Energy Storage Canada…

Energy Storage Canada

 Comments on Ontario Environmental Registry Proposals 013-1913 and 013-1916

 Proposed Amendments to Ontario Regulation 541/05 (Net Metering) and New Regulation to be Made Under the Electricity Act, 1998

  Attention:Mr. Ben Weir, Senior Policy Advisor

 Ministry of Energy, Conservation and Renewable Energy Division, Conservation and Energy Efficiency Branch, Renewable Energy Facilitation Office

 77 Grenville Street

 Floor (FL) 5

 Toronto Ontario

 M7A 2C1

  From:

  Patricia Phillips, Executive Director

 Energy Storage Canada

 MaRS Cleantech, Suite 420, 101 College Street

 Toronto, ON M5G 1L7

  Date: January 18, 2018

  1.Energy Storage Canada (ESC) is the voice of leadership for energy storage and the only industry association in Canada that focuses on advancing opportunities and building the market for energy storage. ESC leverages the strength of its diverse membership (including energy storage developers and technology providers ranging from bulk hydro and gas energy storage, to battery, compressed air, flywheel, and submerged air energy storage) to drive market development in Canada.

  2.ESC has made energy storage a key focus for policy makers. It aims to educate stakeholders and drive awareness about the value that energy storage can deliver in energy systems. It works cooperatively with regulators and policy-makers to ensure fair regulatory treatment for energy storage and that the value of energy storage is realized to optimize power systems are optimized. ESC’s mission is to advance the energy storage industry in Canada through policy advocacy, collaboration, education, and research. ESC works closely with energy sector allies including generators, distributors, transmitters, and end-use customers to push the industry forward in an efficient manner that serves both customers and the system.

  3.Ontario has been a leading jurisdiction in energy storage, but unfortunately a number of regulatory barriers continue to exist that prevent it from delivering the many, multiple benefits and services that only energy storage can provide. Specifically, regulatory barriers are limiting the ability of energy storage to help address the nearly 5 TWh of "electron waste" of the cleanest, cheapest electricity in Ontario.

  4.LTEP 2013 acknowledged a number of regulatory barriers to energy storage in Ontario and prioritized removing them. The Ontario Energy Board, IESO and Ministry of Energy (MOE) have been diligently studying the barriers over the last four years, but have yet to finalize action to remove them. Energy storage therefore continues to experience a number of unintended and inefficient regulatory barriers that are limiting its adoption, operation, and ability to (i) meet the flexibility needs of the system and (ii) help address the increasing spill of potential hydro power and the resulting electron waste of the cleanest, cheapest surplus baseload electricity generation in Ontario.

  5.The Ministry of Energy (MOE) recently proposed: (i) amendments to O. Reg. 541/05 (Net Metering) to enable third-party ownership of net-metered renewable generation facilities and provide flexibility for local distribution companies to enable virtual net metering (VNM) demonstration projects and (ii) a new regulation under the Electricity Act, 1998 to ensure the appropriate siting of renewable energy generation facilities.

  6.These submissions set out ESC's support of, and proposed changes to, the amendments to O. Reg. 541/05 and the proposed new regulation on the understanding that all energy storage may qualify for net metering and VNM.

  7.ESC's submissions address the proposed regulatory changes to: (i) enhance the net metering framework; (ii) allow third party ownership of net-metering facilities; (iii) allow VNM demonstration projects; and (iv) ensure the appropriate siting of renewable energy generation facilities.

  8.Enhancements to Net Metering. ESC supports allowing third-party ownership of net-metered generation facilities and VNM demonstration projects on the understanding that all energy storage will be eligible as renewable resources for net metering. Energy storage resources combined with renewable generation can maximize the use of existing infrastructure and provide more cost-effective solutions. Specifically, ESC submits that the prescribed types of eligible “Renewable Energy Generation Facilities” should be defined more broadly to ensure MOE's intended eligibility of combined renewable and storage systems for net metering. Further, MOE may wish to consider having a required ratio of renewables to storage in future net metering programs, e.g., Renewable Energy Generation Facilities with storage capacity representing more than 25 per cent of nameplate renewable generation capacity should be considered eligible Renewable Energy Generation Facilities for the combined capacity.

  9.Third Party Ownership. ESC submits that there are opportunities for multiple customers to enter into net metering arrangements in aggregate with a generator or utility, such as all customers connected to one feeder. The Independent Electricity System Operator (IESO) and MOE may wish to consider including language that better reflects aggregate customer net metering arrangements and the related potential for VNM.

  10.Virtual Net Metering. ESC submits that while more information is necessary on what the proposed VNM demonstration projects will include (e.g., nameplate capacity), the MOE should clearly express that eligible VNM demonstration programs include energy storage within the project eligibility criteria.

  11.Future VNM demonstration programs should allow credits to be applicable against delivery and Global Adjustment charges, which are capacity based ($/kW-month or kW-customer load / kW-system peak load). ESC further submits that future VNM programs should consider a tiered pricing system, whereby prices paid to net metered and virtual net metered facilities for excess generation fluctuate based on the Hourly Ontario Energy Price or other energy market price signals. Finally, amendments allowing an electricity distributor to enter into net metering agreements with customers to implement VNM demonstration projects should acknowledge that the permitted use of excess generation may also apply to other IESO / utility programs (such as the Industrial Conservation Initiative, if the project is participating in a prescribed program administered by the IESO).

  12.Ensuring appropriate siting of renewable energy generation facilities. ESC submits that it is critical for MOE to simplify and streamline the proposed processes requiring generators to provide confirmation that a renewable energy generation facility (i) meets property boundary setback requirements and (ii) meets prime agricultural area siting requirements, so as not to impede the development of distributed energy resources.

  13.ESC submits that the failure to make such changes to O. Reg. 541/05 and the proposed new regulation will limit the ability of energy storage resources to help address one of the largest inefficiencies in the Ontario electricity system: the waste of nearly 5 TWh of the cleanest, most affordable Ontario electrons, which has increased steadily since 2013. In contrast, making these small changes will assist the MOE and IESO in realizing the flexibility and multiple benefits of energy storage.

  14.Energy storage is unique and particularly valuable to the efficient and optimal use of the existing electricity system. Unlike any other resource in the Ontario energy system, energy storage can provide all of the following services and resulting benefits if the above-mentioned and related regulatory barriers are addressed:

  •Generation and uninterrupted power supply

 •Flexible and peak capacity

 •Frequency regulation service

 •Voltage support

 •Operating reserve

 •Black start

 •Fast(est) ramping to mitigate impact of variable generation from renewable power •Avoided or deferred costs of distribution/transmission upgrades

 •GHG reductions in and outside of the province, lowering reliance on fossil fuel generation •Seasonal storage

 •Load following

 •Spinning reserve

 •Non-spinning reserve

 •Demand shifting and peak demand reduction

 •Transmission and distribution congestion relief

  15.Unlike any other resource in the Ontario energy system, energy storage can: increase the capacity and value from Ontario's existing resources and investments; increase the value, capacity and impact of non-carbon-emitting assets; enhance the resilience of the grid by assisting its protection from disruption, minimizing the economic and social impacts of outages; and decrease electron waste.

  16.ESC therefore requests that you implement the above-mentioned changes to the proposed

 amendments to O. Reg. 541/05, the proposed new regulation under the Electricity Act, 1998 and address the remaining regulatory barriers to energy storage. We thank you for the opportunity to comment and ask that you contact us should you have any questions.

[Original Comment ID: 212079]