing generation options and reducing the need for capital investments in new infrastructure.
However, the ECO has two minor concerns, both of which relate to the transfer of electricity costs away from large industrial consumers and onto other consumers. The first concern is the limitation of critical peak pricing to customers with a load greater than 5 MW. This deprives smaller customers of the ability to reduce their Global Adjustment costs by reducing peak demand. The second concern is that the Global Adjustment includes many support costs that are unrelated to peak demand, such as payments for nuclear generation. Charging 100 per cent of these costs on the basis of a consumer’s peak consumption may be unfair to customers with peaky loads (e.g., commercial building owners).
The first criticism can be addressed by expanding critical peak pricing for the Global Adjustment to more customers. The Ministry of Energy advised the ECO that it intends to evaluate the merits of expanding coverage to a wider group of electricity consumers within 12 months,[16]. an action that the ECO supports. However, even with a larger group of customers subject to critical peak pricing, the criticism that the regulation is unfair to customers with peaky loads would remain. The ECO suggests that a more balanced approach might be to assign some percentage of Global Adjustment costs based on critical peak pricing and some percentage based on volumetric consumption. This may still provide sufficient incentives for peak reduction, while being fairer to consumers in terms of recovering existing system costs.
4.3 Taking Ownership of Electricity Bills: Suite Metering in Multi-Unit Residential Buildings
Bill 235, An Act to enact the Energy Consumer Protection Act, 2010 and to amend other Acts, received Royal Assent in May 2010. While the main focus of Bill 235 was to enhance consumer protection requirements with regard to energy retailers, it also contained provisions relevant to energy conservation that dealt with suite metering in multi-unit residential buildings. In addition to enacting the Energy Consumer Protection Act, 2010 (ECPA), the bill amended several other statutes, including the Residential Tenancies Act, 2006 (RTA).
Suite metering involves billing consumers in multi-unit buildings based on the specific electricity consumption of each unit. It includes unit smart metering, where the LDC installs an individual smart meter for each unit, and sub-metering, where the LDC installs only a bulk meter for the building, and a private company installs and operates an individual meter for each unit and handles the billing of individual consumers. LDCs are subject to a greater degree of oversight by the OEB than sub-metering providers are. However, the rules under the ECPA and the RTA regarding the installation and use of suite meters for individual billing are essentially the same for both groups.
The multi-unit residential sector is large, with approximately 1.7 million units in Ontario, 87 per cent of which are rental units, including social housing and subsidized units. It is estimated that only about 16 per cent of rental units are individually metered for their electricity consumption.[17]
At first glance, suite metering would appear to be a sure win for energy conservation. Residents who are responsible for paying their own electricity costs will certainly exercise more discretion in how they use energy. The energy conservers in a building will no longer be subsidizing the energy hogs. The reality is somewhat more complex. Suite metering has led to heated debate and raised consumer protection issues, particularly for existing rental buildings. On one side, the sub-metering industry and landlords have argued that tenants are in the best position to reduce their energy consumption, and individual billing for electricity through suite metering is the incentive needed to drive this change. On the other hand, tenant and poverty reduction advocates have suggested that landlords are actually in the best position to reduce energy consumption, through efficiency improvements to the building envelope and to the major appliances that they provide to tenants. If suite metering is introduced, the incentive for landlords to make these improvements disappears. From this perspective, suite metering is appealing to landlords not due to its energy efficiency benefits, but because it removes a volatile cost from their books and passes it onto tenants.
The legislative authority for introducing suite metering into rental apartments, prior to enactment of the ECPA, was unclear,[18] but this lack of clarity did not prevent sub-metering companies from entering into agreements with landlords, installing submeters, and billing tenants. The OEB received a large number of complaints from sitting tenants concerning these sub-metering installations. Some common complaints were that the corresponding rent reduction turned out to be far less than the new electricity bill, and that sub-metering providers were charging installation and administration fees. In 2009, the OEB ruled that these installations had been unauthorized and that any resulting contracts were unenforceable.[19]
The ECPA and the RTA amendments remove the confusion and provide a clear legal framework for suite metering, both for LDCs and sub-metering providers. Two subsequent regulations, O. Reg. 389/10 - General, made under the ECPA, and O. Reg. 394/10 – Suite Meters and Apportionment of Utility Costs, made under the RTA, have provided additional details.
