The Registry: Remarkable, but Ready for a Refresh

This year marks the 20th anniversary of Ontario’s Environmental Bill of Rights. It has been a good reason to celebrate, and has given me a chance to reflect on the various civic engagement tools built into the EBR.  None has been more successful or widely used than the Environmental Registry.  Let me share what the Ontario government has done right with the Environmental Registry, and also touch on a few areas for improvement.

Ontario’s Environmental Registry is a searchable online database of government proposals and decisions that have the potential to affect the environment.  The Registry casts a wide net.  It shows what the 14 ministries that fall under the jurisdiction of the EBR are working on, giving you a window not merely into the Ministry of the Environment, but also Natural Resources, Transportation, Municipal Affairs and Housing, Northern Development and Mines and so on.  The Registry is your window to engage in informed dialogue on environmental policy.  It lets the public comment before decisions are made, and offers links to background documents. It also shows you the comments that other people have made, and how these comments helped shape ministries’ final decisions.

Ontario’s Environmental Registry was early off the mark with its focus on transparency and civic engagement.  The Registry offered an online database way back when the global social network was still in its infancy.  In fact, Ontario’s Registry was online when Mark Zuckerberg, the founder of Facebook, was just ten years old.

Since 1995, Ontario ministries have used the Environmental Registry to get feedback on over 30,000 proposals.  What’s more, these proposals (and their associated decisions) are mostly still accessible online, making the Registry an archival treasure trove for anyone who follows Ontario environmental policy.  In a typical year, the Registry allows the public to comment on about 80 proposed environmental policies, acts and regulations, many with province-wide implications. On top of that, Ontarians can comment on about 2,400 site-specific permits and approvals a year, the majority of which are issued either by the Ministry of Natural Resources or the Ministry of the Environment.  And Ontarians do take advantage of their right to comment; proposed policies, acts and regulations typically receive dozens or even hundreds of comments. Sometimes a proposal will draw comments from thousands of people; last year, over 10,000 Ontarians used the Registry to comment on proposed changes to the Endangered Species Act, an issue that I addressed in my 2013 Special Report, Laying Siege to the Last Line of Defence.

Ontario is still unique in having its Environmental Bill of Rights.  But many other jurisdictions (including BC, the U.K.,  New Zealand, and Australia) also offer online tools for citizens to engage on the environment.  Some of these tools have features as good as (or even better) than Ontario’s Registry.

The Environmental Registry is not perfect; I have often reported on its shortcomings, (see Part 1.2 of my 2012/2013 Annual Report) and have encouraged the Ministry of the Environment to update this tool and make it more functional and user friendly.

I know the interface of Ontario’s Environmental Registry is a bit clunky and dated. But I encourage you to use it anyway. Here’s why: using the Registry ensures that your comments are part of the permanent public record.  If you comment via the Registry, ministries are obliged under the Environmental Bill of Rights to consider your comments when making a decision.  Your comments help to broaden and deepen society’s ongoing dialogue on important environmental matters. All in all, the Registry remains a powerful tool for public participation in environmental decision making.

I am fond of a quote by Theodore Roosevelt that prefaces my most recent annual report: “The government is us; we are the government, you and I.” The Registry allows you to put that noble principle into everyday action.



Climate Data: For Baselines, Trend Lines and the Bottom Line

data imageToday I want to zero in on the urgent need for made-in-Ontario climate projections. How can we prepare for climate change and make long-term decisions – how high to build a bridge, for example, or where to site a water treatment plant – if we don’t have reliable data and information?

Decisions on infrastructure span far into the future and have major social and economic consequences. Without trustworthy climate projections customized for Ontario’s local scales, we are handicapped, and left in the dark about the vulnerability of our assets.

In Ontario, some municipal governments and other organizations are using current climate data – such as rainfall intensity, duration and frequency curves – as well as projections to inform infrastructure design and other planning decisions. However, adaptation planning in Ontario is still in its infancy.

GHG2014 cover image thumbOntario lacks easily accessible, downscaled climate data and projections to use in preparing for the “new climate normal,” which I described in my 2014 greenhouse gas progress report.

Unlike Ontario, some leading jurisdictions understand the importance of scientifically sound, readily available and understandable information about future climate and weather conditions. They also see the business opportunity.

