Dear Mr. Weir:…

 Dear Mr. Weir:

  We would like to offer our most sincere thanks for the opportunity to contribute to this consultation process.

  As an early adopter of best practices for climate change mitigation, the City of Guelph was the first municipality in Canada to adopt a community energy plan in 2007. This later became the Community Energy Initiative (CEI), and was not mandated by the Province but rather was implemented solely on the basis of the City taking a leadership position on a critical environmental responsibility matter. Net metering promises to be a critical component of ongoing efforts to increase local generation of renewable energy, a key objective of the CEI.

  GENERAL COMMENTS

  The citizens of Guelph have been enthusiastic adopters of solar photovoltaic systems, as evidenced by the fact that in 2016 Guelph had a rate of participation in the MicroFIT program that was 49% higher than the provincial average. Now that the MicroFIT program has been concluded (as have its companion programs, Feed-In Tariff and Large Renewables Procurement), we would like to see a successor program that will be as effective in encouraging uptake of this important low-carbon energy generation technology as well as other renewable energy generation methods.

  We believe that virtual net metering, third-party ownership, and multiple entity virtual net metering have the potential to continue contributing to the propagation of renewable energy generation systems. This will continue to drive down the cost of such systems, helping Guelph to become progressively more energy self-sufficient, thereby reducing the amount of money that must be sent out of the city to pay for imported energy. Because such energy is produced without carbon emissions, it will also help reduce our community’s contribution to climate change. We therefore encourage the Ministry to implement these measures expeditiously.

  We would like to see Combined Heat and Power (CHP) considered as an eligible technology for net metering. Although CHP typically uses non-renewable fossil fuel, it displaces fuel usage for heating and results in lower emissions overall. Given that CHP also has the potential to migrate to a renewable fuel source such as renewable natural gas, in the medium to long term it can make a more meaningful contribution to emissions reduction goals.

  SPECIFIC COMMENTS - 013-1913

 •Third Party Ownership

 a.Paragraph e: It is unclear why it is necessary for the regulation to include customer acknowledgement of receipt of this information. This information is fundamental to doing business in this industry, and any diligent customer should ask for this information. It may be more appropriate to provide a “how-to” guide to prospective 3rd party net metering customers to aid with their market research and purchase decision rather than mandating disclosure of specific information.

 •Virtual Net Metering (VNM) Demonstration Projects

 a.It is unclear why the regulation would assume no further action beyond demonstration projects. Other jurisdictions have implemented VNM successfully, so the only barriers would likely be regulatory in nature and therefore could be alleviated with the appropriate regulatory amendments. We are enthusiastic for VNM to be made widely available as soon as possible, and would like to see a plan to make this happen rather than only one initial step.

 b.Paragraph d: We enthusiastically endorse the idea of making VNM available across LDC service territories rather than requiring that the generator and consumer be located within the same service territory.

 c.Paragraph e: We would like specific consideration given to net metering being based on Time of Use (TOU) rates or on the Hourly Ontario Electricity Price (depending on the rate class of the host). Solar PV peak production coincides with some of the highest consumption periods, so it is higher value electricity than that created during off-peak periods. It should be valued accordingly.

 d.Paragraph e (continued): LDCs adjust customer metered consumption by 3 to 10% to account for

 line losses. We would like to see all charges other than those arising from local distribution credited back into net metered power, for both import and export, in cases where the generator and the consumer are located in the same service territory (i.e. where the electricity does not pass through transmission infrastructure when travelling from the generator to the consumer). This would include omission of line loss provisions.

 •We would request that the net metering rules be further modified to allow LDCs to recognize generation credits (possibly at some prorated value) to reduce fixed charges on the generator’s invoice. LDCs are transitioning to a “prosumer” model, and the prorated value of solar credits would help fund this transition and encourage LDC innovation while still improving the business case for the generator. Further, legacy generation facilities would be motivated to become cost-competitive with distributed generation sources.

  CONCLUSION

  The City asks that these comments and recommendations be taken into consideration when drafting the legislation associated with net metering in Ontario.

  Sincerely,

  Mario Petricevic

 General Manager

 Facilities Management

 City of Guelph

 T 519-822-1260  x 2668

 E mario.petricevic@guelph.ca

  Alex Chapman

 Manager, Climate Change Office

 Facilities Management

 City of Guelph

 T 519-822-1260  x 3324

 E alex.chapman@guelph.ca

[Original Comment ID: 212075]