Submission re: Proposed…

Submission re: Proposed Enhancements to Ontario’s Net Metering Framework

  1.Introduction - About BluEarth

  BluEarth is a Canadian independent renewable energy company, 99% owned by the Ontario Teachers’ Pension Plan.  With over $1.7 billion of wind, hydro and solar projects in operation or under construction across Canada and the United States, our leadership team is one of the most experienced in Canada having successfully developed, constructed and operated over 2 GW of renewable projects.

  2.Enhancements to Ontario Net Metering Framework (Net-Metered Generation Facilities and Virtual

 Net Metering Demonstration Projects)

  BluEarth supports the proposed amendments on Third Party Ownership.  Allowing third party ownership and financing results in more competitive options for customers deciding how to lower their energy bills.  By facilitating leasing or power purchase agreement (PPA) arrangements for customers with lower access to capital or those who do not want to take on the additional burden of operation and maintenance of an energy system, it creates more customer choice.  There should be no limit to the number of Third Party owners.  Enabling flexible third-party ownership of systems helps to enable vast participation in the program while allowing projects to achieve economies of scale across a larger volume of customers.

  BluEarth continues to support Virtual Net Metering (VNM).  In addition to third party ownership, virtual net metering facilitates development of aggregated energy projects, which creates economies of scale and therefore results in lower costs for customers.  With respect to the proposed VNM Demonstration Projects, we support this approach and suggest storage is permitted as part of the VNM Demonstration program.  We also recommend a focused consultation on the design of the Program as well as the desired outcomes and timelines for moving from Demonstration to a full VNM Program. 

[Original Comment ID: 212056]