The United States is becoming a climate data leader, and it’s worth looking at what it’s doing as an example of best practice. The U.S. government is investing millions of dollars into climate data and modelling to ensure that federal agencies can support communities to prepare for climate change. This Climate Data Initiative is bringing together the private and public sectors to develop tools that help communities and companies prepare for climate change. The U.S. government is actively obtaining a variety of commitments from the private sector to support the initiative.

At the same time, President Obama sees the business advantage for American companies to develop new climate data products and services for both domestic and export markets. The uptake of these products and services by American companies will help ensure continued U.S. economic competitiveness in the face of a changing climate. These climate applications will be “made in America,” meaning that American companies such as Microsoft and IBM will be able to export their climate data expertise. To accelerate progress, the White House is convening private and public sector leaders around focused themes, such as food security, to develop and leverage climate data to ensure American resilience and economic competitiveness.

I find the array of accessible U.S. governmental and non-governmental websites dedicated to providing accurate local climate data, projections, maps and tools truly impressive, even at this early stage. The main U.S. government climate data web portal consolidates much of the available information into a one-stop shop. Other American websites are dedicated to providing information about current drought conditions, managing agricultural risks, assessing the cost-effectiveness of low-impact development, tropical storm maps and links to many more tools and data sets. The National Oceanic and Atmospheric Administration’s National Climatic Data Center manages six Regional Climate Centers. Its Regional Integrated Sciences & Assessments team supports public and private end users to understand and deploy climate data. The National Aeronautics and Space Administration provides a variety of climate datasets and images. The U.S. is also investing in creating 3-D maps that will assist in flood risk management and other climate impacts.

By contrast, the Canadian government has no initiative of comparable scale and scope. Ontario has made some modest investments in climate change modelling. One of the modellers funded by the province has a dedicated website for Ontario climate projections. The Toronto and Region Conservation Authority  has created a real-time flood monitoring website. While these initiatives are a good start, there is clearly a large gap between the needs of climate data users (such as companies, insurers, municipalities and other organizations) and what is available. Some of these organizations can afford to hire consultants when faced with a lack of publicly-funded, scientifically-sound and properly interpreted climate data, but many cannot. I believe the provincial government has a responsibility to ensure that consistent, high-quality climate data are widely accessible in a user-friendly format. Our neighbour Quebec has created an organization, called OURANOS, to fulfill this exact function. In Ontario, the Ontario Climate Consortium is attempting to fill this gap, but without significant government financial support.

Accurate and reliable climate information is a prerequisite for adapting to climate change. Provincial stakeholders need this vital climate information to adapt Ontario’s economy and infrastructure to the changes we know are coming. Now is the time for leadership from the provincial government on this important issue.


The Unforgiving Truth About Unburnable Carbon

GHG2014 cover image thumbIn a recent blog highlighting the findings in my 2014 Annual Greenhouse Gas Progress Report, I stressed that the science of climate change is unequivocal: humans are changing the global climate through deforestation and the burning of fossil fuels. Since the rise of the industrial revolution in the mid-1800s, the concentration of carbon dioxide (CO2) in the atmosphere has increased by over 40 per cent – from 280 parts per million (ppm) to 401 ppm today.  This blanket of greenhouse gases traps radiant heat, which has already resulted in a nearly 1°C rise in atmospheric temperatures since pre-industrial times. While 1°C may not seem like a big deal, it is: the global average temperature difference between today and the last ice age 12,000 years ago was only 4°C.

The Need for a Planetary Carbon Diet

In 2009 the global community adopted a goal [.pdf] to limit global warming to 2°C compared to pre-industrial temperatures to avoid “dangerous … interference with the climate system”. We are already about half-way to this threshold. Consequently, the Intergovernmental Panel on Climate Change (IPCC) released calculations regarding a global carbon budget [.pdf] – a carbon diet if you will – that must be adhered to going forward. To have a reasonable chance of staying within a 2°C increase, the IPCC cautions that the global economy only has about 1,000 Gigatonnes (billion tonnes or Gt) of CO2 remaining for future use (see diagram). At the current worldwide rate of CO2 release (36 Gt CO2 /yr), this global budget will be exhausted in about 28 years; sooner if emerging economies like India and China don’t stem their rising carbon appetites.

