We are writing to strongly urge you to ask the Ontario Energy Board to increase natural gas energy efficiency programs in Ontario to meet the targets in your Made-in-Ontario Environment Plan.

1. The Honourable Minister Greg Rickford
Minister of Energy
99 Wellesley St. W, 5th
Floor
Toronto, ON, M7A 1W1
ndmminister@ontario.ca
The Honourable Minister Jeff Yurek
Minister of Environment
777 Bay St, 5th Floor
Toronto, Ontario M7A 2J3
minister.mecp@ontario.ca
The Honourable Rod Phillips
Minister of Finance
7 Queen's Park Cres, 7th Floor
Toronto, Ontario M7A 1Y7
minister.fin@ontario.ca
July 2020
Re: Natural Gas Energy Efficiency – Jobs, Growth, and Lower Energy Bills
Dear Honourable Ministers Rickford, Yurek, and Phillips,
This letter comes to you from the over ___ corporations, associations, and municipal
representatives listed below. We are writing to strongly urge you to ask the Ontario Energy
Board to increase natural gas energy efficiency programs in Ontario to meet the targets in your
Made-in-Ontario Environment Plan. These programs are a rare opportunity to lower energy bills,
create jobs, cut carbon emissions, and stimulate our economy. As your plan states, these
programs save people money.i
This would also help drive Ontario’s COVID-19 economic recovery by injecting money into the
economy, generating jobs, and lowering operating costs. This is the best kind of economic
stimulus because it would pay for itself over time, improve efficiency, and lower bills.
The benefits of these programs include:

2. • Lower energy bills: Energy efficiency programs lower energy bills for Ontarians.ii
Each
dollar invested creates more than one dollar in savings through reduced energy use.iii
For
example, Enbridge’s programs are forecast to generate $4.71 for every dollar spent by
the utility; its most cost-effective programs in the commercial sector are forecast to
create over $16.00 for every dollar invested.iv
These programs pay for themselves many
times over and have already lowered energy bills by a staggering $6.3 billion in Ontario.v
• Made-in-Ontario jobs: Energy efficiency creates good made-in-Ontario jobs such as
insulation installers, equipment retailers, and retrofit experts. It also creates spin-off jobs
by injecting money into the local economy.vi
Efficiency replaces out-of-province gas
purchases with made-in-Ontario gas savings and jobs. Increasing these programs to the
levels found in leading jurisdictions would create over 18,500 good jobs for Ontarians.vii
• Economic stimulus: Energy efficiency improves productivity by allowing business to
produce the same output with fewer inputs. This makes businesses more competitive
and creates economic growth.viii
Investments in efficiency also stimulate the economy if
the costs are amortized. Increasing these programs to the levels found in leading
jurisdictions would generate $77 billion in increased GDP over 14 years.ix
• Cut carbon costs: Natural gas energy efficiency is by far the cheapest way to reduce
Ontario’s carbon costs.x
The programs pay for themselves with reduced energy use and
costs and therefore the emissions reductions are free. Natural gas creates 29% of
Ontario’s carbon emissions and is the largest source of carbon emissions in the
province after transportation.xi
There is huge untapped potential for cost-effective
natural gas energy efficiency in Ontario - even a conservative analysis found that energy
efficiency can reduce emissions from natural gas by 20% by 2038.xii
Ontario is missing this opportunity and already falling behind on its own targets. In 2018, the
Ontario Government rolled out a plan for increased investments, which were set to start in
2021.xiii
Unfortunately, the current programs are slated to roll-over in 2021 with no increases.xiv
We commend the Ontario Government for taking action by committing to targets for increased
natural gas efficiency programs and directing the Ontario Energy Board to implement all natural
gas energy efficiency programs that are cost-effective.xv
Unfortunately, this does not seem to be
working.

3. We therefore ask you to specifically direct the Ontario Energy Board:
• To increase natural gas efficiency programs to meet Ontario’s targets as a minimum
• To amortize costs to ensure affordability
If you can act quickly, this could be a big part of Ontario’s plan to stimulate the economy, get
out of the pandemic recession, and create good jobs. Amortizing costs can provide consistency
with supply-side gas investments, match the costs and benefits over time, take advantage of
current rock-bottom interest rates, and help stimulate the economy. We are ready to work with
you to create new good jobs as soon as possible and get us all back on track. We would
appreciate a response to these requests from you, which we will ensure is distributed to
representatives of the undersigned corporations and municipalities.
Sincerely,
i
Ontario, Made-in-Ontario Environment Plan, November 29, 2018, p. 23.
ii
OEB, Demand Side Management Framework for Natural Gas Distributors, December 22, 2014, pp. 33-34.
iii
Ibid.
iv
Enbridge Gas evidence in EB-2015-0049, Exhibit B-2-3, p. 7. These figures include all utility costs under the PAC
calculations. The TRC calculations show $2.60 on average and $28.48 for the best programs per $1 invested.
v
Enbridge Gas evidence in EB-2019-0271, Exhibit I.ED.2, p. 1.
vi
Testimony in EB-2015-0029/0049, Transcript Vol. 10, p. 130, lns. 4-11.
vii
Dunsky Energy Consulting, The Economic Impact of Improved Energy Efficiency in Canada, April 3, 2018, p. 33
(These programs would create 259,801 job-years over 14 years, which amounts to 18,557 jobs per year on average).
viii
Centre for Spatial Economics, The Economic Impacts of Reducing Natural Gas Use in Ontario, April 2011.
ix
Dunsky Energy Consulting, The Economic Impact of Improved Energy Efficiency in Canada, April 3, 2018, p. 33.
x
ICF, Marginal Abatement Cost Curve, EB-2016-0359, July 20, 2017, prepared for the Ontario Energy Board, p. 14.
xi
Enbridge Gas evidence in EB-2019-0294, Exhibit I.ED.1, Attachment 1.
xii
Navigant, 2019 Integrated Ontario Electricity and Natural Gas Achievable Potential Study, September 13, 2019,
prepared for the IESO and OEB, p. ix.
xiii
Ontario, Made-in-Ontario Environment Plan, November 29, 2018, p. 23; Auditor General of Ontario, 2019
Annual Report, December 4, 2019, p. 151 (describing “additional required funding for this scenario from 2021 to
2030”).
xiv
Enbridge Gas evidence in EB-2019-0271, Exhibit A; OEB, Procedural Order No. 1, February 24, 2020, p. 3.
xv
Ontario’s target is 3.2 Mt CO2e reduction from natural gas conservation programs by 2030: Ontario, Made-in-
Ontario Environment Plan, November 29, 2018, pp. 23-24; Minister’s Directive to the OEB, March 26, 2014, para.
4(i) (mandating “all cost-effective DSM”); Minister’s Directive to the OEB, March 06, 2019, para. 5 (confirming
that this mandate “shall remain in full force and effect.”).