The key elements of the new suite metering framework are as follows:
- Suite metering is mandatory for new residential buildings;
- Suite metering can only be undertaken in units in existing buildings with the consent of the tenant (for rental buildings) or the condominium corporation’s board of directors (for condominiums);
- Suite metering in rental units includes the additional conditions:
- Rent for sitting tenants must be reduced by an amount that accounts for the cost of electricity, based on a regulatory formula;
- Refrigerators included as part of a rental unit must meet minimum efficiency standards (based on date - existing refrigerators must be 1994 model year or later, replacements must be 2002 model year or later);
- Prior to seeking tenant consent for suite metering, the landlord must provide information on the expected rent reduction and the refrigerator’s energy consumption;
- Suite metering will not be permitted in rental units where electricity is used to heat the unit (unless the suite meter separately measures and bills for only the electricity not used for heating); and,
- When a rental unit is vacated, the landlord is allowed to implement suite metering without consent, however, prospective tenants must be provided with information on the historic electricity consumption of the unit and the refrigerator’s energy consumption.
- The OEB is given authority to regulate the rates of sub-metering providers, should this be necessary.
ECO Comment
There is no doubt that suite metering delivers results. A pilot project in Oakville showed a 22 per cent drop in average electricity consumption in a condominium building which switched from bulk metering to suite metering.[20] This is in line with results from New York State, where a range of case studies shows electricity savings from 10 to 20 per cent following the introduction of suite metering.[21]
Given that new buildings are subject to relatively strict building code and energy efficiency standards, the greatest remaining savings are likely to come from individual behaviour. For this reason, the ECO supports the government’s decision to mandate suite metering in new buildings. However, this should be complemented by policies that support and encourage the highest degree of energy efficiency (substantially better than the Ontario Building Code) in the initial construction of new buildings. The requirement for landlords to provide information on the unit’s historic electricity consumption to prospective tenants is a small step in this direction, as it means that the energy efficiency of the building unit becomes a piece of information that will affect the market rate.
The decision to make suite metering conditional on the consent of sitting tenants in existing buildings will certainly slow the roll-out of suite metering, as it may not make economic sense for landlords to convert to suite metering for a building unless the majority of tenants agree to participate. However, given the attendant consumer protection issues that arose prior to the enactment of the ECPA, this is probably a necessary compromise.
Suite metering of electric heating in rental units is prohibited by the ECPA regulation, because the amount of electricity used for heating these units is more influenced by the properties of the building envelope than tenant behaviour, and it is the landlord who can improve the envelope. The rationale for the regulatory requirement that refrigerators must achieve a certain energy efficiency level prior to allowing suite metering is similar – again, the efficiency of this equipment is not within the tenant’s control. These are sensible decisions, although the ECO believes that an exception could potentially be made to allow suite metering in new electrically heated rental buildings, particularly for buildings that substantially exceed Ontario Building Code energy standards.
The ECO believes that the ECPA permits suite metering under the conditions where it will have the most benefit, while also ensuring adequate consumer protection for existing tenants. The ECO commends the ministries of Energy and Municipal Affairs and Housing for establishing a clear legal framework that will transition Ontarians towards increased responsibility for their electricity consumption.
Conclusion
Overall, the ECO believes that Ontario is generally moving in the right direction with electricity pricing, with the qualifications noted above (in particular, concern regarding the current design of the OCEB). The roll-out and refinement of variable pricing and the clear rules for suite metering ensure that more Ontario consumers will receive price signals that better reflect the true cost of electricity, providing the proper incentives for energy conservation.
References
- ↑ Ontario Ministry of Revenue, “Northern Ontario Energy Credit”, http://www.rev.gov.on.ca/en/credit/noec/index.html (accessed May 2, 2011).