Carbon budget

The Fossil Fuel Industry Wants to Feed Us More

The situation becomes even bleaker when one realizes the considerable disparity between the budget – what can be emitted while staying within the 2°C threshold – and what the global fossil fuel companies publicize are their proven reserves of fossil fuels. The 2012 World Energy Outlook published by the authoritative and independent International Energy Agency (IEA) estimated that the remaining global reserves of all fossil fuels in the ground (coal, oil and natural gas) would emit 2,900 Gt CO2 if burned.  If the IPCC’s 1,000 Gt CO2 scenario is the diet that the global economy must stick with to avoid ecological catastrophe, then about two-thirds of these fossil reserves must stay in the ground – they are unburnable carbon.

The Economics of Unburnable Carbon

Unburnable carbon raises the spectre of portfolio write-downs and stranded assets for fossil fuel-intensive industries, and raises an important financial risk for the industry‘s investors. Within Canada the S&P/TSX Composite Index is one of the most carbon-intensive stock indices in the world.In 2013, the TSX had over 400 companies listed in the oil and gas sector, representing a market capitalization (i.e., the total value or worth of the 400-plus companies) around $400 to $500 billion.

I stressed in my report that the fossil fuel industry and its investors need to re-examine business risk through this new unburnable carbon lens. Several authoritative international organizations, including the IEA, Carbon Tracker, the United Nations [.pdf] and HSBC [.pdf] are warning investors to focus this lens quickly and act accordingly to avoid another kind of catastrophe – an economic one.

Climate Change Science is Certain

Almost 14 years ago, I submitted a special report to the Legislative Assembly of Ontario entitled Climate Change: Is the Science Sound? Concerned about the debate that was ongoing at the time, I felt that – as the Environmental Commissioner of Ontario – it was incumbent upon me to review the scientific evidence and provide Ontario policymakers with my considered opinion as to the strength of the arguments that were being made. I concluded at the time that climate change is occurring and that humans play a key role.

GHG2014 cover image thumbFor anyone who has been paying attention to this issue during the intervening years, it is clear that both the weight of evidence and the certainty of the science are now unequivocal. Enhanced scientific modelling, as well as improved technologies, have allowed scientific organizations such as the Intergovernmental Panel on Climate Change (IPCC), the World Meteorological Organization, and the National Aeronautics and Space Administration (NASA), to reach the same inescapable conclusion: the climate-warming trends that have been witnessed over the past century are almost certainly due to increases in greenhouse gas emissions from human activity. In my most recent report on the Ontario government’s progress in reducing greenhouse gas emissions, I discuss key conclusions reached by the IPCC, as well as others, to again present Ontario policymakers with the most up-to-date scientific information possible on Earth’s changing climate.

In our day-to-day lives, we plan what to wear, and whether to bring an umbrella, based on daily weather forecasts. One day may be warmer or rainier than the next and so we make plans according to the weather. Over a much longer time frame, however, trends in weather patterns are assessed to determine what the climate is for a particular area. In other words, the difference between weather and climate is a measure of time; typically more than a 30-year timeframe. While daily changes in the weather are clear and obvious, it is more difficult to discern whether the climate is also changing.  It is only through the long-term tracking and recording of data that climate patterns, and changes associated with those patterns, become evident.

At a global level, it is through this long-term tracking that scientists have determined that global average temperatures are inexorably rising. As shown below, the longer term trend shows a clear increase, particularly when averaged over 10-year time periods. As shown in the lower portion of the diagram, the average temperature of each succeeding decade has been warmer than the one previous. The most recent data indicates that 2013 was slightly warmer than the preceding two years (source). Within the Northern Hemisphere, the last 30 year period is likely to have been the warmest period during the previous 1,400 years (source).

Surface temp anomaly

A key question in climate change discussions is whether or not severe weather events – such as extreme heat alerts – can be attributed to a changing climate. Over the past year, research (.pdf) has revealed that the frequency with which anomalous extreme heat events are occurring has shifted, such that they now occur more often. The graph below illustrates this for the Northern Hemisphere. The far left box shows that historic summer temperature anomalies from 1951-1980 produce a normal distribution – or bell-curve pattern. The far right tail of the curve – in the darker red that is barely visible – shows that extreme heat events occurred only very rarely; only 0.1 per cent of all temperature events during the 30-year period. Over time, however, there has been a shift in the entire distribution curve; in short, extreme hot weather events are now happening much more frequently than they have in the past.

