January 18, 2018…

January 18, 2018

  Ben Weir

 Ministry of Energy

 Conservation and Renewable Energy Division

 Conservation and Energy Efficiency Branch

 Renewable Energy Facilitation Office

 77 Grenville Street, Floor 5

 Toronto, ON M7A 2C1

  Re:  Proposed Amendment of Ontario Regulation 541/05 – EBR-013-1913

  Dear Mr. Wier:

  Attached please find Cornerstone Hydro Electric Concepts Association’s (CHEC) comments with respect to the Ministry’s invitation to comment on the proposed amendment to Ontario’s Net Metering Regulation 541/05.  This submission addresses the several sections outlined in the proposed amendment dated November 29, 2017 and follows the same format (Attachment A).

  CHEC is an association of seventeen (17) local distribution companies (LDC’s) that have been working collaboratively since 2000.  The comments over the following pages express the views of the CHEC members.

  We trust these comments and views are beneficial to the Ministry’s initiative.  CHEC looks forward to continuing to work with the Ministry in this matter.

  Yours truly,

   Kenneth B. Robertson

   ATTACHMENT A

  Third Party Net Metering – The Ministry of Energy is proposing to amend the net metering regulation to allow other entities to own and operate the renewable generation facility in the following manner:

  a. Eligible customers could request to be billed on a net-metered basis by their distributor. An eligible customer would no longer be required to be an eligible generator. The intent would be to permit other parties (other than the customer) to own and operate the renewable generation facility, if desired by the customer.

  CHEC has no issue with this proposed amendment.

  b. A customer could enter into an agreement with a generator to purchase electricity generated from a renewable energy source. This arrangement would allow surplus electricity that is not consumed by the customer to be conveyed into the distributor’s distribution system, and the customer would receive a credit on their bill for the value of the electricity conveyed into the distribution system.

  CHEC has no issue with this proposed amendment other than a standardized contract for third-party net metering arrangements should be developed by the MoE or the IESO for industry use.   Without the use of a standardized contract there is a risk that vendors of third-party renewable energy facilities could take advantage of the end consumer (i.e.: charges for unused energy, difference between TPNM and provincial pricing, unfair practices, etc.), similar to what has happened in the retailer sector.  A standardized contract would aid in mitigating this risk.

  c. The renewable generation facility, owned or operated by a third-party generator, would be required to be located behind the customer’s meter (i.e. electricity is conveyed directly from the point of generation to another point for the eligible customer’s consumption without relying on the distributor’s distribution system to convey electricity).

  CHEC has no issue with this proposed amendment.

  d. The customer would confirm whether an agreement between the customer and a third-party generator exists for the sale/financing/leasing and installation of the generation facility.

  Distributors do not need to know about ownership or about the private financial concerns of the customer.  Any agreements between the customer and a third-party generator should be kept private and should not be shared with the distributor.

  That said, a distributor would need any third-party renewable energy facility that permits surplus electricity to be conveyed back to the distribution system to meet the requirements as outlined in a distributor’s Conditions of Service and/or Appendix F of the Distribution System Code.  This is to ensure the planning and safety requirements of the distribution system are adequately met.

  e. If an agreement between the customer and a third-party generator for the sale/financing/leasing and installation of the generation facility exists, the customer would acknowledge that the following information has been disclosed to them:

  Same as (d) above.   Customers are responsible for their own financial matters and distributors should only obtain information that is relevant to a net metering arrangement. As a result, items i , ii, and vi to xiv are not required by the distributor.

  f. All other requirements prescribed in the existing net metering regulation (O. Reg. 541/05) would continue to apply (i.e. length of credit rollover period, eligibility to use energy storage etc.). 

 CHEC has no issue with this proposed amendment.

   Virtual Net Metering (VNM) Demonstration Projects – The Ministry of Energy is proposing provisions that will permit electricity distributors to facilitate VNM demonstration projects in the following manner:

  a. Electricity distributors would be permitted to enter into net metering agreements with customers to implement VNM demonstration projects, if the project is participating in a prescribed program administered by the IESO and in accordance with criteria set out in that program.

  VNM requires considerably more system configuration and a means of transferring balances between customer accounts will need to be established ((i.e.: will this fall under the EBT standards?). The IESO program rules will need to take this into account and a billing process should be developed prior to implementation.

  b. A generation facility utilized for a VNM demonstration project would be required to be a renewable generation facility.

  CHEC has no issue with this proposed amendment.

  c. A VNM renewable generation facility would be required to be connected to a distributor’s distribution system at a voltage not to exceed 50 kV, and could not be connected to the transmission system.

  CHEC has no issue with this proposed amendment.

 d. Subject to the discretion of any involved distributors, customers associated with a VNM demonstration project may be located in a distributor’s distribution system other than the distribution system in which the generation facility is located.

  This situation would require that financial transactions occur between distributors.  The OEB should establish an agreement that is to be used between the distributors involved to clearly identify the requirements for these types of transactions.

  e. Distributors implementing VNM demonstration projects would be required to value credits for any electricity conveyed by the generator into a distribution system based on similar principles (affecting only volumetric charges) as currently specified in the existing net metering regulation. 

  If a generation site is being used as VNM for more than one customer, then clear rules need to be established as to how that generation is allocated.  CHEC would propose that a percentage allocation to each customer be assigned at the time the VNM contract is established.  To minimize the administrative burden associated with VNM contracts, revisions to the contract could be permitted once per calendar year.

  Other Matters – The Ministry is further considering how unit sub-meter providers could be involved in the TPO net metering activities being contemplated and in VNM demonstration projects. The Ministry is also considering the same issue for consumers in bulk-metered buildings where the units are individually metered by a licensed distributor rather than a unit sub-meter provider. Unit sub-meter providers are entities, licensed by the Ontario Energy Board, (OEB) and subject to OEB Code, and could include a distributor that works with or for the management of a multi-unit residential complex, such as an apartment or condominium, to provide invoice and other related activities (“billing”) to consumers in bulk-metered buildings. The Ministry invites comment on these matters as well as any other matters relevant to TPO net metering and VNM.

  CHEC has no comment on this issue.

[Original Comment ID: 212043]