- ↑ Ontario Ministry of Revenue, “Ontario Energy and Property Tax Credit”, http://www.rev.gov.on.ca/en/credit/oeptc/index.html (accessed May 2, 2011).
- ↑ An appropriate monthly amount might be 10 per cent of the “all-in” price of 800 kWh of electricity in 2010, which would be approximately $11.40 per month.
- ↑ Aegent Energy Advisors Inc., “Ontario Clean Energy Benefit - A Short-Term Conservation Killer?”, http://www.aegent.ca/newsletters/OntarioCleanEnergyBenefit.html (accessed May 2, 2011), newsletter, November 2010.
- ↑ Electric Power Research Institute, Price Elasticity of Demand For Energy: A Primer and Synthesis (2008), 20.
- ↑ Ontario Energy Board, Regulated Price Plan Price Report, November 1, 2010 to October 31, 2011 (2010), 22.
- ↑ The five peak hours must fall on five different days.
- ↑ Independent Electricity System Operator, “Allocation of Global Adjustment” (presented to Stakeholder Advisory Committee, March 31, 2010), http://www.ieso.ca/imoweb/pubs/consult/sac/sac-20100331-Allocation-of-Global-Adjustment.pdf (accessed May 2, 2011).
- ↑
- ↑ Independent Electricity System Operator, “Diverse Supply Mix Provides Flexibility in Operating Ontario’s Power System - Integration of Renewable Resources Well Underway”, News Release, January 7, 2011. The 2010 values for Ontario electricity consumption (142 TWh) and weighted average Global Adjustment (2.73 cents/ kWH) reported in this news release mean that the total Global Adjustment cost in 2010 was $3.88 billion. Four per cent of this value is $155 million.
- ↑ Ontario Regulation 494/10 - Amending O.Reg. 95/05, made under the Ontario Energy Board Act, 1998.
- ↑ Environmental Commissioner of Ontario, Annual Energy Conservation Progress Report – 2009 (Volume Two): Re-thinking Energy Conservation in Ontario - Results(Toronto, Ontario: 2010), 21.
- ↑ The Brattle Group, Assessing Ontario’s Regulated Price Plan: A White Paper (2010), 8-9.
- ↑ Ontario Energy Board, letter, March 31, 2011. “Re: Review of the Structure and Price Setting Methodology for Timeof- Use Prices; Staff Report to the Board. Board; File No.: EB-2010-0364”.
- ↑ The predictions in the report by the Brattle Group were based on two Ontario pilot studies with small sample sizes, and these studies varied by almost a factor of 10 in their estimates of how much TOU pricing would reduce peak demand (p. 8).
- ↑ Ontario Ministry of Energy, information provided to the ECO in response to ECO inquiry, March 16, 2011.
- ↑ Ontario Ministry of Municipal Affairs and Housing, Suite Metering Provisions Under the Residential Tenancies Act, 2006 and the Energy Consumer Protection Act, 2009 Consultation Paper (2010).
- ↑ Section 53.18 of the Electricity Act, 1998 included a prohibition on “discretionary metering” after November 2005, unless specific authorization was received. The government clarified (through O. Reg. 442/07 under the Electricity Act, 1998) that condominium corporations could enter into suite metering arrangements, but similar rules for the rental sector were never provided. To confuse matters further, section 137 of the Residential Tenancies Act 2006 included rules describing the conditions under which suite meters could be introduced into rental residential units, but this section of the Act was never brought into force. An Ontario Energy Board decision and order (EB-2009-0111) in August 2009 provided explicit authorization for suite metering (specifically, sub-metering) under certain conditions, with the understanding that these rules would soon be superseded by the ECPA and supporting regulations.
- ↑ Ontario Energy Board, EB-2009-0111, Decision and Order (2009).
- ↑ Navigant Consulting, Evaluation of Individual Metering and Time-of-Use Pricing Pilot (2008).
- ↑ New York State Energy Research and Development Authority, Residential Electrical Submetering Manual (2001), 2.
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