N Hemisphere Land Summer Temp Anomalies

Along with rising temperatures, other indicators clearly demonstrate that not only is the climate changing, it is doing so at an accelerated rate. For instance, the average rate at which glaciers and ice sheets are melting has increased in recent years (source). While each of these findings reveals the changes that have occurred in the past, the IPCC also provided projections that should truly give reason to pause and consider what may lie ahead for the future.

Ontario’s policy decisions matter and they can have an influence on our future. I am therefore calling upon the provincial government to show leadership and to make decisions that will help the province move toward a low-carbon economy. The costs of inaction are profound and, in my view, the benefits of taking action are compelling. It is now time for leadership on climate change.

Thought-Provoking Insights Shared at Environmental Bill of Rights Conference

EBR Proclamation UpdatedThis year marks the 20th anniversary of Ontario’s Environmental Bill of Rights (EBR), landmark legislation that has allowed Ontarians to have a say in environmental decisions made by the province. To celebrate and reflect on this milestone, in February I hosted a conference at the University of Toronto on the evolution, effectiveness, successes and future of the EBR and its tools.

We heard a recurring message in remarks by the Minister of the Environment, Environment Critics, former Ministers of the Environment, and panels made up of the EBR Task Force, environmental organizations, and prominent environmental lawyers: the EBR has been effective, and the EBR is still needed. The conference’s stimulating conversations raised many interesting points about the value of the EBR in public engagement, opportunities for improving the legislation, and the role of the EBR going forward. Also, members of my staff shared stories on how Ontarians have used the EBR’s tools to improve environmental protection. A keynote by David McLaughlin – former President and CEO of the National Round Table on the Environment and Economy – contemplated the legacy, potential, and future of the EBR. We rounded up the day’s lively discussions with a reception at Queen’s Park to celebrate the EBR.EBRat20 cover

Listening to the speakers and attendees throughout the day reinforced in my mind that the EBR – while not perfect – is a unique and valued piece of legislation. It is definitely worth celebrating and advertising the EBR’s successes and the rights it gives Ontarians!

I encourage you to go to the conference website and check out the materials, including presentations, notes, photos and an audio recording.


Insuring our Future Against Extreme Weather

In my just-released Annual Greenhouse Gas Progress Report, I note that wild weather –such as ice storms and floods – has increasingly captured the attention of Ontarians.  The province has always experienced periodic heavy downpours and ice storms but, thanks to climate change, the magnitude and frequency of these extreme weather events is increasing. This trend is the new normal.

This message hit home in 2013 when regions as diverse as Toronto, Sault Ste. Marie and Muskoka were struck by damaging storms. On July 8, for example, Toronto experienced a torrential rainstorm. Parts of the city were overwhelmed with up to 126 millimetres of rain in about two hours, more than the previous daily rainfall record of 121.4 millimetres, which was set by Hurricane Hazel in 1954. The subway system and airport were shut down, people were stranded for hours and residents had to wade through streets that had been transformed into rivers.  Similarly, Sault Ste. Marie and Muskoka experienced severe floods the same year. Over the past ten years, citizens in Wawa, Thunder Bay,  HamiltonPeterborough  and other communities across the province have also experienced wet basements, flooded streets and evacuations, sometimes multiple times over.

The Insurance Bureau of Canada estimates that storms that used to occur every 40 years on average can now be expected to occur every six years. Extreme weather is here to stay and will only get worse. Municipalities are on the front lines in terms of dealing with the associated challenges and struggle to manage such repeated disasters – operationally, environmentally and financially.

Many municipalities lack the technical knowledge and financial capacity to adequately adapt to a changing climate. Flooding can come from rivers and lakes overflowing their banks, but in many cases urban flooding is caused by inadequate stormwater infrastructure that cannot handle the intense downpours that are now being witnessed across the province. Some municipalities are attempting to prepare for extreme weather through tools such as green infrastructure or paying for investments by imposing stormwater rates; however, without direction from a higher level of government, communities are working in isolation.

Municipalities have asked the province for help [.pdf] to adapt to a changing and volatile climate, and provincial leadership is clearly needed. However, in my latest GHG Report, I conclude that “on stormwater management and climate change, Ontario ministries have unfortunately not yet stepped up to their responsibilities.”

Municipalities and conservation authorities are not the only ones affected by extreme weather – the insurance industry has noticed these trends as well. While fire was once the main cause of property insurance claims in Canada, the Insurance Bureau of Canada reports that water and wind damage from severe weather has now become the leading loss. For example, insured property damage from the 2013 Toronto flood was pegged at $940 million. As such, it’s expected that insurance rates will go up and some types of liabilities, such as wet basements, will cease to be covered. There have even been headlines warning of uninsurable homes, raising a major question mark when it comes to obtaining or renewing a mortgage.

The insurance industry’s growing concerns about climate risk will also have broader implications for Ontario. As I said at the release of my report, “The insurance/reinsurance industry has been warning us for years that losses due to flooding must be stemmed or it will be impossible to write insurance. Our financial system cannot function without insured risk.” (Watch the video of my remarks) If Ontario does not step up to the plate and provide leadership to municipalities and residents in climate change adaptation, we risk increased, and possibly unmanageable, costs for damage to infrastructure and properties when extreme weather inevitably occurs again.

I believe it is urgent that the provincial government fulfills its responsibilities to help Ontario prepare for the stormwater and flooding impacts of a changing climate. Our province has drifted into troubled waters and without quick action our communities will not be able to weather the coming storms.

Ontario Failing in Fight Against Climate Change

GHG2014 cover image thumbEnvironmental Commissioner Gord Miller says Ontario needs to get back in the game on climate change.

“The latest scientific evidence shows that the pace of climate change is accelerating,” says Miller. “Extreme weather events have increased dramatically around the world. Here in Ontario though, the provincial government hasn’t even delivered on commitments it made seven years ago.”

The Environmental Commissioner today released “Looking for Leadership: The Costs of Climate Inaction”  (download the PDF), his 2014 report on the government’s progress in reducing greenhouse gases (GHG) and meeting the reduction targets contained in its Climate Change Action Plan.

The report shows that the government will likely meet its 2014 target (a 6% reduction in emissions below 1990 levels) largely because of the shutdown of the province’s coal plants. “But it’s not going to meet its 2020 target,” says Miller, “because it has taken very little additional action to implement the Climate Change Action Plan it released seven years ago.”

The Environmental Commissioner points out that transportation, mainly cars and trucks, is the biggest source of GHG emissions in the province. “The 2007 Action Plan said the government would reduce transportation emissions by 19 megatonnes (Mt) by 2020. That goal, unfortunately, has now been cut by almost 80%. I have been given no reason why, and no explanation about what the Ontario government plans to do instead.”

Miller says the province has lost the leadership position it once had. “British Columbia has brought in a carbon tax, Quebec has implemented a cap-and-trade system for carbon credits. Meanwhile, Ontario appears to have lost the ambition it once had and won’t even look at directives to ensure more compact urban development or a serious commitment to using electricity for transportation.”

The Environmental Commissioner says society has to end its reliance on carbon-based fuels, especially for transportation. “We need to limit the increase in global temperatures to 2 degrees Celsius. But that can only be done if we leave two-thirds of the existing oil and natural gas reserves in the ground. People need to understand that brutal fact.”

More information, or to download the report

ECO to release report on greenhouse gas reduction

Media Advisory

The Environmental Commissioner of Ontario will release Looking for Leadership: The Costs of Climate Inaction – the 2014 edition of his annual review of the government’s progress in reducing greenhouse gas emissions.


WHEN: Wednesday, July 9th, 2014 at 10:00 a.m.

WHERE: Room 148, Queen’s Park Media Studio, Legislative Building, Queen’s Park, Toronto, Ontario


The conference will also be available via webcast. To watch the live broadcast of the media conference, please visit Please note the Commissioner will not be taking questions via webcast, but will be available for individual interviews after the news conference.


For more information or to schedule interviews, contact:

Hayley Easto, Communications & Outreach Coordinator,
416-325-3371 or

For French language release and bilingual support, contact:

Jean-Marc Filion, 705-476-9665.


  • Media not currently accredited by the Legislative Assembly (Queen’s Park) Media Gallery must register with the Press Gallery if they wish to participate in the conference. To register, contact Gerald Christopher, Press Gallery Coordinator – Room 387A or 416-325-7922 or
  • The full Report will be available in print and PDF formats at 9:00 a.m. on July 9th, 2014. To download the report, visit


Aussi disponible en français.


Lowering Coal Plant Emissions – U.S. EPA Prescribes Flexible Energy Efficiency

The United States Environmental Protection Agency (EPA) has released its proposed rule to limit carbon dioxide (CO2) emissions from electricity generating stations. There will be much discussion in the U.S. before this rule is finalized next year.  For us here in Ontario, I want to highlight the argument for energy conservation that EPA has made.

The guiding principle of the draft rule is flexibility. The US EPA’s approach supports states’ rights by providing states with flexibility.  This is appropriate to conditions across the US where each state has a different mix of generation sources and various opportunities to lower emissions from power plants.  And so EPA deliberately chose not to fence in states by requiring them to meet the regulation only though upgrades of power plants to emit less CO2.

In fact, the agency did quite the opposite.  It encourages state implementation plans to meet the new stricter emission targets in several ways. Power plant upgrades, carbon capture or converting from coal to cleaner natural gas are all options that can be pursued at the site of a coal-fired generating station.  However, there are options located outside of the power plant’s gates [PDF] that states can use. Improving energy efficiency is explicitly presented as a way to meet the targets.  EPA is asking policy makers to look broadly at the energy sector, invest in conservation programs and consider market trends in product energy efficiency.  States can choose [PDF] among demand-side management, codes and standards, carbon pricing mechanisms, energy storage, renewable energy and others.

Why is this important to us in Ontario? The closure of our last coal plant means our electricity sector has been greatly decarbonized compared to most US states.  We don’t need the “outside-the-fence flexible solution” to lower emissions since our power sector already contributes much less to climate change. True enough but Ontario still has many gas-fired plants that emit CO2 and so we should not be complacent.

We also have our own homegrown reasons for not adding electricity supply and pursuing energy efficiency instead.  A recent report by the American Council for an Energy Efficient Economy examined efficiency programs in 20 states and concluded they were much cheaper than supply-side solutions. The average cost of 2.8 cents per kilowatt-hour for efficiency programs was about one-third to one-half of the cost of new electricity supply options.  Here in Ontario, the province’s electricity planning agency, the Ontario Power Authority, provides similar information which is highlighted in the Ministry of Energy’s conservation discussion paper [PDF].  Ontario’s energy efficiency programs cost roughly half as much as the cheapest supply option.

Relative Cost of Electricity

The take-away is that in Ontario too, energy efficiency is cheaper than any kind of new supply and is the top ranked option. Building new plants or refurbishing old ones increases electricity prices.  For this reason, if Ontario doesn’t want to add supply and needs an “outside the fence solution”, the same flexible response contained in the EPA rule is right in front of our noses. And as a bonus, this energy efficiency solution is the lowest cost option.

Coming Soon: Smart Meters for All Large Electricity Consumers

smart meterAs most Ontarians likely know, nearly every household and small business in Ontario is now using electricity smart meters – meters that can record electricity consumption in hourly periods, enabling time-of-use pricing that more accurately reflects the varying cost of producing power at different times of day.

What you may not know is that not all larger business customers do the same. Surprisingly, many of these larger business customers do not currently have an electricity meter that tracks hourly consumption. Without a smart meter, these customers pay an averaged electricity price that is the same at all hours of the day.

This is about to change. Last week, the Ontario Energy Board moved to close this data gap [PDF], bringing such customers into line with all other Ontario consumers who are billed based on their actual hourly usage. Distribution utilities are required to install smart meters for new business customers going forward, and for all existing business customers by 2020. Once a smart meter is in place, these large customers will pay an electricity price that varies hourly and is partially set by the market. The hourly price provides a fine-grained signal as to when electricity supply is plentiful, and when it is scarce and more expensive.

Hopefully this change will cause more businesses and industries to examine their pattern of electricity use and shift some of their discretionary consumption to lower-priced hours. The potential benefits include lower bills for customers and lower greenhouse gas emissions for the province, as a result of businesses shaving their peak demand and the province using less gas-fired generation to meet this peak. The ECO has long supported more accuracy in electricity pricing.

green buttonOf course, collecting the data is only the first step. To drive change, price and consumption data needs to be easily accessible to customers. The government has recently taken some steps to make it easier for households to understand and act on their smart meter data, through the Green Button initiative. Hopefully we will see similar actions for larger customers, given that the potential energy and cost savings for these customers are proportionally greater.